Privacy Policy

Last updated: May 2018

    Purpose of our Privacy Policy

  1. The collection and processing of a user’s (“you”, “your”, “user”, “registered user”) personal data will always be in line with the rules set out by the General Data Protection Regulation (GDPR). We strive to keep all information as clear and transparent as possible to you so that you understand;
    1. Who we are;
    2. How we protect, manage, use and protect your personal data obtained collected while using our Your Freebie Style site (“Site”);
    3. Our lawful basis for processing your data;
    4. How we intend to use or share your personal data; and
    5. How to de-register/unsubscribe.
  2. Who is Processing Your Personal Data?

  3. Marketing Punch Ltd (United Kingdom)(“Marketing Punch”, “we”,”us”, “our”) is a company registered with the Information Commissioner’s Office (ICO) in the United Kingdom with Registration Number Z1503626. We act as the Data Controller and the registered owner of the Site.
  4. How We’ll Protect Your Personal Data

  5. When you register to this Site and sign up to our emailing list, we’ll store your data in our secure servers. Our servers and processes are in line with requirements unde the Data Protection Act 1998, the Electronic EU Regulations 2011 and the EU General Data Protection Regulations (GDPR). We’ll only hold your data for as long as there is a general business purpose to do so, and in accordance with our ​Data Retention Policy​ .
  6. Our Purpose & Legal Basis for Processing Your Personal Data

    Our legal bases are as follows;

  7. Consent​ – we will only process your data when you optionally consent by signing up to this Site. By signing up and clicking continue, it is made clear that you are doing so to create an account and enter Free Cashpot Lottery. Sign up is completely optional.You can register without consenting to the Terms, however this will impact your entry in the Service, and there would be no means to contact you, should you be randomly selected.
  8. Legitimate Interest​ (LI) – we’ve thought carefully and performed the necessary Legitimate Interest Assessments to balance our interests with yours, before relying on LI. Therefore, in addition to your consent, we will store your email address so we can manage your participation in the Service. We may also process and store data to suppress and/or unsubscribe users. For instance,if a user wishes to de-register, or wish to not receive e-communications from us, or be able to sign up to the Site again,we need to keep a record of the collected data (username, email or IP) in order to adhere to these requests. A user still has the ‘right to be forgotten’ in which case all of the personal information we hold about user will be deleted. They would then appear to us as a new user and would be able to sign up again using the same details.
  9. Personalisation and Serving of Relevant Advertising​ (“Ads”) – also known as ‘automated decision making’, we aim to personalise by analysing user activity to better interact and serve ads of relevance or interest to you. This Site is free, and funded by our trusted third-party Companies and Partners. Upon visiting and registering, you will be presented with advertisements. By clicking on one of the ads and leaving our Site, you accept the Privacy Policies of those third party companies. We do not accept any risk or liability once you’ve left our Site.
  10. Use of Your personal data

  11. We use your personal data only to manage your participation and entry into Free Cashpot Lottery (the “Service”). We will only collect the below data that is adequate, relevant and limited to what is needed to deliver the Service (in accordance with Article 5 (1), (c) of the GDPR);
    • Your chosen Username (to manage your participation with the Service); and
    • Email Address (to contact you)
  12. When you visit our sub-page ( http://www.freecashpotlottery.co.uk/free-lotteries/ ) and click on the other Lotteries and leave our site,you will be redirected. From then, you’ll leave the Site and will be bound by the Privacy Policy of the other Promoters/Owners. We accept no liability for what happens to your data after you leave our Site.

    Marketing to Children

  13. We do not knowingly, nor deliberately or aim to, collect personal data from data subjects under the age of 18, either for registration or for marketing purposes. Any data we reasonably believe has been collected for data subjects under 18 will be deleted, and any entries to the Service immediately voided without notice.
  14. Your Rights

  15. You have the right to:
    1. obtain access to your personal data;
    2. receive information about us and the purposes for which we process your personal data;
    3. prevent processing which may cause you damage or distress;
    4. object to direct marketing and select the contact channels by which we market
    5. object to purely automated decision-making in certain cases;
    6. you have the right to seek compensation through the civil courts for a breach of a data controller’s obligations;
    7. ask us to correct any errors and/or delete the information we hold ;
    8. Be forgotten by requesting all personal data collected from you, by us, be deleted completely from our database, systems and servers*;
    9. opt out of any further contact by us or selected brand partners or sponsors;
    10. The right to lodge a complaint with a supervisory authority (in the UK, it is the ICO); and
    11. Be notified in the event of a data breach, where data lost or stolen involves your personal data.
  16. If you would like to amend, correct, request access to or completely delete details or contact us in relation to the above, please contact us ​ here .​ We may need to hold some data about you in order to suppress, block or prevent further entries.

