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PRIVACY POLICY

Privacy Policy 

Last Updated: 12th August 2023 

Who is Processing Your Personal Data? 

1. Marketing Punch Ltd (company number 06692565) (United Kingdom)(“ Marketing Punch”, “we”, ”us”, “our”) is the registered owner of these prize draw service websites and owns all rights, including the sites’ respective IP, copyrights and trademarks. We are 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 Marketing Punch Ltd, with Registration Number Z1503626. This privacy policy applies to the following websites owned and operated by us (collectively to be called “the sites”): 
www.offerx.co.uk 
www.offerx.co.uk/gettestkeep
www.activeyou.co.uk 
www.nationalconsumerreview.co.uk

Our Commitment to Protecting Your Personal Data

2. Marketing Punch is 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 work within the guidelines and advice provided by and made available by the Information Commissioner's Office, the regulator of the Data Protection Act 2018 and abide by the ICO’s requirements. 

3. 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/. 

Purpose of this Privacy Policy

4. This Policy sets out how we manage, use and protect your personal data collected while using our sites. 

5. We will only use or share your personal data in a manner that is in accordance with this Privacy Policy, and as stated within the registration opt-in definition, and only where we have obtained your prior active consent. Consent is obtained using clear and specific statements that are prominently displayed as part of the registration process on the sites. 

 

Our Purpose for Processing Your Personal Data

6. Marketing Punch has 5 main business purposes; 

6.1. To manage the participation of the registered individual in draws and/or promotions organised by us; 

6.2. 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 3 rd 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 3 rd party games opportunities where you provide your details direct to the company). 

6.3. To communicate, (via email, telephone or the chosen contact method) the data of interest to OfferX selected companies and trusted partners (“named third party companies”). Advertising will be sent by these named third party companies, subject to explicit, active consent by the registered individual prior to signing up or registering to our websites. 

6.4 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.

6.5 We may also share your details with identity verification organisations which help other organisations verify your identity and prevent others from misusing your details.

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); 

Our Legitimization for Processing Your Personal Data

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

7.1.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; 

7.2. 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; 

7.3. 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 

7.4. 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 

7.5. where appropriate, relevant (and with consent) communicate your data to our trusted Partners. You may object to this processing at any time by emailing us: datacompliance@marketingpunch.co.uk

 

Collection and Use of Your personal data

8. 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.

9. The categories of personal data we may collect from you upon registration of via visiting our website: 

  • Your name

  • Your title

  • Your date of birth

  • Your contact information, including email and phone numbers

  • Demographic information

  • Your address and postcode

  • Your IP address or other online identifiers such as Cookies

 

Use of Your Personal Data

10. We use your personal data collected via the Marketing Punch 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

 

11. 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). 

12. 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.

To understand more please click through to the websites of the companies below:
USM LTD – Privacy Policy
Offers You Might Like – Privacy Policy
GB Group – Privacy Policy

13. 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. 

14. 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. 

15. You can change or update your communication preferences at any time here http://www.offerx.co.uk/communication-preferences-login

16. 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. 

17. We will only store your data in accordance with our Data Retention Policy. To read our Policy, click here. 

For more information on how your Data is passed on when participating in a Branded Survey, refer to 27-33. 

Profile Matching (aka Profiling) 

18. To enhance the services we provide, we aim to share your data match your profile to third companies, as well as Marketing Services Providers that will either process your data to better understand the likely characteristics for their customers or others like them , or may directly have goods or services that would be of interest to you. It makes sense for us to ensure that you only receive offers that are relevant to you and fit within the context of your lifestyle and available purchasing power. For example, if you have provided your car insurance renewal data and have consented for third parties to contact you about one month before your renewal date, we will work with third party brand partners to send you a car insurance quote tailored to your needs – thus saving you time researching the entire market. This may mean that you receive advertising that is more relevant to you via direct mail/telemarketing/email or when you visit a website.

The data that we provide our third parties may be added to the information that they already hold about you. So, a car insurance company will check whether you have been a customer of theirs before. This is to ensure that they provide the right types of products, services and pricing to you. 

When first contacting you, they always will seek your appropriate opt in and consent. 

