I. ABOUT THESE TERMS AND CONDITIONS

1. Your Use of This Website

   These terms and conditions, together with the documents or Website pages referred to in the terms and conditions (the “Terms and Conditions”), apply to the Website home page (the “Website”).

   All visitors to or users of this Website are referred to as “Members”, “you” or similar terms.

   By clicking to accept or agree to these Terms and Conditions, you are acknowledging that you have read, accepted and agreed to be bound by the Terms and Conditions, including our Privacy and Cookie Policy, and you are therefore advised to read these Terms and Conditions and our Privacy and Cookie Policy carefully before proceeding to use the Website and before providing any data to us. If you do not agree to these Terms and Conditions or our Privacy and Cookie Policy you must not use this Website or create a personal account on the Website (an “Account”).

   Any violation of these Terms and Conditions may lead to termination of your Account, cancellation of any credit on your account (“Cash”, as defined more fully in clause VII of these Terms and Conditions) or other items earned or accrued including referrals, as well as any other applicable legal remedy.

2. About Us

   This Website is owned and operated by InboxPounds Limited (“InboxPounds®”, “us”, “we” or similar terms) registered in England and Wales under company number 07871672 and with registered address 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT. InboxPounds® is a subsidiary of CotterWeb Enterprises, Inc., a corporation registered in the United States of America.

3. About the Website

   The Website provides visitors with a means of access to offers from a range of third party advertisers, including those offering insurance, travel, finance, utilities and on-line gambling. We do not supply any products or services you may access via the Website – all products and services are provided by, and purchased from, independent third party sites (even where these may be co-branded with InboxPounds®) to which you navigate via the Website (“Advertised Sites”). Purchases from Advertised Sites will be subject to the terms and conditions of the third party product/service provider, which you are advised to read carefully before concluding your purchase.

   Nothing within the Website is, or shall be deemed to constitute, financial or other advice or a recommendation to purchase any product or service. Any and all information provided within the Website is for general information purposes only.

4. Reservation of Rights

   We reserve the right to modify these Terms and Conditions at any time. Such changes, including retroactive changes, are effective once posted on this or a similar page of our Website. Changes may include, but are not limited to, rules regarding the earning of Cash and the redemption of Cash or any other item. Pages or features of this Website as well as offers appearing on this Website, including prizes, gifts, sweepstakes, offers, or other items or activities may be discontinued or changed without notice (“Offers” as more fully defined in Section VI below).

   If such changes are made, your continued use of the Website will be deemed to constitute your acceptance of the amended Terms and Conditions. You are expected to check this page of the Website from time to time to take notice of any changes made, as they are binding on you.

   We reserve the right to remove any material or posting you make on the Website if, in our opinion, such material does not comply with the content standards which we set for the Website.

   We reserve the right to suspend or curtail your access to the Website at any time without notice including making certain parts of the Website unavailable at our discretion.

   Changes to the Privacy and Cookie Policy will be made in accordance with the terms of the Privacy and Cookie Policy

5. Viruses, Hacking and Other Offences

   You must not misuse our Website by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, the servers on which our Website is stored or any server, computer or database connected to our Website. You must not attack our Website via a denial-of-service attack or a distributed denial-of service attack.

   By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website will cease immediately.

   We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any website linked to it.

II. MEMBERSHIP

1. Valid Information

   Members must be living individuals, and not corporations or any other type of entity. Members must provide a valid e-mail address during registration in order to activate their Account. The country listed in your personal member profile associated with your Account (“Member Profile”) must be the country you are both living in, and logging into your Account from. In addition, any time you provide information to this Website, to any advertisers on the Website (“Advertisers”, as more fully defined in Section VI), or in response to any Offer, such information must be accurate and complete and be your own information and not the information of any other person. This includes, but is not limited to, the registration process, Profile Surveys, and any other place where information is requested.

   Any personal data you provide to us will be used only in ways that are fair and in accordance with these Terms and Conditions and the terms of our Privacy and Cookie Policy.

