Privacy Policy – OnlineDeals-Club.com

Last Update: 01/07/2024 

Introduction

At OnlineDealsClub (hereinafter: we or us) we strive to be open and transparent towards participants, so we have written our privacy policy in the most clearly legible manner possible. In the privacy policy we explain what your rights are, what data we keep about you, with whom we share your data and how we protect your data.

1.     ABOUT THIS PRIVACY POLICY

This Privacy Policy provides you with information about the processing of your personal data and applies to all our services and related services.

We promise to tell you in the clearest way possible how we use your data. We will use your data to keep you fully informed, keep your data secure and accessible and to allow you to maintain control over your own data.

We collect your personal data to help us understand your needs and guides the way in which we interact and communicate with you about ours, and our trusted third parties (subject to your consent) products and services. 

We ensure policies and procedures are in place to protect the data you provide when registering to our sites, and we process it in order to provide you with the services you have requested or, where you have given us your permission to do so, to send you information that we think you'll find interesting, and thereafter when we store your data on our secure servers.

We seek to fully comply with the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Electronic EU Regulations 2011 and the UK General Data Protection Regulations (UK GDPR). For further information, please visit https://ico.org.uk/.

OnlineDeals-Club.com is owned and operated by CRS Advertising B.V. (hereinafter CRS Advertising) and is the registered owner of these websites and owns all rights, including the sites' respective IP, copyrights and trademarks. We are registered with the ICO office (The Information Commissioner's Office in the United Kingdom) as a Data Controller and Data Processor under the business name CRS Advertising B.V., with Registration Number ZB690188.

If you would like to share with us your questions or comments, please read section 19 on how to contact us. If you do not agree with the contents of this Privacy Policy, we remind you that you can always choose not to use our services.

2.     INFORMATION

When you are registering on OnlineDealsClub websites, it is not until you click the submit button that your information is transferred to the CRS database. Once you have completed and submitted all your details, you have then completed the registration confirming you are a valued member of our website. The information collected at registration can include name, address, telephone number, email address, date of birth. We may use other reputable partners to provide its services in connection with your registration.
Once you are registered with the our website, you consent to CRS Advertising, its sponsored question clients and website sponsors, being able to send you communications via the channel(s) you consented to as part of the sign up process until such time as you exercise your right to opt-out of receiving such communications. Also you are giving your permission for us to share your information with third parties such as, but not limited to the commercial use of the database through the sending of commercial communications of third parties, be it Direct Advertisers or Advertising Networks.

3.     BUSINESS PURPOSES

Our main Business Purposes for processing your personal data are :

o    To manage the participation of the registered individual in draws and/or promotions organised by us

o    To meet the purposes of funding our free websites. Our commercial aims are mainly funded by advertising, the sending of commercial communications containing named third party offers, the carrying out of branded surveys, market/product/item reviews, provision of 3rd party gaming opportunities etc. All third party Companies and Partners are listed on the site.

o    To share your data with the marketing services providers, who will use it as an input to products and services to help organisations better understand the likely characteristics of their customers. The legal basis for this sharing is 'legitimate interest', as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons.

o    We may also share your details with identity verification organisations which help other organisations verify your identity and prevent others from misusing your details.

o    We will only minimize the data and process only where it is adequate relevant and limited to what is necessary in relation to the purposes stated above, in accordance with Art. 5 (1), (c) of the UK GDPR;

4.     LEGITIMIZATION

Our legitimate interest basis for obtaining and processing of your data is to:

o    Manage your participation (as the registered individual) in our prize draws, promotions and/or device testing campaigns on our owned sites such as maintaining your registration to our site;

o    Improving and personalising our site to you, and this could be where we may market directly to you, about other relevant offers that may be of interest to you;

o    Determine whether any of our trusted Partners we work with may have services, products and offers that may be of interest to you based on your preferences;

o    Assess (on a case by case basis, via a balancing test) to determine products and services via marketing campaigns to ensure that we balance the potential impact of your interests of ourselves and our clients;

o    Where appropriate, relevant (and with consent) communicate your data to our trusted Partners. You may object to this processing at any time by contacting us through our UK GDPR representative in the United Kingdom as listed in the next article.

