ABOUT

This privacy policy sets out the data processing practices carried out by us in relation to any personal information we hold relating to you. We are committed to protecting and respecting your privacy. We are committed to protecting your data. We collect your personal data to help us understand your needs and guides the way in which we interact and communicate with you about ours, and our trusted third parties (subject to your consent) products and services. We ensure policies and procedures are in place to protect the data you provide when registering to our sites, and we process it in order to provide you with the services you have requested or, where you have given us your permission to do so, to send you information that we think you'll find interesting, and thereafter when we store your data on our secure servers. We seek to fully comply with the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Electronic EU Regulations 2011 and the EU General Data Protection Regulations (GDPR). If you wish to find out more, please visit https://ico.org.uk/. {{brand}} is owned and operated by {{organizer}} and is the registered owner of these websites and owns all rights, including the sites' respective IP, copyrights and trademarks. {{company}} is registered with the ICO office (The Information Commissioner's Office in the United Kingdom) as a Data Controller and Data Processor under the Trading Name {{company}}, with Registration Number ZA212237.

YOUR INFORMATION

When you are registering on {{brand}} websites, it is not until you click the submit button that your information is transferred to the DP database. Once you have completed and submitted all your details, you have then completed the registration confirming you are a valued member of our website. The information collected at registration can include name, address, telephone number, email address, date of birth. We may use other reputable partners to provide its services in connection with your registration.
Once you are registered with the our website, you consent to {{company}} , its sponsor question clients and website sponsors, being able to send you communications via the channel(s) you selected as part of the sign up process until such time as you exercise your right to opt-out of receiving such communications. Also you are giving your permission for us to share your information with third parties such as, but not limited to:The commercial use of the database through the sending of commercial communications of third parties, Direct Advertisers or Networks (such as Click Labs Group and their  Client Portfolio, We Breathe Media and their  Client Portfolio, Monetise Media LTD  Client Portfolio, among others).

BUSINESS PURPOSES

Our main Business Purposes for processing your personal data are :

1. To manage the participation of the registered individual in draws and/or promotions organised by us
2. To meet the purposes of funding our free websites. Our commercial aims are mainly funded by advertising, the sending of commercial communications containing named third party offers, the carrying out of branded surveys, market/product/item reviews, provision of 3rd party gaming opportunities etc. All third party Companies and Partners are listed on our site (except for our branded surveys, which rely on your explicit consent prior to your details being shared, and our 3rd party games opportunities where you provide your details direct to the company).
3. To share your data with the marketing services providers, who will use it as an input to products and services to help organisations better understand the likely characteristics of their customers. The legal basis for this sharing is 'legitimate interest', as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons.
4. We may also share your details with identity verification organisations which help other organisations verify your identity and prevent others from misusing your details.
5. We will only minimize the data and process only where it is adequate relevant and limited to what is necessary in relation to the purposes stated above, in accordance with Art. 5 (1), (c) of the GDPR);

LEGITIIMIZATION

Our legitimate interest basis for obtaining and processing of your data is to:

1. Manage your (as the registered individual) participation in our draws, promotions and/or device testing campaigns on our owned sites such as maintaining your registration to our site;
2. improve and personalise our site to you, and this could be where we may market directly to you, about other relevant offers that may be of interest to you;
3. determine whether any of our trusted Partners we work with may have services, products and offers that may be of interest to you based on your preferences; and
4. assess (on a case by case basis, via a balancing test) to determine products and services via marketing campaigns to ensure that we balance the potential impact of your interests of ourselves and our clients; and
5. where appropriate, relevant (and with consent) communicate your data to our trusted Partners. You may object to this processing at any time by contacting us through our GDPR representative in the United Kingdom by clicking: Here

GDPR UK REPRESENTATIVE

The UK-GDPR representative is the point of contact for all questions concerning the data protection of UK citizens and the contact for data protection supervisory authorities.
Want to submit a SAR, RTE, Breach Report or any sort of request? Please click here

• GDPR Local Ltd
• Contact: Adam Brogden
• Phone: + 441 772 217 800
• Address: 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB

MARKETING SERVICE PROVIDERS:

We will share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing, targeted advertising, measurement & identity resolution purposes. Marketing Services Providers carry out data profiling. They will combine your data with data they get from other sources (including public sources) and use it to create predictive models. Marketing Services Providers use these models to try to predict behaviour and preferences (e.g. how likely you are to buy a holiday online or take a particular type of holiday) or likely circumstances (e.g. whether you are eligible for a particular credit card).

Marketing Services Providers will also try to match and then link your data with data that they receive about you from other sources, to make sure that the data they hold about you is correct.

