CINXE.COM

<html> <head> <link rel="preconnect" href="https://fonts.googleapis.com"> <link rel="preconnect" href="https://fonts.gstatic.com" crossorigin> <link href="https://fonts.googleapis.com/css2?family=Montserrat:ital,wght@0,100..900;1,100..900&display=swap" rel="stylesheet"> <style> body {font-family: 'Montserrat';color: #0F0F4B;} h1 {color: #8264C8; font-size: 2rem;} h2 {color: #FF00A5; font-size: 1.5rem; padding-left: 5px;} h3 {color: #00C8C8; font-size: 1.2rem; padding-left: 10px;} h4 {color: #8264C8; font-size: 1rem; padding-left: 15px;} p {color: #0F0F4B;} table {width: 100%;} table, th, td {font-size: 1rem; border: 1px solid; border-collapse: collapse; vertical-align: top;} </style> </head> <body> <title>OUR PRIVACY POLICY</title> <h1>OUR PRIVACY POLICY</h1> Effective 1 September 2024 OUR PRIVACY PROMISE Our priority is building trust with our customers. As part of this we are fully committed to respecting our customers’ privacy and ensuring that their data is secure at all stages of their journey with us. The purpose of this document (“Policy”) is to let you - as one of our customers - know about how your data is being handled by us when you visit or use our sites, so that you can feel confident using our services from day one. <h3>Who we are </h3> When you use our services, Marketing VF Ltd (“MVF” or “we”), acts as a ‘data controller’ (i.e. a company that is responsible for protecting your privacy). We are registered as a ‘data controller’ with the UK’s supervisory authority, the Information Commissioner’s Office (ICO), under registration number Z1995728. You can confirm our registration on the ICO’s website <a href="https://ico.org.uk/ESDWebPages/Entry/Z1995728">here</a>. See the <a href="#exercise_rights">“How to exercise your rights and contact us”</a> section below for our contact details. <h3>Our brands </h3> We operate under a number of different brands, including: Approved Index, Clear Living, Clinic Compare, The Eco Experts, Expert Market, ExpertsinMoney, Expert Reviews, GoWizard, Hear Clear, Inspire Digital, Lasik Eyes, MoveHub, ProFind, Startups, Survey Compare, Tech.co, The Prep, The Inside Lane, Mint Pillow, The Roadmap, The Level, The Net Gains, The SKUpe, Raise the Bar, Dental Bite, EduCompare, CompareCardServices and WebsiteBuilderExpert. While it is likely that you will be more familiar with these brands, as these are the names our sites operate under, this Policy will refer to ‘MVF’. <h3>Your data rights </h3> Did you know that, by law, you have certain rights in relation to your data? These include the right to revoke your consent and the right to object to direct marketing at any time. You may exercise any of these rights via <a href="https://preferences.safe-click.net/">Your Privacy Choices</a>. <hr> <h2>NAVIGATING OUR POLICY</h2> To make it easier for you to navigate our Policy, we have numbered each of the sections, as listed below. This will allow you to quickly scroll or skip to the sections that you want to know more about. <ol> <li><a href="#our_services">OUR SERVICES</a></li> <li><a href="#how_sites_work">HOW OUR SITES WORK</a></li> <li><a href="#what_info">WHAT INFORMATION WE COLLECT & HOW WE USE IT</a></li> <li><a href="#phone_numbers">HOW YOUR TELEPHONE PHONE NUMBER IS USED WHEN WE COMMUNICATE WITH YOU BY PHONE OR SMS MESSAGE</a></li> <li><a href="#data_sharing">SHARING YOUR DATA</a></li> <li><a href="#cookies">COOKIES & EVENT TRACKING</a></li> <li><a href="#data_storing">STORING YOUR DATA</a></li> <li><a href="#data_rights">YOUR DATA RIGHTS</a></li> <li><a href="#data_transfer">TRANSFERRING YOUR DATA</a></li> <li><a href="#exercise_rights">HOW TO EXERCISE YOUR RIGHTS & CONTACT US</a></li> <li><a href="#us_customers">ADDITIONAL PRIVACY NOTICE FOR US CUSTOMERS</a></li> <li><a href="#info_security">SECURING YOUR INFORMATION</a></li> <li><a href="#policy_changes">CHANGES TO THIS POLICY</a></li></ol> <ol> <h3><a id=our_services><li>OUR SERVICES</a> </h3> Depending on which of our sites you are visiting, MVF offers a number of different services. When you are on our sites, it should always be clear which service applies to you. <ul> <li>Requests for quotes or information - We endeavour to put our customers in contact with relevant providers (“Suppliers”) of a product or service (“Product”) that they are interested in. The request could be in order to receive a quote, further information or to book an initial consultation or appointment. </li> <li>Earning opportunities - We enable our customers to find and participate in online surveys and other earning opportunities (“Offers”) with market research companies (also referred to as “Suppliers”).</li> <li>Editorial content - Our writers create useful Product reviews, articles and newsletters to help our readers make informed decisions as to the Products they wish to enquire about, purchase or trial, or the Offers they wish to sign up to. </li> <li>Competitions, prize draws and events - From time to time, we run competitions, prize draws and events.</li> <li>News and insights - Our news and insights provide our customers with industry updates, product and service recommendations, exclusive offers, and the latest news on relevant brands and sectors.</li> <li>User research - We may offer customers the opportunity to participate in research or studies aimed at improving our customers' experience with our products and services. </li></ul> <h3><a id=how_sites_work><li> HOW OUR SITES WORK</a></h3> Our aspiration is to help our customers make easier buying decisions and to connect them with relevant Suppliers at a click of a button. Our services are obligation-free so whether or not you go on to purchase or trial a Product, book an appointment or sign up to any Offer, the decision is entirely yours! Unless you are on our site just to read more about a Product or Offer (in which case, please read on), our services generally rely on our customers to submit information to us via a webform. If you choose to submit a webform with us, we’ll do our best to connect you with one or more relevant Suppliers as follows: <ul> <li>Requests for quotes or information - when you complete and submit our webforms, we will share this information with relevant Suppliers. We’ll tell them who you are and your Product requirements (based on the information you have provided to us) and, depending on your request, they’ll then follow up with you directly by phone, email or SMS message. For certain Products, before connecting you with relevant Suppliers, we may call you to confirm your details or requirements or, if you have requested an appointment, to book an appointment. Our sites may also give you the option to click out directly to a Supplier’s website or to call the Supplier directly.