Web-Clubs processes your data for the purposes of Club website administration and for direct marketing. When doing so Web-Clubs takes your privacy seriously and takes every reasonable precaution to safeguard the personal information you supply to it. We will only use or share your personal data in a manner that is in accordance with this document.
More about Web-Clubs
Web-Clubs Digital Ltd is a digital marketing company which owns and maintains various online Clubs, their websites and email brands. These special interest Club websites provide a meeting place for like-minded individuals where they can benefit from free membership and enjoy useful content; such as information, practical advice, new ideas, events, discounts, offers, Q&A’s, links to related sites, exclusive deals and free to enter competitions. Contact with members is maintained by regular Club email newsletters.
Web-Clubs Digital Ltd registered office is 8 Temple Square, Aylesbury, Bucks, HP20 2QH. Company registered in England and Wales, number: 11832568
Web-Clubs Digital Limited is registered as a Data Controller and Data Processor with the Information Commissioner Office (ICO) under number ZA510032.
Web-Clubs is committed to protecting your data. We collect your personal data to help us understand your needs and this guides the way in which we interact and communicate with you about your Club(s) – this includes our third parties’ (subject to your consent) products and services and the use of your data by our marketing services providers. 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 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/.
Why we collect and process personal data
We process data under the following lawful basis as defined by the ICO:
Consent : when you have given us clear and unambiguous permission to contact you in certain ways i.e. by email or by telephone.
Contract : we may need to process personal data to fulfil a contractual obligation.
Legal Obligation : we may need to process data to fulfil legal requirements.
Legitimate Interest : when there is a legitimate interest for ourselves and our clients in processing data to provide products and services to consumers through marketing campaigns. Balancing the commercial gain needed to conduct a data business for ourselves alongside the potential impact on the consumer.
Specifically Web-Clubs Digital Ltd has 4 main business purposes for processing your personal data;
- To manage the participation and membership of our Club websites. The legal basis for this processing is subject to your active consent.
- To meet the purposes of funding our free websites. The use of our Club websites is mainly funded by advertising and through the sending of commercial communications of named third parties. The legal basis for this processing is subject to your active consent.
- To communicate, (via email, telephone or the chosen contact method) the data of interest to Web-Clubs selected third party companies. Advertising will be sent by these named third party companies, subject to consent by the registered individual. The legal basis for this processing is subject to your active consent.
- To share your data with the marketing services providers, who will use it as an input to products and services to help organisations better understand the likely characteristics of their customers. The legal basis for this sharing is ‘legitimate interest’, as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons.
We collect personal data so that we can target you with member’s offers and content that we believe may be relevant to you. Without profiling you in this manner, we would send you less relevant marketing messages.
Collection and use of your personal data
We collect data in 4 ways;
- Data you enter by forms, either on our websites or through an email we send.
- Browsing data such as views, clicks and transaction history on websites we control.
- Open, click and transaction behaviour on emails we send.
- Data received from third parties featuring Web-Clubs content, promotions or membership recruitment programmes – third parties include (but not limited to) social media platforms, search engines, blogs, banner advertising, affiliate networks and other lead generation website partners.
When registering we may collect your name, title, date of birth, postal addresses, email addresses, phone numbers, gender, IP addresses and other online identifiers such as Cookies.
Registration is required to join our Clubs and benefit from email newsletter content and other member benefits, however merely browsing does not require registration.
We use your personal data collected to :
- Provide you with information about the products and services we offer.
- Provide you with a more personalised service.
- Conduct market research.
- Run prize draws and promotions.
- Pass on your details to selected third party companies which provide you with other offers, promotions and marketing communications of interest to you.
- For analysis purposes or to build data products. In these instances, the information is aggregated and wherever possible anonymised in line with the ICO’s code of practice. Again, these products are of a marketing nature.
Depending on the consents that you set up at the time of registration and what personal data we hold about you, we may process your personal data ourselves or through our data processing partners that will process data on our behalf.
Third Party Companies
To enhance the services we provide, we also aim to match your profile to third party companies that we determine (from analysis, targeting and profiling) will have goods or services that would be of interest to you. It makes sense for us to ensure that you only receive offers that are relevant to you and fit within the context of your Club membership, lifestyle, interests and available purchasing power. The data that we provide our third parties may be added or appended to the information that they already hold about you – when first contacting you, they always will seek your appropriate opt in and consent.