For example, they might do this to

• check whether you have recently moved address; or
• keep the IP address they hold about you up to date. IP addresses change regularly. The IP address they receive from us might change too quickly to make the data you provide through us useful for marketing purposes. Marketing Services Provider might find it helpful for this to be refreshed from time to time to ensure marketing messages are being delivered to the correct consumers, on the correct device(s).

They share your data, including the profiled data they have created about you, primarily to:

• help organisations better understand the likely characteristics of their customers (and find others like them)
• improve the relevancy and appropriateness of an organisation's marketing to its customers (e.g. offers, its products and services); and
• help them communicate with their customers more effectively offline and online. This may mean that you receive tailored advertising via direct mail or when you visit a website.

In sharing your data with Marketing Services Providers, we rely on a lawful ground called legitimate interest , as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons. To understand more about the use of your data by Marketing Services Providers, and to find out how to exercise your data protection rights in relation to their use of your data (including how to opt-out), please click through to the websites of the companies below:

Experian Ltd	Read Policy	All free and paid for Experian consumer services are provided by Experian Ltd (registered number 653331.) Experian Ltd is authorised and regulated by the Financial Conduct Authority (firm reference number 738097). Experian Ltd is registered in England and Wales with registered office at The Sir John Peace Building, Experian Way, NG2 Business Park, Nottingham, NG80 1ZZ. The web monitoring feature and its alerts within CreditExpert is not Financial Conduct Authority regulated activity.
LiveRamp	Read Policy	We will share your data with LiveRamp, who will use it for a variety of direct marketing, targeted advertising, measurement & identity resolution purposes. You can learn more and opt-out from their services at any time
Mdeg Ltd	Read Policy	The Core, Steventon, Abingdon, OX13 6AB
Data Enhancement Solutions Ltd	Read Policy	Albany Chambers, 26 Bridge Road East,, Welwyn Garden City, Herts, AL7 1HL
TDP Agency	Read Policy
Perfect Ingenuinity Ltd	Read Policy
Austinshire Partners, LLC	Read Policy	Austinshire Partners, LLC, of 8760-A Research Boulevard #133, Austin, TX 78758
Permission Media Group Ltd	Read Policy	13th Floor, Piccadilly Plaza, Manchester, M1 4BT. Company Number: 09140601. Data Protection Number: ZA126165 At registration you have the option to opt-in to sponsors of our website. Website sponsors have their own privacy policies and some have their own opt-in statements, it is strongly recommended that you read and understand this information. We collect, store and use data collected about you and your answers to specific questions asked by our question sponsors and/or selected third parties - (see Data Collection Notice section below). We, along with our opted in question sponsors and website sponsors, will contact you with offers and information which we/they feel will be of interest to you through post, email, social media, online advertising, telephone and/or mobile.
WINR Data Pty Ltd.	Read Policy	100 Walker Street, North Sydney, 2060
Sagacity Data Ltd	Read Policy	My Data Choices, 120 Holborn, London, EC1N 2TD

CATEGORIES OF DATA

We collect your details when you register or visit on one of our websites; subscribe to our service; correspond with us by phone, e-mail or otherwise. 'personal data' or 'personal data' means the information you provide during the registration process and any information you provide when entering prize draws, quizzes, surveys or competitions. Registration is required to participate in any of the branded surveys on the site, however merely browsing does not require registration.

Personal information falls into three categories:

• identifiable information which is any information about you from which you can be personally identified. Common examples include your name, postal address, date of birth, telephone numbers, IP addresses or email addresses
• anonymous information which is information that does not identify you personally but categorises you into groups or sectors, common example include demographic information such as age group, gender, marital status, income or the number of people in your household; and
• lifestyle information which is information about your way of life and interests and similar anonymous information, it does not identify you personally.

Our legal basis for processing your data is as follows:

• You name and postal address: there is a legitimate interest for ourselves, our website sponsors, partners and selected third parties in processing data to provide products and services to consumers through marketing campaigns.
• Your Email and Telephone Number is processed under Consent as registration to this website provides us with a clear and unambiguous Opt-In.
• On a case by case basis, a balancing test is performed to ensure that we balance the potential impact of the campaign on the consumer and their rights of processing data, with the interests of ourselves and our clients

USE OF YOUR PERSONAL DATA

We use your personal data collected via our sites to

• Provide you with information about the products and services we offer
• Provide you with a more personalised service
• Conduct market research
• Run prize draws and promotions
• Pass on your details to selected Companies and Trusted Partners which provide you with other offers and promotions of interest to you
• For analysis purposes or to build data products. In these instances, the information is aggregated and wherever possible anonymised in line with the ICO's code of practice. Again, these products are of a marketing nature.
• E-Append data for third party use
• Provide enforcement data for third party use