19. Data sharing in this way allows them to contact you in their own name about their products, services, promotions, offers and competitions, and/or to update their records for fraud prevention, debt tracing and anti-money laundering purposes. 

Marketing Services Providers

We will share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing, testing, research & product development 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 (e.g. to check whether you have recently moved address).

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.

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:

Archant Community Media Limited (Co Reg 00019300) - ICO Z6513805 - 
https://www.archant.co.uk/articles/privacy-policy

Experian Ltd - About Experian Marketing Services

ESB Connect - http://privacy.esbconnect.com/

Choose leads Privacy policy

Fusion BPO Services (Company Number 07484788) - https://www.fusionbposervices.com/privacy-policy-united-kingdom.php

Lead 365 - Lead 365 Privacy policy

Lexis Nexis - https://www.lexisnexis.com/global/privacy/en/privacy-policy-uk.page

LiveRamp – https://liveramp.uk/privacy/web-privacy-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: https://liveramp.uk/privacy/web-privacy-policy/

Lloyd James Media – Privacy Policy

MDEG Ltd – https://www.mdeg.co.uk/how-we-process-data.html

Portafina - https://www.portafina.co.uk/legal/privacy-and-cookies-policy/

REaD Group - REaD Privacy policy

The Data Partnership Group Ltd T/A TDP Agency (Co Reg 00612316) - ICO ZA537625 - https://tdpagency.co.uk/privacy-policy/

Austin Shires Partners - https://privacy.austinshirepartners.com/en/

Direct Data Services (DDS) Limited - https://www.directdataservices.co.uk/privacy-policy/DDS and their partners may share your data with third parties who may use it to send you Marketing communications via telephone, email or post. They may also use your data for analysis, profiling, linkage, or to extend their databases by appending additional information to existing information they may already hold on you as their customer . DDS and their partners may also share your data with third parties who may use it for 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, and revenue collection.

Potential D Ltd - https://www.potentiald.co.uk/

CACI Ltdhttps://www.caci.co.uk/data-privacy/consumer-information/

We may share your contact information with our partner WINR Data Pty Ltd. (WINR) and their global partners for the purpose of: 

ID Protection - preventing others from misusing your details. This may include ID validation for anti-money laundering, anti-fraud, preventing crime, asset recovery, debt collection and reuniting people with unclaimed assets. 

Advertising - providing offers that are relevant to you. This may involve data analysis, matching, profiling and predicting behaviours so you may receive advertising that is more relevant to you.

WINR and their partners will retain your information for as long as necessary to perform these functions. You can opt-out of all WINR activity by contacting their Privacy Officer https://www.winrdata.com/privacy-policy

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.

 

Marketing to Children

20. We do not knowingly, deliberately or aim to, collect personal data from children under the age of 18, either for registration or for marketing purposes. Our sites all ensure that a ‘You Must Be 18+ To Enter’ disclaimer is included in the registration section. 

Our Partners and their Industry Sectors

21. Our trusted Partners, both sponsors of the site and particular surveys, may wish to contact you based on your profile, but will only do so subject to your consent and preferences. They operate within the following industry sectors:

 

SectorDescription and examples

Automotive + Show companies

Test Drives / Brochure Request

Retail + Show companies

General Stores

Online retail

Property

Utilites

Finance + Show companies

Banking

Claims Companies

Debt

Loans, Credit cards and mortgages

Gambling + Show companies

Lottery

Online Bingo

Online Casino

Insurance + Show companies

Personal

Travel

Travel + Show companies

Holidays

Lifestyle + Show companies

Fitness

Health & Well Being

Online Dating

Online Sweepstakes

General + Show companies

Call Centre

Data Processor

Marketing Companies

Utilities + Show companies

General

Telecom

Public Sector + Show companies

Public Sector

Security + Show companies

General

You are in Control

22. You may choose to restrict the collection or use of your personal data in the following ways: 

 

  • Our website forms will always have an unticked box for third party telephone marketing, which you can optionally select upon registration so that your personal data can be passed on to our third parties for direct marketing purposes. Our website forms will always have an unticked box for offer base email marketing, which you can optionally select upon registration so that Marketing Punch can send you emails from selected companies (listed at collection) for direct marketing purposes. 