2. Comply with Laws

   Members must comply with all applicable laws and regulations as they relate to the use of this Website or relations with us.

3. Duplicate Accounts

   Members may not create more than one Account with the Website. In addition, we do not allow:

   1. More than one Account in the same household
   2. More than one Account with the same mailing address
   3. More than one Account using the same computer

4. Signup Bonus

   Upon the creation of an account, a member will earn an initial Cash earnings, which will be credited to their Account as described in other sections of these Terms and Conditions (“Signup Bonus”). To qualify for the Signup Bonus, Members must sign up and activate their Account.

5. Account Cancellation

   Members may cancel their Account any time by clicking the “Cancel Account” link in the “My Account” tab. In addition, all PaidEmails^™ sent to Members include a link to the cancellation page. If a Member cancels their Account, they will forfeit all their Cash in their Account and referrals. In addition, any requested or pending payments for that Member are removed and forfeited.

6. Password and Account Security

   In connection with your Account, you will create a personal password (“Password”). You are responsible for keeping your Password confidential and secure, and you are responsible for all actions taken using your Password.

7. Age

   To create an Account, to be eligible to accrue Cash, or to otherwise use this Website, you must be at least eighteen (18) years old.

8. Current and Accurate Contact Information

   Members are responsible for maintaining accurate and complete contact information and promptly updating such information if they move, their contact information otherwise changes, or if a Member has difficulty receiving emails from InboxPounds® at the e-mail address provided. If a payment posted to a Member is returned to us for any reason, including our being provided with inaccurate or outdated contact information, we will hold such payment for up to ninety (90) days and will resend the payment upon request and receipt of correct contact information within the ninety (90) day period. If we do not receive a request to resend payment along with correct contact information within ninety (90) days, then we will destroy the cheque, all Account Cash giving rise to the payment will be deemed forfeit, and the payment is forfeited and permanently waived. (“Cash”, as defined more fully in clause VII of these Terms and Conditions)

9. Delivery Location

   Members are responsible for selecting a secure and reliable mail delivery address for their payments and other communications. We are not responsible for any stolen or lost cheques and will not replace cheques allegedly cashed improperly by third parties so long as such cheque was sent to the mailing address as indicated in your Account information at the time such cheque was sent. If your household postbox is not secure, we recommend you obtain a secure post office box.

10. Code of Conduct

    By agreeing to these Terms, you're agreeing that you will also follow these rules: (1) Do not publicly display or use the Website or features to share inappropriate Content or material including but not limited to; nudity, pornography, graphic violence, use harassing or hate comments to employees of the Website and/or its members. This includes the Website and all forms of social media (Facebook, Twitter, Instagram etc.). Failure to comply may result in the loss of account and earnings. (2) You are responsible for all usage on your Account, whether or not authorized including your log in, password and Account information.

III. REFERRALS

1. Tracking

   Members can use their Referral URL to refer other Members to the Website. Because InboxPounds® allows only one Account per computer, our referral tracking software will not allow one Member to refer another Member if they are using the same computer.

2. Spam and Unsolicited Email

   Members may not send unsolicited email to persons they do not know in order to refer other Members to the Website and may only forward emails to people they know would be happy to receive them. We cannot possibly list all acceptable and unacceptable methods of advertising. If a Member has a specific question as to whether or not a particular advertising method is acceptable, they should contact us (using the Contact Us page) prior to engaging in that action.

   1. Members may not send unsolicited e-mail (e-mail that has not been actively invited by the recipient) advertising InboxPounds® or the Website.
   2. Members may send solicited e-mail (e-mail that has been actively invited by the recipient) to their subscribers or friends advertising InboxPounds® or the Website. However, Members must adhere to all applicable, current legislation and regulations, including the provisions of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended). Further guidance on the provisions of this legislation is available at the Information Commissioner’s Office website.

3. Refer-a-Friend Service

   Members may use our Refer-a-Friend Service to automatically send an e-mail notification to their friends. However, if the Member’s Refer-a-Friend e-mail results in a complaint, the Member’s Account may be terminated. You should use the Refer-a-Friend Service to notify only your close personal friends, where you know that the friend will be happy to receive the e-mail notification.

