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Welcome to InboxPounds® Limited’s Privacy and Cookie Policy

InboxPounds® Limited respects your privacy and is committed to protecting your personal data. This Privacy and Cookie Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy and Cookie Policy is provided in a layered format so you can click through to the specific areas set out below.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. COOKIES
  6. DISCLOSURES OF YOUR PERSONAL DATA
  7. SOCIAL MEDIA AND ONLINE ENGAGEMENT
  8. INTERNATIONAL TRANSFERS
  9. DATA SECURITY
  10. DATA RETENTION
  11. YOUR LEGAL RIGHTS
  12. PRIVACY SHIELD CERTIFICATION OF COTTERWEB ENTERPRISES INC.

I. IMPORTANT INFORMATION AND WHO WE ARE

  1. Purpose of this Privacy and Cookie Policy

    This Privacy and Cookie Policy aims to give you information on how InboxPounds® Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up and create an account with us or take part in any of our great prizes, games, offers, surveys and competitions (Offers).

    This website is not intended for children and we do not knowingly allow children to create a members account or profile on the website.

    It is important that you read this Privacy and Cookie Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy and Cookie Policy supplements the other notices and is not intended to override them.

  2. Who is InboxPounds® Limited?

    InboxPounds® Limited is a company registered in England and Wales which owns and operates this UK website and collects your data through and in relation to it.

    The operation of this website and the associated activities of InboxPounds® Limited in relation to its UK members are governed by the UK data protection authority, the Information Commissioner’s Office (ICO). InboxPounds® Limited is registered with and pays all applicable fees to the ICO. Our registration number is Z2994933. You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues, whose website and contact information can be found at www.ico.org.uk. The phone number to contact the ICO is 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

    We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy and Cookie Policy. If you have any questions about this Privacy and Cookie Policy, including any requests to exercise your legal rights, please contact the DPO using the contact details set out below.

  3. InboxPounds® Limited’s contact details are:

    Full name of legal entity: InboxPounds® Limited

    Name or title of DPO: Chief Technical Officer, Tom Healy

    Email address: dpo@inboxpounds.co.uk

    Telephone number: 651 289 0720

  4. Who is CotterWeb Enterprises Inc. and why is InboxPounds® Limited sharing data with them?

    Many of InboxPounds® Limited’s operations are supported by website servers located in the United States under the control of its US parent company, CotterWeb Enterprises Inc., details of which can be found here. As a result, InboxPounds® Limited will transfer your data outside the European Economic Area (EEA) to its parent company, CotterWeb Enterprises Inc. in the United States and these two companies together are regarded as joint controllers in relation to the personal data received through and in relation to this UK website. This Privacy and Cookie Policy is issued on behalf of both companies and so when we mention “InboxPounds®”, “we”, “us” or “our” in this Privacy and Cookie Policy, we are referring to both InboxPounds® Limited and CotterWeb Enterprises Inc. as joint controllers responsible for processing your data, unless we clearly indicate otherwise by using either company’s full registered name. See the section on Privacy Shield certification at section 12 below to see how CotterWeb Enterprises Inc. is also protecting your data protection rights.

  5. Changes to the Privacy and Cookie Policy and your duty to inform us of changes

    This version was last updated on June 13, 2018 and historic versions can be obtained by contacting us. We may make changes to this Privacy and Cookie Policy at any time. You can always access the most up to date version here or by clicking on a link to the Privacy and Cookie Policy on our website.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  6. Third-party links

    This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

II. THE DATA WE COLLECT ABOUT YOU

  1. About Personal Data

    Personal data, or personal information, means any information about an individual from which that person can be identified.