Data sharing in this way allows them to contact you in their own name about their products, services, promotions, offers and competitions, and/or to update their records for fraud prevention, debt tracing, enforcement & anti-money laundering purposes, affordability and identification of vulnerability. This may mean that you receive advertising that is more relevant to you via direct mail or when you visit a website.
Third party companies include (but are not limited to) TV Licensing, LFS Claims, Club La Costa (UK) PLC, Sky UK Ltd, Shop Direct, Carphone Warehouse, IG Index, Infinian Data Solutions, Peoples Postcode Lottery and E.ON. To understand more please follow the links through to the websites of these companies and let our data protection team know if you would prefer to not have your details passed on.
The type of marketing you will receive
Web-Clubs may send you emails which contain marketing messages from the third party companies and brands we work with. The headers and footers within the email will make it clear that Web-Clubs are sending these messages but the content will be provided by the brand we work with.
Web-Clubs may also share the personal information you supply with third parties who may send you marketing by post using Legitimate Interest as their legal basis.
The marketing messages you will receive will be relevant to one of our Clubs or fall within the data categories listed below:
Description and Examples
- Online and Mail Order
- General stores and FMCG
- Home furnishings & improvement
- Fashion and clothing
- Mobile and landline
- Premium subscription service – channels, sports, entertainment
- Loans, credit cards and mortgages
- Investments & savings
- Funeral Plans
- Personal and Life
- Other Insurance
- Travel Booking
- New model launches
- Awareness (including brochures, test drives etc)
- Entertainment (including Slots, Videos, Prizes etc)
- Gambling (including Sports, Casino, Slots etc)
|Promotions & Offers
- Special events (including Black Friday, Prime Day etc)
- Health & Well-being
- Food & Drink
- Media & publishing companies
- Legal Services
- Educational institutions
- Compensation, Legal Services and Personal Injury
- Legal Service
- Not For Profit
- Tracing Services
- Acting in alignment with the sectors, descriptions and examples as interpreted above
|To see some examples of the marketing messages and brands you might expect to receive, please click here.
Marketing Services Providers
We will share your data with the Marketing Services Providers listed below, who will use it for a variety of purposes which may include direct marketing, targeted advertising, measurement & identity resolution purposes. Marketing Services Providers may carry out data profiling. They may combine your data with data they get from other sources (including public sources) and use it to create “predictive models”. Marketing Services Providers use these models to try to predict behaviour and preferences (e.g. how likely you are to buy a holiday online or take a particular type of holiday) or likely circumstances (e.g. whether you are eligible for a particular credit card).
Marketing Services Providers may also try to match and then link your data with data that they receive about you from other sources, to make sure that the data they hold about you is correct. For example, they might do this to:
– check whether you have recently moved address; or
– keep the IP address they hold about you up to date. IP addresses change regularly. The IP address they receive from us might change too quickly to make the data you provide through us useful for marketing purposes. Marketing Services Provider might find it helpful for this to be refreshed from time to time to ensure marketing messages are being delivered to the correct consumers, on the correct device(s).
They may share your data, including the profiled data they have created about you, primarily to:
– help organisations better understand the likely characteristics of their customers (and find others like them);
– improve the relevancy and appropriateness of an organisation’s marketing to its customers (e.g. offers, its products and services); and
– help them communicate with their customers more effectively offline and online. This may mean that you receive tailored advertising via direct mail or when you visit a website.
To understand more about the use of your data by Marketing Services Providers, and to find out how to exercise your data protection rights in relation to their use of your data (including how to opt-out), please click through to the websites of the companies below:
Acxiom Ltd, Kinesso Ltd, Omnis Data Ltd, Sagacity, We Breathe Media & Client Portfolio, Monetise Media & Client Portfolio, Verso Group, Yes Offers Limited, Experian, Indicia, Lepus Marketing Limited, TDP Agency, Data Locator Group Limited, Twenty Ci, Austinshire Partners (Results Generation), LiveRamp UK Limited, PDV Ltd, GBG Plc, CACI and Equifax. ESB Connect (The Goody Bag + Opt-me-in.com) will send your offers from brands big and small via email. To see details of who they work with visit www.opt-me-in.com/brands and to see email examples, please visit www.opt-me-in.com/emails. Data Mixx Ltd may combine, analyse & profile your information and share this information with other organisations for the purposes of debt collection, debt recovery, fraud prevention, tracing/locating you, verifying your identity, verifying the information they hold about you is correct, and for assessing affordability. More details of how DML use this data can be found here.
