Effective Date: May 22, 2018
HOW DO WE COLLECT INFORMATION AND WHAT INFORMATION DO WE COLLECT?
We collect and otherwise process various personal data relating to you through the methods discussed below.
Website Registration Forms
We collect information about you when you register on one of our websites. This registration information may include, but is not limited to your:
- e-mail address
- full name
- mailing address
- telephone number
- date of birth
We also collect information about you when you complete a survey or offer form on one of our websites or web pages. This information may include, but is not limited to: your e-mail address, name, mailing address, telephone number, date of birth, gender, and payment information; information about your background, interests, education, career goals, and shopping preferences; and any other personal information or unique preference information you provide to us or our advertisers.
We may also ask you questions about your health. We acknowledge that any information you provide concerning your physical or mental health or condition is sensitive personal data. We will, accordingly, never require you to answer any questions about your health. We will ask for your consent when collecting this information.
Website operators that license our ad serving technology pass information to us so that we may serve advertisements to you. The information passed may include, but is not limited to, your IP address, e-mail address, name, mailing address, telephone number, date of birth, and gender.
When you complete a registration or offer form that is hosted by one of our website publisher partners on our behalf, the website publisher partner may submit all or a portion of the information that you submitted on the form to the Company. This information may include, but is not limited to: your IP address, e-mail address, name, mailing address, telephone number, date of birth, gender, and payment information; information about your background, interests, health, education, career goals, and shopping preferences; and any other information you provide to our website publisher partner.
We may receive information about you, including but not limited to your IP address, e-mail address, first name, last name, mailing address, and telephone number, from third party marketing partners that provide us with consumer data to manage on their behalf.
Automatic Information, Digital Identifiers and “Cookies”
We automatically receive and store certain types of information about you through the data sources listed above.
Additionally, you may be familiar with the term “cookies”, which are unique alphanumeric identifiers that store information on your computer. A cookie is placed on your computer when your web browser accesses our website.
There are utilities available for purchase from independent software providers to install on your computer as well as tools/preferences you can choose through most web browsers to make website visits anonymous. Of course, cookies let you have a more satisfying website experience, so we recommend that you leave them turned on.
There are a number of ways to manage and delete cookies depending upon the browser you use. If you are using Microsoft Windows Explorer version 7, for example, in order to view your cookie settings:
- Open “Internet Explorer”
- Click on the “Tools” menu
- Select “Options” from the drop down menu
- Select the “Privacy” tab
- Select “Advanced Options”
And if you wish to view and delete any cookies on your machine:
- Open “Internet Explorer”
- Click on the “Tools” menu
- Select “Options” from the drop down menu
- On the “General” tab under the “Browsing History” section select “Settings”
- Select “View Files”
- Select and delete any cookies you object to.
You can find further information by searching for “cookies” in your browser documentation or help function.
We also collect information through our web server applications. This information includes your Internet Protocol or “IP” address, date/time stamp, browser type, and referring URL.
Additionally, we may use pixel tracking technology to track the completion of transactions with us or our advertisers, the source information for those transactions, and your IP address, date/time stamp, browser type, and referring URL.
HOW DO WE USE THIS INFORMATION?
We may use your personal data for the purposes below.
We serve advertisements to you based, in part, on your IP address, the demographic and geographic information you submitted to the Company during the website registration process, and other socio-economic information, psychographic information, Internet behavior (e.g., browsing, search, shopping, purchase, and ad response behavior), and lifestyle information about you that we obtain from affiliated entities and from third parties.
We also use third party advertising companies to serve advertisements when you visit our websites. These companies may use and optimize information about your visits to this and other websites in order to provide advertisements about goods and services that may be of interest to you.
Our website technology may pre-select certain offers for you to view based on the demographic and geographic information you submitted to the Company during the website registration process in order that you receive offers that we believe are of most interest to you. Additionally, this technology may pre-fill some or all of the offers’ data fields with the information you submitted during the website registration process in order to prevent you from having to re-enter this information. We may not show all of the pre-filled data fields to you.
We utilize customized post transactional or “upsell” technology to help advertisers generate sales, while providing you with a series of great offers we think may be of interest to you. Once you purchase a product or service from one of our reward advertisers, you will be offered additional products or services that we think may be of interest to you. If you elect to purchase products or services from a third party advertiser in the post transactional channel, please input all necessary information on the subsequent advertiser form, including, but not limited to, your credit card information. You need to complete this information because we do not pass this information to the third party advertiser.
