MyOffers Company Information

We are a direct marketing organisation called MyOffers 2019 Limited "MyOffers" registered in England and Wales under company registration number 12199927, whose registered office is at Green Heys, Walford Road, Ross-On-Wye, Herefordshire, HR9 5DB and is a subsidiary of DM Ltd.

We are registered with the Information Commissioners Office under registration number ZA560068.

We operate under the brand names MyOffers, Testers Keepers, ImproveMyHearing, ImproveMyVision and SwitchMyUtility. We run a competition website and utility-switch 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.

For those of you that enter competitions and prize-draws by using MyOffers and Tester Keepers, our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive communications including (but not limited to) direct marketing communications. You can access the privacy controls via our Website at https://www.myoffers.co.uk/account, by signing in and clicking on 'My Account'. You can also at any time amend or update your personal data and other details via our Website at https://www.myoffers.co.uk/account, by signing in and clicking on 'My Account'.

For those customers that register with SwitchMyUtility.com, ImproveMyVision and ImproveMyHearing, your personal data is used for limited purposes which are detailed in section 2 of this document. You will always remain in control of your data and can contact us on the details below at any time.

Our offices are at Sunningdale, The Belfry Business Park, 13 Colonial Way, Watford, Hertfordshire, WD24 4WH and you can contact us by phone on 01923 478075 where you can speak to the Compliance Department or email compliance@myoffersltd.co.uk with your questions.

The data that you provide us is for the following purposes:

Direct Marketing - our brands MyOffers and Testers Keepers will contact you by email, SMS or telephone to ask you questions for marketing purposes. We also share your details with selected companies who want to contact you by telephone and post to offer you goods and services that we believe will be of benefit to you.

Profiling - we will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you. Profiling analyses aspects of an individuals lifestyle, behaviour, and interests to make predictions on whether you might find our clients offers and products interesting. We will never make automated decisions about you which would have a negative impact on your rights. Our partners may use your data for tailored advertising, measurement of the effectiveness of the advertising, and identity resolution (i.e. recognition)

ID Protection & Tracing - we will also share your details with credit reference and identity verification organisations which help other organisations verify your identity and prevent others from misusing your details.

For SwitchMyUtility.com, ImproveMyVision and ImproveMyHearing customers, we will use your details for direct marketing purposes only. Selected companies will only ever contact you by telephone or post. We will not use your data for any other purpose, including profiling, ID Protection & Tracing or Marketing Service Providers.

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, MyOffers 2019 Limited, Sunningdale, The Belfry Business Park, 13 Colonial Way, Watford, Hertfordshire, WD24 4WH;

By email to: compliance@myoffersltd.co.uk.

By telephone on: 01923 478075

Your data must be processed by us using one of the valid legal bases defined by the Regulations. When you provide your personal data we process this using two different legal basis depending on the purpose; either consent or legitimate interests. We will never switch from one legal basis to another without your permission. The different purposes are summarised in the table below:

Consent

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 policy.

• We obtain consent for our brands to contact you by telephone where your number is registered on the Telephone Preference Service (TPS) or by email and SMS.
• To pass your contact details to named third parties where Privacy and Electronic Communications Regulation (PECR) applies such as email marketing or where your telephone number is registered with the TPS
• To pass your contact details to named third parties where your postal address is registered with the Mailing Preference Service (MPS).
• Where our client has specifically asked us to gain your consent to pass on your details.
• We obtain your consent for using your personal information for promotional purposes. If you enter a competition on our website and are a winner, we will publish your name, picture and comment on our website.
• All cookies & similar technologies which do not meet the "strictly necessary" exemption under PECR.

Legitimate Interest

As a direct marketing business we process personal information for various legitimate business purposes which include some or all of the following:

• To enhance our services for the benefit of our customers including verification and validation
• To help make the communication more relevant and contextual
• To better understand how our customers interact with our services
• To provide direct marketing communications which we think will be of interest to you
• To determine the effectiveness of our and our clients promotional campaigns
• To identify and prevent fraud

These legitimate business purposes relate to the following activities:

• Direct Marketing - Postal and telephone marketing by both MyOffers 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.