5.     UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, Company’s Name has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

o    by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/

o    by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

6.     MARKETING SERVICE PROVIDERS

We may share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing, targeted advertising, measurement & identity resolution purposes. Marketing Services Providers carry out data profiling. They can combine your data with data they obtain from other sources (including public sources) and use it to create predictive models or to make sure that the data they hold about you is correct. 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).

For example, they might do this to:

o    Check whether you have recently moved address; or

o    Keep the IP address they hold about you up to date. Marketing Services Provider might find it helpful for the IP address to be updated from time to time to ensure marketing messages are being delivered to the correct consumers, on the correct device(s).

They share your data, including the profiled data they have created about you, primarily to:

o    Help organisations better understand the likely characteristics of their customers (and find others like them)

o    Improve the relevancy and appropriateness of an organisation's marketing to its customers (e.g. offers, its products and services); and

o    Help them communicate with their customers more effectively offline and online. This may mean that you receive tailored advertising via direct mail or when you visit a website.

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. 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:

WINR Data Pty Ltd. - https://www.winrdata.com/privacy-policy/

Lead 365 Limited - https://lead365.co.uk/privacy-policy

7.     CATEGORIES OF DATA

We collect your details when you register or visit on one of our websites; subscribe to our service; correspond with us by phone, e-mail or otherwise. 'personal data' or 'personal data' means the information you provide during the registration process and any information you provide when entering prize draws, quizzes, surveys or competitions. Registration is required to participate in any of the branded surveys on the site, however merely browsing does not require registration.

Personal information falls into three categories:

o    Identifiable information which is any information about you from which you can be personally identified. Common examples include your name, postal address, date of birth, telephone numbers, IP addresses or email addresses

o    Anonymous information which is information that does not identify you personally but categorises you into groups or sectors, common example include demographic information such as age group, gender, marital status, income or the number of people in your household; and

o    Lifestyle information which is information about your way of life and interests and similar anonymous information, it does not identify you personally.

Our legal basis for processing your data is as follows:

o    Your name and postal address: there is a legitimate interest for ourselves, our website sponsors, partners and selected third parties in processing data to provide products and services to consumers through direct marketing campaigns.

o    Your email and telephone number is processed under Consent as your registration to this website provides us with a clear and unambiguous Opt-In.

o    On a case by case basis, a balancing test is performed to ensure that we balance the potential impact of a campaign on the consumer and the processed data, with the business interests of CRS Advertising and our clients

8.     USE OF YOUR PERSONAL DATA

We use your personal data, as registered by you and collected via our sites, to:

o    Run prize draws and promotions

o    To automatically fill in data on third-party pages

o    Pre-fill your details on a third party page. Unless you decide to send this data to the third party, this party will not receive your data.

o    Provide you with information about the products and services we offer

o    Provide you with a personalised service

o    Conduct market research

o    Share on your details with selected Companies and Trusted Partners which provide you with other offers and promotions of interest to you

o    Run data analysis or to build data products. In these instances, the information is aggregated and wherever possible anonymised in line with the ICO's code of practice. 

o    To comply with legal obligations and requests from investigative authorities

In addition CRS Advertising may:

1.     Process your personal data ourselves or through data processors that will process data on our behalf (we retain full responsibility) for ensuring the data processor complies with this policy and all current data protection regulations).

2.     Collect your data and will share it for commercial gain with third parties. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation's own legitimate interest. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification. When supplying your information to third parties for purposes including but not limited to online linkage, fraud prevention and tracing, we will rely upon legitimate interests as our legal basis for processing your data

3.     Depending on the consents that you set up at the time of registration and what personal data we hold about you, we may pass your personal data to Site Sponsors, Brand Partners or Data Partners and Marketing Service Providers (collectively 'third parties') who may contact you by post, email and telephone for direct marketing purposes. We will also share your data with the Marketing Services Providers who will process your data to 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/telemarketing/email or when you visit a website.

4.     Depending on what personal information we and our website sponsors, partners and selected third parties hold about you, we and they may contact you by post email, social media, online advertising, telephone and/or mobile in line with the permissions you provided to us at registration.

5.     Share your details with identity verification and/or identity resolution organisations which help other organisations verify your identity and prevent others from misusing your details.