</li> <li>News and Insights - When you register to receive our news and insights, we will periodically contact you with the latest updates and offers. If you sign up to download or receive insights from our Suppliers, we will share your information with the relevant Suppliers. This includes your name, email address, phone number and Product interests, based on the details you've provided. Based on your preferences, the Supplier may contact you directly via phone, email, or SMS.</li> <li>Earning opportunities - when you complete and submit our webform, our sign-up process will ask you to select the specific Offers that you would like to participate in. Once you have submitted the webform, you will receive a confirmation email for each Offer that you expressly selected. The email will come from us, or from the Supplier that you selected, and it will ask you to confirm your choice by clicking on a link. If you still wish to participate in the Offer, then simply click on the link, which will take you through to the Supplier’s website. You will also receive a general email from us welcoming you to our survey-keen community!</li></ul> <h4>RECEIVING MARKETING MESSAGES</h4> We enjoy regularly updating our customers about other Products and Offers that might be of interest to them. This means that we may email or SMS message you about similar Products or Offers to your initial request, unless you opt-out of receiving such marketing messages. You can change whether or not you receive these messages at any time through <a href="https://preferences.safe-click.net/">Your Privacy Choices</a>. You also have the following options: <ul> <li>To opt-out of emails - You can click on the unsubscribe link in an email</li> <li>To opt-out of SMS messages - You can text “STOP” in response to the SMS message</li></ul> From time to time, we may also ask to send you browser notifications via a pop up box when you visit our sites (e.g. at the end of a webform). If you allow these notifications, you will receive regular messages from us about great offers, top tips, popular guides and more information about each Supplier. All our messages give you the option to unsubscribe by clicking on the notification settings and selecting 'Disable Notifications'. For additional information about our use of telephone numbers for SMS communications, see section below, <a href="#phone_numbers">‘HOW YOUR TELEPHONE PHONE NUMBER IS USED WHEN WE CONTACT YOU BY PHONE CALL OR SMS MESSAGE’.</a> <h3><a id=what_info><li>WHAT INFORMATION WE COLLECT & HOW WE USE IT</a></li></h3> If you visit our sites and use our services, we may collect certain information about you. We want you to understand: <ul> <li>What information we collect and how we collect it</li> <li>Why we collect your information (i.e. what do we use it for and who we may share it with)</li> <li>What lawful basis we rely on to collect your information</li></ul> The tables below explain this in more detail. <ol start="1"> <li>Contact details (e.g. name, email address, telephone number, postal code) and Product requirements</li></ol> <table> <tbody> <tr> <td colspan="1" rowspan="1"> How we collect it</td> <td colspan="1" rowspan="1"> Why we collect it</td> <td colspan="1" rowspan="1"> Lawful Basis</td></tr> <tr> <td colspan="1" rowspan="7"> <ul> <li>When you click to submit our webforms</li> <li>When you submit your details via a pop-up box on our sites)</li> <li>If we call you after your submission</li></ul> </td> <td colspan="1" rowspan="1"> Products and Offers <ul> <li>To connect you with relevant Suppliers</li> <li>To confirm your details or requirements </li> <li>To book an appointment</li> <li>To email or SMS message you with more information about the Products that you have shown an interest in</li></ul></td> <td colspan="1" rowspan="1"> Consent - You will see on our webforms that we have a really clear consent statement. This statement sets out the Suppliers that will contact you. You may revoke your consent at any time</td></tr> <tr> <td colspan="1" rowspan="1"> Similar Products and Offers To email or SMS message you about similar Products</td> <td colspan="1" rowspan="1"> Consent - You may revoke your consent at any time. You also have the right to object to direct marketing. In some countries, we send such marketing messages on the basis of an existing customer exemption. In these instances we may send such messages only if you have not opted out of receiving them </td></tr> <tr> <td colspan="1" rowspan="1"> Automated decision-making Before we pass your request to any Suppliers, our service may involve an element of automated decision-making. Our technology platform may automatically assess your Product requirements and pass your request to such Suppliers that would like to receive requests at the time your request is made.</td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> Verification To verify that your submission is genuine (i.e. submitted by a real human). We may work with 3rd parties (e.g. Contact State) to carry out the verification. You can find out more about how Contact State uses this data <a href="https://www.contactstate.com/legal/prospect-notice">here</a>.</td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> Customer Services For customer service purposes. For example: <ul> <li>to request feedback about your experience using our sites and services, and dealing with the Suppliers with which we connected you</li> <li>to respond to other enquiries or requests that you direct to us</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> Marketing <ul> <li>To create custom or look alike audiences (see section 4 for more detail).</li> <li>To identify customer trends in order to better understand which of our customers are engaging with our services</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> Data Enrichment <ul> <li>To enhance our understanding of the services you require, we may match certain business-related data that you provide us with the corresponding data held by third parties.