Addressable TV Advertising - A form of television advertising where advertisers are able to target video adverts to specific households during scheduled TV programmes. Relevant advertisements are then shown while you are watching TV either on-demand, live-streaming or traditional television viewing.

• 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)
  We also share anonymised data with third parties that we collaborate with to optimize campaign performance and display online adverts to you. The personal information is hashed using the latest and most secure technology, hashing refers to the process of transforming data to a combination of numbers and letters which cannot be recognised or decoded so it is not considered personal data as it has been anonymised.
  We also collect information when you visit our site using cookies and similar technologies. Should you prefer not to share such information, you can select your preferred options on this website by selecting the “Cookie Settings” shown at the bottom left-hand corner of this site.
• ID Protection & Tracing - 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:

• To pass on your personal information to our clients for marketing purposes who will send postal marketing to you, (except where you are registered with the MPS) or contact you by telephone (except where you are registered with the TPS). Marketing will only ever be from organisations operating within the industry sectors described below.
• To call you where your telephone number is not registered on the TPS.
• To call you where we have obtained your details from a third party. We will always be named within their privacy policy as a party to whom they share your information; once contact is made we will obtain your consent at the earliest opportunity. You will always be given the option to opt out should you not wish to hear from us again.
• To process your personal information for the purposes of customer analysis, non-automated profiling and direct marketing, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
• To pass to our clients for use including 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. More information on this can be found in the Credit References and other Agencies section.
• To determine the effectiveness of our clients promotional campaigns and advertising, and to develop our products, services, systems and relationships with you.
• Processing your information to protect you against fraud when using our website, and to ensure our websites and systems are secure.
• To pass on your details to companies to help their clients tailor products and services which best suit your needs. They will also use your data for fraud prevention. More information on this can be found in the Marketing Services Providers section.
• To pass some of your details to social media platforms such as Facebook and TV advertising platforms to understand if you use that platform. This is known as matching or linkage. If you do use that platform, we may ask it to show you relevant advertising which we think will be of interest to you based on the information you have previously provided us. If your data does not match, the platform will immediately delete it. The platform will typically match based on email address, postal address or IP address. They will act as processor and will not share the Data with third parties or other advertisers. They will delete the Data promptly after the match process is complete. The platform will maintain the confidentiality and security of the Data by maintaining technical and physical safeguards that are designed to (a) protect the security and integrity of data while it is within the platform's systems and (b) guard against the accidental or unauthorised access, use, alteration or disclosure of data within its systems.

It is important that we keep your details up to date, therefore we use various methods such as Quick Address Systems (QAS) which is a service provided by Experian Ltd, National Change of Address (NCOA®) which uses information taken directly from the redirection application forms of people who are moving and the Edited Electoral Register (EER) which contains the names and addresses of those voters who have indicated that their details can be used for a purpose other than electoral or statutory use, e.g. for direct marketing use by a commercial or other organisation.

For all types of processing, we apply various measures to carefully protect your privacy rights. In considering the most appropriate legal basis, MyOffers 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. This documentation is available by writing to: The Data Protection Officer, MyOffers 2019 Limited, Sunningdale, The Belfry Business Park, 13 Colonial Way, Watford, Hertfordshire, WD24 4WH; or by email to: compliance@myoffersltd.co.uk;

As with all your data you can also object to us processing your data in this way. Your rights are detailed below.

Personal data means any information that can be used to identify directly or indirectly a specific individual. During the course of completing a lifestyle survey we collect different types of personal data from you. This data can be categorised into four types:

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.

You always have the right to refuse to answer any question.

1. A. Our Group of Companies and Brands
2. B. Groups of recipients within the specific industry sectors listed
3. C. Marketing Service Providers
4. D. Named clients
5. E. Credit Reference Agencies
6. F. Organisations regulated by the Financial Conduct Authority (FCA)

A. Our Group Companies and brands;

• MyOffers 2019 Ltd – and its brand names MyOffers, Testers Keepers, ImproveMyHearing, ImproveMyVision and SwitchMyUtility.com
• Data Locator Group Ltd and its brands Surveys.co.uk, ThePrizeFinder.com and Consumer Lifestyles™
• PDV Ltd - PDV is a Data Processor working on behalf of Data Controllers to store, prepare and share data with reputable UK businesses for marketing purposes. PDV works under instruction of the Data Controllers, such as Data Locator Group, who collect information directly from you. To object to the processing of your information please contact PDV by telephone on 0800 093 1551 or by email at client.services@pdv.agency
• Transactis (2017) Ltd

B. Groups of recipients within specific industry sectors listed below;

From time to time we also supply data to these sectors via agencies/brokers; we ensure that these agencies/brokers are reputable firms.