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

    1. Member Identity Data includes [first name, last name, username or similar identifier and login password].
    2. Member Contact Data includes [residential address, email address and telephone numbers].
    3. Member Reward Payment Data includes [name, residential address and amount of member’s reward if receiving payment by cheque or by pre-paid master card or name and associated Paypal account email if receiving payment by Paypal].
    4. Transaction Data includes [details about reward payments made to you and other details of your interactions with us including Offers completed by you or referrals of other members that you have introduced to InboxPounds®].
    5. Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
    6. Profile Data includes [post code, your interests, preferences, feedback and survey responses including phone number, date of birth, gender, education level, household income, job title, work industry, organisation annual revenue, children’s ages, children’s genders, employment status, work decision making role, departmental influence, organization primary industry, number of employees, relationship status, work department, own or rent home, mobile phone type, type of pet, play video games and/or use of gaming consoles].
    7. Usage Data includes [information about how you use our website, product and services].
    8. Marketing and Communications Data includes [your preferences in receiving marketing from us and third parties and your communication preferences].

    Personal data can be anonymised or pseudonymised, which means ensuring that when it is processed it either no longer includes any identifying elements or has those elements replaced with a value like a number from which an individual cannot be identified (Anonymous Data). Personal data can be considered to be Anonymous Data either on a temporary basis, because we still hold the means to re-associate it with your information from which you are personally identifiable, or on an irreversible basis by us destroying or irretrievably removing the identifying elements entirely so they cannot be re-associated in future. We will sometimes use your data in a form which is Anonymous Data as part of our security measures to minimise the risk of it being used to in an unauthorised way whilst being processed.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookie Policy.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  2. Member Referrals

    You may also give us the personal data of a name and email address for someone else who you want to refer to our website and services (a Member Referral) because by making a Member Referral you can earn additional rewards to your Member account. If you do provide us with a Member Referral it is important, firstly that you get that person’s permission to give their personal data to us and make sure they understand this means we will be sending them email communications to provide them with a link to our website and Offers. Secondly, you should point them to this Privacy Policy so they can understand how we might use their personal data if they do choose to become a member and have their own account with us. If a person creates a membership account with us following a Member Referral by you, we will use the Member Identity Data and our cookies (see Cookies section below) in order to verify their registration matches the data you provided for the Member Referral so that you get correctly credited for that Member Referral resulting in a new member registration on our website.

  3. If you fail to provide personal data

    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. By way of example, we cannot establish a member account for you if we do not have your Member Identity Data and we cannot pay out your rewards if we do not have your Member Reward Payment Data.

    Of the types of personal data identified above, Profile Data is personal data you provide to us entirely at your option, but it will make a significant difference to your experience whilst using our website and services. In particular, the quality and appropriateness of the Offers that we send to you are considerably enhanced the more Profile Data we hold about you. You will still receive Offers even if you choose not to provide us with Profile Data, but you should be aware these Offers will not have been tailored to suit your personal preferences if we do not hold sufficient Profile Data and so you may not find them appropriate or be able to qualify for the same sort of rewards for everything we send to you. You are always in control of how much or how little Profile Data we hold about you as this is an area of your member’s account which you can alter at any time, correcting, updating or removing your Profile Data as you choose.

III. HOW IS YOUR PERSONAL DATA COLLECTED?

  1. Data Collection

    We use different methods to collect data from and about you including through:

    1. Direct interactions. You may give us your Member Identity, Member Contact and Member Reward Payment Data by filling in forms or by corresponding with us via our website or by phone, email or otherwise. This includes personal data you provide when you:
      1. create a membership account on our website;
      2. subscribe to our service or publications;
      3. request marketing to be sent to you;
      4. enter a competition, promotion or survey; or
      5. give us some feedback.
    2. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the section below on our use of cookies for further details.
    3. Membership checks from other advertisers. We may receive parts of your Member Identity Data such as your email address from third party advertisers wishing us to check whether you are already a member of our website. This is only used to ensure you do not receive repeat Offers from us because you are already a member with an account on our website.