Customer Service and Fulfillment
We use your personal data to operate the promotion, service your account and to fulfill rewards earned through Company websites. We also use your personal data to verify your identity or claimed account status and, where we consider appropriate, investigate your compliance with the terms and conditions of the offer. We will also retain any correspondence.
If you have indicated your consent to receive marketing messages, we use your information in our online (e.g., e-mail marketing) marketing programs within the Retail, Finance[payday loans,Mortgage Loans, Secured Loans, Unsecured Loans, etc], Insurance, Travel, Charity, Lifestyle, Online Gambling, Online Gaming & General sectors. If you would like to be removed from these programs at any time, follow the opt-out instructions.
Where we intend to use or otherwise process your personal data for a purpose other than the purpose for which it was collected, we will provide you with information regarding the purpose for the processing, as well as other relevant information, prior to processing your personal data for the new purpose.
WHAT IS OUR LEGAL BASIS FOR PROCESSING
On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide services to you. We may also process your personal data to respond to your inquiries concerning our products and services.
On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.
Additionally, we process your personal data when necessary to do so for compliance, gift fulfillment, and direct marketing purposes and these interests are not overridden by your data protection rights. Where we process your personal data for this purpose, our legitimate interest is to carry out our activities to improve our services and ensuring the security of our services.
If the processing of personal data is necessary and there is no statutory basis for such processing, we will ask for your consent to process your personal data. You have the right to withdraw your consent to processing of personal data at any time.
If you wish to exercise the right to withdraw consent, to contact our Data Protection Officer.
WHAT IF I DO NOT PROVIDE MY INFORMATION
Providing your information is not required, however, we will not be able to register you on our website to contact you if you have any questions unless valid and truthful registration information is supplied. We will not be able to tailor the merchandise, gift cards and incentives we offer to you without your gender, age, date of birth, and/or certain financial information. Our website may not work properly on your device or you may not be able to access all the features of our website, if inaccurate or incomplete contact information is provided.
HOW DO WE SHARE INFORMATION?
We may share your personal data for the purposes stated below.
Within the Company
We share your information with various third party vendors, in the EEA or abroad, that are not part of the Company, including but not limited to vendors that provide us with technology to deploy commercial e-mail, vendors that sell the products or services for which you have qualified through one of our websites, and shipping companies that we utilize to ship products to you.
When you participate in an offer by completing a form, we will transfer the information you submitted on the form to the applicable advertiser. Company advertising partners may be located in or outside the EEA. By submitting the form you consent to such information being transferred.
When you answer “yes” or “no” to a survey question, some or all of the information that you submitted during the website registration process will be transferred to advertisers that we believe may be of interest to you.
When you select “yes” next to an offer, we will transfer some or all of the information that you submitted during the website registration process to the applicable advertiser. By indicating your interest in the offer you consent to the transfer of your personal data.
Ad Serving Companies
If you have indicated your consent to receive marketing messages, we share, license or sell your information to third parties, whose location may be in or outside the EEA, for various marketing purposes, including their online (e.g., e-mail marketing) and offline (e.g., telemarketing, cell phone text messaging, skip tracing, and direct mail) marketing programs. If you would like to be removed from these programs at any time, and follow the opt-out instructions.
If you have indicated your consent to receive marketing messages, you consent to us sharing, licensing, or selling your data with Marketing Partners which are companies/businesses, located in or outside the EEA, who collect data and help their clients tailor products and services through targeted advertising which best suit your needs. Our Marketing Partners will process your data in compliance with all laws, regulations and guidance with regard to data protection. We will share your data with our Marketing Partners, who like us, may use it to create products and services to help organisations 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 from organisations within the industry sectors listed above, that is more relevant to you via direct mail or when you visit a website, mobile app or watch TV. If you would like to be removed from these programs at any time, and follow the opt-out instructions.
We use third party vendors to enhance our database with additional elements, including but not limited to age ranges present in your household, whether you own or rent a home, the length of time you have lived at your residence, whether you are a mail order buyer or responder, household income, and gender. We may also use third party vendors to validate the data we have in our database.