C. Marketing Service Providers are companies who collect data from Data Controllers, such as ourselves, and help their clients tailor products and services which best suit your needs.

We will share your data with the Marketing Services Providers, who will use it for a variety of direct marketing purposes. Marketing Services Providers carry out data profiling. They will combine your data with data they get from other sources to create 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) or keep the IP address they hold about you up to date. IP addresses change regularly. The IP address they receive from us might change too quickly to make the data you provide through us useful for marketing purposes. Marketing Services Provider might find it helpful for this to be refreshed 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:

• help organisations better understand the likely characteristics of their customers (and find others like them);
• improve the relevancy and appropriateness of an organisation’s marketing to its customers (e.g. offers, its products and services); and
• help them communicate with their customers more effectively offline and online. This may mean that you receive tailored advertising via direct mail, when you visit a website, via a mobile app or watch TV. The Marketing Services Providers will not however advertise their own products or services to you.

We do not share information such as cookies. However, Marketing Service Providers may link the personal information we share with them to cookies stored on your browser or device, but only if you have already provided the necessary permissions.

In sharing your data with Marketing Services Providers, we rely on ‘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),

To see a list of Marketing Service Providers click here.

D. Named Clients

Whilst we use overseas call centres to conduct surveys on our behalf, your data is never sent to them but held on secure servers here in the UK. Our call centres are able to access your information in order to conduct surveys on our behalf, under our strict instructions but they are not able to save or download your data into their own systems.

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. To understand more about the products or services they offer please click through to our named clients.

E. Credit Reference and Other Agencies

When you register with MyOffers and Testers Keepers, we will collect your data and share it with third parties. These organisations will have a relationship with you or need to use your information where they have a lawful reason, which will include these organisations’ 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. You have the right to object to this processing at any time by contacting us at compliance@myoffersltd.co.uk. To understand more please click through to the websites.

F. Credit Reference and Other Agencies

In addition to organisations that fall within the industry sectors listed in section B, we may also supply data to organisations that are regulated by the FCA. This includes organisations that offer pre-paid funeral plans. Data is supplied using the legal basis legitimate interests and clients will use your information in line with our privacy policy for marketing purposes only. In supplying this information, we in no way advise, recommend, arrange, or distribute financial services provided by an FCA authorised firm, nor are we incentivised on the basis of how many financial policies are sold. If you have any concerns you should always take independent advice. Please see www.fca.org.uk for further information.

Once you register with MyOffers or Testers Keepers you will receive a welcome email, and regular newsletters packed with great prizes for you to win. You may also receive further emails, SMS messages and telephone calls describing new prizes and specific events relevant to you as a member of MyOffers.Once you register with SwitchMyUtility.com, ImproveMyVision and/or ImproveMyHearing you will only receive telephone calls with details of other special offers or money saving opportunities relevant to you as a member.

You have a right to object to such processing see below.

There is information on how you can un-subscribe at the bottom of every email that MyOffers sends out. We provide you the opportunity to 'opt-out' of having your personally identifiable information used for certain purposes, when we ask for this information. For example, if you answer questions from one of our loans clients but do not want to apply for a loan you can state not applicable and you will not receive communication from the loan client.

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us, We offer an opportunity to opt-out of certain communications on our 'My Account' section on MyOffers - https://www.myoffers.co.uk/account you may contact us at 01923 478075 or MyOffers 2019 Limited, Sunningdale, The Belfry Business Park, 13 Colonial Way, Watford, Hertfordshire, WD24 4WH.

Profiling enables organisations to better understand who their customers are so they can make their marketing communications more relevant.