IV. HOW WE USE YOUR PERSONAL DATA

  1. Data Usage

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    1. Performance of Contract - Where we need to perform the contract we are about to enter into or have entered into with you.
    2. Legitimate Interest - Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
    3. Comply with a legal or regulatory obligation - Where we need to comply with a legal or regulatory obligation that we are subject to.
    4. Consent - Where you have explicitly consented to us doing so in the way we will explain below. Consent is only used as a legal basis for our processing in relation to how we use your Profile Data. Profile Data is information which we don’t have to have in order to run your member account, but it makes a very big difference to your experience of our services if you do choose to provide us with it and in doing so give your consent to how we use it. We’ll explain more here.

  2. Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contacts us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/Activity
    Type of data
    Lawful basis for processing including basis of legitimate interest
    Purpose/Activity
    To register you as a new member
    Type of data
    1. (a) Member Identity Data
    2. (b) Member Contact Data
    Lawful basis for processing including basis of legitimate interest
    Performance of a contract with you
    Purpose/Activity
    To process and deliver your request for membership reward services including to manage payments of your member rewards
    Type of data
    1. (a) Member Identity Data
    2. (b) Member Contact Data
    3. (c) Member Reward Payment Data
    4. (d) Transaction Data
    Lawful basis for processing including basis of legitimate interest
    1. (a) Performance of a contract with you
    2. (b) Necessary for our legitimate interests
    Purpose/Activity
    To manage our relationship with you which will include notifying you about changes to our terms or Privacy and Cookie Policy in the event of a fundamental change
    Type of data
    1. (a) Member Identity Data
    2. (b) Member Contact Data
    Lawful basis for processing including basis of legitimate interest
    1. (a) Performance of a contract with you
    2. (b) Necessary to comply with a legal obligation
    3. (c) Necessary for our legitimate interests (to keep our records updated and to study how members use our services)
    Purpose/Activity
    To enable you to partake in Offers
    Type of data
    1. (a) Member Identity Data
    2. (b) Member Contact Data
    Lawful basis for processing including basis of legitimate interest
    1. (a) Performance of a contract with you
    2. (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
    Purpose/Activity
    To email potential new members that you identify as part of our Member Referral scheme
    Type of data
    Data you provide to us as a Member Referral
    Lawful basis for processing including basis of legitimate interest
    Necessary for our legitimate interests (to provide you with correct credit for making a referral as a means of growing our membership)
    Purpose/Activity
    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to provide you with access to support through our Live Chat facility
    Type of data
    1. (a) Member Identity Data
    2. (b) Member Contact Data
    3. (c) Technical Data
    Lawful basis for processing including basis of legitimate interest
    1. (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise and for identifying concerns or issues raised by a member during use of our Live Chat facility)
    2. (b) Necessary to comply with a legal obligation
    Purpose/Activity
    To use data analytics to improve our website, Offers/services, marketing, member relationships and experiences
    Type of data
    1. (a) Technical Data
    2. (b) Usage Data
    Lawful basis for processing including basis of legitimate interest
    Necessary for our legitimate interests (to define types of member for our Offers and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
    Purpose/Activity
    To deliver relevant website content and targeted member Offers or advertisements to you and measure or understand the effectiveness of the member Offers or advertisements we provide to you
    Type of data
    1. (a) Member Identity Data
    2. (b) Member Contact Data
    3. (c) Usage Data
    4. (d) Marketing and Communications Data
    5. (e) Technical Data
    Lawful basis for processing including basis of legitimate interest
    Necessary for our legitimate interests (to study how members use our products/services, to develop them, to grow our business and to inform our marketing strategy)
    Purpose/Activity
    To make suggestions and recommendations to you about Offers or services that may be of interest to you
    Type of data
    1. (a) Member Identity Data
    2. (b) Member Contact Data
    3. (c) Technical Data
    4. (d) Usage Data
    Lawful basis for processing including basis of legitimate interest
    Necessary for our legitimate interests (to develop our Offers and services and grow our business)
    Purpose/Activity
    The purpose of profiling your preferences from your Profile Data in order for us to provide a more tailored service to you for each of the purposes:
    1. (a) To deliver relevant website content and targeted Offers or advertisements to you and measure or understand the effectiveness of the Offers or advertisements we provide to you
    2. (b) To make suggestions and recommendations to you about Offers or services that may be of interest to you
    Type of data
    Profile Data
    Lawful basis for processing including basis of legitimate interest
    1. (a) Necessary for our legitimate interests (to tailor our Offers and services and grow our business) – only when used in a depersonalised or pseudonymised form, that means we only use it under this condition if your Profile Data can be separated from any information from which you are personally identifiable and so can be processed as Anonymous Data
    2. (b) Consent – your Profile Data which is personally identifiable or when used together with other data which is personally identifiable will only be used for these purposes with your specific consent. You may choose to update, amend or remove your Profile Data at any time using our Profile Dashboard which will give you control over the consent you give us to use this specific Profile Data at all times.
    Purpose/Activity
    To share your Profile Data with Named Market Research Partners (see definition of who this is listed below) for them to identify suitable targeted Offers to send to you
    Type of data
    Profile Data
    Lawful basis for processing including basis of legitimate interest
    Consent – your Profile Data which is personally identifiable or when used together with other data which is personally identifiable will only be shared with third parties for these purposes with your specific consent. You may choose to update, amend or remove your Profile Data at any time using our Profile Dashboard which will give you control over the consent you give us to use this specific Profile Data at all times.