4. False Advertising and Testimonials

   Members may not make untrue or exaggerated statements when advertising InboxPounds® or engage in any unfair or deceptive trade practice as defined by law. For example, a Member may not put on their website: “Join InboxPounds® and get paid £1.00 for every Email you read!” If the Member provides information about InboxPounds® on their website, they must ensure the information is updated and accurate. A Member’s Account may be terminated for false advertising.

   You must be especially careful to obey applicable laws and regulations regarding testimonial or endorsement by you recommending InboxPounds®, an Advertiser or Offer, so that such testimonial or endorsement is not false or misleading. For example, if you made an online statement recommending InboxPounds®, then you should also disclose the material connection between yourself and InboxPounds®.

5. Referral Rewards

   Members will be instantly credited 10% of all Qualified Earnings generated by Members they refer to InboxPounds®. There is no limit to the amount of referrals you can have or the amount of cash you can earn from your referrals. Qualified Earnings are defined within the InboxPounds® Knowledge base

IV. INACTIVITY

V. PERMANENT REMOVAL

If you do not visit our Website while being logged in or confirm a PaidEmail^™ at least one time in a 6-month period, your Account will be permanently removed and all Cash or other items accrued will be forfeited. In the event of the death of any Member, such Member’s Account is automatically and immediately terminated, and all Cash or other items accrued in such Account are forfeited.

VI. CASH EARNING ACTIVITIES

VII. CASH AND PAYMENT

1. About Cash in Your Account

   You can earn Cash which is credited to your Account as described in the other sections of these Terms and Conditions, and which is subject to your compliance with all Terms and Conditions. Your Account, including any Cash or other credits in your Account, is non-transferable and non-assignable, and may not be pooled, lent, sold, or exchanged. We may change rules about requesting Cash payment or redeeming other credits in your Account at any time and such changed rules will apply to Cash already accrued as well as to Cash accrued in the future. You may request Cash payment out of your Account (also referred to as “redeeming” Cash) only as permitted by these Terms and Conditions. Redeeming Cash and receipt of any payment by you is contingent upon your: (1) full compliance with these Terms and Conditions; and (2) compliance with the specific rules or terms then in effect for the particular redemption offer.

2. You may not redeem Cash until you have accrued at least twenty pounds (£20.00) in your account (the “Minimum Payment Amount”) or such other amount as may be designated by us. The terms “Cash”, “Pounds” and similar terms are used interchangeably in this Website to mean any and all sums attributed to your Account. You have no right to redeem the Cash in your Account, and we have no liability or obligation to pay you whatsoever, unless and until you have accrued at least the Minimum Payment Amount in your Account. Unless and until you have accrued the Minimum Payment Amount, such Cash is deemed a contingent liability, which is entirely contingent upon: (1) your accrual of at least the Minimum Payment Amount in your Account, and (2) your full compliance with these Terms and Conditions. Unless and until your Account balance reaches the Minimum Payment Amount, the Cash in your Account has no cash value.

   For example, if you open an account with an initial balance of 1 pound (£1.00), and then accrue another fourteen pounds (£14.00) in cash in that account, giving a total of £15.00, you are not eligible to receive any payment, and we are not liable to you for any amount. In this example you would have to earn yet another five pounds (£5.00), giving a total of twenty pounds (£20.00) accrued balance, before you would be entitled to any payment.

   Currently, the Minimum Payment Amount required to request a cheque payment is £20.00; however, this amount may change from time to time.

3. Requesting Payment

   You can request payment of the Cash in your Account, subject to the remainder of these Terms and Conditions, by clicking the “Request Payment” link under the “My Account” tab. As noted above, you may not request payment and the Cash in your Account has no actual cash value until you have accrued at least the Minimum Payment Amount. A description of each payment request method will be displayed, and if the Member’s Account balance is large enough, a link to request that method of payment will also be displayed. Members may have only one pending payment request at a time.