In addition:

o    Email and Telephone data will only be released to third parties where you have given your positive consent (e.g. at the time of registration) allowing you to fully understand your registration preferences.

o    Telephone data will only be released to carefully selected partners that subscribe to using the TPS registry (see 'Opting Out' below). Note: if you explicitly request to be called by one of our sponsors or advertising partners this will supersede the TPS.

o    We will only store your data in accordance with our Data Retention Policy as listed in article 15. 

o    We may share your personal information with our partner WINR Data Pty Ltd (WINR) and their global partners for the purposes of:
Fraud Prevention - preventing others from misusing your personal information. This may involve identity verification for anti-fraud, anti-money laundering, anti-crime, asset recovery, debt collection and reuniting individuals with unclaimed assets; and
Digital Advertising - providing personalised advertising and content that is relevant to you. This may involve identity resolution for data analysis, matching and linkage.
 WINR and their global partners will process and retain your personal information for as long as necessary for these specific purposes and on the lawful basis of consent and/or legitimate interests.
You can submit a request to exercise any of your privacy rights to the Data Protection Officer at WINR https://www.winrdata.com/privacy-policy/

Our website sponsors, partners and selected third parties include:

o    CRS Advertising - https://crsadvertising.com/privacy/

o    Wowcher Limited - https://www.wowcher.co.uk/page/privacypolicy

o    GoGroopie - https://www.gogroopie.com/privacy

o    DiscountExperts - https://www.discountexperts.com/privacy

o    Outspot - https://www.outspot.co.uk/en/help/privacy

o    Utilita Energy Limited - https://utilita.co.uk/terms#privacy

o    Hutchison 3G UK Ltd - https://www.three.co.uk/privacy-safety

o    British Gas - https://www.britishgas.co.uk/privacy-policy.html

o    Scottish Power - https://www.scottishpower.co.uk/legal/privacy-policy

o    Sky UK - https://www.sky.com/help/articles/privacy-hub-home

o    Your Lotto Service - https://yourlottoservice.co.uk/privacy/

o    One Family - https://www.onefamily.com/privacy-notice/

o    Aura Media Group - https://www.auramediagroup.co.uk/privacy-policy

o    WRM Media - https://wrm-media.com/privacy_policy.php

o    Advice Global - https://adviceglobal.com.mt/privacy-policy/

From time to time we may add or remove businesses from this list and we will update this web page accordingly. We recommend that you always read their terms and conditions and/or disclosure statement.

9.     VERTICALS

LIFESTYLE

-       Astrology

-       Automotive

-       Competition Sites

-       Education, Research & Self Improvement

-       Gambling

-       Health & Welfare

-       Lotteries

-       Parenting

-       Subscription Services

-       Travel and Leisure Pursuits

-       Tracing, ID and Fraud

-       Jobs & Employment

HOUSEHOLD & TECHNOLOGY

-       Electric, Gas, Water & Multi-Utilities

-       Home Improvement and Construction

-       Household Goods & Services

-       Air Source Heat Pumps

-       IT Services & Software

-       Media, TV, Radio, Film, Online & Print

-       Real Estate

-       Solar

-       Telecommunications

LEGAL SERVICES

-       Personal Injury Claims

-       PPI Claims

-       Mortgages Claims

-       Investments Claims

-       SERPS/Pensions Claims

FINANCIAL SERVICES

-       Comparison Websites

-       Loan Providers

-       Mortgage Providers

-       Debt Collection

-       Financial Providers/Services

-       Insurance Providers

-       Shares

-       Investment Management

PUBLIC SECTOR

-       Government

-       Political

-       Legal Services

-       Not for Profit

-       Tracing Activities

-       Personal Injury

TRAVEL

-       Holiday vendors

-       Hotel Operators

-       Airlines

-       Cruise Operators

-       Car Rental Agencies

-       Holiday homes

-       General Tourism Operators

RETAIL

-       Repair of household appliances

-       Fashion and Leisure Goods

-       FMCG Producers & Retailers

-       General Marketing & Advertising

-       Online and Offline Retailers

10.  GENERAL DISCLOSURE OF PERSONAL INFORMATION

o    Service providers - We rely on service providers who work on our behalf and who may need access to certain personal data. This includes companies that we use to manage the technical infrastructure that we need to provide the services, to help us protect and secure our systems and services.