  3. Profiling and Consent

    Being an InboxPounds® member is all about you receiving great opportunities to earn rewards through our membership service. We will still send you Offers, even if you don’t provide us with any Profile Data, so if you don’t want to fill in those details you still get the chance to earn cash rewards with InboxPounds®.

    However, the best way to get the most out of your membership with InboxPounds® and to earn more cash rewards, is if we can use the Profile Data that you provide to us in order to make sure we only send you the particular Offers that we think will suit you the best. We use Profile Data to learn about your personal preferences and interests and this will determine which Offers we send to you – this is a largely automated process known as profiling. The only decisions that our profiling methods make about you and your personal information is to determine what type of Offers you are most likely to want to see from us given your personal preferences and demographic information. Our profiling methods do not get used for any other purpose than to give you great Offers and improve our service to you.

    We strive to provide you with choices regarding certain personal data uses, particularly around the type of Offers, marketing and advertising that you see when you visit our website or receive opportunities to earn cash rewards with us. With this in mind, we have established our Profile Dashboard where you can view and make certain decisions about your personal data use.

    You are always in control of the amount of personal information which you give to us on your Profile Dashboard. By completing information in the Profile Dashboard you are giving us your consent to the use we’re describing in this section of the Privacy and Cookie Policy. You can remove information you previously provided in the Profile Dashboard at any time to withdraw your consent (opt out) to your Profile Data being used in this way.

    You can also make specific choices about whether you consent to your Profile Data being shared with third parties for the purposes of matching their Offers to your personal preferences. On the Profile Dashboard you’ll find a clear box which you can tick if you are happy for us to share your Profile Data only with those Named Market Research Partners which are specifically listed below. You can untick this box at any time to withdraw your consent (opt out) to your Profile Data being shared with the Named Market Research Partners.

V. COOKIES

  1. About Cookies and Third Party Technology.

    A “cookie” is a small data file that may be saved to and stored on your computer when you visit a website or open an email. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies permit a website to “remember” whether your computer has visited the website before and helps the website create a more personalised experience for you and records activities taken by you, such as Offers completed. In this way cookies also allow us to verify the identity of a new member registration to ensure it matches the details of a Member Referral and so allow us to credit you with additional rewards for making that Member Referral.

    For a full list of all cookies used on our website, please follow this link to cookie information.