</li> <li>Those third parties may share additional data with us to improve how we engage with you and carry out segmentation of our customers. </li></ul> </td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> When you enter your postal code or ZIP code on our webform </td> <td colspan="1" rowspan="1"> Products and Offers To display appointment locations available in your area</td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests </td></tr> <tr> <td colspan="1" rowspan="1"> If you partially fill out our webform but do not submit it</td> <td colspan="1" rowspan="1"> Products and Offers To email you to see if you’re still interested in the Product or Offer</td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> When you create an account</td> <td colspan="1" rowspan="1"> Managing your account To create and manage your account</td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> When you sign up to our events, awards, competitions, prize draws or surveys</td> <td colspan="1" rowspan="1"> Events <ul> <li>If you enter an event or award (e.g. the annual Startups Awards, Startups 100 and Young Guns), to run the event or award and contact you in respect of the same where you have submitted an application (e.g. to send out event details)</li></ul> Competitions and Prize Draws <ul> <li>If you enter a competition or prize draw on our site, to run the competition or prize draw, or contact you regarding your entry.</li> <li>Where we are running a competition or prize draw jointly with another party, or promoting one on behalf of another party, we may share your entry details with that party, but only for the purposes of managing the competition or prize draw.</li></ul> Surveys <ul> <li>To analyse survey results</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> When you join our mailing lists to receive newsletters, guides, whitepapers, e-books etc. as advertised on our sites</td> <td colspan="1" rowspan="1"> Mailing Lists <ul> <li>To send you such content.</li> <li>If you have consented to receiving emails from named third-parties, we will pass your email address to those parties so they can email you. We may also send you emails on behalf of such third parties.</li></ul></td> <td colspan="1" rowspan="1"> Consent - You may revoke your consent at any time</td></tr> <tr> <td colspan="1" rowspan="1"> When you post reviews or comments on our sites</td> <td colspan="1" rowspan="1"> Reviews and Comments To publish or respond to reviews and comments left on our sites</td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> When you submit a sign up form to participate in our research or study</td> <td colspan="1" rowspan="1"> User Research To ensure that our study includes a representative group of people.</td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> We may receive data from our third party data suppliers </td> <td colspan="1" rowspan="1"> Products and Offers To contact you about our Products, Offers, news and insights</td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests </td></tr></tbody></table> <ol start="2"> <li>Sensitive Information (e.g. medical conditions and other information about your health) - We will only collect this information if you are using our services in relation to health Products.</li></ol> <table> <tbody> <tr> <td colspan="1" rowspan="1"> How we collect it</td> <td colspan="1" rowspan="1"> Why we collect it</td> <td colspan="1" rowspan="1"> Lawful Basis</td></tr> <tr> <td colspan="1" rowspan="1"> <ul> <li>When you click to submit our webforms for health Products</li> <li>If we call you after your submission to confirm your health Product requirements</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>To assess which health Supplier to connect you with</li></ul></td> <td colspan="1" rowspan="1"> Consent - You may revoke your consent at any time </td></tr></tbody></table> <ol start="3"> <li>IP address (this is a unique number associated with a computer or device, which enables it to communicate with other computers and devices over the Internet), other online identifiers, geolocation, device specification</li></ol> <table> <tbody> <tr> <td colspan="1" rowspan="1"> How we collect it</td> <td colspan="1" rowspan="1"> Why we collect it</td> <td colspan="1" rowspan="1"> Lawful Basis</td></tr> <tr> <td colspan="1" rowspan="1"> <ul> <li>When you click on our ads (e.g. on Google, Facebook, TikTok etc)</li> <li>When you interact with our sites by clicking on any links</li> <li>When you click to submit a webform</li> <li>When you click on links in emails or SMS messages we send you</li></ul> </td> <td colspan="1" rowspan="1"> Verification <ul> <li>To stop unwanted traffic (i.e. spam and fraudulent visitors) to our site. </li> <li>To verify with our Suppliers that a request has been submitted by you and not by someone else</li> <li>To verify with our Suppliers that you have consented to being contacted by us and them</li> <li>To verify that your request has come from a particular country, state or region</li></ul> <ul> <li>To identify if you have submitted a duplicate request</li> <li>To identify that your request has originated from our sites</li></ul> Marketing <ul> <li>To personalise ads to suit you based on your location. We may use a third party to assist us with identifying the IP address location parameters.</li></ul> Products and Offers <ul> <li>To display appointment locations available in your area</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr></tbody></table> <ol start="4"> <li>Event Data (e.g. user agent, IP address, country, language, and browser/app used) - We may use third party device data collection tools and similar tracking technologies (that sit behind our ads and sites) to collect such data</li></ol> <table> <tbody> <tr> <td colspan="1" rowspan="1"> How we collect it</td> <td colspan="1" rowspan="1"> Why we collect it</td> <td colspan="1" rowspan="1"> Lawful Basis</td></tr> <tr> <td colspan="1" rowspan="1"> If you interact with our ads on one of our advertising partners’ platforms (e.g. Facebook, TikTok, and LinkedIn)</td> <td colspan="1" rowspan="1"> <ul> <li>For marketing attribution purposes (i.e. to better understand how you interact with our content and track the relevance of our marketing campaigns to your interests) </li> <li>For measuring and reporting on the performance of our ad campaigns</li> <li>For ad targeting (but only if you haven’t opted out)</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr></tbody></table> In relation to Event Data that we share with TikTok for the purposes set out above, both MVF and TikTok are joint data controllers. For any subsequent processing TikTok will be an independent controller. <ul> <li>To find out more about how TikTok uses your data, you can visit their privacy notice <a href="https://www.tiktok.com/legal/page/eea/new-privacy-policy/en">here</a>. </li> <li>MVF has an agreement with TikTok that determines our respective data responsibilities as joint controllers (including that we have agreed to provide to you with the information set out above and that TikTok is responsible for enabling you to exercise your rights with regard to your personal information stored or otherwise processed by TikTok after the joint processing.)