WHO ARE WE
OUR COMMITMENT TO YOU & YOUR PERSONAL DATA
- CLG is committed to protecting your data. We collect your personal data to help us understand your needs and this 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 EU based servers. We work within the guidelines and advice provided by the Information Commissioner's Office, the regulator of the Data Protection Act 1998 and the GDPR and abide by the ICO’s requirements.
- We seek to fully comply with the Data Protection Act 1998, 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 visithttps://ico.org.uk/
- This Policy sets out how we manage, use and protect your personal data collected while using our sites and that of our media partners.
OUR PURPOSE FOR PROCESSING YOUR PERSONAL DATA
- CLG has 2 main business purposes:
- The management of an Affiliate Network.
- The management of various owned/hosted and partners lead generation websites across multiple verticals and geographies
To this end, it is necessary to submit the data of a consumer that registers on our site (“registered individual”) to standardisation, filtering and verification prior to submission to the relevant advertiser or client. The categories and methods of marketing communication which the registered individual’s may receive will be determined, subject to their active consent. All Companies, partners and brands whether owned or that of our partners are listed on our site, prior to registering for full transparency.
Internally to communicate, (via email, telephone, skype, SMS or the chosen contact method) the data of interest to CLG 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. Proof of this consent can be provided upon request by emailing or writing to us and will be provided within the timeframes allowed under GDPR.
- We will minimize the data we collect and process it 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);
- The lawful basis for which we process your personal data is consent.
COLLECTION AND USE OF YOUR PERSONAL DATA
- To manage the participation of the registered individual in Lead Generation Campaigns, organised by CLG as promoted directly via its owned sites, advertising clients and agencies;
- For the fulfilment of a contract with selected Companies and trusted Partners;
- To carry out third party advertising campaigns / market studies by us where consent has been obtained from the registered individual; and
- To communicate the registered individual’s data to companies, organisations and/or entities interested that they have actively consented to, in carrying out advertising campaigns / market studies / competitions.
- We collect your details when you register on one of our websites or complete one of our clients lead generation campaigns / pages. ‘Personal data’ means the information you provide during the registration process and any information you provide when completing one of our or one of our partners lead generation programmes.
- The categories of personal data we may collect from you upon registration of our website. Please note we do not collect as part of our registration pages any sensitive data which make include race, ethnicity, political or religious views, Sexual orientation, health or trade union memberships.
USE OF YOUR PERSONAL DATA
- 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, device type.
- We use your personal data collected via the CLG sites and that of our advertising partners to:
- Provide you with information about the products and services we offer
- Provide you with a more personalised and targeted services
- 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
- Share your data with third party companies who may contact you. 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.
- 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.
- We may process your personal data ourselves or through data processors that will process data on our behalf for ensuring the data processor complies with this policy and all current data protection regulations.
- Depending on the consents that you set up at the time of registration and what personal data we or our partners hold about you, we may pass your personal data to our partners who may contact you by post, email, SMS, WhatsApp and telephone for direct marketing purposes.
- We may share your data with selected third parties for marketing communications and analysis
- Email and Telephone/SMS 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.
- You can change or update your communication preferences at any time.
- 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.
- We will only store your data in accordance with our Data Retention Policy.
MARKETING TO CHILDREN
- 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 PARTNERS AND THEIR INDUSTRY SECTORS
- Our clients may wish to contact you based on your profile, but will only do so subject to your consent and preferences outlined at the registration. They operate within the following industry sectors:
YOU ARE IN CONTROL
- Claims Management
- Competitions and Prizes
- Deals, Offers, New Products & Services
- Electrical Services
- Employment & Recruitment
- Fast Moving Commerical Goods (FMCG)
- Financial Products
- Gambling and Lotteries
- Health and Beauty
- Home Improvements and Renovations
- Life assurance
- Mail Order
- Mis-sold financial products
- Pension Reviews
- Pre-paid Funeral Plans
- Public Sector
- Retail & lifestyle
- You may choose to restrict the collection or use of your personal data in the following ways:
- The registration forms will always have an unticked and unbundled where requires box for third party marketing, which you can optionally select to allow your personal data to be sent to our partners for direct marketing purposes.
- You can control the channels of which you receive marketing, whether by email, phone, SMS or post by selecting the appropriate unticked box in the website forms, which determine the method by which you wish to be contacted.
- Where consent has been previous obtained by us or our trusted partners to using your personal data for direct marketing purposes, you can change your mind at any time by emailing our Compliance Officer at email@example.com, calling 0203 002 2822 or unsubscribing from any of our emails.
- 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;
- Be notified in the event of a data breach, where data lost or stolen involves your personal data; and
- Write to, report, or complain to your relevant supervisory authority, depending on your EU Member State (example, for UK data subjects, it is the ICO).
- If you would like to amend/delete details or contact us in relation to the above, please contact using the ‘Contact Us’ page, alternatively send an email to firstname.lastname@example.org
YOUR DATA AND OUR DATA PARTNERS
- Your 'Personal Details' (and other details depending on which activities you chose to participate in on our sites or that of our advertisers) may be shared, by way of either single or multiple use data licences, with selected partners who may then contact you by email, telephone, SMS or post depending on the consents that you supplied us at the time of registration or subsequently.
- We usually only permit Data Partners to use these details to contact you for a pre-specified limited period. 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 during registration (see 'Cookies' section 46 for more details) may also be shared with our partners for the purpose of validation.
- 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.
- To understand more please click through to the websites of the companies below. If you'd like more information about our sponsors, please visit oursponsors page.CLICK HERE to view our partners.
OPTING IN / OPTING OUT
- You have the option of Opting In or Out of receiving marketing communications from ourselves and our partners at any time, including at registration.
- When registering your details, your permission will be sought to:
- Receive offers and updates by email, telephone and post from selected third party companies which we believe will be of interest.
- Agree that our trusted partners may contact you with more interesting offers by telephone.
- You will be required to acknowledge that you have read, understood and agreed to our terms prior to registration.
- CLG 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 (positive opt in) will you consent to receive additional marketing communication.
- You may change your preferences at any time via emailing email@example.com once you are registered.
- Third-party providers are able to send you communications via email, post, SMS 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. Should any marketing material be received after 28 days please firstname.lastname@example.org immediately or call us on 0207 002 2822
OPTING OUT – ADDITIONAL INFORMATION
- 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 towww.mpsonline.org.uk
Opting Out– Email or SMS (text message) Contact
You can unsubscribe from receiving e-mail or SMS marketing communications from any individual third-party by using the instructions in any email communication such third-party 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.
DATA SAFETY OUTSIDE THE EUROPEAN UNION
- 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.
SECURITY AND STORAGE OF YOUR PERSONAL DATA
- We store all data collected in a secure environment on servers located within the EU 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.
- 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.
Third party cookies that we use:
ACCESS, RECTIFICATION AND ERASURE OF YOUR PERSONAL DATA
- You may request access to, rectification and/or erasure of any personal data which we hold about you under the 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 write to or email us as soon as possible, at the address below. We will promptly endeavour to correct any information found to be incorrect.
- You may at any time unsubscribe from our sites or any/all of our partners manually by email@example.com
Tel: 0203 002 2822
The Compliance Officer
Click Labs Group Ltd
91 Waterloo Road
CHANGES TO THIS POLICY
- 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. If we make substantial changes to this policy, we will notify you via email.
Last Updated 25th March 2019