4. Tax Matters

   You are responsible for any and all tax liability arising from or associated with your use of this Website, including liability arising from your accrual of Cash or your redemption of Cash for cash or other items.

5. Payment Schedule

   Requests to redeem Cash and send payments are processed on the first Wednesday that occurs at least 8 days after the payment was requested. This means payment requests will be processed between 10 and 16 days after request. After requesting payment, Members can view their scheduled payment processing date by clicking the “My Profile” link under the “My Account” tab.

   Payments are processed on Wednesday of every week and generally posted within 3 days, depending on holidays and how many payment requests there are for that week.

   All payments are inspected immediately prior to processing. Payment requests belonging to Members who have become inactive (as described above in Section IV) or who have duplicate Accounts will not be processed and will be removed.

6. Returns and Reversals

   Any time you return a purchased item for which you received Cash in your Account, and any time you void, cancel, rescind, or reverse any Cash shopping transaction for which you received Cash in your Account, InboxPounds® may subtract a corresponding amount of Cash from your Account. Similarly, if any Advertiser notifies us that it is reversing its transaction with you for any reason on any of our Cash Earning Activities, we will subtract a corresponding amount of Cash from your Account. A pattern of completing Offers followed by reversals is considered fraudulent activity, and may result in the termination of your Account and forfeiture of your Cash earnings and referrals.

7. Fraud Prevention

   InboxPounds® reserves the right to request further information from Members to ensure they have not fraudulently completed Offers. This information may include, but is not limited to, a copy of the credit card statement that was used to complete the Offers, in order to ensure a stolen credit card was not used.

   InboxPounds® reserves the right to place any payment request on hold, for any reason, until the requested information has been provided by the Member. Ample notice will be given to the Member to provide this information. If the Member does not provide this information before their payment is scheduled to be processed, their Account will be suspended until they do so. All decisions by InboxPounds® regarding fraud or suspected fraud are binding and final.

VIII. GENERAL TERMS

1. Copyrights and Trademarks

   All content, materials, images, and other items on or accessed directly through this Website (collectively, the “Content”) belong to InboxPounds®, its third party licensors, or third party Advertisers. There are some important rules about using and copying the Content. You may download or print one copy of the Content on this Website, but only for your personal, non-commercial use. When you download or print a copy of the Content, you must also include all copyright and other notices that are in the Content, including the copyright notice on the bottom of the page.

   The Content is protected by English as well as foreign copyright laws. If you use the Content in a way that is not clearly allowed by these Terms and Conditions, you are violating your agreement with us and may be violating copyright, trade mark, and other laws. In that case, we automatically revoke your license to use the Content and you must immediately destroy any copies you have made. All right, title, and interest in and to the Content remains with InboxPounds® or our third party licensors. All rights not expressly granted are reserved.

2. Notice of Infringing Images or Content: DMCA Notice

   If you believe in good faith that any photos, images, text, or other Content appearing on this Website infringes any copyright or other intellectual property right owned by you, please send a Notice to:

   copyright@cotterweb.net

   Or to:

   Copyright Agent
   CotterWeb Enterprises, Inc.
   1295 Northland Drive
   Suite 300
   Mendota Heights, MN 55120
   USA

   Notice. The notice must include the following information: (a) a physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed; (b) identification of the copyrighted work (or other intellectual property right) claimed to have been infringed; (c) identification of the material that is claimed to be infringing or the subject of infringing activity; (d) the name, address, telephone number, and email address of the complaining party; (e) a statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent or the law; and (f) a statement that the information in the notification is accurate and, under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed. If US law requires any additional or different procedure, then the terms of such law shall control.

3. Linking to the Website

   You may link to the home page of the Website, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

   You must not establish a link from any website that is not owned by you.

   Our Website must not be framed on any other site, nor may you create a link to any part of our Website other than the home page. We reserve the right to withdraw linking permission without notice, and may do so where the website from which you are linking fails, in our opinion, to comply with the content standards which we set for the Website.

