- 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;
- Who we are;
- How we protect, manage, use and protect your personal data obtained collected while using our Your Freebie Style site (“Site”);
- Our lawful basis for processing your data;
- How we intend to use or share your personal data; and
- How to de-register/unsubscribe.
- 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.
- 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 .
- 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.
- 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.
- 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.
- 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)
- 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.
- You have the right to:
- obtain access to your personal data;
- receive information about us and the purposes for which we process your personal data;
- prevent processing which may cause you damage or distress;
- object to direct marketing and select the contact channels by which we market
- object to purely automated decision-making in certain cases;
- you have the right to seek compensation through the civil courts for a breach of a data controller’s obligations;
- ask us to correct any errors and/or delete the information we hold ;
- Be forgotten by requesting all personal data collected from you, by us, be deleted completely from our database, systems and servers*;
- opt out of any further contact by us or selected brand partners or sponsors;
- The right to lodge a complaint with a supervisory authority (in the UK, it is the ICO); and
- Be notified in the event of a data breach, where data lost or stolen involves your personal data.
- You may unsubscribe at any time by;
- Clicking on the ‘unsubscribe’ link at the bottom of every email we send; or
- By contacting us here .
- Clicking on the ‘unsubscribe’ link at the bottom of the website.
- 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.
- 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.
- 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.
- 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.
Email the DPO here or by post:
- 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.
Who is Processing Your Personal Data?
How We’ll Protect Your Personal Data
Our Purpose & Legal Basis for Processing Your Personal Data
Our legal bases are as follows;
Use of Your personal data
Marketing to Children
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.
Who We Pass Your Data To
Data Safety Outside the European Union
The type of cookies that we use on our sites are:
|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|
|Pingdom||PRUM_EPISODES||Allows us to monitor user experience.|
|Essential site cookies||cookiesenabled
|These cookies are essential for the operation of to the Site.|
Access, Rectification and Erasure of your personal data
The Data Protection Officer
Marketing Punch Ltd,
Upper Mills Trading Estate,
Stonehouse, Gloucestershire, GL10 2BJ, England, UK
Tel: 01453 707400