Privacy Policy

What does this policy cover?

This policy describes how Final Replay Limited (also referred to as “FR”, “we” or “us”) will make use of your personal data when you visit our website at (“Website”), enter into a prize draw on, when you buy a product in our shop or when you pledge to the #fullcolour66 crowdfund project (the “Crowdfund Project”).  

It also describes your data protection rights, including a right to object to some of the processing which FR carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

What information do we collect?

Wecollect and process the following personal data about you:

  • your name,
  • your date of birth,
  • your home address and email address,
  • your telephone number,
  • your purchase history and the products you have viewed on our shop,
  • your payment details including your billing address,
  • products you’ve viewed,
  • your IP address and browser type,
  • your cookie data,
  • any comments you may post on our websites, and
  • if you win the prize draw we may also need your photograph.

 What information do we receive from third parties?

We also receive information about you from the Crowdfund Project website – if you are a paying entrant then we will receive information including your email address,  name, address in some cases, payment details and the type and number of rewards you have bought or if someone else gifted you a reward and/or  entry to the prize draw then they will give your details described above to us.

How do we use this information, and what is the legal basis for this use?

We process this personal data for the following purposes:

  • To fulfil a contract, or take steps linked to a contract: this is relevant where you enter our prize draw. This includes:
    • verifying your identity;
    • taking payments;
    • communicating with you; and
    • arranging the delivery of the rewards and any prizes.
  • As required by FR to conduct our business and pursue our legitimate interests, in particular:
    • we will use your information to provide products and services you have requested, and respond to any comments or complaints you may send us;
    • we use information you provide to investigate any complaints received from you or from others, about our website or our products; and
    • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
  • Where you give us consent:
    • to send you direct marketing in relation to our relevant products and services, or other products and services provided by us as well as our future crowdfunding projects, our affiliates and carefully selected partners,
    • to place cookies on your device, please check “Cookies” section in this policy to find out more about the cookies we use, and
    • to use the data for the purpose which we explain at that time.
  • For purposes which are required by law:
    • in response to requests by government or law enforcement authorities conducting an investigation.

Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on our balancing tests by contacting us using the details set out later in this policy.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests.  You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.


Subject to your consent, we use cookies and similar technologies to provide, evaluate, improve, and protect our website and services except where these are strictly necessary cookies.

About Cookies

A cookie is a small piece of text that is placed on your website browser, device, or hard drive when you visit a website or use an application. We use the following types of cookies:

•              Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the websites, and to use their features – for example, to remember your shopping basket or to enable a secure checkout process. Without these cookies, we would not be able to provide you with services like enabling appropriate content based on your type of device.

•              Analytics Cookies. These cookies help us analyse how you interact with our site for instance which pages visitors go to most often and if they get error messages from web pages – and allow us to optimise our service. We use Google Analytics and JetPack cookies to monitor and improve our site performance, services and your experience.

Any personal information collected and/or processed through or in association with the cookies described above will be handled in accordance with this Privacy Policy.

What is the lifespan of the cookies?

Cookie retention details are provided in the table below. If we have asked for your consent to use cookies, this means we will ask you for consent again at this point.

Necessary CookiesSession
Analytics CookiesUp to 13 Months

How to Manage Cookies

If you wish to prevent cookies from tracking your activity on our website, you can change your cookie preferences at any time here:  Or alternatively, set your browser to block certain cookies or to notify you when a cookie is set. If you block cookies, certain features on our website may not work. For more information on how you can customize your browser’s cookie setting please visit the link to your web browser below:

Who will we share this data with, where and when?

Personal data will also be shared with third party service providers, who will process it on behalf of FR for the purposes identified above. In particular, we use third party providers for website hosting, email distribution, reward creation and delivery, prize draw operations, prize delivery, merchandise creation and delivery, and payment processing.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

We may transfer your data to our service providers in South Africa and in the United States and your data is adequately protected by the EU Commission’s approved standard contractual clauses.  A copy of the relevant mechanism can be provided for your review on request.

What rights do I have?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

For entry into the prize draw promotion the provision of your name and contact information is mandatory: if relevant data is not provided, then we will not be able to send you a prize if you win. All other provision of your information is optional.

How do I get in touch with you?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at or by writing to Final Replay Limited, 2nd Floor, Regis House, 45 King William Street, London, UK, EC4R 9AN.

How long will you retain my data?

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Where we process personal data in connection with performing a contract or for a draw or competition, we keep the data for 6 years from your last interaction with us.