   If you wish to make any use of material on our Website other than that set out above, please address your request to us at our Contact Us page.

4. Links from the Website

   Where the Website contains links to other sites and resources provided by third parties, these links are provided for your information and convenience only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. Your use of other websites is subject to the terms and conditions of those websites, including the privacy policies of those websites.

5. Limitation of Liability

   1. To the extent permitted by law, you agree that neither InboxPounds®, nor any person or company associated with InboxPounds®, including Advertisers or third party suppliers (collectively, the “Covered Entities”) shall be liable for any damage resulting from your use or inability to use this Website or the materials on this Website.
   2. To the extent permitted by law, the Covered Entities hereby expressly exclude:
      1. All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity,
      2. Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our Website or in connection with the use, inability to use, or results of the use of our Website, any websites linked to it and any materials posted on it, including:
         1. Loss of income or revenue;
         2. Loss of business;
         3. Loss of profits or contracts;
         4. Loss of anticipated savings;
         5. Loss of data;
         6. Loss of goodwill;
         7. Wasted management or office time; and

         whether caused by tort (including negligence), breach of contract (including fundamental breach) or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.

   3. The total liability of Covered Entities for losses, damages, or claims of any kind shall be limited to the amount of your actual damages, not to exceed the greater of £250 or the amount of Cash in your account at the time the claim arises. In no event shall the Covered Entities be liable to you for any losses or damages other than the amount described above.
   4. The limitation of liability in this clause does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

6. Exclusion of Warranty

   1. All content on this Website is provided to you on an “as is” “as available” basis without warranty of any kind either express or implied.
   2. InboxPounds® makes no warranty as to the accuracy, completeness, currency, or reliability of any content available through this Website, including but not limited to the offers provided by Advertisers. You are responsible for verifying any information before relying on it. Use of the Website and the content available on the Website or linked to by the Website is at your sole risk.
   3. InboxPounds® makes no representations or warranties that use of the Website will be secure, uninterrupted or error-free. You are responsible for taking all necessary precautions to ensure that any content you may obtain from the Website or from linked websites is free of viruses or similar destructive programs.
   4. To the extent permitted by law, you agree that InboxPounds® shall not be liable for any claim or damages related to any loss, destruction, or alteration of data related to your use of the Website. The foregoing disclaimer includes but is not limited to reliance by you or any third party on any content or information obtained through the use of the Website, or any damage or harm resulting from any mistakes or omissions in, or delays in transmission of, information to or from the Website, interruptions in telecommunications connections to the Website, or viruses, whether caused in whole or in part by negligence, acts of god, telecommunications failure, theft or destruction of, or unauthorised access to the Website, or related information or programs.

7. Indemnity

   You agree to indemnify, defend and hold the Covered Entities described above harmless from and against any and all costs, liabilities, losses, and expenses (including, but not limited to, reasonable legal fees) resulting from any claim, suit, action, or proceeding brought by any third party against any of the Covered Entities alleging or arising from or related to your use of the Website or any breach of these Terms and Conditions by you. This paragraph survives expiration or termination of your Account, your membership or these Terms and Conditions.

8. Independent Parties

   You and InboxPounds® are independent parties as to one another. You are not InboxPounds’ agent or employee for any purpose and shall not hold yourself out as InboxPounds’ agent or employee.

9. Contact Us

   Our contact information is available at the Contact Us page.

   Members seeking support for their Account should login to the Member’s Section and click the “Support Centre” link.

10. Governing Law and Jurisdiction

    The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to or use of our Website although we retain the right to bring proceedings against you for breach of these Terms and Conditions in your country of residence or any other relevant country.

    These Terms and Conditions and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.

11. Limitation on Claims

    You agree that in the event you have or may have any alleged claim against InboxPounds® or any of the Covered Entities, you shall pursue such claim only in your individual capacity, and you shall not agree to join or be a part of any class action, consolidated action, or similar action. You also agree that your damages are limited as set forth elsewhere in these Terms and Conditions and that you are not eligible to receive, and shall not seek, legal fees in relation to any claim you have or may have against InboxPounds® or any of the Covered Entities.

