PRIVACY STATEMENT
OPENTOP EUROPE LIMITED
Whose registered address is at Palladium House, 1-4 Argyll Street, London, United Kingdom W1F 7LD and whose company number is 09156428
1 Your rights in relation to privacy
For the purposes of the Data Protection Act 1998 (the "Act") the data controller is Opentop Europe Limited.
This statement applies to any personal information collected from you by Opentop Europe Limited (we, us, our) via one of the websites or mobile applications (Promotional Platforms) owned or operated by us or our network of third party promotional partners (" Partners").
This statement does not apply to the practices of organisations that we do not own or control, or to people that we do not employ or oversee even if links to their websites appear on our Promotional Platforms. We recommend you examine the privacy policies and statements of such other parties.
We understand the importance of protecting the privacy of an individual's personal information. This statement sets out how we aim to protect the privacy of your personal information, your rights in relation to your personal information managed by us and the way we collect, hold, use and disclose your personal information.
In handling your personal information, we will comply with the Act. This policy statement may be updated from time to time.
2 What kinds of personal information do we collect?
Personal information is information about a living individual who can be identified from such information or from such information and other information which is in the possession of, or is likely to come into the possession of, the data controller. During the provision of our services, including if you access our Promotional Platforms, register an account, opt-in to offers, deals and competitions, and complete surveys, we may collect your personal information.
Generally, the kinds of personal information we collect includes your name, address, telephone number, date of birth, marital status and email address. In some circumstances we may also hold other personal information provided by you.
We may collect information about you in the course of your interaction with our Promotional Platforms including your internet protocol (IP) address, the date and time of your visit, the pages you have accessed, the links on which you have clicked and the type of browser that you were using, which may be linked to your personal information.
3 How do we collect personal information?
Generally, we collect your personal information directly from you, if you:
• set up or update an account or other registration on our Promotional Platforms;
• opt-in to offers, deals and competitions;
• complete surveys;
• actively participate and use our Promotional Platforms; or
• submit an enquiry to us via our Promotional Platforms.
There may be other occasions when we collect your personal information from other sources such as from an information services provider or a publicly maintained record. Generally, we will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect the personal information from you.
We may also collect statistical information if you access and use our Promotional Platforms by utilising features and technologies of your internet browser, including cookies and pixel tags. If you have provided personal information to us, we may link this statistical information to your personal information for the purpose of providing services to you.
4 Why do we need your personal information?
We collect, hold, use and disclose your personal information where it is reasonably necessary for the purposes of:
• providing relevant marketing material to you;
• selling, renting or forwarding your personal information in aggregated form to allow third party advertisers (to whom you have opted in) to communicate their products and services to you;
• selling, renting or forwarding your personal information in aggregated form to third party agencies and brokers, who may in turn pass on such personal information to third party advertisers;
• improving our services through analysing aggregated data reports;
• displaying your name and the county, or region in which you live if you win a prize draw on our Promotional Platforms, and if required by law, in relevant newspapers;
• facilitating a proposed or actual transfer or sale of all or part of our business or assets;
• accounting, billing and other internal administrative purposes; and
• fulfilling our other legal requirements.
5 How may you be contacted?
We and/or third party advertisers (subject to us having obtained your consent) may contact you from time to time by telephone (including SMS), by post or by email, or by such other means as you may from time to time agree.
6 Who do we disclose your personal information to?
We may disclose your personal information with your consent to third party advertisers for the purposes specified in paragraph 7 or for any other purposes specified above in paragraph 4. We may also disclose your personal information with your consent or if disclosure is required or authorised by law.
7 Disclosure of personal information outside the European Economic Area ("EEA")
The data that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement.
We may disclose your personal information to recipients outside the EEA:
• in order to provide our services and/or products;
• for administrative or other business management purposes; or
• where you have provided your consent to us disclosing your personal information to one of our Partners located overseas.
Recipients of such disclosures for the purpose of our administrative or business management purposes are located in the United States of America and may also be located in other countries notified to you from time to time.
Where you have consented to us disclosing your personal information to a Partner that is located overseas, we will endeavour to notify you of the country or countries to which your personal information will be disclosed at the time you provide your consent.
8 Direct marketing
At the time of entering a promotion or otherwise from time to time, we may seek your consent to us disclosing your contact details to a specified Partner.
Where you have provided your consent, we may disclose your personal information to the Partner for the purpose of the Partner contacting you for promotional purposes, and the Partner may contact you with special offers via the communication channel or channels specified at the time of obtaining your consent.
In the event you do not wish to receive such communications, you can opt-out by contacting us via the contact details set out in paragraph 10, through any opt-out mechanism contained in a communication or by logging in to your account and using the info and feedback form.
If you unsubscribe or opt-out, your account will be deleted after the next prize draw to be conducted and you will not have your data provided to any third party advertisers or people for marketing or other purposes (except to the extent as required by law to disclose it). You may at any point re-subscribe by re-registering.
9 Security of your personal information
We take all steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. We hold personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.
We will destroy or de-identify personal information in circumstances where it is no longer required, unless we are otherwise required or authorised by law to retain the information.
10 Can you access and correct the personal information that we hold about you?
We take steps reasonable in the circumstances to ensure personal information we hold is accurate, up-to-date, complete, relevant and not misleading. Under the Act, you have a right to know if your personal data is being processed, a description of your personal data held by us, the purposes for which your personal data is being processed and the recipients or classes of recipients to whom we may disclose your personal data. Your right of access to this information can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
To obtain access to your personal information:
• you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected; and
• you must be reasonably specific about the information you require.
If we refuse your request to access or correct your personal information, we will provide you with written reasons for the refusal and details of complaint mechanisms. We will also take steps reasonable in the circumstance to endeavour to provide you with access in a manner that meets your needs and our needs.
We will endeavour to respond to your request to access or correct your personal information within 7 days from your request.
11 How to contact us
For further information or enquiries regarding your personal information held by us, or if you would like to opt-out of receiving any promotional communications from us or our Partners, please contact us at [email protected], or call +44 (0) 207 947 4087.
12 Privacy complaints
If you believe that we are in breach of the Act, you can make a privacy complaint to us.
Please direct all privacy complaints to us on the contact details specified in paragraph 11. At all times, privacy complaints:
• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations or affect your commercial arrangements with us.
We will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Information Commissioner's Office.