    In addition to cookie technology, InboxPounds® use additional third party technology and tracking tools to record Offers and activities completed by you, friends referred by you, and to communicate information about you, such as anonymised demographic information (e.g., age, gender), in order to target Offers and advertisements to specific groups as requested by advertisers. Cookies and other tracking technology are collectively referred to as “Cookies and Recording Tools”.

    Your computer permits you to change the settings on your web browser to not accept and/or disable Cookies and Recording Tools. However, if you do not accept Cookies and Recording Tools used by InboxPounds®, you may not be able to use certain functions on the website or on certain links to external websites. More importantly, if you do not accept Cookies and Recording Tools you will not receive credit for Offers or other actions completed by you because we are unable to track and record your activity. If you do not want to accept Cookies and Recording Tools, you must stop using this website.

    Also remember that any time you leave our website using a link to a third party’s website, such as one of the advertisers or partners who have links and adverts on our website, they may also use cookies. So make sure you visit their cookie policy to ensure you are comfortable with how they do things once you have left our website.

    Except for essential cookies, all cookies will expire after the period of time provided here.

  2. Referral and Affiliate Tracking

    InboxPounds® uses cookies in order to collect Transaction Data which allows us to track new Member registrations. This ensures Members are properly credited for referring other Members, as well as to track the rewards you’ve earned by completing Offers which have connected you to our advertisers and partners.

  3. Member Recognition

    After you have logged on as a Member into the InboxPounds® Member’s Section, cookies are used to remember your Member name and password so they do not need to be entered during every visit to our website. You can logout of the Member’s Section if you do not wish to have this information saved.

  4. Change of purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

VI. DISCLOSURES OF YOUR PERSONAL DATA

  1. About Disclosure

    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

    1. Internal Third Parties being other companies in the CotterWeb Group – As explained above, InboxPounds® Limited and CotterWeb Enterprises Inc. are the two companies in the CotterWeb Group and each of these companies is a joint controllers, together being responsible for processing your data.
    2. External Third Parties could be any of the following:
      1. Professional advisers including lawyers, bankers, auditors and insurers based either in the UK or the US who provide consultancy, banking, legal, insurance and accounting services to the CotterWeb Group.
      2. HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
      3. Our third party service providers and business partners who assist with the running of the website and our Offers, services and products including hosting providers, payment processing partners, software service providers and backup and support services providers. Our third party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.
      4. Named Market Research Partners – those market research partners with which CotterWeb Group has an existing relationship and which are named on the Profile Dashboard so you can specifically choose whether or not you consent to your Profile Data being shared with these Named Market Research Partners and whether you wish to remove your consent at any time (which, if you do, we will ensure means your Profile Data is removed from our records within a reasonable time from your request and that this withdrawal of consent is also passed on to the Named Market Research Partners so that they stop using the Profile Data that we have shared with them previously). The Named Market Research Partners are shown below together with links to their own privacy policies:
        1. Critical Mix Inc.
        2. Toluna Inc.
        3. Survey Sampling International LLC
      5. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy and Cookie Policy.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

VII. SOCIAL MEDIA AND ONLINE ENGAGEMENT

  1. Social Media

    We occasionally use a variety of new technologies and social media options to communicate and interact with our members. These sites and applications include popular social networking and media sites. To better engage the public in ongoing dialog, we use certain third-party platforms including, but not limited to, Facebook and Twitter. These third-party websites and applications are web-based technologies that are not exclusively operated or controlled by us. When interacting on those websites, you may reveal certain personal information to us or to third parties. Other than when used by our employees for the purpose of responding to a specific message or request, we will not use, share, or retain your personal information.

    The Facebook privacy policy is available here.

    The Twitter privacy policy is available here.

VIII. INTERNATIONAL TRANSFERS

  1. International Transfer of Data

    We share your personal data within the CotterWeb Group. This will involve transferring your data outside the EEA.