We use some of the information you provide to match with our clients data so that they will better understand the characteristics of their customers, such as age, hobbies and interests. This only happens when you are both on MyOffers database and you are a customer of our client. We do not give them specific information about you but we will tell them how many of the customers are male/female or live in a certain city. We also help identify whether or not you have similar attributes to a typical customer of our client so they can target you with offers of goods and services tailored to you. We will never profile you on the basis of ethnicity, religion, politics or health as these are not valid reasons for which you should be targeted for marketing purposes and nor do we collect this information. We also do not make automated decisions about you which have a negative impact on your rights. Marketing Services Providers we share your data with can also use profiling to target you for marketing purposes. Once again you can ask us to stop using your data in this way at any time.

Whilst we use overseas call centres to conduct surveys on our behalf, your data is never sent to them but held on secure servers here in the UK. Our call centres are able to access your information in order to conduct surveys on our behalf, under our strict instructions but they are not able to save or download your data into their own systems.

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.

We take your data privacy rights seriously. Whilst the law does not put a time limit on the amount of time we should hold your personal data, MyOffers only wishes to retain 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 long as you are happy for us to do so.

In addition, to help MyOffers maintain the most recent indication of your marketing and data processing preferences, we will provide you with ongoing reminders of your data subject rights with access to this privacy policy. We refer to this as engagement or notification recency. Therefore our data retention policy considers the purpose, the legal basis under which it is processed and also the most recent engagement.

• Marketing where we process your data under consent we will stop using it for marketing purposes after five years. Where we rely on legitimate interests we will continue to process your data for ten years, subject to receiving notification from ourselves that we hold your information.
• Profiling we will stop using your data for this purpose after ten years.
• Tracing and Credit Reference as this purpose plays an important function of protecting individuals, we will retain your data for twenty years. However, only basic name, date of birth and contact information is retained for this purpose.

In addition, when completing lifestyle questions you may provide us with information such as the make and model of your car or the newspaper you read. Where information such as this has less use over time, it will be removed sooner than the retention periods detailed above.

It is important that the personal data we hold and process is accurate and up-to-date. Therefore, we regularly refresh the database against suppression lists and remove those who no longer wish to be contacted. As we explain in the section marked What are your rights? you can withdraw your consent to us at any time.

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 Policy 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. You can withdraw consent in the following ways; In writing to: The Data Protection Officer, MyOffers 2019 Limited, Sunningdale, The Belfry Business Park, 13 Colonial Way, Watford, Hertfordshire, WD24 4WH; By email to: compliance@myoffersltd.co.uk; or By telephone on: 01923 478075

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

In order to keep consumer records as up to date as possible we use third party products to help us verify and suppress data.

• Experian QAS, supplied by Experian PLC, is a data verification service. It uses the Edited Electoral Roll and details given by multiple companies to re-verify consumer information.
• Telephone Preference Service (TPS) and Mailing Preference Service (MPS). Managed by the Data and Marketing Association (UK) Ltd, these are central registers of individuals who do not wish to receive unsolicited marketing calls or direct mail. You can register for these free of charge at www.tpsonline.org.uk and www.mpsonline.org.uk
• National Change of Address (NCOA®) which uses information taken directly from the Royal Mail redirection application forms of people who are moving.
• Mortascreen is a product of MiExact Ltd. It is data management solution and enables organisations to identify deceased records using verified notifications of death.
• Clients and other Data Controllers with whom we share data, will on occasion return data to us for the purpose of verification and accuracy. In line with GDPR, this enables us to erase or rectify data without delay.

From time to time, we will also use third parties to supply data subjects personal information to us for marketing purposes.

• Other data controllers - where you have completed a marketing survey either online or by telephone and a DLG brand is named in their privacy policy as a company with whom they share information. DLG will typically rely on legitimate interest for this processing. Consent will only be relied upon with your express permission.
• Publicly available information relating to properties such as Energy Efficiency Ratings or land registry data. We use this information to try to tailor campaigns to your wants and needs where we can rather than sending mass mailings which may not interest you. As this is not considered personal data, a legal basis for processing is not required.
• Acorn, provided by CACI, is a consumer classification that segments UK households, postcodes and neighbourhoods into 6 categories, 18 groups and 62 types. population. Acorn is a postcode level tool rather than an individual level database. As this is not considered personal data, a legal basis for processing is not required.

When we do collect information from third parties, we always check that they have a valid legal basis to process and share your data with us.

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