</li></ul> <ol start="5"> <li>Audio and Video Call recordings (Please be aware that sensitive personal information may be recorded where you voluntarily disclose health information to us over the phone)</li></ol> <table> <tbody> <tr> <td colspan="1" rowspan="1"> How we collect it</td> <td colspan="1" rowspan="1"> Why we collect it</td> <td colspan="1" rowspan="1"> Lawful Basis</td></tr> <tr> <td colspan="1" rowspan="1"> <ul> <li>If we call you after your submission to confirm your details and Product requirements</li> <li>If we call you after you have used our service to ask for service feedback</li></ul> </td> <td colspan="1" rowspan="1"> <ul> <li>We digitally monitor and/or record calls between you and us for the purposes of quality control and staff training </li> <li>Occasionally, we may need to provide Suppliers with limited access to such recordings in order to resolve disputes</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> <ul> <li>If you are selected to participate in our research or study video or audio session </li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>We capture video and audio recordings of our user research sessions for reference purposes</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr></tbody></table> <ol start="6"> <li>Disposition data (i.e. information on whether or you have purchased a Product or signed up to an Offer with one of our Suppliers)</li></ol> <table> <tbody> <tr> <td colspan="1" rowspan="1"> How we collect it</td> <td colspan="1" rowspan="1"> Why we collect it</td> <td colspan="1" rowspan="1"> Lawful Basis</td></tr> <tr> <td colspan="1" rowspan="3"> We may receive data (including health data) back from our Suppliers</td> <td colspan="1" rowspan="1"> <ul> <li>To handle a Supplier query regarding a request sent to them or an enquiry that we have sent to them in order to enable us to resolve the query</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> <ul> <li>To enable us to improve our marketing</li> <li>To identify customer trends in order to better understand which of our customers are engaging with our services</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr> <tr> <td colspan="1" rowspan="1"> <ul> <li>To create custom/look alike audiences (see more section 4 for more detail).</li></ul></td> <td colspan="1" rowspan="1"> Legitimate interests - You have the right to object to processing based on legitimate interests</td></tr></tbody></table> <h3><li><a id=phone_numbers>HOW YOUR TELEPHONE PHONE NUMBER IS USED WHEN WE COMMUNICATE WITH YOU BY PHONE OR SMS MESSAGE</a></li></h3> When you provide your telephone number to us through one of our webforms, we may use that number to reach out to you directly, whether by giving you a call and/or sending you an SMS message. We do so in order to : <ul><li>confirm the details of your requirements</li> <li>to book an appointment with one of the Suppliers that you’ve matched with</li> <li>to respond to other enquiries or requests that you direct to us</li> <li>to talk to you about other similar Products that may be of interest to you</li> <li>to request feedback from you about your experience using our sites and services, and dealing with the Suppliers that we connected you with</li></ul> When we contact you using the telephone number you provide, we do so using our telephone system management platform, and a customer service representative will speak to you directly. Our telephone system management platform does not generate or dial random or sequential numbers and requires manual selection by our customer service representative. It is our practice to only reach out to you at sociable hours in compliance with law, using our customer service designated number. If we inadvertently contact you outside of sociable hours, please notify us using the information below so that we may correct the error going forward. We will not call you using technologies that are considered automatic telephone dialling systems or with an automated recorded voice message. In all cases, we will only reach out to you because you’ve filled out one of our webforms looking to receive matches and/or quotes for the Products that you’re looking to receive or if you have otherwise requested a call. For SMS messages, Message and Data rates may apply. You can opt-out of SMS communications by replying “STOP.” <h3><li><a id=data_sharing>SHARING YOUR DATA</a></li></h3> In providing our services to you, and to ensure that we are able to provide you with a good customer experience, we may share your data with third parties. We work with the following categories of third parties: <ul> <li>Suppliers - The Suppliers that we connect you with and who contact you in relation to the Products or Offers. As explained above, if you submit our webform, we’ll pass your request to one or more relevant Suppliers (named on the consent statement). We will do this in a secure way e.g. using HTTP Secure (HTTPS), which means the data is encrypted. If you have expressed an interest in a financial Product, some Suppliers may pass your data to third-party credit check agencies as part of your application but you will be made aware of this in the consent statement. </li></ul> <ul> <li>Advertising platforms - We work with a number of companies (e.g. social media platforms and search engines) through which we run our marketing campaigns and reach new potential customers. In fact, this could be one of the ways in which you found out about our site! We may share data with these companies to monitor how our campaigns are performing or to reach new audiences who might benefit from our services (see our explanation of ‘customer and lookalike audiences’ below). </li></ul> <ul> <li>Trustpilot - We work with Trustpilot to gather reviews from our customers. If you post a review of us on Trustpilot by clicking through the Trustpilot link on our pages, we share your name and email address with Trustpilot in order to enable them to set up an account for you to post the review, and to verify your review as genuine.