WHO ARE WE ?

Fusion BPO Services Ltd (“Fusion”, “FBS”, “WE”, “US”, “OUR”) is the registered owner of these prize draw service websites and owns all rights, including the sites’ respective IP, copyrights and trademarks. We are registered with The Information Commissioner's Office in the United Kingdom ("The ICO") as a Data Controller and Data Processor under the Trading Name Fusion BPO Services Ltd, with Registration Number Z3154361. This privacy policy applies to the following websites owned and operated by us (collectively to be called "the sites"):

OUR COMMITMENT TO PROTECTING YOUR PERSONAL DATA

FBS is committed to protecting your 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 work within the guidelines and advice provided by and made available by the Information Commissioner's Office, the regulator of the Data Protection Act 1998 and abide by the ICO’s requirements.

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 EU General Data Protection Regulations (GDPR). If you wish to find out more, please visit https://ico.org.uk/

PURPOSE OF THIS PRIVACY POLICY

This Policy sets out how we manage, use and protect your personal data collected while using our sites. We will only use or share your personal data in a manner that is in accordance with this Privacy Policy, and as stated within the registration opt-in definition, and only where we have obtained your prior active consent. Consent is obtained using clear and specific statements that are prominently displayed as part of the registration process on the sites and can be withdrawn at any time by you.

OUR PURPOSE FOR PROCESSING YOUR PERSONAL DATA

FBS has 3 main business purposes:

OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

Consent and legitimate Interest.

Data must be processed by us using one of the legal valid bases defined by the regulation, summarised in the table below.

Purpose For use by our self For use by third parties
Marketing - by email Consent Not applicable - Unless you provided specific consent for named organisation
Marketing - by SMS Consent Not applicable - Unless you provided specific consent for named organisation
Marketing - by Telephone Consent - where your number registered with Telephone Preference Service (TPS) Legitimate Interest - where your number is not registered with Telephone Preference Service (TPS)
Marketing - by Post Legitimate Interest - where your number is not registered with Mailing Preference Service (MPS), we will ask you for specific consent. Legitimate Interest - where your number is not registered with Mailing Preference Service (MPS), we will ask you for specific consent.
Tracing, ID verification and credit reference Legitimate Interest Legitimate Interest
Profiling & analytics Legitimate Interest Legitimate Interest

Consent

It means where you have given consent to a specific organization to contact you a communication channel or channels which you have agreed to for specific grounds which in the context of processing will be for Marketing purpose. When we ask for your consent for a specific organisation, we will do this by giving you the opportunity to answer a question on the phone.

You can withdraw your consent at any time now or in the future.

We will inform you what we will doing with the information and explain your rights to withdraw the consent and how you can do that. We will only use your personal information for the purpose that you have provided the consent for.

Legitimate Interests

As a direct marketing business, we process personal data for commercial benefit, we require an appropriate legal basis to do. Data may be processed in fulfilment of legitimate interest. This includes using your data for telephone, SMS and postal marketing of ourselves or others, but in either case communication will be in Purpose For use by our self For use by third parties Marketing - by email Consent Not applicable - Unless you provided specific consent for named organisation Marketing - by SMS Consent Not applicable - Unless you provided specific consent for named organisation Marketing - by Telephone Consent - where your number registered with Telephone Preference Service (TPS)Legitimate Interest - where your number is not registered with Telephone Preference Service (TPS)Marketing - by PostLegitimate Interest - where your number is not registered with Mailing Preference Service (MPS), we will ask you for specific consent. Legitimate Interest - where your number is not registered with Mailing Preference Service (MPS), we will ask you for specific consent. Tracing, ID verification and credit referenceLegitimate Interest Legitimate Interest Profiling & analytics Legitimate Interest Legitimate Interest relation to products or services which we trust may be interesting to you based upon information which you have supplied to us.

For all types of processing, we apply various standards to carefully protect your privacy rights. However, as with all your data you can also object to us processing your data. In this way. Your rights are details below.

For all types of processing, we apply various measures to carefully protect your privacy rights. In considering the most appropriate legal basis, FBS conduct Legitimate Interest Assessments. These are detailed evaluation 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.

COLLECTION AND USE OF YOUR PERSONAL DATA

We collect your details when you register on one of our websites. ‘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, but is not required to browse.

The categories of personal data we may collect from you upon registration of via visiting our website:

We will never collect financials information such as about your bank account or credit card details and nor will collect any sensitive information such as your medical history, religious or political beliefs.

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

We use your personal data collected via the FBS sites to:

We may 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).

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 our partners who may contact you by post, email, SMS and telephone for direct marketing purposes.

We may share your data with selected third parties for marketing communications, market research, analysis, and to profile and extend their databases by appending additional information to an existing information they may already hold on you as their customer.

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

You can change or update your communication preferences at any time

Telephone data will only be released to carefully selected partners where it has been TPS’d (see ‘Opting Out’ below). Note: if you request a call from one of our sponsors or brand partners this will override the TPS.

WHO MAY WE SHARE YOUR DATA WITH?

A: Our Group Companies and Brands

B: Groups of recipients within specific industry listed

FBS and our trusted Partners, both sponsors of the site and particular surveys, may wish to contact you based on your profile, but will only do so subject to your consent and preferences. They operate within the following industry sectors:

C: Marketing Service Providers

Marketing Service Providers are companies who collect data from Data Controllers, such as us, and help their clients tailor products and services which best suit your needs. They may also use your data for fraud prevention. The Marketing Services Providers we work with are strictly limited to only those organisations we have completed checks on and who will process your data in strict compliance with all laws, regulations and guidance about General Data Protection. We will share your data under strict licence terms with the Marketing Services Providers listed below, who like us, will use it to create products and services to help organisations better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels

The data you share with us may be transferred to a US company which is certified under the Privacy Shield.

