SECTION 1: INTRODUCTION
For your information, this website (“Website”) is operated and wholly owned by Submission Technology Ltd., registered in England with the company number 04456811.
Submission Technology Ltd. ("Submission Technology," "we," or "us"), respects your privacy and is committed to protecting it through our compliance with this Privacy Notice.
This Privacy Notice (together with our Terms & Conditions) sets out the basis on which any personal data you provide to us, will be processed.
Submission Technology is the controller of your data and we are registered with the information commissioner. Our registration number is Z7981900. Submission technology is committed to the protection of your data and adheres to all privacy laws which include the General Data Protection Regulation(GDPR) as implemented by the Data Protection Act 2018 and the Public Electronic Communication Regulation(PECR).
SECTION 2: INFORMATION WE COLLECT ABOUT YOU
As permitted by applicable law, we may collect, use, store and transfer different kinds of Personal Data about you when you use our services. We have grouped these into the following categories of Personal Data:
SECTION 3: HOW YOUR DATA IS COLLECTED
We collect data that you supply us with directly which includes contact information, profile data, and marketing and communications data by filling in a form or corresponding with us by post, phone, e-mail or otherwise. This includes Personal data you provide when you:
SECTION 4: HOW WE USE YOUR DATA
We will only use your Personal Data where permitted by law. Our Lawful basis for collecting personal data is as follows;
In specific situations, we collect and process your data with your consent. For example, when we rely on your consent to send you direct marketing by email or via push notifications on your device. Or, when we rely on your consent to transfer your data to third parties you are interested in receiving direct marketing from. We collect your consent when applicable laws require it (including but not limited to the Privacy and Electronic Communications (EC Directive) Regulations 2003 & The EU General Data Protection Regulation). Where we rely on your consent to use your personal data, you have the right to withdraw your consent an anytime. You can do this by contacting us at email@example.com. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Performance of a Contract
In certain circumstances, we need your personal data for the performance of a contract to which you are a party.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity.
This is when we have an interest in conducting and managing our business, to enable us to give you the best experience when using the Website, products, and services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Purpose of collecting your data
In the list below, we have described in what context your personal data was collected,
SECTION 5: DISCLOSURE OF YOUR DATA
We require all parties who process your data to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purpose and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Employees of Submission Technology will process your data when you need to speak to the customer service team or our Data Protection Officer. Access to your Personal Data will be controlled and only granted where necessary to provide our services to you and/or allow us to perform any necessary or legitimate functions.
Service providers who process your Personal Data on our behalf to support our business and help provide our services to you.
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.
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.
Third parties where you have expressly consented to the disclosure of your Personal Data, for example, for direct marketing purposes.
Law enforcement agencies, courts, supervisory authorities, regulatory bodies and related third-parties, to the extent that we are permitted or required to do so by law, or in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity.
From time-to-time, we may run contests, special offers, or other events or activities with a third-party sponsor. If you provide information to the third-party, you give them permission to use it for the purpose of that promotion. We cannot control the use of your Personal Data after you have submitted it to the third-party. If you do not want your information to be processed by the third-party, you can choose not to participate in the promotion.
Parties we do not transfer your data to
Our Website 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.
Where in the world your data is transferred
Submission Technology is headquartered in the UK. The information that you provide or that we collect as a result of your interaction with the Website and/or the user of the Services will only be transferred to parties located within the EU that have been recognised by the European Commission as providing an adequate level of data protection. In rare circumstances, when transfers need to take place to countries outside of this consideration, we have put in place measures, including ensuring the recipient is bound by EU Standard Contractual Clauses, to protect your Personal Data.
SECTION 6: HOW LONG YOUR DATA IS KEPT
We do not retain your personal data for longer than necessary for the purposes set out in this report. The length of time we hold your data will depend on our ongoing relationship with you, our legal obligation, any request you may make to delete your personal data, and our legitimate interest in relation to the management of our own rights.
Typically, we store Identity Data, Contact Data, Marketing Data and Profile 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.
Once we no longer have a purpose to retain your personal data, we will securely destroy your personal data subject to the foregoing and in accordance with applicable laws and regulations. If you request to receive no further contact from us, we will keep some of your basic Identity and Contact Data on a suppression list to avoid sending you unwanted communication in the future.
SECTION 7: YOUR DATA SUBJECT RIGHTS
Right to information
You have a right to know what Personal Data we collect and further process about you and how we use it.
Right to access
You have a right to be provided with a copy of your Personal Data.
Right to rectification
You have a right to correct or update any inaccurate or incomplete Personal Data we hold about you. We encourage you to rectify inaccurate data to ensure our records are up to date. We may need to verify the accuracy of the new data you provide to us. In most cases, you will be able to update your own records in your account.
Right to erasure/be forgotten
You have the right to ask us to erase Personal Data when there is no good reason for us to continue to process it. This is not an absolute right, meaning we may not always be able to comply with your request. If this is the case, we will inform you in a timely manner with reasons why.
Right to restrict processing
You have the right to ask us to restrict processing of your Personal Data e.g., if you want us to establish the accuracy of your data, where our use of your data is unlawful, but you do not want us to erase it, where you need us to hold data longer than our retention period for the purpose of legal claims, or you have objected to our use of your data, but we need to verify whether we have an overriding legitimate ground to use it.
Right to request data portability
In certain circumstances, you have the right to request the transfer of your Personal Data to you or to a third party in a commonly used machine-readable format. This right only applies to automated information which you provided your consent for us to use or where we used the information to perform a contract with you.