</li></ul> <ul> <li>Service providers who process data on our behalf - There are some companies who we engage to (i) provide a service essential to running our business (e.g. cloud storage providers, email service providers and cloud telephony providers) or (ii) provide analytics and consultancy services. We share data with these companies in order to provide our services to you as best we can.</li></ul> In each case, we have appropriate contracts in place with these companies and Suppliers to ensure the protection and confidentiality of your information. Custom and lookalike audiences We like to work with Facebook, Google, TikTok and other platforms (“Platforms”) to reach out to you with adverts for other Products that you might be interested in. We also like to use Platforms to reach out to other people who might like to use our service. We do this in two ways. In both cases, your information, along with other information, is used to create a custom audience and/or a lookalike audience. Whenever an audience is shared with a Platform, the data is first hashed and pseudonymised, meaning that any data within the audience that could identify a person is replaced with an artificial identifier. So, the process is secure. Also, we don’t share more data than we need to for the purpose of creating the audience. <ul> <li>Custom audience – A custom audience is a list of our existing customers. From time to time, we share this with Platforms. As explained above, the data is first hashed and pseudonymised. The Platform uses this audience to show our customers our adverts for other Products that they might be interested in.</li> <li>Lookalike audience – A lookalike audience is an audience created by the Platform. From time to time, we share with Platforms a list of customers. The Platform uses this list to find and create lookalikes – i.e. other Platform users who have similar characteristics to the customers – to which it shows our adverts. Again, as explained above, the data is first hashed and pseudonymised.</li></ul> Sharing calls On occasion, we may pass calls to local police enforcement when necessary under the lawful basis of protecting the vital interests (e.g. the life or safety) of the individual involved. <h3><li><a id=cookies>COOKIES and EVENT TRACKING</a></li></h3> Cookies A cookie is a small text file that is placed on your computer by a website that you visit. They 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. Web browsers generally allow you to control cookies through the browser settings and you can clear your cookies at any time. We use cookies on our sites. To find out more about the cookies we use (including the purposes for which we use them) and to manage your cookie settings, visit our cookies preference centre via the 'Cookies Settings' button found on our sites. Event Tracking We may use click identifiers (i.e. a random unique sequence of letters and numbers) or hashing techniques for marketing attribution purposes, to identify new and returning visitors on our sites, or for other event tracking purposes. Unlike the use of cookies, these techniques do not use any technology to store data on your device. These techniques rely on data voluntarily provided or supported by your browser (e.g. user agent string, IP address etc) and we will never attempt to use them to circumvent the browser or request excessive data about your device. <h3><li><a id=data_storing>STORING YOUR DATA</a></li></h3> We will only hold your information for as long as we need to in order to fulfil the purposes for which it was collected in the first place, as set out in this Policy. Specifically: <ul> <li>We will keep the information we collect from you (as detailed in section 3) for 4 years after your webform submission to enable us to resolve any disputes or queries from Suppliers and as recommended or required by applicable data protection laws.</li> <li>If you haven’t opted out of receiving marketing from us, we will keep your details, and send you emails, until such time as you don’t engage with our emails for a period of 6 consecutive months.</li> <li>We will only store data inputted by you in a partially completed webform for 24 hours from when you leave the webform, subject to an automatic back-up of that data being made and stored for 30 days from the date you partially completed our form. Such back-up will not be readily accessible by us and your data will not be used for any other purpose.</li> <li>If you are selected to participate in our user study, we may retain your personal information for as long as it is necessary (but no longer than 2 years) for our research purposes. If you are not selected to participate in our study, we will delete your information within 1 month.</li></ul> <h3><li><a id=data_rights>YOUR DATA RIGHTS</a></li></h3> Do you know, you have a number of data rights, which will be determined by the country in which you reside. We have set these out for you in the tables below. To exercise any of your data rights, you can contact us via the details set out in the ‘HOW TO EXERCISE YOUR RIGHTS and CONTACT US’ section of this Policy. <ol type="A"> <li>The European Economic Area (“EEA”) / United Kingdom (“UK”)</li> If you reside in the EEA or the UK, you have certain rights under the GDPR and UK GDPR in relation to your information. In relation to our site, and the service that we provide, those rights are as follows: <table> <tbody> <tr> <td colspan="1" rowspan="1"> Right to be informed</td> <td colspan="1" rowspan="1"> You have the right to be informed about how we collect and use your personal information. That’s the aim of this Policy! </td></tr> <tr> <td colspan="1" rowspan="1"> Right of access </td> <td colspan="1" rowspan="1"> You have the right to ask us for a copy of the personal information we hold about you, and to check that we are lawfully processing it.</td></tr> <tr> <td colspan="1" rowspan="1"> Right of rectification</td> <td colspan="1" rowspan="1"> If personal information that we hold about you is inaccurate or out-of-date and requires correction, you have a right to have the data rectified or completed.