We are a direct marketing organisation called Submission Technology Ltd registered in England and Wales under company registration number 04456811, whose registered office is at The Beater House, Turkey Mill, Ashford Road, Maidstone, ME14 5PP.
We are registered with the Information Commissioners Office under registration number Z7981900.
We operate under the brand name Freeclub UK. We run a freebies and prize draw website where we promote and run marketing questionnaires on behalf of some of the leading UK brands to help them target their products and services better.
Our offices are at James Whatman Court, Turkey Mill, Ashford Road, Maidstone, Kent, ME14 5PP and you can speak to the Compliance Department by phone: 020 7183 1653 or by email: dpo@submissiontechnology.co.uk
Personal data means any information that can be used to identify directly or indirectly a specific individual. As you enter prize draws and complete surveys, we collect different types of personal data from you. These can be summarised into the following categories:
| Category | Description |
|---|---|
| Identity | This relates to basic information such as your gender, name, and date of birth. |
| Contact | This relates to information such as your postal address, email address and telephone number. |
| Transaction | This relates to information such as the offers or prize draws you have signed up for or services that you have subscribed to on Freeclub UK. |
| Technical | This relates to information such as your access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, and other technology on the devices you use to access this website. |
| Lifestyle | This relates to your likes and dislikes or your hobbies and interests, e.g. whether you like to travel. |
| Preferences | This relates to your preferences around marketing and the type and frequency you wish to receive marketing. |
We will never collect special category data including medical history, religious or political beliefs and nor will we collect information such as your bank account or credit card details.
The data you provide us is used for the following purposes:
You can ask us to stop processing or sharing your details at any time now or in the future.
In writing to: The Data Protection Officer, Submission Technology, James Whatman Court, Turkey Mill, Ashford Road, Maidstone, Kent, ME14 5PP;
By email to: dpo@submissiontechnology.co.uk.
By using our privacy form: https://privacy.submissiontechnology.co.uk/form/
Your data must be processed by us using one of the valid legal bases defined by the Regulations. We will never switch from one legal basis to another without your permission. The different purposes are summarised in the table below:
| Purpose | For use by Freeclub UK | For use by Third Parties |
|---|---|---|
| Promotion publication of winners on Freeclub UK | Legitimate Interest (we will only publish your first name) | Not applicable |
| Promotion of product reviews on Freeclub UK | Consent | Not applicable |
| Transactional emails about your account | Legitimate Interest | Not applicable |
| Marketing by Email | Consent | Consent |
| Marketing by SMS | Consent | Consent |
| Marketing - telephone |
Consent - where your number is
registered on the Telephone
Preference Service.
Legitimate Interest — where your number is not registered on the Telephone Preference Service. |
Consent — but only when you
provide specific consent for a
named organisation.
Legitimate Interest - where your number is not registered on the Telephone Preference Service. |
| Marketing by post | Legitimate Interest (where you are registered on the Mailing Preference Service we will ask for your specific consent). | Legitimate Interest (where you are registered on the Mailing Preference Service we will ask for your specific consent). |
| To operate Freeclub UK (e.g. create an account for you) | Legitimate Interest | Not applicable |
| Profiling and Analytics | Legitimate Interest | Legitimate Interest |
| Fraud prevention or investigation by a regulatory body | Compliance with a legal obligation | Compliance with a legal obligation |
In short this is where you consent to a specific organisation, to contact you by a communication channel or channels which you have agreed to, for specific reasons, which in the context of our processing will be for marketing purposes. When we ask for your consent for a specific organisation, we will do so by giving you the opportunity to tick a box online or answer a question on the phone.
You can of course withdraw your consent at any time and we will describe how later on in this notice.
As a direct marketing business we process personal information for various legitimate business purposes which include some or all of the following:
These legitimate business purposes relate to the following activities:
Direct Marketing - Postal and telephone marketing by both Freeclub UK and other third parties, but in either case communications will be in relation to products or services which we believe are of interest to you based upon information which you have provided us.
Social Media Advertising - Using data provided by you to serve advertising to you on social media platforms such as Facebook.
Profiling - We will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you (for more information, please refer to the profiling section)
ID Protection, Verification & Validation - This is in relation to appropriate agencies which we have listed below which could help protect your identity and prevent fraud.
We process your data in the following ways:
For all types of processing, we apply various measures to carefully protect your privacy rights. In considering the most appropriate legal basis, Freeclub UK conducted Legitimate Interest Assessments. These are detailed evaluations of each type of data processing activity to ensure that we have balanced the need of the processing against the rights of the individual to ensure minimal privacy impact.