Our partners link the personal information we share with them to cookies stored on your browser or device, which will collect information such as your IP address, browser or operating system type and version, and demographic or inferred interest information.

To understand more please click through to the website.

D. Named Clients

We will share your data with recipients who fall within industry sectors which are listed in section 5B of this privacy policy. We also supply data to the following clients, who have specifically asked to be named. All clients will use your information in line with our privacy policy for marketing purposes. This may mean that you receive advertising from them in relation to products or services which we believe are of interest to you based upon the information which you have provided us. To understand more about the products or services they offer please click through to our named clients.

E: Credit Reference and Other Agencies

We Collect your data and will 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 organisation own legitimate interest.

COMMUNICATIONS

Once you are register with ILoveMyOffers you will receive a welcome email, and regular newsletters packed with great prizes for you to win. You may also receive further emails and SMS messages describing new prizes and specific events relevant to you as a member of ILoveMyOffers.

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 IloveMyOffers 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 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 opt-out

PROFILING

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

FBS may use your information to provide to match with our client’s data so that they will better understand the characteristics of their customer common habits and pursuits. Profiling is summarizing consumer data which include lifestyles, preferences, demographics, and buying patterns. It provides additional insight into customers and to assist our customers to identify and acquire a richer apprehension of their target market, enabling relevant and tailored marketing. We do not use profiling or any of the information we hold to make automated decisions about you.

DO WE TRANSFER YOUR DATA TO OTHER COUNTRIES?

We work with suppliers such as Call Centres in the Philippines and India, who call you on our behalf to conduct our surveys under our brand names. These Call Centres act as our processors under strict instructions from ourselves. We monitor the calls they make to ensure quality is controlled and we regularly inspect their premises and check that security and data protection standards are of the highest quality. We also send data to clients who operate overseas, primarily in the United States and South Africa but under strict contract rules that ensure your personal details are only processed under the same laws that we operate under here in the UK by using one of these safeguards:

Transfer data to a non-EEA country whose data protection laws have been approved by the Europeans Commission as providing adequate protection for data subjects’ rights.

Put in place a contract with the recipient that means they must protect data to the same standards as the EEA. This is known a Model Contract Clauses.

Transfer data to organisations that are part of EU-US Privacy Shield. This imposes stronger obligations on U.S. companies to protect Europeans’ personal data. The Privacy Shield requires the U.S. to monitor and enforce more robustly and cooperate more with European Data Protection Authorities.

HOW LONG WILL WE KEEP YOUR DATA FOR?

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, FBS 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 FBS 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 the most recent engagement.

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.

INDIVIDUALS RIGHTS

A: Right to be informed – When we accumulate your data, we must inform you what are we going to make out with it primarily through this privacy policy and consent statement.

B: Right to access – You own the right to reach us in writing to request details of the data we have about you.

C: Right to Rectification – You have the right to ask us to rectify the information that we hold about you if it's inaccurate or incorrect.

D: Right to erasure – This is also known as “the right to be forgotten”. This gives you right to request your information to be removed/erasure verbally or in writing. A word of warning though, we maintain a list of the people who have asked not to be touched, we ensure that you get no further marketing from our groups or clients as a termination of this action.

E: Right to Restrict processing – You have the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that’s your wishes are repeated in the future.

F: Right to data portable –This gives you right to ask the holder of your information to transfer that information to another business. It enables you to take advantage of applications and services which can use this data to find a better deal.

G: Right to Object – You have the right to object to the processing of your information for marketing purpose and profiling for marketing uses. You likewise hold the right to ask us cease processing based on our legitimate interest, where there is no overriding justification for the processing of your information. Your rights and freedoms override our interests.

H: Rights related to automated decision-making including profiling – We don’t use automated decision-making process which would cause a potentially damaging effect you.

I: Right to withdraw consent at any time – You have right to withdraw your consent to the processing of your data at any time and we must provide you with the information to need to execute so, at the time we collect your data and each time we contact you. You can pull away the consent in the following ways.

By Emailcompliance@fusionbposervices.com

By phone – 01582 763 090 or

In Writing – The Compliance Manager/Data Protection Officer, Fusion BPO Services Ltd, Suite 140, Westlink House, 981 Great West Road, Brentford, TW8 9DN

J: Right to lodge a complaint – If we cannot deal with your compliant to your satisfaction you have right to complain to a relevant supervisory authority which include.

DO WE COLLECT DATA FROM OTHER SOURCES?

In order to keep consumer records as up to date as possible we use third party products to help us verify and suppress data. We use a product called Experian QAS, supplied by Experian PLC, which uses the Electoral Roll and details given by multiple companies to collate and re-verify consumer information. We also match your data against industry suppression files; Telephone Preference Service (TPS) and Mailing Preference Service (MPS). Managed by the Direct Marketing Association (UK) Ltd, these are central registers of individual’s 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

FBS do use 3rd parties to supply data subject personal information to us this includes when data controller supply us with information where you have have completed a survey either online or telephone where a FBS brands is named on the controller privacy policy as a company with whom they share information.

POLICY CHANGE

We reserve the right to add to or amend this privacy policy at our sole discretion. Please review our privacy policy on a regular basis to make sure you have read the latest version and you understand what we do with your personal information. Your continued use of our services or our web sites following the posting of changes to these terms means that you consent to those changes

Last updated, 17th Feb 2021, in accordance with the requirements of the General Data Protection Regulation (GDPR) and Data Protection Act 2018

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