PRIVACY POLICY

We are careful and do not use consent light-hearted as a legitimate ground for processing personal data as a one-size-fits-all solution. We adopted all the measures that are legally required for its work in commercial intermediation in digital marketing and, more specifically, in the field of protection of personal data.

We are MPP Media Pay Plus Ltd, registed at Arch. Makario III, 161; 5th Floor/ Office 5; 3027 Limassol, Cyprus. MPP commits to protect its customers’ and partners’ personal data as carefully as possible. This privacy policy is intended for achieving transparency about the way personal data are processed and stored for (direct) marketing purposes. MPP will adhere to and respects the requirements of the General Data Protection Regulation 2016/679 and as well the Privacy and Electronic Communications Regulations (PECR). MPP handles everyone’s privacy carefully. In order to do so, MPP adheres to privacy legislation, as stipulated in this section, in addition to legal standards which are dictated by approved codes of conduct. MPP complies with the requirements of the current UK Data Protection Act 2018 and other applicable privacy legislation for an accurate processing of personal data. The party responsible for data processing (Controller) is MPP, with ICO registration number ZA529743.

Consent
In accordance with our data processing operations we have checked if your consent is the most appropriate basis for processing. We ask our customers and respondents to positively opt-in prior to any start of the processing. The request for consent to you is made prominent and separate from any conditions that may apply to the promotions you have participated. Your consent is (also) used to administer the campaigns you are interested in. If you withdraw consent you contact data is blocked until you have given your consent again. Any given consent is never made on a default mode. We keep a record of when and how we received your consent on an individual identifiable basis. We also keep a record of exactly what you were shown or told at the time of participating to the campaign.

Should you have questions about the campaign to which you participated in, then please contact our Data Protection Officer at [email protected] who can reply to you directly for any question or concern you may have.

We would like to specify to you why we process data and what we’re going to do with it, for which purposes data are going to be used and further processed.

Consent or withdraw
We give individual options to consent or positively opt-in to different purposes and types of processing. We name our organisation and any third party controllers who will be relying on the consent at the moment of collecting your data. We inform our customers and respondents that they can withdraw or refuse their consent without detriment. We perform on withdrawals of consent as soon as we can and direct our customers and respondents how to do so. In offering online communication directly to our customers and respondents we seek consent in accordance with and necessary for the purposes of our data processing operations and our relation with you. We have age-verification measures (and parental-consent measures for younger children) in place to avoid that children (below 12) and youngsters (12-18) can participate to our services.

Principles
Under the Directive 95/46/EC we already worked with the principles for processing. These principles continue to be in effect, and relate to:
• Lawfulness, fairness and transparency;
• Purpose limitation and compatible use;
• Data minimisation;
• Accuracy;
• Storage limitation;
• Integrity and confidentiality; and
• Accountability (the controller shall be responsible for, and be able to demonstrate compliance).

Categories of data
The categories of personal data which are necessary to provide the services are:
• the customer’s and respondent’s first and surname, title, gender, date of birth, address, postcode, place of residence and similar data required for communication by the person concerned.
• contact data such as (mobile) telephone number and email address.
• consent data including name, surname, e-mail address, IP adres and copy of campaign materials.
• preferences or (confirmed) opt-in requests how to be contacted via email, mobile phone number and sms or mms.
• opt-out request not to be contacted for marketing purposes at all.
• preferences for different kinds of promotions, goods or services.
• prize winner data, including photo of the prize winner when disclosed.
• further information requests and/or contact history.

Sectors
The sectors, in which data are processed in the UK, and accordingly in line with this privacy policy, are:
Charity, Media, Telecoms, Telecommunication, Utilities, Mobility, Home Improvements, Broadcaster, TV, Wills, Funeral Plan, Retail, Automotive, Shopping, Beauty and health, Cosmetics, Insurance products, Financial services (only contact data), Travel, Leisure, Sports, Games, Trivia, SMS and mobile service providers, and partners such as Aura Media, Solar, Air Source Heat Pumps.
These categories of personal data and partners are processed for purposes which are based on your consent.
We may also share your details with identity verification organisations which help other organizations verify your identity and prevent others from misusing your details. Advertising – providing offers that are relevant to you. This may involve data analysis, matching, profiling and predicting behaviours so you may receive advertising that is more relevant to you.
We may share your contact information.
We may share your personal information with our partner WINR Data (WINR) and their global partners for the purposes of:
Fraud Prevention – preventing others from misusing your personal information. This may involve identity verification for anti-fraud, anti-money laundering, anti-crime, asset recovery, debt collection and reuniting individuals with unclaimed assets; and
Digital Advertising – providing personalised advertising and content that is relevant to you. This may involve identity resolution for data analysis, matching and linkage.
WINR and their global partners will process and retain your personal information for as long as necessary for these specific purposes and on the lawful basis of consent and/or legitimate interests.
You can submit a request to exercise any of your privacy rights to the Data Protection Officer at WINR https://www.winrdata.com/privacy-policy/
Monetise Media Ltd and their clients. Links are: https://monetise.co.uk/ https://www.monetise.co.uk/privacy-policy/ https://www.monetise.com

Legitimate interests
Legitimate interests are used as a ground for data processing in accordance with the laws, regulations and the preferences of the partners we work with. The legitimate interests are our own interests and the (commercial, legitimate) interests to provide you with own offers or offers of this parties which you would like to receive (common, legitimate interests). The promotions contain not only offers which benefit our customers’ and respondents’ contact preferences (see above) but also apply to educate you about discount offers and for that purpose sending the correct email and sms on the right moment. In order to balance the commercial interests with your privacy preferences we never collect or ask for more data than is necessary for a proper operational performance of our online communication.