In sharing your data with Marketing Services Providers, we rely on a lawful ground called ‘legitimate interest’, as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons. If you would prefer to not have your details passed on in this way, you have the right to object by contacting our data protection team at any time.
Cookies and similar technologies
Cookies we use:
||These cookies allow us to collect information about how visitors use the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
||We are a match partner of LiveRamp.
When you use our website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating system, with our partner, LiveRamp Inc and its group companies (‘LiveRamp’). LiveRamp may drop a cookie on your browser or directly in our emails and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. Similarly, when you use our mobile apps, we may also share hashed and de-identified email addresses, mobile device ID, location data, and advertising identifiers with LiveRamp, which uses that information to create a link between your mobile device and its databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email and in app etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. You have the right to exercise your rights under GDPR including opting out of LiveRamp’s Cookie or Mobile Identifiers and can easily do so by clicking on this link: https://your-rights.liveramp.uk/home
|ESB Connect Limited
||We are a match partner of ESBConnect. Their cookies set an identifier linked to your email address which enables them to identify visitors to their advertising clients’ websites and send personalised emails or serve personalized ads via display, social, video or mobile. To opt out of ESB Connect Email please email [email protected].
You can use your browser settings to accept or reject new cookies and to delete existing cookies. You can also set your browser to notify you each time new cookies are placed on your computer or another device. You can find more detailed information about how you can manage Cookies at the All About Cookies and Your Online Choices websites.
Data Protection – generating, accessing and updating your personal information
We do not knowingly, deliberately or aim to, collect personal data from children under the age of 18, either for registration or for marketing purposes. Where consent has been previously been obtained by Web-Clubs or our trusted partners for use within direct marketing purposes, you can change your mind at any time by using the unsubscribe link in any email that you receive from us, or by simply contacting us directly to update your details. To update your details, to manually unsubscribe, or to object to any form of data processing you can contact Web-Clubs directly using the information below :
Data Protection Officer
Web-Clubs Digital Limited
8 Temple Square
Your data protection rights summary
Under data protection law, you have several rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances, and an absolute right to object to your data being used for marketing purposes.
- Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Other industry wide services where you can opt out from targeted marketing or use your right to complain :
The Information Commissioner: www.ico.org.uk
Postal Marketing – You can opt out of postal marketing by registering with the Mail Preference Service (MPS) at http://www.mpsonline.org.uk/. This service is administered by the Direct Marketing Association and recognised by the ICO.
Telephone Marketing – You can opt out of all telemarketing activity by registering details with the Telephone Preference Service (TPS) at http://www.tpsonline.org.uk/. This service is administered by the ICO.
The Direct Marketing Association: www.dma.org.uk
The Citizens Advice Bureau: www.adviceguide.org.uk
Security of your personal data
Web-Clubs are committed to protecting the security of your personal information and we have appropriate industry standard technology alongside physical and administrative procedures in place for a company of our size and complexity to protect the data that has been collected, processed and stored. Our software is kept up to date with the latest releases to protect against industry known vulnerabilities, however, despite our best efforts the Internet is not 100% secure and we cannot guarantee the security of any information you send to us via the Internet. We will not be responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of such information.
From time to time there may be a requirement to transfer your information to one of our third party companies, IT partners or third party marketing service providers. Some of these companies may have operating staff or have IT systems in countries overseas including countries located outside the European Economic Area (EEA). Such a transfer will only happen where we are satisfied that adequate levels of protection are in place to ensure the integrity and security of any information being processed whilst compliant with all applicable privacy and data protection laws. This would include seeking confirmation that these same companies are aware of GDPR, adhere to the regulations set out and are aware of your rights.
Retention of your personal data
Whilst the law does not put a time limit on the amount of time we should hold your personal data, all data collected or processed will not be kept for longer than is necessary. Web-Clubs primary method of communication, membership validity and retention is focused and measured on the last engagement of a member – last sent/opened/clicked an email. Any membership record which is no longer engaged will be stored for maximum of 6 years after the date of last engagement date. Any membership record which has opted out or is inaccurate will be retained indefinitely for the sole purpose of maintaining a suppression file.
Changes to this policy
We may change this policy from time to time by updating this page – when we do, we will also revise the last updated date featured here :