</td></tr> <tr> <td colspan="1" rowspan="1"> Right of erasure</td> <td colspan="1" rowspan="1"> In certain circumstances, you have the right to request that personal information we hold about you is deleted (e.g. if the information is no longer necessary for the purposes for which it was collected or processed).</td></tr> <tr> <td colspan="1" rowspan="1"> Right to restrict processing</td> <td colspan="1" rowspan="1"> In certain circumstances, you have the right to request the restriction or suppression of your personal information.</td></tr> <tr> <td colspan="1" rowspan="1"> Right of data portability</td> <td colspan="1" rowspan="1"> In certain circumstances, you have the right to obtain (in a structured, commonly used and machine-readable format) and reuse your personal information for your own purposes across different services. </td></tr> <tr> <td colspan="1" rowspan="1"> Right to object</td> <td colspan="1" rowspan="1"> You have the right to object to our processing of your personal information. This includes the right to object to direct marketing. </td></tr> <tr> <td colspan="1" rowspan="1"> Right to withdraw consent</td> <td colspan="1" rowspan="1"> Where you may have provided your consent to our collection, processing and transfer of your personal information (e.g. to Suppliers), you have the right to withdraw your consent at any time. You can exercise this right by managing <a href="https://preferences.safe-click.net/">Your Privacy Choices</a>.</td></tr></tbody></table> <li>US Customers</li></ol> If you are a US customer (i.e. if you reside in the United States on more than a temporary basis), you will benefit from the consumer data rights afforded to you by the local State Laws. These may include the right to have your personal information deleted, and the right to object to your personal information being ‘sold’ to third-parties. For more information, see the section below titled ‘ADDITIONAL PRIVACY NOTICE FOR US CUSTOMERS’. <h3><li><a id=data_transfer>TRANSFERRING YOUR DATA</a></li></h3> There may be instances where we need to transfer your information outside the UK. For example, where you are using our services outside of the UK, we may need to transfer your information outside the UK. As of 1 January 2021, the UK is no longer a part of the EEA. Although the UK is no longer part of the EEA, we will still hold your data to the same level of protection as we did when we were part of the EEA. This means that for any transfer of your data outside of the UK, we will continue to take steps to ensure that it is protected to the same level of protection that applies to transfers of data outside of the EEA. Certain countries have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection and we will continue to only transfer data to those countries on this basis. Other countries do not have the same level of legal protection as countries in the EEA, or with an adequacy decision. If we do transfer your data in this way, we will take steps to ensure that it is protected to the same levels that apply in the EEA. This may include, for example, adopting the EU’s standard contractual clauses. <h3><li><a id=exercise_rights>HOW TO EXERCISE YOUR RIGHTS and CONTACT US</a></li></h3> There are 3 ways in which you can contact us and exercise your rights as explained in this Policy: <ol start="1"> <li>Via “Your Privacy Choices” - this is an easy-to-use portal through which you can withdraw your consent to being contacted by us and Suppliers at any time. A link can be found <a href="https://preferences.safe-click.net/">here</a>.</li> <li>Via email - our data protection team is on hand Monday to Friday to answer your data questions and action your requests. Please email us at <a href="mailto:dataprotection@mvfglobal.com">dataprotection@mvfglobal.com</a> and we will try to respond to you or action your request as soon as we can. For user research, please email us at <a href="mailto:user.research@mvfglobal.com">user.research@mvfglobal.com</a> , including your full name and study details (e.g. date and time) where applicable.</li> <li>Via post - you can also write to us at our registered office address: 1st and 2nd Floors, Wenlock Works, 1A Shepherdess Walk, London, N1 7QE, United Kingdom.</li> <li>Via phone - if you are based in the United States, you can call us at the following toll-free number +18558180062.</li></ol> Our lead supervisory authority for the processing set out in this Policy is the UK Information Commissioner’s Office (ICO). If you are unhappy with how we have processed your data, you have the right to make a complaint to the ICO. If you are based outside of the UK, or you have a complaint concerning our activities outside of the UK, you may prefer to lodge a complaint with a different Supervisory Authority. A list of relevant authorities can be accessed <a href="http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080">here</a>. Our EU Representative We have appointed an EU representative based in the Netherlands. The details of our EU representative are as follows: Software Vergelijken B.V. located at Heresingel 4B, 9711 ES Groningen, Netherlands. If you are based in the EU and have any questions regarding this Privacy Policy, or any questions relating to data protection or privacy, you can contact our EU representative directly at <a href="mailto:dataprotection@mvfglobal.com">dataprotection@mvfglobal.com</a>. <h3><li><a id=us_customers>ADDITIONAL PRIVACY NOTICE FOR US CUSTOMERS</a></li></h3> This section of our Policy applies to customers who are residents of the below US states, in compliance with local state laws (“State Laws”): <ul> <li>California - California Consumer Privacy Act and California Privacy Rights Act</li> <li>Virginia - Virginia Consumer Data Protection Act</li> <li>Colorado - Colorado Privacy Act</li> <li>Connecticut - Connecticut Data Privacy Act</li> <li>Utah - Utah Consumer Privacy Act</li> <li>Texas - Texas Data and Privacy Act</li> <li>Oregon - Oregon Consumer Data Privacy Act</li> <li>Montana - Montana Consumer Data Privacy Act</li></ul> <h4>Information we collect</h4> When US customers visit our sites, we may collect certain personal information about them. The table below explains what personal information we collected in the preceding twelve months since the section of this Policy was last updated, and how we used, disclosed, sold or shared (for cross-context behavioural advertising purposes) it, broken down by categories. <table> <tbody> <tr> <td