1. We may process your personal data ourselves or through data processors that will process data on our behalf (we retail full responsibility) for ensuring the data processor complies with this policy and all current data protection regulations).
2. We may collect your data and will share it for commercial gain with third parties. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation's own legitimate interest. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification. When supplying your information to third parties for purposes including but not limited to online linkage, fraud prevention and tracing, we will rely upon legitimate interests as our legal basis for processing your data
3. Depending on the consents that you set up at the time of registration and what personal data we hold about you, we may pass your personal data to Site Sponsors, Brand Partners or Data Partners and Marketing Service Providers (collectively 'third parties') who may contact you by post, email and telephone for direct marketing purposes. We will also share your data with the Marketing Services Providers who will process your data to better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels. This may mean that you receive advertising that is more relevant to you via direct mail/telemarketing/email or when you visit a website.
4. Depending on what personal information we and our website sponsors, partners and selected third parties hold about you, we and they may contact you by post email, social media, online advertising, telephone and/or mobile in line with the permissions you provided to us at registration.
5. We and our website sponsors, partners and selected third parties operate in the following areas for use in any of the manners described above.We may also share your details with identity verification organisations which help other organisations verify your identity and prevent others from misusing your details.
6. Email and Telephone data will only be released to third parties where you have given your positive consent (usually at the time of registration) allowing you to fully understand your registration preferences.
7. Telephone data will only be released to carefully selected partners where it has been TPS'd (see 'Opting Out' below). Note: if you request a call from one of our sponsors or brand partners this will override the TPS.
8. We will only store your data in accordance with our Retention Policy . To read our Policy, click here
9. We may share your personal information with our partner WINR Data Pty Ltd (WINR) and their global partners for the purposes of: Fraud Prevention - preventing others from misusing your personal information. This may involve identity verification for anti-fraud, anti-money laundering, anti-crime, asset recovery, debt collection and reuniting individuals with unclaimed assets; and Digital Advertising - providing personalised advertising and content that is relevant to you. This may involve identity resolution for data analysis, matching and linkage. WINR and their global partners will process and retain your personal information for as long as necessary for these specific purposes and on the lawful basis of consent and/or legitimate interests. You can submit a request to exercise any of your privacy rights to the Data Protection Officer at WINR Privacy Policy

Our website sponsors, partners and selected third parties include:

• ESB Energy - Read Policy
• Hutchison 3G UK Ltd - Read Policy
• Lead 365 Ltd - Read Policy
• HomeShield Direct Limited - Read Policy
• Octopus Energy - Read Policy
• So Energy - Read Policy
• Sky UK Limited - Read Policy
• LocaliQ - Read Policy
• Wowcher - Read Policy
• Wowcher t/a LivingSocial - Read Policy
• USM LTD - Read Policy
• Offers You Might Like - Read Policy
• GB Group - Read Policy
• Data OD Ltd - Read Policy
• Beagle Street - Read Policy
• Kwik Fit - Read Policy
• Sunlife Limited - Read Policy
• Pharmacy2U - Read Policy
• Howden Insurance (formerly known as A-Plan Insurance) - Read Policy

Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn’t outweighed by the effects it will have on the relevant individuals. On that basis we may pass your information to Data OD Ltd who may share this information with other third parties. The data that is shared may be used for analysing, modelling and contact for purposes including affordability assessments, anti-money laundering, asset repatriation, contact information validation, credit risk and affordability assessments , debt collection services , determining debt portfolio value, fraud prevention services, identity verification services, pre-populating online forms, vulnerability assessments and other related services. If you do not wish for your data to be used this way by Data OD Ltd please opt-out using this link. You can use this link to opt-out at any time after you have shared your data. You can also email MyInfo@dataondemand.co.uk with any requests about your information. For additional information about how your data is processed by Data OD Ltd, please use this link link

Click here to see our list of valued, third party data partners, who could send you marketing messages. From time to time we may add or remove businesses from this list and we will update this web page accordingly. You should always read their terms and conditions and/or disclosure statement.

VERTICALS

GENERAL DISCLOSURE OF PERSONAL INFORMATION

• In the event we sell or buy any business or assets, in which case we may disclose your personal information to the prospective buyer or seller of such business or assets.
• If {{company}} or substantially all of its assets are acquired by a third party, in which case personal information held by it will be one of the transferred assets.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of {{company}} our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

AUTOMATED DECISION MAKING

Automated decision making occurs when an electronic system uses personal data to make decisions without human intervention. An example of this is where a customer record is selected by an algorithm for a direct marketing or customer communication campaign based on a set of parameters. The GDPR allows organisations to make automated decisions in the following circumstances:

• Where it is necessary to perform a contract with the customer, and their rights have been safeguarded;
• Where it is authorised by European Union or Member state law applicable to {{company}} or to you
• When the customer has given explicit written consent, and their rights have been safeguarded

YOUR RIGHTS

Your rights in controlling how we use your data - Under data protection law you have rights regarding how we process your data. Please use the following contact details to exercise any of the rights below:

• GDPR Local Ltd, attn. Adam Brogden
• 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
• Phone: + 441 772 217 800

The UK GDPR provides the following rights for individuals:

• The right to be informed - You have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under the UK GDPR. You can read more about this right here
• Your right of access - You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about this right here
• Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right here
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here
• Your right to data portability - This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. You can read more about this right here
• You have the right to complain to the ICO by visiting their website at http://ico.org.uk/, or by telephoning 0303 123 1113, or by post at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

SECURITY AND STORAGE OF PERSONAL INFORMATION

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure.
Data Safety Outside the European Union: You should be aware that some external data processors may be based outside the European Union, whose laws provide a different standard of protection than that provided under English law. We will not release your data to a non-EU country processor without performing proper due diligence as to the standards of data protection within the specified country and proof of compliance with the standards of the UK Data Protection Act 2018 and other relevant legislation. Such requirements will be part of a formal and legally binding Data Processing agreement

LENGTH OF PERIOD DATA IS RETAINED

We only retain information for as long as it is required for the purpose(s) for which we legitimately use it, or for longer periods if required for legal and regulatory reasons.
We will retain your personal data as follows:

• All users are automatically unsubscribed from email, telephone and/or direct mail communications, removed from our member base and placed in the suppression table if they do not click or open an email within the first 30 emails sent or if there is inactivity (not opened or clicked an email) for a period of 6 months.
• Active users personal data will be retained for a period of 5 years or until they become inactive as detailed above, they unsubscribe directly with us or request that their data is no longer processed by {{company}} (please refer to Your Rights section of this Privacy Policy for further information).
• The personal data of users who have opted-out are stored in our suppression file indefinitely, this is to make sure the data subject receives no further communication from {{company}} unless they expressively request this by opting into the site again. We store the following details to support that aim:

OPTIN/OPTOUT

• You have the option of Opting In or Out of receiving marketing communications from ourselves and our various partners at any time - including at registration by choosing the " To enter without receiving marketing messages".
• When registering your details, you will be required to actively opt in to;
  • receive offers and updates by email, telephone and post from selected third party companies which we believe will be of interest.
  • Agree that our trusted partners may contact you with more interesting offers by telephone
  • Acknowledge that you have read, understood and agreed to our terms prior to registration.
• By registering or signing up, it is made clear, in plain english that by doing so, you have read, acknowledged and agreed to the terms and conditions and this privacy policy, which governs how your information will be processed, and that consent upon registration to receive marketing communications from us
• We will always remain transparent in disclosing how we intend to process your data, and where your data may be passed on, subject to your consent and preferences upon registration. All companies and partners we work with will be named, and the categories in which they operate in will be made available to you. These opt-ins are optional and only when you put a tick in the box will you consent to receive additional marketing communication.
• Third-party providers are able to send you communications via email, post or telephone only until such time as you exercise your right to opt out of receiving such communications. However please be aware that marketing campaigns are often planned well in advance, so your changes will be accepted immediately, but may not be effective immediately.
• In addition, Website Sponsors have their own privacy policies and some have their own opt-in statements. It is strongly recommended that you read and understand this information.

If you wish to unsubscribe from any future emails you can use our form

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

CHANGES TO THIS PRIVACY POLICY

We may make changes to this privacy policy from time to time. You should check this page regularly to see our most up to date policy. We will tell you about any changes to this privacy policy by showing the date of the changes in the Last updated section at the bottom of this page.

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Cookie	Name	Purpose
{{domain}}	_fbp	We use cookies to track the source of your visit to the website.
cdn.formulead.com	ck_stp lid plc scr	We use cookies to track the source of your visit to the website.
Universal Analytics (Google)	_ga _gali _gat_UA-1036645-1 _gid	These cookies are used to collect information about how visitors use our websit. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. Read Google’s overview of privacy and safeguarding data

FURTHER INFORMATION

Want to submit a SAR, RTE, Breach Report or any sort of request? Please click here
You can contact the Data Protection Officer or GDPR representative in the United Kingdom on: contact@gdprlocal.com or by writing to

DP is registered with the ICO office (The Information Commissioner's Office in the United Kingdom) as a Data Controller and Data Processor under the Trading Name {{company}}, with Registration Number {{ico}}.

If you have questions regarding the privacy policy please contact us by following the link or by writing to the address above or by emailing {{email}}

Copyright – 2024 {{brand}}

Last update: 31rd May 2024