o    Investigative authorities and privacy supervisors - We share your personal information when we believe in good faith that it is necessary to comply with a legal obligation under applicable law, or to comply with a valid, valid and authorized request or order, such as a search warrant, a court order or a subpoena. We also share your personal data if we believe in good faith that this is necessary in view of our own legitimate interests or those of a third party for national security, investigative purposes, litigation, criminal investigation, the security of persons, or to prevent imminent physical harm. or prevent death, as we determine these interests outweigh your interests or your fundamental rights and freedoms which require the protection of your personal data.

o    Buyers for our company - We share your personal information with buyers or potential buyers with whom we may negotiate or proceed with the sale of our business. In such case, we will continue to ensure that your personal data remains confidential and will notify you before your personal data is transferred to the buyer or before a different Privacy Policy applies to your personal data.

o    Scientific researchers - We forward your personal data in the context of activities such as statistical analyzes and scientific studies, but only after we have pseudonymised them.

o    Sponsors (advertising partners) - If you have given permission for parties to contact you by telephone, email, SMS or postmail for marketing and advertising purposes, these parties become a data processor with regard to the data you choose to provide to them. You are then subject to the Privacy Policy of these parties. We recommend that you read this Privacy Policy. If you have given permission for these parties to contact you, we will share your data with these parties. When you give your consent, you decide with which parties your data can be shared, and you can see for what purpose and at what frequency they will contact you.

11.  AUTOMATED DECISION MAKING

Automated decision making occurs when an electronic system uses personal data to make decisions without human intervention. An example of this is where a customer record is selected by an algorithm for a direct marketing or customer communication campaign based on a set of parameters. The GDPR allows organisations to make automated decisions in the following circumstances:

o    Where it is necessary to perform a contract with the customer, and their rights have been safeguarded;

o    Where it is authorised by European Union or Member state law applicable to CRS Advertising or to you;

o    When the customer has given explicit written consent, and their rights have been safeguarded.

12.  YOUR RIGHTS

Privacy legislation, including the General Data Protection Regulation, grants you certain rights with regard to your personal data. We are transparent about our services and are happy to offer you options to determine who has access to your personal data and when. Please use the following contact details of our UK Data Representative, EDPO UK Ltd, to exercise any of the rights below:

o    Via online request form: https://edpo.com/uk-gdpr-data-request/

o    By writing to EDPO UK Ltd, 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

In principle, and subject to limitation under applicable law, you have the following rights:

o    Right to information and access - the right to obtain information about and access the personal data we process about you;

o    Right to rectification - the right to request that we correct or update your personal data if it is inaccurate or incomplete;

o    Right to be forgotten - the right to request that we delete your personal data;

o    Right to restriction of processing - the right to request that we temporarily or permanently stop processing all or part of your personal data;

o    Right to object

-       Right to object to the use of your personal data due to your specific situation.

-       Right to object to direct marketing.

o    Right to data portability - the right to request a copy of your personal data in electronic form, and the right to transmit that personal data for use in the context of third party services; and the

o    Right not to be subject to automated decision-making - the right not to be subject to decision-making based solely on automated decision-making (i.e. without human intervention), such as profiling, if that decision would lead to legal effects or other significant consequences for you.

If you have any concerns about our processing of your personal data, we ask for your goodwill to try and resolve the issue together with us. If you request information about your personal data, we ask you to include the following information when you contact us:

-       Your full name, date of birth and all personal data relating to your request;

-       A description of the information you are requesting, including a date range;

-       A copy of your current and valid photo id (e.g. A passport).

Alternatively, you always have the right to complain to the ICO by visiting their website at http://ico.org.uk/, or by post at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

13.  TRANSFER TO OTHER COUNTRIES

We may transfer your personal data to companies in other countries to carry out the activities described in this privacy policy. We may also transfer your personal data or outsource data processing to third parties in a country other than your own. The privacy legislation that applies to your personal data may therefore differ from that of your own country.

