For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is InboxPounds Limited a company registered in England and Wales with registered number 07871672 and with registered address Webber House, 26-28 Market Street, Altrincham, Cheshire WA14 1PF. InboxPounds Limited is a subsidiary of CotterWeb Enterprises, Inc, a corporation registered in the United States of America.
Our Compliance Officer for the purpose of the Act is Tom Healy.
Last Updated: May 14, 2018
I. INFORMATION COLLECTION
InboxPounds® directly obtains and processes the following types of information (collectively referred to as “Member Data”)
- Members may be required to provide subsequent demographic information in order to receive Signup Bonus(es) and/or qualify for other promotions. Demographic information includes, but is not limited to: birth date, gender, marital status, education completed, household income, and number of children in household.
- If you contact us, we may keep a record of that correspondence.
- InboxPounds® may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of visits to our Website, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing or payment purposes or otherwise, and the resources that you access.
- We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our Advertisers. This is statistical data about our Members’ browsing actions and patterns, and does not identify any individual.
Means of Collection
We collect Member Data at the time you join InboxPounds® or create an account on our Website. Members may join InboxPounds® by completing one of our signup forms, through Co-Registration, or other means as we may determine at any time in the future.
II. USE OF INFORMATION
Use of Information
Member Data is used by InboxPounds® for the purposes set forth below and for purposes that are materially similar to or compatible with these purposes. InboxPounds maintains reasonable procedures to help ensure that any personal data (as described in Section I.1) is reliable for its intended use, accurate, complete and current.
- to ensure that content from our Website is presented in the most effective manner for you and for your computer;
- to provide you with information, products or services that you request from us which we feel may interest you and where you have consented to be contacted for such purposes;
- to carry out our obligations arising from any contracts entered into between you and us;
- to allow you to participate in interactive features of our service, when you choose to do so;
- to notify you about changes to our services;
- InboxPounds® members automatically receive 1-3 PaidEmails™ per day. These emails inform members about the latest product and service offers from our Advertisers. Members are credited for confirming they have read their PaidEmail™ messages. InboxPounds® sends different types of PaidEmail, some can be confirmed directly from the link within the email, while others require a subsequent action by the member. Follow the instructions in each PaidEmail™ to be sure you are credited properly. InboxPounds® members are required to subscribe to PaidEmail™. To stop receiving PaidEmail messages, members must cancel their membership. The “My Account” tab contains a “Cancel Account” link to stop your InboxPounds® membership.
- your postal address may be used to send payments earned by you or otherwise communicate with you;
- demographic information may be used to target advertisements to you; to stop receiving targeted advertisements see Section VI.2;
- membername, email address, and Password are used for your protection in order to restrict access to your account;
- Member Data may be sold or disclosed to third parties as described in sections II.2 and III below;
- Member Data may be disclosed to allow us to comply with our legal obligations where release of information relating to Members is required by law;
- Member Data may be disclosed in response to valid requests from public authorities, including to meet national security or law enforcement requirements;
- cookies may be used as described in Section IV below;
any additional purpose subsequently authorized by you. Before we use your personal data for a purpose that is materially different than the purpose we collected it for or that you subsequently authorized, we will provide you with an opportunity to opt-out.
Sharing of Information
InboxPounds® does not rent, sell, or share Member Data, except in the following circumstances:
- We will release Member Data where it is necessary for us to do so in order to comply with any legal obligation or requirement, including in response to valid requests from public authorities.
- We may release Member Data in order to enforce or apply our Terms and Conditions and other contractual agreements, or to protect the rights, property, or safety of InboxPounds®, our Members, our Advertisers, our parent company or others. This includes but is not limited to exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction and any investigation in relation to the same.
- In particular, we may share demographic data with our Advertisers where such sharing is necessary for the provision of the InboxPounds® services and performance of the contractual obligations between InboxPounds® and the Advertisers. We do not share personal data with our Advertisers unless you opt-in to the co-registration process (as described in Section III).
- We share Member Data when Co-registration Boxes (as described at Section III) are checked during the course of registration.
- We may share Member Data with third parties as reasonably necessary for us to operate this Website and to provide offers and services to you that we think will be of interest to you, unless you indicate to us that you do not wish your Member Data to be disclosed for this purpose.
- We reserve the right to rent, sell, share or transfer the Member Data in the event part or all of our business or assets are sold to, merged with, or acquired by another company or our company undergoes a reorganization. We may share Member Data with CotterWeb Enterprises, Inc., the American parent corporation of InboxPounds® on the basis that CotterWeb Enterprises, Inc., has in place measures recognised by the European Commission as adequate protection for personal data transferred to them from the EU.
InboxPounds® signup pages may contain co-registration checkboxes, where Members can choose to “co-register” for other websites during their registration with InboxPounds® by checking the checkbox next to the co-registration Offer. Members are not required to select any co-registration boxes to join InboxPounds®; however, they may be required to do so in order to qualify for Signup Bonuses and/or other offers or promotions.
