Privacy Notice V7 14/6/2018

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V7, 14 June 2018

This Privacy Notice is important because it explains to You how we may use the personal Information We collect and hold about You. Should you have any questions about this Privacy Notice please see the contact details at the bottom of the Notice.

Throughout this Privacy Notice we will talk about UK Data Protection Law, this predominantly means the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 as well as the EU GDPR regulations which came into force on 25th May 2018.

The Original Data Company Ltd is a company registered in England & Wales under company number 09509986. Our registered office is: The Barn, Blue House Farm, Warren Street, Lenham, Kent, ME17 2ED. The Original Data Company Ltd are Data Controllers of the Personal Information held about You and accordingly are registered with the Office of the Information Commissioner (ICO) under the Data Protection Act 1998. Our registration number is ZA116547.

Our Data Protection Officer is Ian Foulsham. He can be contacted by Email: compliance@theoriginaldatacompany.com or Write to: The Data Protection Officer, The Original Data Company Ltd, The Barn, Blue House Farm, Warren Street, Lenham, Kent, ME17 2ED.

The Original Data Company Ltd owns and operates a number of websites which include, but are not limited to: www.surf4hub.com / www.surf4prizes.com / www.surf4cover.com / www.surf4surveys.com / www.fashionforensics.com for a full list please visit: www.surf4group.com

We want this Privacy Notice to be honest, open and transparent because We know that Your privacy, and the protection of Your Personal Information is important to You. We take every reasonable precaution to ensure compliance with UK Data Protection Law. Further information about Your rights under UK Data Protection Law is available from the Office of the Information Commissioners (ICO) Website. If You wish to find out more please visit: www.ico.org.uk We do not want to collect or hold any Personal Information about You that You do not wish or intend to give. That is why it is important that You read this Privacy Notice carefully.

We collect three categories of Personal Information about You; Identifiable Information, Anonymous Information and Lifestyle Information. 'Identifiable Information' means any information about You from which You can be personally identified, common examples include (but are not limited to); Your name, address, date of birth and email address. 'Anonymous Information' means information that does not identify You personally but categorises You into certain groups or categories. Commonly this is demographic information such as; age group, gender, marital status and income. Anonymous Information is useful because it allows Us to build statistical and analytical information about You which means We can better identify products and services that are relevant to You. 'Lifestyle Information' means information about Your way of life and interests. Like anonymous information it does not identify You personally but helps Us understand You better. Together We call this 'Personal Information'.

The Personal Information We collect will be held by Us on Our database which is hosted on secure servers based in the European Economic Area ("EEA"). We use a variety of physical and network security technologies and procedures to help protect Your information from unauthorised access, use, or disclosure. We also operate stringent people processes which means that only a limited number of people in our organisation have access to the information contained in the database. We have established procedures to cope with events that happen that are beyond Our control. We are also certified as meeting the requirements of ISO 27001:2013 in the provision of data cleansing and the management of consumer lists.

We collect Personal Information about You in several ways including the following:

• when You enter one of Our competitions or prize draws;
• when You complete one of Our lifestyle questionnaires or surveys;
• when You complete Our unsubscribe form;
• when You submit a Data Protection Enquiry or Subject Access Request (SAR);
• when We purchase or license Your information from other suppliers.

When You are entering Personal Information onto Our website it is not until You click the submit button that Your Personal Information is transferred to Us. Unfortunately, the internet is not a 100% secure medium and We cannot guarantee or accept any liability for any loss or damages in relation to information that You submit that is lost in transit. We also purchase &/or license Personal Information from other third parties. We call these third parties Data Contributors. Your Personal Information may be collected by Data Contributors if You have submitted information to a website, (for example when entering a prize draw), completed a telephone survey or lifestyle questionnaire or when buying goods and services from third parties. Regardless of the way Your Personal Information is collected Our Data Contributors warrant to Us that You have consented to Your Personal Information being passed to Us and that the consent is current. We call this permission Opt-In. We only ever work with Data Contributors that operate within UK Data Protection Law and are registered with the ICO at the time of purchase.

You have the right under UK Data Protection Law to Opt-Out of receiving marketing material at any time and more information is shown about this in section 11 and 12 below.

Data, like many other products and services can be sold or licensed. When We license data to third parties We call them Clients. We work hard to ensure that We only deal with reputable Clients who like Us operate in accordance with UK Data Protection Law. We enforce this through Our contractual relationships with Our Clients in which they undertake to operate in accordance with the UK Data Protection Law and continue to enforce the rights You have. More information about those rights is set out in this Privacy Notice. Sometimes Our Clients operate in countries outside of the European Economic Area (EEA) who operate under different data protection laws. Where this happens We enforce additional contractual provisions to ensure they provide an adequate level of protection as required by UK Data Protection Law.

Here is a list of business categories in which Our Clients operate. Depending on what personal information We hold about You Our Clients may contact You by post or email for direct marketing, debt collection and tracing.

For a more detailed list of the types of companies that fall into each business category please click on the category name.

We Use Your Personal Information to:

• Pass your details on to selected Clients who will contact You with offers and promotions;
• Help other companies to profile and extend their personal databases;
• Provide You with information about the products and services We offer;
• Conduct market research;
• To unsubscribe You from Our databases;
• To add You to Our suppression file/Do not contact file;
• Send You newsletters with news items and blogs from our websites including competitions and promotions;
• To communicate with You about an enquiry You have made;
• To make a profile of You. A profile can be created by combining third party list information with information collected by Us. This information helps us to target advertising and promotions to You;
• To wealth screen You to ascertain that You are likely to have sufficient financial capability to support specific fundraising or other activity;
• Help Clients who undertake online marketing to help provide online advertisements that are relevant to You. You may be contacted by post or email only.