For example, personal data collected within the European Union may be transferred to and processed by third parties in a country outside the EU. In such cases, we strive to ensure that the transfer of your personal data complies with applicable privacy laws and, in particular, that appropriate contractual, technical and organizational measures are taken, such as the use of standard contractual clauses approved by the European Commission. For more details about the security measures we have taken to protect your personal data, please refer to article 9 of this Privacy Policy.

14.  HOW WE PROTECT YOUR DATA

The security of your personal data is a priority for us. We have taken appropriate technical and organizational measures to protect your personal data.

We have implemented a variety of pseudonymization, encryption, access and retention policies to protect against unauthorized or unlawful processing, loss, destruction or damage, unauthorized access and unnecessary retention of personal data in our emails.

If your personal data is shared, we require this party to take appropriate technical and organizational measures to protect your personal data and, if necessary, we will conclude a processing agreement.

15.  DATA RETENTION PERIOD 

We will not retain your personal data for longer than 36 months, except for legitimate and essential business purposes (e.g. to enable the promotion to run, to make business decisions about new features and data-based offers, to comply with our legal obligations and to resolve disputes).

Where you have consented to parties contacting you by telephone, email, SMS or postmail for marketing and advertising purposes, these parties will be independent data controllers in relation to the data you choose to provide to them. You are then subject to the Privacy Policy of these parties. We encourage you to read these Privacy Policies. There you can read how they manage your personal data and how long your data will be stored on their systems.

We store your data for 36 months. If you request this, we will delete or anonymize your personal data before that time so that you can no longer be identified, unless we are legally obliged to retain certain personal data for a longer period, such as in the following situations:

o    If there is a problem with your participation in the competition/giveaway or with your consent for parties to contact you by telephone, email, text message or post for marketing and advertising purposes, for example to demonstrate that you you have given permission;

o    If we need to retain personal data to comply with our legal, tax, accounting and audit obligations, we will retain the necessary personal data for as long as necessary under applicable law; and/or

o    Where retaining personal data is necessary for our legitimate business interests, such as fraud prevention.

16.  YOUR CONSENT

o    You have the option of Opting In or Out of receiving marketing communications from ourselves and our various partners at any time - including at registration by choosing the option to "To continue without sharing your data with marketing partners".

o    When registering your details, you will be required to actively opt in to;

-       receive offers and updates by email, telephone and post from selected third party companies which we believe will be of interest;

-       Agree that our trusted partners may contact you with more interesting offers by telephone;

-       Acknowledge that you have read, understood and agreed to our terms prior to registration.

o    By registering or signing up, it is made clear, in plain english that by doing so, you have read, acknowledged and agreed to the terms and conditions and this privacy policy, which governs how your information will be processed, and that consent upon registration to receive marketing communications from us

o    We will always remain transparent in disclosing how we intend to process your data, and where your data may be passed on, subject to your consent and preferences upon registration. All companies and partners we work with will be named, and the categories in which they operate in will be made available to you. These opt-ins are optional and only when you put a tick in the box will you consent to receive additional marketing communication. 

o    Third-party providers are able to send you communications via email, post or telephone only until such time as you exercise your right to opt out of receiving such communications. However please be aware that marketing campaigns are often planned well in advance, so your changes will be accepted immediately, but may not be effective immediately.

o    In addition, Website Sponsors have their own privacy policies and some have their own opt-in statements. It is strongly recommended that you read and understand this information.

17.  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.

18.  CHANGES TO THIS PRIVACY POLICY

From time to time we may make changes to this Privacy Policy. Any changes will be published on this page and you should check this page regularly to see our most up to date policy. The date of the last update at the top of this document will indicate this.

19.  HOW TO CONTACT US

Thank you for reading this Privacy Policy. Do you have any questions about this Privacy Policy? Please make them known by reaching out to our Data Protection Officer via email to [email protected], or by sending a letter to the following address:

CRS Advertising BV

Papaverweg 177

1032 KE Amsterdam

The Netherlands

Conversely you may also contact our UK GDPR representative in the United Kingdom:

o    Via online request form: https://edpo.com/uk-gdpr-data-request/

o    By writing to EDPO UK Ltd, 8 Northumberland Avenue, London WC2N 5BY, United Kingdom