When a Member co-registers for an Offer by checking the co-registration checkbox, any information they provide to InboxPounds® may be shared with the Advertiser associated with the co-registration Offer. InboxPounds® cannot control and will have no responsibility for what Advertisers subsequently do with that information.
Privacy on Other Sites
This Website may contain links to third party websites. We provide these links for your convenience, but we do not review, control or monitor the privacy practices of websites operated by others. We are not responsible for the performance of these sites or for your business dealings with them. Your use of other websites is subject to the terms and conditions of those websites, including the privacy policies of those websites.
IV. COOKIES AND THIRD PARTY TRACKING TECHNOLOGY
About Cookies and Third Party Technology.
A “cookie” is a small data file that may be saved to and stored on your computer when you visit a website or open an email. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies permit a website to “remember” whether your computer has visited the website before and helps the website create a more personalised experience for you and records activities taken by you, such as offers completed.
For a full list of all cookies used on the Website, please follow this link to cookie information http://www.inboxpounds.co.uk/pages/cookie_info.
In addition to cookie technology, InboxPounds® and our Advertisers use additional third party technology and tracking tools to record offers and activities completed by you, friends referred by you, and to communicate information about you, such as anonymised demographic information (e.g., age, gender), in order to target offers and advertisements to specific groups. Cookies and other tracking technology are collectively referred to as “Cookies and Recording Tools”.
Your computer permits you to change the settings on your web browser to not accept and/or disable Cookies and Recording Tools. However, if you do not accept Cookies and Recording Tools used by InboxPounds® and our Advertisers, you may not be able to use certain functions on the Website or on certain links to external websites. More importantly, if you do not accept Cookies and Recording Tools you will not receive credit for Offers or other actions completed by you because we and our Advertisers are unable to track and record your activity. Except for essential cookies, all cookies will expire after the period of time provided athttp://www.inboxpounds.co.uk/pages/cookie_info.
Referral and Affiliate Tracking
After a Member has logged into the InboxPounds® Member’s Section, cookies are used to remember their membername and Password so they do not need to be entered during every visit to our Website. Members can logout of the Member’s Section if they do not wish to have this information saved.
V. STORAGE OF DATA
Security and Servers
InboxPounds® takes reasonable precautions to protect Member Data from loss, misuse and unauthorised access, disclosure, alteration and destruction. We use a number of physical security mechanisms (such as locks), electronic security mechanisms (such as authentication, firewalls, passwords, encryption methods) and procedural security mechanisms (such as back up practices and rules regarding handling and use of information) designed to protect the security and integrity of Member Data.
The data we collect from you will be processed and stored on servers securely held by VISI, a Tier 3 Data Centre facility at their premises at 10290 West 70th Street, Eden Prairie, MN 55344, United States (or by such other person / at such other premises as we may notify to you from time to time), with backup data held at the corporate offices of CotterWeb Enterprises, Inc. at 1295 Northland Drive, Mendota Heights, MN 55120, United States.
Transfer of Member Data outside the EEA
InboxPounds® stores Member Data, including personal data, in the United States. To facilitate our business operations, we may transfer, store, or process personal data that we collect from you outside the European Economic Area (“EEA”) in countries that may not have the same data protection laws as your country or the EEA, including the United States. When we transfer or share (as described in Sections II.1 and III above) personal data with recipients in other countries, we enter into written contracts requiring such recipients to provide the same level of protection as set forth in this Privacy and Cookies Policy with respect to your personal data. Personal data may also be processed by staff operating outside the EEA who work for us, our parent company, our Advertisers (in the case of co-registration) or for one of our suppliers (for the purposes set forth in Section II.2). Such staff may be engaged in, among other things, the fulfilment of your Account, the processing of your payment details and the provision of support services.
Where we have given you (or where you have chosen) a Password which enables you to access certain parts of our Website, you are responsible for keeping this Password confidential. We ask you not to share a Password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we take reasonable precautions to protect Member Data (as set forth in Section V.1), we cannot guarantee the security of any Member Data transmitted to our site; any transmission is at your own risk.
Data Retention and Purpose Limitation
Subject to applicable law, we retain your personal data in a form that identifies or is capable of identifying you only for as long as it serves a purpose that is compatible with the purposes for which the personal data was collected or subsequently authorized by you in accordance with Section II.
VI. YOUR RIGHTS
InboxPounds may limit or deny access to your personal data where the burden or expense of providing access would be unreasonable or excessive under the circumstances or where the rights of other persons would be violated.
Use of Member Data for marketing purposes
In relation to third party websites
Our Website may contain links to and from the websites of our partner networks, Advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Right to Withdraw Consent
You have the right to withdraw your consent at any time or to access and request that we rectify or remove your personal data from our system(s). You may exercise this right by submitting a written request to the contact information provided in Section VII.
In addition to the rights set forth above, you have the right to request correction, amendment or deletion of your personal data by submitting a written request to the contact information provided in Section VII.
VII. CONTACT US
26-28 Market Street