On rare occasions we will be asked to share your information for the prevention of fraud or with regulatory bodies who are investigating complaint made by a consumer.
Service Providers process your Personal Data on our behalf to support our business and help provide our services to you. These service providers are our Data Processors and are contractually required to protect your data in the same way we do. Service Providers include:
Professional advisers such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, financial, auditing, and accounting services to us so we can operate our business.
Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of Submission Technology, our customers or others.
We use email and push notification service providers in order to communicate to you about Freeclub UK.
| Industry Sector | Examples include, but not limited to: |
|---|---|
| Automotive | e.g. car manufacturers, test drives, servicing, breakdown cover |
| Charity | e.g. animal welfare, disaster relief, children’s medical, elderly, environmental, health |
| Gaming | e.g. bingo, betting, competitions, lottery |
| Leisure | e.g. food & drink, events, museums, cinema |
| Financial Products | e.g. banking, credit cards, investments, loans, mortgages, debt management, tax/accountancy services |
| Insurance | e.g. car, home, life, medical, pet, income protection, travel, warranty products. |
| Health / Mobility | e.g. fitness, beauty, opticians, hearing, care homes, mobility |
| Home Improvements | e.g. house moving, blinds & curtains, insulation, boilers, conservatories, doors & windows, extensions, gardens, solar panels, home security systems, home appliances and the repair thereof. |
| Wills | e.g. writing new Wills or reviewing existing Wills |
| Funeral Plans | e.g. to arrange and pay for a funeral in advance |
| Mail Order | e.g. catalogues, online retailers |
| Market Research | e.g. to gather information about consumers' opinions and preferences |
| Media | e.g. online, television, radio, newspapers, magazines |
| Retail | e.g. fashion, groceries, electrical goods, comparison sites, discounts, FMCG, nicotine and smoking alternatives |
| Telecoms | e.g. landline, mobile phones, broadband, digital TV |
| Travel | e.g. long haul holidays, city breaks, flights, UK breaks, accommodation |
| Education | e.g. online tutoring, personal development, academic camps. |
| Utilities | e.g. gas & electricity switching, other household utilities such as water |
We will share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing, testing, research & product development purposes. Marketing Services Providers carry out data profiling. They will combine your data with data they get from other sources (including public sources) and use it to create “predictive models”. Marketing Services Providers use these models to try to predict behaviour and preferences (e.g. how likely you are to buy a holiday online or take a particular type of holiday) or likely circumstances (e.g. whether you are eligible for a particular credit card).
Marketing Services Providers will also try to match and then link your data with data that they receive about you from other sources, to make sure that the data they hold about you is correct (e.g. to check whether you have recently moved address).
They share your data, including the profiled data they have created about you, primarily to:
To understand more about the use of your data by Marketing Services Providers, and to find out how to exercise your data protection rights in relation to their use of your data (including how to opt-out), please click through to the websites of the companies below:
We may share your contact information with our partner WINR Data Pty Ltd. (WINR) and their global partners for the purpose of:
ID Protection - preventing others from misusing your details. This may include ID validation for anti-money laundering, anti-fraud, preventing crime, asset recovery, debt collection and reuniting people with unclaimed assets.
Advertising - providing offers that are relevant to you. This may involve data analysis, matching, profiling and predicting behaviours so you may receive advertising that is more relevant to you.
WINR and their partners will retain your information for as long as necessary to perform these functions. You can opt-out of all WINR activity by contacting their Privacy Officer https://www.winrdata.com/privacy-policy
In sharing your data with Marketing Services Providers, we rely on a lawful ground called ‘legitimate interest’, as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons.