12. Third Party Rights

    1. To the extent that the provisions of clauses VIII.5, VIII.6, VIII.7 and VIII.11 provide rights for the benefit of persons that are not parties to these Terms and Conditions, the parties agree that these rights are enforceable third party rights, validly exercisable by any person identified by the description set out in Clause VIII.5 as the definition of Covered Entities.
    2. Except as expressly provided elsewhere in these Terms and Conditions, a person who is not a party to these Terms and Conditions shall not have any rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any of the terms of these Terms and Conditions. This does not affect any right or remedy of a third party which exists or is available apart from that Act.

13. Miscellaneous

    1. If any provision of these Terms and Conditions is held to be overbroad, invalid, or unenforceable, such provision shall be deemed amended to the minimum extent necessary to render such provision valid and enforceable. If any provision cannot reasonably be deemed amended, then such provision shall be struck and the remaining provisions shall be enforced.
    2. Headings are for reference purposes only and in no way define, limit, construe or describe the scope or extent of such section.
    3. Members may not sell, assign, or otherwise transfer any rights under these Terms and Conditions, including any membership, Cash, or other benefit. InboxPounds® may assign or transfer its rights and obligations under these Terms and Conditions.
    4. Our failure to act with respect to any failure by you or others to comply with these Terms and Conditions does not waive our right to act with respect to subsequent or similar failures.
    5. These Terms and Conditions, along with any changes or updates thereto by us as described above, set forth the entire understanding and agreement between us with respect to the subject matter hereof. All sections of these Terms of Use, other than those sections dealing with your future accrual of Cash, survive expiration or termination of your Account or your right to use or visit this Website for any reason.

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 April 31, 2019 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; and
      • use of the search engine facility on our website. By electing to proceed with a search and by clicking the “search” button, you give your express consent to the use of Technical Data and Usage Data in returning search results to match your search terms. 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.

   Purpose/Activity

   To deliver search results which match search terms you enter into the search engine facility on our website

   Type of data

   1. (a) Usage Data
   2. (b) Technical Data

   Lawful basis for processing including basis of legitimate interest

   Consent – your Usage Data and Technical 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. Your consent is provided when you click the “search” button on our website.

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.

4. Search Engine and Consent

   When you are using our website you may wish to use the search engine facility to find something in particular on the website. If you do decide to use this facility you should be aware that this part of our website is made available using one of our external third party providers called System1 LLC, who provide search engine facilities, and that when they undertake a search they will in turn transfer the data used to other third party providers such as Microsoft and Google.

   If you give your consent by clicking on the “search” button on our website then System1 LLC will have access to your Usage Data and Technical Data. They will only have access to the Usage Data and Technical Data which is necessary for the purpose of matching search results to the search terms that you’ve entered into the search facility. To carry out this service there is interaction by System1 LLC with Google and Microsoft functionality to allow matching search results to be returned to you.

   System1 LLC will only use your Usage Data and Technical Data in accordance with their own Privacy Policy and that Privacy Policy also gives you an explanation of how System1 LCC will use and transfer data to Microsoft and Google: http://system1.com/terms/privacy-policy

   You are always in control of the amount of personal information which you give to us when using our website and using the search engine facility is no different. By using the search engine you are giving us your consent only to the data transfers and use we’re describing in this section of the Privacy and Cookie Policy. You can withdraw your consent by stopping using the search engine at any time and System1 LLC or any of the third parties to which they transfer your Usage Data and Technical Data will no longer have access to it.

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. System1 LLC who provide search engine facilities on our website. As part of this service there is interaction with Google and Microsoft functionality to allow search results to be returned which match the search terms you enter on our website. An explanation of how System1 LCC will use and transfer data to Microsoft and Google is set out in System1 LLC’s privacy policy, a link to which is set out below. If you do not wish for your data to be used and transferred in this manner then please do not use the search engine.
         http://system1.com/terms/privacy-policy
      5. 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
      6. 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