Additionally, if you have indicated your consent, we may share, license or sell your information to third parties for use in their data validation, enhancement, information verification services, and, to the extent permitted by law, individual reference or look-up services. These third parties may be located in or outside the EEA.
Governmental Agencies or Other Companies
We may share your information with law enforcement officials or governmental agencies in or outside the EEA: (1) in response to their request; (2) when permitted or required by law; or (3) to establish our compliance with applicable laws, rules, regulations, or guidelines.
In order to enhance your privacy, where you indicate you wish to “opt-out” of receiving marketing messages from us we may retain your name and contact details as part of a “suppression file” so that we can honour your preference. We may also share this information with third parties for suppression or opt-out purposes.
We may also share your information with third parties when: (1) trying to protect against or prevent actual or potential fraud or unauthorized transactions; (2) investigating fraud that has already taken place; (3) enforcing or applying existing terms and conditions and/or other agreements; (4) protecting the rights, property or safety of our websites, our users or others; or (5) responding to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims.
In all cases, this information is not provided to these entities or persons for marketing purposes.
Right to Transfer
Should the Company choose to sell or transfer all or part of its business assets, it is possible that the information we possess may be transferred as part of that transaction to a location outside the EEA. The Company ensures adequate protection when transferring personal data outside the EEA by incorporating model contract clauses into a contract between the parties transferring data. The Company may retain a copy of the information post sale or transfer as permitted by applicable law.
COMPANY CUSTOMER CHOICES
By indicating your consent to receive marketing messages, you are consenting to receive marketing communications from the Company and indicating your consent to receive marketing messages from its third party marketing partners both in or outside the borders of the EEA. If, after you have shared your information with the Company, you decide that you do not want to receive marketing communications from the Company and its third party marketing partners, you can discontinue the communications by and following the opt-out instructions. If you have registered or submitted information under more than one e-mail account, you must submit separate unsubscribe requests for each account.
Request for More Information
ACCESS TO INFORMATION AND COMPLAINTS
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information or to have your personal information suppressed for marketing purposes, please. Updates or removal of inaccurate contact details can be made by you at any time. You may also ask us to stop or restrict our processing or transfer of your personal information or to delete your information entirely.
The Company is committed to fulfill your rights with regard to the processing of your personal data under the General Data Protection Regulation (GDPR). To raise any concerns regarding use and disclosure of your personal data, please contact us at [email protected] and the Company will investigate your complaint, take appropriate action, and report back to you within thirty (30) business days.
In accordance with Article 38 of the GDPR, you may contact the Company Data Protection Officer (DPO) concerning issues related to the processing of your personal data and to exercise your rights under the GDPR. The Company DPO contact details are as follows: Compliance Manager can be contacted at [email protected]
Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence, which in the UK is the Information Commissioner’s Office whose address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
WHAT HAPPENS IF I HIT A LINK TO ANOTHER SITE FROM A COMPANY WEBSITE?
WHAT IS THE POLICY WITH RESPECT TO COMMUNICATING WITH CHILDREN?
Company websites are intended for use by persons over the age of 18. Persons under that age are not eligible to participate in Company websites or receive a reward. We recognize the unique privacy concerns regarding children. We are committed to carefully protecting privacy where children are involved no matter the point of contact. If a parent or guardian is made aware that a child has provided us with any personal data through any point of contact, to contact us and we will delete the information about the child referenced from our files.
There is no such thing as complete security on the Internet or otherwise. The Company uses various security techniques on our websites to help protect against the loss, misuse or modification of information we’ve collected from you. When you access your personal information or transmit information to us, that information is stored on servers that we have taken steps to protect from unauthorized access or intrusion. While we strive to protect your information, the Company cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with the Company, its partners and affiliates.
LOCATION AND CROSS-BORDER TRANSFER
The Company and its servers are located in the United States of America. The Company may transfer and store personal information that it has collected about its customers in the United Kingdom outside of the borders of the EEA. This personal information may also be processed by staff and third party marketing partners operating inside or outside the EEA who work for us or for one of our suppliers. Such staff and marketing partners may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By using the Company websites and submitting your personal data, you agree to this international transfer, storing and processing of such information. The Company ensures adequate protection when transferring personal data outside the EEA by incorporating model contract clauses into a contract between the parties transferring data.
LIMITATION OF LIABILITY