Review Club LLC
Review Club Global
Privacy and Cookies Policy
Last Modified: October 27, 2020
Review Club LLC (Review Club, us or we) sets forth the following Privacy and Cookies Policy for https://worldreviewers.com/. This explains how and why we acquire and use your personal data in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR). Personal data means any information relating to an identified or identifiable natural person (Personal Data).
Review Club is a US company registered in the state of Delaware with offices at 128 Court Street, 3rd Floor, Black Plains, PA 16345. We are registered as a data controller with the Information Commissioner's Office (ICO) under registration number ZA320278. If you would like more information about us, please contact our Data Protection Officer, Martin Lorter, at the address above or at email@example.com.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
- Your name, address and other contact details;
- your gender;
- your date of birth;
- certain information about your financial position including your card payment details (but not your card number), an estimate of how much debt you have, the type of debt you have (credit card, student loan etc.) and an estimate of your household income;
- information about your use of our website including your log in information, technical information such as the type of device you are using, your IP address, the web browser, operating system and platform and your time zone settings;
- information about how you found our website, the pages you looked at on our website, the website you visited when leaving our website and the date and time of your visit; and
- products or services that you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, and the methods used to browse away from the page.
WHY WE NEED YOUR PERSONAL DATA
We need your Personal Data so that:
- you can take part in the rewards or promotions that we offer;
- we can reply to any enquiries you make to us;
- we can make suggestions to you about goods and services that we offer, and tailor these to you;
- we can share it with our third-party data controllers, including interest-based advertising partners as described further below, including to create anonymized sets of Personal Data which may be used for programmatic advertising purposes;
- we can provide you with email alerts, text/SMS message alerts and push notifications that you have consented to receive or that we are required to send concerning users’ registrations, promotions, our products or services or other information;
- we can measure the effectiveness of our adverts and tailor them to you; and
- we can administer our website, including troubleshooting, data analysis and survey purposes and help us keep our website safe and secure.
OUR LEGAL BASIS FOR PROCESSING
When we process your Personal Data, we do so on the basis that we can rely on a legal basis for such processing. The legal bases on which we rely are:
- for the performance of a contract if you have entered into a contract with us;
- a legitimate interest where we process your Personal Data in order to tailor the advertising, merchandise, gift cards and incentives we provide to you to ensure that we only show you those which we think may be of interest to you;
- your consent, where you have expressly provided your consent to us processing your Personal Data for certain purposes. Where we process Personal Data on the basis that you have given your consent for us to do so, you can withdraw your consent at any time.
WHERE DO WE GET THIS PERSONAL DATA FROM?
- Forms, online data fields, and surveys that you fill in and submit to us;
- any of our websites which we own and operate;
- other companies in our group of companies who share Personal Data with us on the basis of an agreement which is in place between the group; and
WHO DO WE SHARE YOUR PERSONAL DATA WITH AND WHY?
We may share your Personal Data with:
Third-Party Agents or Service Providers:
We may transfer your Personal Data to our third-party agents or service providers who perform functions on our behalf including:
- other companies which we own and control and are part of our affiliated group of companies which includes our affiliate Fluent, LLC which provides operational service and other support of our websites in the UK;
- third parties which supply us with products and services, such as hosting our databases and collecting payment information, optimising our website, and verifying your registration information; and/or
- third parties if we believe, in good faith, that it is necessary to protect our rights, property, safety or reputation or the rights, property, safety or reputation of any of our customers or partners.
Third-Party Data Controllers:
In some cases, we may transfer Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for example:
- our named third party partners for the purpose of receiving marketing communications (a full list of which is available here), but only if you have agreed to receive marketing communications from those specific third parties by giving your consent;
- third parties where we are required to do so in order to comply with our legal obligations or the requirements of a regulatory authority; and/or
- third parties if we buy or sell our business or assets (in which case we may need to share Personal Data with the prospective buyer or seller of such business or assets).
We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level or protection for Personal Data as we provide. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received.
WHAT HAPPENS IF I DON'T PROVIDE MY PERSONAL DATA?
You are not obligated to provide us with your Personal Data, and if you decide not to:
- we won't be able to register you on our website (we need to know who you are);
- we won't be able to contact you if you have a query (as we won't have your name and contact details);
- we will not be able to tailor the merchandise, gift cards and incentives we offer to you without your gender, age, date of birth, certain financial information; and
- our website may not work properly on your device without the information about your visit.
WHERE IS MY PERSONAL DATA STORED?
The Personal Data we collect about you may be transferred to and stored outside the European Economic Area (EEA), in particular in the United States of America (USA). It may also be processed by staff operating outside the EEA who work for us or for one of the third parties with which we share Personal Data.
We comply with, and ensure that third parties with whom we share Personal Data comply with, the provisions of the GDPR and any other relevant data protection legislation to ensure that adequate protection is provided to any Personal Data which is stored or processed outside the EEA. You can ask us for a copy of the relevant safeguards implemented in relation to any such transfer outside of the EEA.
HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
- We maintain reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction.
- All Personal Data you provide to us is stored on our secure servers located in a secure facility operated by Rackspace US, Inc. and located in Ashburn, Virginia, USA.
- We use industry standard security measures to encrypt your Personal Data.
- You are responsible for keeping your password confidential.
- We will do our best to protect your Personal Data you provide to us via the internet, but such transmission is not completely secure. Subject to our responsibility to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, any transmission of Personal Data over the internet is at your own risk.
- If you follow a link to any of our partners' or advertisers' websites, these websites may have their own privacy policies and we do not accept any responsibility or liability for these policies.
- We keep your Personal Data for as long as it is necessary to provide you with the services you have requested.
- We may retain your Personal Data for up to six years from when we stop providing our services to you, in accordance with laws in the UK and the USA on legal limitation periods, unless a longer retention period is required or permitted by law.
AUTOMATED DECISION MAKING AND PROFILING
We use automated decision-making and profiling techniques to help us decide which survey questions to ask you, which adverts to show you when you use our website and which of our third-party advertisers to share your data with. This might be based on your economic situation or your interests. This means that the questions and adverts you are shown, and who your data is shared with, are determined without human intervention.
WHAT ARE MY PRIVACY RIGHTS UNDER THE GDPR?
As a “data subject” under the GDPR, you have a number of rights (detailed below) which you can seek to exercise. If you wish to exercise any rights you should contact us using the ways detailed in this Privacy and Cookies Policy.
If you seek to exercise your rights, we will explain to you whether or not the right applies to you; these rights do not apply in all circumstances and are subject to, for example, our legal obligations, reasons of public interest and defence of legal claims.
- Right to withdraw consent. To the extent you provide consent to the processing of your Personal Data, you can withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
- Right of access to and rectification of your Personal Data. If you would like to request access to, correction, amendment or deletion of your Personal Data, you can submit a written request here. We may request specific information from you to confirm your identify. In some circumstances we may charge a reasonable fee for access to your information. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access.
- Right to erasure (or, “Right to be forgotten”). You can ask us to stop processing and delete your personal data in certain circumstances (for example where it was processed on the basis of your consent and you withdraw such consent or where it is no longer necessary for us to process it).
- Right to data portability. You can request to receive your Personal Data from us in a machine-readable, commonly used format of our choosing and/or have us transfer your Personal Data directly to another controller.
- Right to object to, or restrict processing. Where the processing of your Personal Data is based on consent, contract, or legitimate interests, you may restrict or object, at any time, to the processing of your Personal Data as permitted by applicable law. We may continue to process your Personal Data if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.
- Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, except as allowed under applicable data protection laws.
We will use best efforts to notify the third parties with whom we shared your Personal Data about any request for erasure, rectification or restriction you make to us, unless it proves impossible or involves disproportionate effort. Upon your request, we will share the list of recipients with you.
CONTACT AND COMPLAINTS
If you have any questions, feedback or wish to make a complaint, please contact us using the details below:
You also have the right to lodge a complaint with a supervisory authority (the ICO) by writing to the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or calling 0303 123 1113. Further information about how to do this can be found at: www.ico.org.uk.
COOKIES AND INTEREST BASED ADVERTISING
- keep track of your progress through our reward and promotion processes;
- recognise you whenever you visit this website;
- obtain information about your preferences, online movements and use of the internet;
- carry out analysis to help improve our content and to better understand our user, customer and visitor requirements and interests; and
- target our marketing and advertising campaigns and those of our partners more effectively.
These third-party Cookies may also enable the delivery of interest-based advertisements based on a user’s visit to our Website and/or other websites. In addition, our partners use information gathered in this manner to recognize you across different channels and platforms, including computers, mobile devices, and Smart TVs and may use this information over time for advertising, analytics, attribution and reporting purposes.
We work with third-party suppliers who may also set cookies on our website, for example comScore, Quantcast, CAKE, Facebook and Adobe Flashplayer (which we use to display video content). These third-party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party.
DESCRIPTION OF COOKIES
Name of cookie
|Owner|| Purpose for the cookie|
|comScore||comScore||This service enables census measurement of sites by placing web tags on our online content and ads. comScore views calls from these tags on the panel in addition to measuring the direct server calls which allows validation that the tag calls are measuring activities consistent with our audience measurement methodology. This tagging network is used for both visitation-based and duration-based metrics. |
|Quantcast||Quantcast||This service enables us to understand our audience by platform- web and mobile – country, time period and additional demographics characteristics. |
|CAKE||CAKE||This service is an affiliate tracking platform that places cookies to enable us and our advertiser and publisher partners to source traffic and measure performance.|
HOW TO TURN OFF COOKIES
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.
Changes we may make to this Privacy and Cookies Policy in the future will be posted on this page and, where appropriate, sent to you via email.
© Review Club LLC October 27 2020