colspan="1" rowspan="1"> Category</td> <td colspan="1" rowspan="1"> Fields</td> <td colspan="1" rowspan="1"> How we used it</td> <td colspan="1" rowspan="1"> Who we disclosed it to</td> <td colspan="1" rowspan="1"> Who we sold or shared it with</td></tr> <tr> <td colspan="1" rowspan="1"> A. Identifiers</td> <td colspan="1" rowspan="1"> <ul> <li>First and last name</li> <li>Email address</li> <li>Telephone number</li> <li>Postal address</li> <li>IP address</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>As per section 3(A) of this Policy</li> <li>The process of connecting you with relevant Suppliers may involve an element of automated decision making</li> <li>To create custom/lookalike audiences for marketing purposes (as set out in section 4 of this Policy</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>With Suppliers who you have consented to being contacted by </li> <li>With our advertising partners (e.g. Facebook, TikTok) but only in a hashed and pseudonymised format</li> <li>With our service providers (e.g. cloud storage providers and email service providers)</li></ul></td> <td colspan="1" rowspan="1"> With our advertising partners (e.g. Facebook, TikTok) but only in a hashed and pseudonymised format to reach new audiences who might benefit from our services (see our explanation of ‘customer and lookalike audiences’ in section 4).</td></tr> <tr> <td colspan="1" rowspan="1"> B. Personal information categories</td> <td colspan="1" rowspan="1"> <ul> <li>First and last name</li> <li>Email address</li> <li>Telephone number</li> <li>Postal address</li> <li>IP address </li> <li>Any other electronic data submitted, stored, sent or received by you</li></ul></td> <td colspan="1" rowspan="1"> As per category A</td> <td colspan="1" rowspan="1"> As per category A</td> <td colspan="1" rowspan="1"> As per category A</td></tr> <tr> <td colspan="1" rowspan="1"> C. Protected classification characteristics </td> <td colspan="1" rowspan="1"> <ul> <li>Age</li> <li>Sex and gender</li> <li>Medical conditions</li> <li>Mental or physical disability</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>To connect you with relevant Suppliers who can service your Product or Offer requirements</li> <li>The process of connecting you with relevant Suppliers may involve an element of automated decision making</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>With Suppliers who you have consented to being contacted by </li></ul></td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> D. Commercial information</td> <td colspan="1" rowspan="1"> <ul> <li>Interest in a Product via our webforms and whether the Product was purchased or if the inquiry was pursued </li> <li>Interest in participating in Offers</li></ul> </td> <td colspan="1" rowspan="1"> As per category C</td> <td colspan="1" rowspan="1"> As per category C</td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> E. Biometric information</td> <td colspan="1" rowspan="1"> None</td> <td colspan="1" rowspan="1"> Not applicable</td> <td colspan="1" rowspan="1"> Not applicable</td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> F. Internet or other similar network activity</td> <td colspan="1" rowspan="1"> <ul> <li>IP address</li> <li>Other information regarding your interaction with our sites, applications, or advertisements</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>To stop unwanted traffic (i.e.spam and fraudulent visitors) to our site</li> <li>To verify with our Suppliers that a request has been submitted by you and not by someone else</li> <li>To verify with our Suppliers that you have consented to being contacted by us and them</li> <li>To verify that your request has come from a particular country, state or region</li></ul> <ul> <li>To identify if you have submitted a duplicate request</li> <li>To identify that your request has originated from our sites</li></ul> <ul> <li>To personalise ads to suit you based on your location</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>With the Supplier with whom you were connected</li> <li>With a third party service provider who assists us with identifying the IP address location parameters</li> <li>With our service providers who help us verify your request and your consent</li></ul></td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> G. Geolocation data</td> <td colspan="1" rowspan="1"> <ul> <li>Geolocation</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>For the purposes of measuring and reporting on the performance of our ad campaigns.</li> <li>To personalise ads to suit you based on your location</li> <li>To verify that your request has come from a particular country, state or region</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>With a third party service provider who assists us with identifying the IP address location parameters</li></ul></td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> H. Sensory data</td> <td colspan="1" rowspan="1"> <ul> <li>Audio information</li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>We digitally monitor and/or record calls between you and us for the purposes of quality control and staff training </li></ul></td> <td colspan="1" rowspan="1"> <ul> <li>Occasionally, we may need to provide Suppliers with limited access to such recordings in order to resolve disputes</li></ul></td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> I. Professional or employment-related information</td> <td colspan="1" rowspan="1"> None</td> <td colspan="1" rowspan="1"> Not applicable</td> <td colspan="1" rowspan="1"> Not applicable</td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> J. Non-public information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))</td> <td colspan="1" rowspan="1"> None</td> <td colspan="1" rowspan="1"> Not applicable</td> <td colspan="1" rowspan="1"> Not applicable</td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> K. Inferences drawn from other personal information</td> <td colspan="1" rowspan="1"> None</td> <td colspan="1" rowspan="1"> Not applicable</td> <td colspan="1" rowspan="1"> Not applicable</td> <td colspan="1" rowspan="1"> Not applicable</td></tr> <tr> <td colspan="1" rowspan="1"> L. Sensitive personal information</td> <td colspan="1" rowspan="1"> <ul> <li>Health data</li> <li>Any other data that you voluntarily provide to us</li></ul></td> <td colspan="1" rowspan="1"> As per category A (we do not collect genetic data)</td> <td