Right to object to processing
You have the right to object to the processing of your Personal data in the following circumstances: (i) at any time your Personal Data is being processed for direct marketing; or (ii) in circumstances when we rely on our legitimate interests to process your Personal Data. We may demonstrate we have a compelling reason to process your information, for example, for preventing fraud.
Right to withdraw consent at any time
At any time, you have provided us with your consent to process your Personal Data, you have a right to withdraw your consent. We will advise you if this affects the services or products we can provide to you.
Right not to be subject to a decision based solely on automated decision-making
You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. However, your right does not apply if: (i) you gave us your consent to process your data in this way; (ii) we are permitted by law to make our decision; or (iii) our automated decision was necessary to enter into a contract with you.
How to make a request
If you would like to exercise any of the data subject rights, please send an email to firstname.lastname@example.org. 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.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can make a complaint to the UK Supervisory Authority, the Information Commissioner’s Office (ICO). You can contact the ICO through their website: https://ico.org.uk/concerns/ or by telephone: 0303 123 1113.
SECTION 8: UNSUBSCRIBE FROM MARKETING OR DELETE YOUR ACCOUNT
If you have an account with Free Club you can unsubscribe from marketing emails by clicking the ‘unsubscribe’ link at the bottom of our emails, or you can submit your request via our online form: https://privacy.submissiontechnology.co.uk/form/. You are free to unsubscribe from direct marketing emails at any time. Please allow up to 48 hours for changes to take effect. When you unsubscribe we will store your name and email address on a separate database to ensure we do not contact you again.
To delete your account, please sign into your account, select menu and click on your profile. At the bottom of your profile page, there is an option to delete your account. You will need to enter your account password. If you cannot remember your password, please contact our customer service team at email@example.com. Deleting your account will not delete your personal data. If you wish to exercise your right to erasure ("be forgotten"), please submit your request via our online form: https://privacy.submissiontechnology.co.uk/form/.
To unsubscribe from Free Club push notifications, please follow the advice given by One Signal, our push notification provider, here: https://documentation.onesignal.com/docs/unsubscribe-from-notifications. Push notifications will only ever come from Free Club and not third parties. You are free to opt-out of push notifications at any time.
SECTION 9: SECURITY AND STORAGE OF YOUR PERSONAL DATA
Submission Technology is 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, Submission Technology 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.
To access your Submission Technology account, you must type in the correct password. It is your responsibility to keep this password secure; consider changing your password every 3-6 months. Ideally, your password should be at least 8 characters long, contain at least one capital letter, some numbers and a special character (e.g. ? ! , _) and should not be disclosed to anyone. If you believe that your login details have been compromised, please contact us immediately.
Submission Technology is 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.
SECTION 10: COOKIES AND SIMILAR TECHNOLOGIES
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:
Strictly Necessary & Functional 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.
Performance & Analytical Cookies
These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these Cookies we will not know when you have visited our site and will not be able to monitor its performance. We use Analytical cookies in our emails to improve our service to you which can detect, Email Client Version, Date and time of opening, Dwell time, IP address and Geo-location.
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.
SECTION 11: UPDATES TO THIS POLICY
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.
SECTION 12: CONTACT INFORMATION
Our contacts details are below;
The Data Protection Officer
The Beater House
Customer Service Enquiries
The Beater House
CALIFORNIAN CONSUMER RIGHTS
As a Californian resident, under the Californian Consumer Privacy Act, you are entitled to
Right to Access
To obtain a full copy of all information we maintain about you, you may send us a request using the contact information at the end of this Notice. After receiving the request, we will tell you when we expect to provide you with the information. We offer this service for free unless your request is excessive or manifestly unfound.
Right to Opt-Out
If you wish us to opt you out of receiving direct marketing from us or our partners, you may click the unsubscribe button at the bottom of the email, or through the unsubscribe link at the bottom of our website or contact us using the information at the end of this Notice.
Right to Erasure
If you wish us to remove or change personal data you have provided us with, you may contact us using the information at the end of this Notice.
Right to Equal Services and Price
The “right to equal service and price” refers to the Californian Consumer Privacy Act (2018)’s prohibition against discriminating against consumers who exercise their rights under the CCPA. Where a consumer exercises a right, a business is prohibited from denying goods or services, charging a different price, imposing penalties, providing a different level or quality of service, or suggesting the consumer will receive a different price or rate or different level or quality of goods or services.
When we receive any request to access, edit or delete personal data, we will first take reasonable steps to verify your identity.
For non-Californian residents, for any opt-out or deletion requests, please follow the “Do Not Sell My Data” link at the bottom of the page and complete the form.
PROTECTING YOUR CHILD’S PRIVACY
We follow the Children’s Online Privacy Protection Act (COPPA). Our website is not designed for use by anyone under the age of 18, however, we are aware that a child may attempt to access our website. We do not allow anyone under the age of 18 to register and do not knowingly collect personal data from a child. If you are a parent or guardian and believe your child is using our website, please contact us. We may ask for proof of identification before we remove any information to prevent malicious removal of account information. If we discover on our own that a child is accessing our website, we will delete the information as soon as we discover it, we will not use the information for any purpose, and we will not disclose the information to third parties. You acknowledge that we do not verify the age of our users any further than asking for an accurate date of birth nor do we have any liability to do so. If you are a child, please seek the permission of a parent or guardian before accessing our website.
OUR EMAIL POLICY
We comply with the federal CAN-SPAM Act. You can always opt-out of receipt of further email correspondence from us or our affiliates.
This privacy notice was last updated on 23/3/21