Our trusted Partners, both sponsors of the site and particular surveys may wish to contact you based on your profile, but will only do so subject to your consent and preferences. These are listed below:
Amalfi Outsourcing (Pty) Ltd
507 and 508 3rd Floor Park Square, 5 and 9 Park Avenue, Umhlanga Ridg, Kwa-Zulu Natal, 4320
Amalfi Outsourcing (Pty) Ltd T/A 777 Lottos
71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ
Amalfi Outsourcing (Pty) Ltd T/A First Prize Lottos
Irodotou 16, 3095, Limassol, Cyprus
Aura Media Group Limited
Ground Floor, Suite F, Breakspear Park, Breakspear Way, Hemel Hempstead, HP2 4TZ
Austinshire Partners LLC (Results Generation Group)
8760-A Research Boulevard Suite 133 Austin TX 78753
British Gas
Millstream, Maidenhead Road. Windsor, Berkshire, SL4 5GD
Concentrix CVG Intelligent Contact Ltd
Bredbury 2 Horsfield Way Bredbury Park Industrial Estate Bredbury SK6 2SU Stockport Greater Manchester
Daily Privilege (a data base of Kontik Media LTD)
71-75 Shelton Street, London, WC2H 9JQ
Data Locator Group Ltd “DLG”
Green Heys, Walford Road, Ross-On-Wye, Herefordshire, HR9 5DB
Eazy Solutions (Lotto)
Victory House, Archbishop Makarios Avenue 205, Limassol 3030, Cyprus
Gener8 Now Ltd t/a Roccabox
2 Ambleside Drive, Walton, WF26TJ
GL Membership LTD (Good Life)
4 Wimpole Street, London, W1G 9SH
Go Groopie Ltd
Alpha House, 100 Borough High Street, London SE1 1LB
Homeshield Direct Ltd
168 Church Road, Hove, BN3 2DL
Lead 365 Ltd
Suite 3, Sanctus House, Olympus Park, Quedgeley, Gloucester GL2 4DH
Noticed LTD
71-75 Shelton Street, London, WC2H 9JQ
Offermail.co.uk (Owned by Noticed LTD)
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
OneFamily (Family Assurance Friendly Society Limited)
16-17 West Street, Brighton, East Sussex, BN1 2RL
Outspot
Dorp 16, 9830 Sint-Martens-Latem, The Netherlands
PDV Ltd
Green Heys, Walford Road, Ross-On-Wye, Herefordshire, HR9 5DB
PMDSC Ltd
30 Station Lane, Hornchurch, Essex, RM12 6NJ
Pure Cremation Funeral Planning Limited
Charlton Park Crematorium, Charlton Down, Andover, SP11 0TA
ScottishPower Energy Retail Ltd
320 St Vincent Street, Glasgow, G2 5AD
Shavekit Ltd
PO Box 375, WALLINGTON, SM6 6DN
Sky UK Limited
Grant way , Isleworth, Middlesex, TW7 5QD
The Football Pools
Walton House, 55 Charnock Road, Liverpool L67 1AA
Three (Hutchison 3G UK Ltd)
450 Longwater Avenue, Green Park, Reading, Berkshire, RG2 6GF
Veriform Limited t/a Stay Covered
145/147 Hatfield Road, St. Albans, Hertfordshire, AL1 4JY
Wowcher Limited
Dalston Works, 69 Dalston Lane, London, E8 2NG.
Wowcher Limited t/a LivingSocial
Dalston Works, 69 Dalston Lane, London, E8 2NG.
Yourlottoservice UK Ltd.
Long Acre Barn, Pury Hill Business Park, Near Alderton, Towcester, England, NN12 7LS
Freeclub UK contains affiliate links to third-party websites. You may click on these to complete offers provided by third parties. Please note, if you follow a link to any such website, we do not accept any liability or responsibility, because these websites have their own Terms & Conditions and Privacy Policies.
We do not transfer your data to these third-parties but to improve your user experience when you click on a third-party offer and are transferred to the third-party website, we may pre-populate the third-party form with your Personal Data. It is your choice to submit this data to the third-party, we will never do this for you.
Submission Technology is headquartered in the UK, any data we collect from you is held on secure servers here in the UK. Whilst the majority of our business is with clients resident in the UK we do have some clients based outside of the UK and EEA. Where their local privacy laws have not been approved by the UK and EEA, transfers are made subject to contracts which include Standard Contractual Clauses also known as Model Clauses, approved by the UK and EEA, designed to protect your rights and freedoms under the Applicable Laws here in the United Kingdom.
For more information, please contact dpo@submissiontechnology.co.uk
We only hold your data for as long as it is required for the purposes for which it was collected; for as long as it remains accurate and up-to-date; and most importantly, for as long as you are happy for us to do so. The length of time we keep your data will also depend on any legal obligations we may have.
Typically, we store Identity, Contact, Lifestyle, Transaction and Preference Data for a period of 12 months since your most recent activity in your account to answer customer queries, maintain an account in case you wish to come back to our website and monitor the site for fraudulent activity. If you ask us not to contact you again, we will keep your Identity and Contact Data permanently on a suppression list to ensure we don’t contact you.
Once we no longer have a purpose to retain your personal data, we will securely destroy your personal data in accordance with applicable laws and regulations.