colspan="1" rowspan="1"> As per category A</td> <td colspan="1" rowspan="1"> Not applicable</td></tr></tbody></table> Please note that the categories of personal information set out above are obtained directly from you when you submit a webform through our site and indirectly from you (for example, through call recordings, cookies or other tracking mechanisms). <h4>Individual Rights</h4> US consumers in the states listed above have certain rights in relation to their personal information. This section describes your rights and explains how you can exercise them. <table> <tbody> <tr> <td colspan="1" rowspan="1"> Right to delete personal information</td> <td colspan="1" rowspan="1"> You have the right to request that your personal information collected by us be deleted. To exercise this right, please email us at <a href="mailto:dataprotection@mvfglobal.com">dataprotection@mvfglobal.com</a>. Once we receive and confirm your verifiable request, we will delete (and direct the Suppliers who we pass your information to in order to provide the service to delete) your personal information from our records, unless an exception applies.</td></tr> <tr> <td colspan="1" rowspan="1"> Right to correct inaccurate personal information</td> <td colspan="1" rowspan="1"> You have the right to correct any inaccurate, out-of-date, or otherwise obsolete personal information that we have collected from you. To exercise this right, you can email us at <a href="mailto:dataprotection@mvfglobal.com">dataprotection@mvfglobal.com</a>. </td></tr> <tr> <td colspan="1" rowspan="1"> Right to know categories and specific pieces of personal information</td> <td colspan="1" rowspan="1"> You have the right to know what personal information we collect about you, for what purpose, from whom we collect it, and whether we sell or disclose the information. We hope that this Policy provides the information that you are looking for. However, to make such a request, you can email us at <a href="mailto:dataprotection@mvfglobal.com">dataprotection@mvfglobal.com</a>. </td></tr> <tr> <td colspan="1" rowspan="1"> Right to opt-out of a sale or sharing of personal information</td> <td colspan="1" rowspan="1"> You have the right to opt out of the sale or sharing (for cross-context behavioural advertising) of your personal information. If you would like to opt out of the sharing of your personal information via cookies, you can opt out at any time by clicking on the cookie icon at the bottom left hand corner of your browser screen and adjusting your settings. If you would like to opt out of the sharing of your personal information for custom audience purposes, you can opt out at any time via the link on our sites stating “<a href="https://preferences.safe-click.net/">Your Privacy Choices</a>”, verifying your email and clicking on the option “Do Not Sell or Share My Personal Information”.</td></tr> <tr> <td colspan="1" rowspan="1"> Right to limit the use and disclosure of sensitive personal information</td> <td colspan="1" rowspan="1"> You have the right to opt out of the analysis of your health personal information (which could be included in any disposition data received from Suppliers) at any time. You can opt out of the use of your sensitive personal information at any time via a link on our sites stating “<a href="https://preferences.safe-click.net/">Your Privacy Choices</a>”, verifying your email and clicking on the option “Limit the Use of My Sensitive Personal Information”.</td></tr> <tr> <td colspan="1" rowspan="1"> Right of non-retaliation</td> <td colspan="1" rowspan="1"> You have the right not to be discriminated against if you exercise any of your consumer rights. </td></tr></tbody></table> Requests to know, delete and correct <ol type="A"> <li>Verification</li> Requests to know, delete, and correct must be verified. To begin the verification process, please email us at <a href="mailto:dataprotection@mvfglobal.com">dataprotection@mvfglobal.com</a> and from there, we will take you through the process. Verifiable consumer requests for access can only be made by you twice within a 12-month period. The request must also: <ul> <li>Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information (e.g. by verifying your identity through your email address).</li> <li>Describe your request with a sufficient level of detail that allows us to properly understand, evaluate and respond to it.</li></ul> We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. <li>Response </li> Once we have received a verifiable request, we will aim to respond within 45 days. Sometimes we may require more time. If we do, we will let you know by email with the reasons why and the period of extension. <li>Authorising an agent</li></ol> If you are acting as an authorised agent to make a request to know, delete, correct, or opt out on behalf of a US customer resident in the above states, email us at <a href="mailto:dataprotection@mvfglobal.com">dataprotection@mvfglobal.com</a> and attach a written authorisation signed by the resident. Other disclosures <ul> <li>Minors</li></ul> We do not knowingly sell or share Personal Information of customers under 16 years of age. <h3><li><a id=info_security>SECURING YOUR INFORMATION</a></li></h3> We want you to be confident in trusting us with your information. To ensure that the necessary protection is in place, we have implemented a number of technical, organisational and security measures including: <ul> <li>Measures that look to ensure availability and access to your data is restored in a timely manner in the event of a physical or technical incident</li> <li>Implementing internal user identification and authorisation processes</li> <li>Measures that look to ensure protection of your data during transmission</li> <li>Measures that look to ensure protection of your data during storage</li> <li>Measures that look to ensure the physical security of the locations where your data is being processed</li> <li>Measures that look to ensure that your data is not retained for longer than necessary </li> <li>Measures that look to ensure we only collect data that is necessary </li></ul> This list is not exhaustive and may change from time to time. <h3><li><a id=policy_changes>CHANGES TO THIS POLICY</a></li></h3> This Policy is effective from the date specified at the top of this Policy and is our most up-to-date version, which supersedes any earlier version. From time to time, we may update this Policy.