  • You can control the channels of which you receive marketing, whether by email, phone, SMS by selecting the appropriate unticked box in our website forms, which determine the method by which you wish to be contacted;

  • You can opt out from any of our e-communications (email, SMS etc) at any time by clicking UNSUBSCRIBE, replying STOP or contacting us directly

  • Where consent has been previous obtained to us or our trusted partners to using your personal data for direct marketing purposes, you can change your mind at any time by going to the Preferences section of the website http://www.offerx.co.uk/communication-preferences-loginor emailing our Data Protection Officer at datacompliance@marketingpunch.co.uk 

  • WhatsApp - When joining our WhatsApp messaging list, a user provides explicit consent to receive WhatsApp messages from us by following these steps: 

    • Adding the phone number stated on the signup page to their address book

    • Actively sending a message to that number that says ‘Start’

  • Push Notifications- When joining our push notification list for sending offers you provide us with direct consent to send you push notifications by explicitly turning on this browser-level permission.

 

Your Rights

Under data protection law you have rights regarding how we process your data.

23. You have the right to: 

23.1. obtain access to your personal data;

23.2. receive information about us and the purposes for which we process your personal data;

23.3. prevent processing which may cause you damage or distress;

23.4. object to direct marketing and select the contact channels by which we market 

23.5. object to purely automated decision-making in certain cases;

23.6. you have the right to seek compensation through the civil courts for a breach of a data controller’s obligations;

23.7. ask us to correct any errors and/or delete the information we hold ;

23.8. Be forgotten by requesting all personal data collected from you, by us, be deleted completely from our database, systems and servers*;

23.9. opt out of any further contact by us or selected brand partners or sponsors; 

23.10. Be notified in the event of a data breach, where data lost or stolen involves your personal data; and 

23.11. Write to, report, or complain to your relevant supervisory authority, depending on your EU Member State. For UK data subjects, this is the Information Commissioner’s Office (ICO) and their contact details are: 

The Information Commissioner’s Office
Wycliffe House, Water Lane, 
Wilmslow, Cheshire, SK9 5AF
https://ico.org.uk/make-a-complaint/ 
Tel: 0303 123 1113

If you would like to exercise any of your above rights or have any questions regarding this Privacy Policy, please email datacompliance@marketingpunch.co.ukor write to:

The Data Protection Officer
Marketing Punch Ltd,
Studio 33,
Kestrel Court,
Waterwells Drive Gloucester, GL2 2AT 
Tel: 01453 707400



(*) We may reserve the right to retain personal data where a reasonable expectation exists in order to fulfill an obligation. This may include suppression, ie. to “block” future communications received by request of the data subject, a regulatory authority or by law. In this event,the data subject will be informed accordingly of our reliance on this expectation(s). 

 

Your Data and our Data Partners

24. Your 'Registration Details' (and other details depending on which activities you chose to participate in on the Site) will be shared, by way of either single or multiple use data licences, with selected Data Partners who may then contact you by email, telephone or post depending on the consents that you supplied us at the time of registration or subsequently. 

25. We usually only permit Data Partners to use these details to contact you for a pre-specified limited period And they, like us, are obliged to comply with all relevant data protection requirements regarding their holding and use of these details including screening (according to the method used to contact you) against the Telephone Preference Service (TPS) and Mailing Preference Service (MPS) prior to use. Your IP address (see 'Cookies' section 46 for more details) will not be shared with our Data Partners unless you participate in their Branded Survey (see below). 

26. Participating Data Partners may also use your personal data for the purposes of fraud prevention, e.g.: anti-money-laundering and debt tracing according to their privacy policies. 