You have a number of rights under the law which include;
A. Right to be informed - When we collect your data we have to tell you what we are going to do with it primarily through this Privacy Notice and consent statement.
B. Right of access - You have the right to contact us verbally or in writing to request details of the information we hold about you.
C. Right of rectification - You have the right to ask us to rectify information that we hold about you if it is inaccurate or incomplete.
D. Right to erasure - This is also known as the right to be forgotten and gives you the right to request your information be removed if there is no compelling reason for its continued processing. A word of warning though we keep a list of people who have asked not to be contacted which we use to ensure that you receive no further marketing from our group or clients as a result of our activity. Without this list your data could enter our system again from another source and we would have no record of the fact that you asked us not to contact you.
E. Right to restrict processing - this is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are respected in the future.
F. Right to data portability - this gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly used if you were switching banks, insurance companies, utilities companies and mobile phone providers.
G. Right to object - you have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. You also have the right to ask us to cease processing based on our legitimate interests, where there is no overriding justification for the processing of your data. Your rights and freedoms override our interests.
H. Rights related to automated decision making including profiling - we do not use automated decision making processes which would have a potentially damaging effect on you. But if we did you have the right to obtain human intervention, express your point of view, obtain an explanation of the decision and challenge it.
I. Right to withdraw consent at any time where relevant - you have the right to withdraw your consent to the processing of your information at any time and we must provide you with the information to need to do so, at the time we collect your data and each time we contact you.
J. Right to lodge a complaint with a supervisory authority - If we cannot deal with your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which include; The Information Commissioners Office; Wycliffe House, Water Lane, Wilmslow, SK9 5AF, or call: 0303 123 1113 or online at https://ico.org.uk/concerns/ and The Advertising Standards Authority - https://www.asa.org.uk/make-a-complaint.html
How to exercise your rightsYou can access the data we hold on you by visiting our data portal: https://mydata.submissiontechnology.co.uk. For all other requests, you can fill in our privacy form: https://privacy.submissiontechnology.co.uk/form/uk.
We will respond to your request without undue delay and no later than one month. You will not usually be required to pay a fee to exercise your rights unless your request is manifestly unfounded or excessive.
We may need to confirm your identity before fulfilling your request and ensure your right to access your Personal Data (or exercise 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.
For any questions, please contact our Data Protection Officer by email at dpo@submissiontechnology.co.uk
We are committed to protecting the security of your personal data. We protect your data with security measures under the laws that apply, and we meet international standards. We use a variety of technologies to help protect your personal data from unauthorised access, use, or disclosure.
Unfortunately, the Internet is not a 100% secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us via the Internet. In the event of a data breach that affects your data, we will notify you when legally required to do so.
We are not responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of your data.
The safety and security of your Personal Data also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your login or account credentials with anyone and keep your account information secure. We urge you to be careful about giving out information in public areas of the website like message boards, where information will be available to other users of the website. If you believe that your access credentials or Personal Data have been compromised, please contact us immediately.
For more information, please contact dpo@submissiontechnology.co.uk
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A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Other storage technologies you may come across include web beacons and pixels. A web beacon is an often-transparent graphic image that is placed on our website or in an email that is used to monitor the behaviour of users visiting our sites or receiving our emails. Web beacons are usually used in conjunction with cookies to check that you can see our content. A pixel refers to the code that is placed on our website that triggers a cookie. A pixel is essentially an image but instead of calling an image to be displayed, it calls an application on a media buying platform that will cause a cookie to be downloaded to your browser if your browser settings allow.
To find out how to opt-out of the collection and use of your information via storage technologies, see our section below on Blocking or Declining Cookies.
For further information about behavioural advertising, cookies and other storage technologies, and the steps you can take to protect your privacy online visit http://optout.aboutads.info/?c=2#!/ or http://www.youronlinechoices.eu/
We use the following cookies:
These Cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. Functional Cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. You can set your browser to block these Cookies, but some parts of the site will not then work.
These Cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store direct personal information but are based on uniquely identifying your browser and internet device. If you do not allow these Cookies, you will experience less targeted advertising.
We do not respond to do not track requests (DNT) on our website as there is no recognised international standard.
If more than one person uses your device, the choices set up by other people will apply to you as well unless you change them. For example, if you share a computer with your family, you may see adverts based on sites they have visited as well as sites you have visited.
In the event of updates to our service that materially expand the sharing or use of your personal information in ways not already disclosed to you, we will notify you by email and update this privacy notice accordingly. We will gain your consent for processing activities where necessary.
Last Updated: 12/02/2024