    Unsubscribing

  17. You may unsubscribe at any time by;
    1. Clicking on the ‘unsubscribe’ link at the bottom of every email we send; or
    2. By contacting us ​​ ​here .
    3. Clicking on the ‘unsubscribe’ link at the bottom of the website.
  18. Who We Pass Your Data To

  19. We use the below external companies/services to help us perform our legitimate interests. This includes hosting and storing the data:
    • Siteground​ –host SiteGround Hosting Ltd. 3rd Floor, 11-12 St. James’s Square London SW1Y 4LB
    • Rackspace​ –which is a third party cloud server certificated in ISO 27001, ISO 9001,ALCPA, SOC3, PCI, bsi ISO 14001 and bsi OHSAS 18001.Marketing Punch have a dedicated server service with Rackspace ® which includes unmatched performance of a bare metal server, enhanced security with a managed dedicated hardware firewall, backup and monitoring, managed web application stack and proactive security patches. We also have a copy of user data stored on Microsoft Azure, this is used by the control centre for reporting purposes. Personal data is retained as specified in the data retention policy.
  20. Data Safety Outside the European Union

  21. 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 1998 and other relevant legislation. Such requirements will be part of a formal and legally binding Data Processing agreement.
  22. IP Address/Cookies

  23. We automatically collect your IP address and record the web page from which you originated if you are using the Site. Cookies are used to increase your security, not infringe on your privacy. Cookies are needed to monitor, facilitate, administer and optimise the website and service for users and to earmark any possible technical issues that may arise within the website or the service. We may use your IP address to help identify you, tend to any difficulties and to gather demographic and profile information. We also use the ‘cookies’ to collect information about your online activity on our website, such as the web pages you visit, the links you click, and the searches you conduct on our website.
  24. The type of cookies that we use on our sites are:

    Cookie Name Purpose
    Google Analytics _ga
    __utma
    __utmb
    __utmc
    __utmv
    __utmz
    These cookies allow the Site to collect information about how visitors use the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google
    Google Adsense __gads
    _drt_
    _id
    Google uses cookies to serve more relevant ads across the web and limit the number of times a given ad is shown to you. When you visit a website, view an ad, or click an ad supported by Google’s advertising services, Google may set a cookie on your browser. This advertising cookie will appear in your browser as coming from the domain “doubleclick.net”. ​Learn more about Googles Policies
    Pingdom PRUM_EPISODES Allows us to monitor user experience.
    Network Punch Enc_aff_session_nnn Network Punch uses cookies to track the source of your visit to the Site.
    Essential site cookies cookiesenabled
    cookietest
    PrizePunch
    ASP.NET_SessionId
    qb:nnnn
    These cookies are essential for the operation of to the Site.

    Access, Rectification and Erasure of your personal data

  25. You may request access to, rectification and/or erasure of any personal data which we hold about you under he Data Protection Act 1998 and the GDPR. If you believe that any information we are holding on you is incorrect or incomplete, or you would any data we may hold about you to be completely deleted, please email or write to us as soon as possible at address below. We will promptly endeavour to correct any information found to be incorrect.
  26. If you have questions regarding this Privacy Policy, please contact us by following:
    Email the DPO ​ ​here ​ or by post:
  27. The Data Protection Officer

    Marketing Punch Ltd,

    Unit 35-41,

    Upper Mills Trading Estate,

    Stonehouse, Gloucestershire, GL10 2BJ, England, UK

    Tel: 01453 707400

    Changes to this Policy

  28. We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.This policy is effective from the ​ last updated​ date.