Branded Surveys on the Site

27. If you take part in a branded Survey on the site, then we will, in addition to the Registration Details referred to above, provide the Survey Sponsor (who will be clearly named) with your personal data as follows ('Survey Details'):

28. IP address (the unique numbers that identify the computer you are using to participate in the Survey)

29. Your responses to the Survey and date of response and any other information specific to the Survey that you are asked to provide 

30. Cookies captured from your use of the Site generally and in completing the Survey. 

31. The Survey Sponsor will use your responses and the Registration Details to identify what future competitions, surveys, offers, and information about their products and services you may be interested in, and to contact you by the methods referred to above. We do not place a specific timeframe on their use of the Registration and Survey Details 

32. Please note as part of the registration process and completing the branding surveys and giving your consent you are agreeing to be contacted by the companies running the Branded Surveys by the methods referred to in 6.2, including by telephone. This will take preference over any registration that you may have with the TPS (Telephone Preference Service) of the number you have provided to us or updated with us. It is always your choice as to whether you want to receive such calls, so if you are registered with the Telephone Preference Service and decide you no longer wish to hear from Marketing Punch, you can leave the Marketing Punch Scheme at any time. 

33. If you no longer wish to hear from any of the companies running the Surveys who have received your personal data, you will need to contact each of them directly to request this. This also applies to any other preference service you may have registered with such as the Mailing Preference Service. 

Entering a Prize Draw 

All prize draws on the Site will be clearly marked as either being sponsored by us or a named third-party sponsor ('Competition Sponsor'). Your Registration Details, that you submit when entering the competition will be used to administer the competition and as follows: 

34. If you enter a prize draw which is sponsored by us, this personal data may be, subject to your consent, shared with our Data Partners. 

35. Some prize draws have additional provisions for how your personal data is used. Please ensure you read the particular terms and conditions for each prize draw before taking part in that prize draw. 

 

 

3 rd party gaming opportunities

36. The site allows you access to many games including bingo and slot machines. The games are provided by a third party and when you “CLICK TO PLAY” you will be taken to the 3 rd party’s website where you can register to play. We do not pass on any personal data to the 3 rd party. You should read their privacy policy and terms and conditions of play before signing up. 

Opting In / Opting Out

37. 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.

38. When registering your details, you will be required to actively opt in to; 

38.1. receive offers and updates by email, telephone and post from selected third party companies which we believe will be of interest. 

38.2. Agree that our trusted partners may contact you with more interesting offers by telephone 

38.3. Acknowledge that you have read, understood and agreed to our terms prior to registration.

Marketing Punch 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. 

 

39. 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 OfferX

40. You may change your preferences at any time via the “How to Unsubscribe” pages once you are registered. 

41. 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. 

42. 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. 

Opting Out – Additional Information 

43. You can unsubscribe or opt out from any communications from our scheme or any third-party brand at any time as indicated above, but you may also wish to consider the following for a more general Opt-Out. 

 

Opting Out – Postal Contact You can withdraw your consent for postal marketing from anyone by adding your details to the Mail Preference Service. For more details please go to www.mpsonline.org.uk

 

Opting Out – Email or SMS (text message) Contact. You can unsubscribe from receiving e-mail or SMS marketing communications from ourselves or individual third-party by using the instructions in any electronic communication such parties sends you (usually an ‘unsubscribe’ or ‘STOP’ link)

Opting Out – Telephone calls To withdraw your consent for live or automated calls from anyone, you can add your name to the Telephone Preference Service which is maintained at this website address: www.tpsonline.org.uk

Opting Out – Social Media

You can configure your advertising preferences on social media such as Facebook, Twitter, Instagram or Pinterest by accessing your settings or preference options on the relevant platform. 

 

44. You may unsubscribe from our WhatsApp mailing list at any time. To unsubscribe you may do any of the following: 

  • Reply to any of our messages with 'Stop' to unsubscribe 

 

45. Push Notification - You may unsubscribe from our browser notification mailing list at any time. To unsubscribe you may: Follow the instructions on this page

Data Safety Outside the European Union

46. 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.

 

Security and Storage of Your personal data

47. We store all data collected in an encrypted environment and only for as long as is necessary However, despite our best efforts the Internet is not 100% secure and we cannot guarantee the security of any information you send to us via the Internet. We will not be responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of such information.

IP Address/Cookies

48. We automatically collect your IP address and record the web page from which you originated if you are using the service’s website. 

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. 

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. 

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 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 

PingdomPRUM_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. 

Changes to this Policy

52. 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.

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