    Many of our External Third Parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
    2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
    3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

IX. DATA SECURITY

  1. About Data Security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

X. DATA RETENTION

  1. How long will you use my personal data for?

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    By law and in order to answer any member payment queries or respond to any claims regarding payments made, we have to retain a record of some of the basic information about our customers (including Member Identity Data, Member Contact Data and Member Reward Payment Data) for seven years after they cease being members for these accounting and tax purposes. This record of historic payments we have made to you and the account to which those payments relate are kept separately from details of all other elements of your member account once your account is no longer active. This information is secured and access is further restricted to ensure these records are not used for any other purposes than to respond to such legal, accounting, tax and any other related payment queries or claims if necessary.

    In all other respects, the personal data that you provide to us will only be retained for the life of your member account being active. If your member account is inactive for 6 months, the Member Identity Data, Member Contact Data and Member Reward Payment Data will be deleted from our member records databases and replaced with a string of numbers which means all other information such as any Transaction Data, Technical Data or Profile Data can no longer be re-associated with your personal information. Following a further period of 7 days, after which our back up facilities are overwritten, the only information retained relating to your member account will then permanently be Anonymous Data. Once it has become Anonymous Data (so that it can no longer be associated with you) your information will be retained indefinitely for research and statistical purposes without further notice to you.

    In some circumstances you can ask us to delete your data: see Request erasure below for further information.

XI. YOUR LEGAL RIGHTS UNDER GDPR (For EU Individuals)

  1. About your Legal Rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

    Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. With InboxPounds® and our My Account page you are always in control of the information we hold about you and so can ensure it is correct and accurate yourself at any time.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent (opt out) at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you and neither will the Named Market Research Partners who have also relied on your consent to process the Profile Data we have shared with them. We will advise you if this is the case at the time you withdraw your consent.

    The right to file a complaint with your regional Data Protection Authority regarding the handling of your personal data by us. Please go to this list of Data Protection Authorities to locate contact information for your DPA.

    If you wish to exercise any of the rights set out above, please contact us.

XII. PRIVACY SHIELD CERTIFICATION OF COTTERWEB ENTERPRISES INC. (For EU Individuals Whose Data Is Transferred to the US)

  1. Privacy Shield

    The EU has established strict protections regarding the handling of personally identifiable information that is received in the US from the EU (“EU Personal Data”) and this includes requirements to provide adequate protection for that EU Personal Data.

    CotterWeb Enterprises, Inc. is subject to the regulatory and enforcement authority of the US Federal Trade Commission.

    CotterWeb Enterprises, Inc. complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield. CotterWeb Enterpries Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

    Pursuant to the Privacy Shield we are required to notify those members from the EU that we may be compelled to release their EU Personal Data in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

    We acknowledge the right of those members from the EU about whom we process EU Personal Data to access their personal data pursuant to the Privacy Shield. Individuals wishing to exercise this right may do so by contacting CotterWeb Enterprises Inc. at the contact details provided below. As an organization which is compliant with the Privacy Shield Principles, CotterWeb Enterprises Inc. remains liable for the processing of the EU Personal Data by a third party acting on our behalf, unless we can prove we were not a party to the actions giving rise to the damage.

    EU individuals can, under the Privacy Shield, control whether their personal information is to be disclosed to a third party or to be used for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized by that individual. Prior to filling out the Profile Survey, consent is requested to authorize the disclosing your information. If we need to use your personal data for a purpose that is materially different from the purpose(s) for which you have previously provided consent, we will notify you and we will explain the legal basis which allows us to do so. If you wish to opt out of our use of your data in this way, you may withdraw consent (opt out) at any time by visiting the My Account page.

    In compliance with the Privacy Shield Principles, CotterWeb Enterprises Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact CotterWeb Enterprises Inc. at:

    Name or title of DPO: Chief Technical Officer, Tom Healy

    Email address: dpo@cotterweb.net

    Telephone number: 651 289 0720

    CotterWeb Enterprises Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit here for more information and to file a complaint. This service is provided free of charge to you.

    If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1


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