We will share your data with the Marketing Services Providers listed here, who will use it to create products and services to help organisations better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels. This may mean that you receive advertising that is more relevant to you via direct mail or when you visit a website. To understand more please click through to the websites of the companies listed.

We process data under the following lawful basis’:

Consent: where we have Your consent to receive marketing communications for compatible products and services through specified channels.

Legitimate Interest: there is a legitimate interest for ourselves and our clients in processing data to provide products and services to consumers through marketing campaigns. On a case by case basis, a balancing test is performed to ensure that we balance the potential impact of the campaign on the consumer and their rights of processing data, with the interests of ourselves and our clients.

Legal Obligation: we may need to process data under this basis, for example where a Subject Access Request (SAR) is made to remove or amend details, this data will be processed under the lawful basis of Legal Obligation.

You can opt out anytime from Us holding Your Personal Information on Our database by unsubscribing here. We call this process suppression. This is standard marketing industry practice approved by the ICO and means that just enough information about You is retained to ensure that Your wishes are respected. Suppressing, rather than deleting, Your details has the objective of preventing Your records being reintroduced into Our database in the future. Following suppression of Your details, marketing communications should stop within a maximum period of twenty eight days for electronic communications and two months for postal communications.

You have the right to withdraw consent to the processing of Your information at any time. This includes the right to withdraw processing based on legitimate interests.

You have the right to be forgotten / total erasure. This gives You the right to request Your information be removed completely. We would not recommend this but would strongly suggest the action referred to above in point 10 as complete erasure of Your data could lead to Us loading Your information again.

You have the right to know what Personal Information We hold about You on Our database. If You would like to know more about this process and what We need from You to meet Your request please follow the link here.

You have the right to lodge a complaint with a supervisory authority, if You are not satisfied with the way we have dealt with your complaint: The Information Commissioners Office

1. We will hold information about You on Our database until such time as You ask Us to suppress Your information.
2. Once You have clicked 'submit ' on Our website You consent to The Original Data Company Ltd, being able to send You communications via post or email until such times as You exercise Your right to unsubscribe from receiving such communications.
3. We will share information about You with Clients and Sponsors. Information about You may be held and used by Clients and Sponsors on their websites and/or on databases owned and controlled by them.
4. You consent to Our Clients and Sponsors sending You communication via post or email until such times as You withdraw your consent for sending such communications.
5. Our Data Retention Policy:
   The Original Data Company Ltd will retain Your details for as long as they are valid, accurate and up to date or until such time that You choose to unsubscribe directly with Us or via one of our partners who are making use of Your details provided by Us. Where We hold an email address for You We will maintain regular contact and will ensure that You have the opportunity to opt out at least once every six months. Our backup policy is to backup data daily, overwriting the previous days back up to make sure that we only process up to date information.

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file. Cookies are small pieces of information stored by Your browser on Your computer's hard drive. We Use cookies to allow Us to understand who has seen which pages, to determine how frequently particular pages are visited and to determine the most popular areas of Our Websites.

Cookies may be used to enable embedded content from external sites, YouTube for example, and/or our advertisers, but we do not have access to them or control over them. The cookies are set by the relevant source website. For more information about these cookies, including how to set your preferences for these cookies, please refer to those websites for more information.

If You wish to disable cookies then You can do so by adjusting Your browser settings although please note that by disabling cookies You may not be able to register with or use all features of Our website.

We may collect IP addresses from Form submissions (registration or contact forms for example) and in this case we will only use this data for identifying and restricting spam or robot submissions to our website.

We may use web beacon technology, as well as other new and evolving technology. A web beacon is an object that is embedded in a web page or an email and is usually invisible to the user but allows checking that a user has viewed the email or page. This can also be used to transfer an individual’s unique user identification to a database and associate the individual with previously acquired information about an individual in a database. We track information related to email and web pages viewed by an individual, such as the hyperlinks clicked on by an individual, whilst viewing a webpage or an email. This usage information will allow us to track and monitor an individuals usage. We use these technologies to determine products or services an individual may be interested in, in order to provide a more relevant and targeted service.

If The Original Data Company Ltd or any of its assets are acquired by or merged with another entity, your Personal Information may be one of the transferred assets. If We choose to sell or transfer Our assets, We may choose to retain a copy of Your information post sale or merger.

We will occasionally update this Privacy Notice. We will tell You about these changes by posting a notification at the foot of Our websites. If the changes We make to the Privacy Notice in any way affect Your rights under UK Data Protection Law, especially in relation to how We collect and hold information about You We will contact You to explain the changes and obtain Your permission to do so.

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If You have any comments or queries in connection with this Privacy Notice, please contact The Original Data Company Ltd by: Email at ian@theoriginaldatacompany.com; or Write to: The Data Protection Officer, The Original Data Company Ltd, The Barn, Blue House Farm, Warren Street, Lenham, Kent, ME17 2ED.

If you have any queries about data usage please email us at info@theoriginaldatacompany.com.

Privacy Notice – Version 7 – Updated 14th June 2018 – Update to section 9 – clarification of lawful basis.

Privacy Notice – Version 6 – Updated 11th June 2018 – Data Protection Act 2018 replaces Data Protection Act 1998 (section 2).

Privacy Notice – Version 5 – Updated 10th May 2018 – List of companies which we may share your personal information with updated (section 8).

Privacy Notice – Version 4 – Updated 30th April 2018 – Additional rights added to Section 11.

Privacy Notice – Version 3 – Updated 5th February 2018 – Marketing category separated from General & lifestyle category for increased clarity; new companies added to the list of companies which we may share your personal information with.

Privacy Notice – Version 2 – Updated 11th October 2017 – We now fully list all companies which we may share your personal information with.