Terms and conditions

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 to receive emails via registering to this Site. By registering and clicking on our Get Freebies button t is made clear that you are doing so tio join our email mailing list to receive freebies and offers (collectively, the “Services”). Our Site forms will always be accompanied with a consent statement, heading and text, (shown clearly and unambiguously) disclosing that you will receive emails containing freebies and offers.Pressing Get Freebies button is optional, freely given and represents a positive opt-in. You can browse and use the site without consenting to the Terms, however this prevents us from delivering some of the services sought by you from this Site.
  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 personal data you enter so we can personalise the website to enhance registered users have when visiting/re-visiting. It also allows us to segment users by this activity in order to send the most relevant offers via email. We may also process and store data to suppress and/or unsubscribe users. For instance,if a user wishes to unsubscribe from our email marketing we need to keep a record of that email in order to make sure it can’t be signed up with again. 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 subscribe again using the same details. To request this please visit our contact page ​ here​ .
  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 isiting 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 to email you directly with Freebies and Offers, provide you with a more ersonalised service, to analyse user preferences or activity to assist in improving our site and building better products. 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 Email Address
    • Your First Name (so we can personalise our e-communications to you)
    • Your device’s IP address (so we can mitigate fraud & data duplication)
  12. You may withdraw your consent at any time by contacting us directly.

    Marketing to Children

  13. We do not knowingly, nor deliberately or aim to, collect personal data from data subjects under the age of 8, 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 our competitions 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/delete details or contact us in relation to the above, please contact us ​here.

    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. 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. IP Address/Cookies

  21. We automatically collect your IP address and record the web page from which you originated if you are using the service’s website.
  22. 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.
  23. Most browsers automatically accept cookies, but you can modify your web browser setting to decline cookies. If you choose to do this, you may not be able to avail yourself of some or all of the functionalities that the website or the service may offer.
  24. The type of cookies that we use on our sites are:

    Cookie Name Purpose
    Google Analytics _ga
    __utma
    __utmb
    __utmc
    __utmv
    These cookies allow OfferX 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 OfferX website.
    Essential site cookies cookiesenabled
    cookietest
    PrizePunch
    ASP.NET_SessionId
    qb:nnnn
    These cookies are essential for the operation of the OfferX website.

    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 datacompliance@marketingpunch.co.uk​ 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.

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