Who is Processing Your Personal Data?

WRM Media Ltd ("WRM", "we", "us", "our") is the registered owner of these prize draw service websites and owns all rights, including the sites’ respective IP, copyrights and trademarks. We are registered with The Information Commissioner's Office in the United Kingdom ("The ICO") as a Data Controller and Data Processor under the Trading Name WRM Media Ltd, with Registration Number Z9830964. This privacy policy applies to the following websites owned and operated by us (collectively to be called "the sites"):

• www.prizereactor.co.uk

Our Commitment to Protecting Your Personal Data

WRM is committed to protecting your data. We collect your personal data to help us understand your needs and guides the way in which we interact and communicate with you about ours, and our trusted third parties (subject to your consent) products and services. We ensure policies and procedures are in place to protect the data you provide when registering to our sites, and we process it in order to provide you with the services you have requested or, where you have given us your permission to do so, to send you information that we think you'll find interesting, and thereafter when we store your data on our secure servers. We work within the guidelines and advice provided by and made available by the Information Commissioner's Office, the regulator of the Data Protection Act 2018 and abide by the ICO’s requirements.

We seek to fully comply with the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Electronic EU Regulations 2011 and the EU General Data Protection Regulations (GDPR). If you wish to find out more, please visit https://ico.org.uk/

Purpose of this Privacy Policy

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and specific statements that are prominently displayed as part of the registration process on the sites, and can be withdrawn at any time by you.

Our Purpose for Processing Your Personal Data

WRM has 3 main business purposes:

• To manage the participation of the registered individual in draws and/or promotions organised by us.
• To meet the purposes of funding our free websites. The commercial use of our competition website prizes are mainly funded by advertising and through the sending of commercial communications of named third parties, market and/or product/item reviews etc. To this end, it is necessary to submit the data of a consumer that registers on our site ("registered individual") to standardisation, filtering and verification. The categories and methods of marketing communication which the registered individual’s may receive will be determined, subject to their active consent. All Companies and Partners are listed on our site, prior to registering.
• To communicate, (via email, telephone or the chosen contact method) the data of interest to WRM selected companies and trusted partners ("named third party companies"). Advertising will be sent by these named third party companies, subject to explicit, active consent by the registered individual during the process of signing up or registering to our websites.

We may also process your personal data where the benefits of doing so are not outweighed by the interests or fundamental rights or freedoms of individuals.

Our Legal Basis for Processing Your Personal Data

The basis of legitimization for the purposes of our processing is:

• To manage the participation of the registered individual in draws, promotions and/or device testing campaigns organised by WRM as promoted directly via its owned sites, including marketing by us.
• For the fulfilment of a contract with selected Companies and trusted Partners.
• To carry out third party advertising campaigns / market studies by us where consent has been obtained from the registered individual.
• To communicate the registered individual’s data to companies, organisations and/or entities interested that they have actively consented to, in carrying out advertising campaigns / market studies.
• To share your data with Marketing Services Providers under the legal basis of Legitimate Interest for the purposes listed below

When you have given us clear and unambiguous permission to contact you in certain ways i.e. by email or by telephone, we process your data with your Consent. You can object to us processing your personal information for this purpose as described below, under the ‘Your Rights’ heading. We will minimize the data and process it only where it is adequate, relevant and limited to what is necessary in relation to the purposes stated above, in accordance with Art. 5 (1), (c) of the GDPR);

Collection and Use of Your personal data

We collect your details when you register on one of our websites. ‘Personal data’ means the information you provide during the registration process and any information you provide when entering prize draws, quizzes, surveys or competitions. Registration is required to participate in any of the branded surveys on the site, but is not required to browse.

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

• Your name
• Your title
• Your date of birth
• Your contact information, including email and phone numbers
• Demographic information
• Your address and postcode
• Your IP address or other online identifiers such as Cookies

Use of Your Personal Data

We use your personal data collected via the WRM sites 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 Companies and Trusted Partners which provide you with other offers and promotions of interest to you
• Share your data with third party companies who may contact you. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation's own legitimate interest. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, enforcement, anti-fraud processes, asset recovery and asset reunification.
• 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.

We may process your personal data ourselves or through data processors that will process data on our behalf (we retain full responsibility) for ensuring the data processor complies with this policy and all current data protection regulations).

Depending on the consents that you set up at the time of registration and what personal data we hold about you, we may pass your personal data to our partners who may contact you by post, email, SMS and telephone for direct marketing purposes.

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

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

You can change or update your communication preferences at any time

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

We will only store your data in accordance with our Data Retention Policy. To read our Policy, click here.

Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn’t outweighed by the effects it will have on the relevant individuals. On that basis we may pass your information to Data OD Ltd who may share this information with other third parties. The data that is shared may be used for analysing, modelling and contact for purposes including affordability assessments, anti-money laundering, asset repatriation, contact information validation, credit risk and affordability assessments , debt collection services , determining debt portfolio value, fraud prevention services, identity verification services, pre-populating online forms, vulnerability assessments and other related services. If you do not wish for your data to be used this way by Data OD Ltd please opt-out using this link https://dataondemand.co.uk/opt-out/.  You can use this link to opt-out at any time after you have shared your data. You can also email MyInfo@dataondemand.co.uk with any requests about your information. For additional information about how your data is processed by Data OD Ltd, please use this link https://dataondemand.co.uk/personal-data-privacy-notice/

Profile Matching (aka Profiling)

To enhance the services we provide, we aim to match your profile to third companies that we determine from analysis that 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 lifestyle and available purchasing power.

The data that we provide to our third parties may be added to the information that they already hold about you. As an example, a car insurance company will check whether you have been a customer of theirs before. This is to ensure that they provide the right types of products, services and pricing to you.

Data sharing in this way allows them to contact you in their own name about their products, services, promotions, offers and competitions.

Marketing to Children

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.

Industry Sectors

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

• Air Source Heat Pumps
• Automotive
• Charities
• Claims Management
• Compensation
• Competitions and Prizes
• Dating
• Deals, Offers, New Products, Services
• Education
• Electrical Services
• Employment and Recruitment
• Energy
• Entertainment, Gaming, Leisure
• Fast Moving Commerical Goods (FMCG)
• Financial Products
• Funeral Plan
• Gambling and Lotteries
• Health and Beauty
• Home Improvements
• Home Improvements and Renovations
• Industry Sector
• Insurance
• Investment
• Laser Eye Surgery
• Legal
• Life assurance
• Lifestyle
• Mail Order
• Marketing Service Providers
• Mis-sold financial products
• Other
• Pension Reviews
• Pharmaceutical
• Pre-paid Funeral Plans
• Property
• Public Sector
• Publishing/Media
• Recruitment
• Retail and lifestyle
• Solar
• Telecommunications
• Trace, Asset Repatriation and Debt Collection
• Travel
• Utility

You are in Control

You may choose to restrict the collection or use of your personal data in the following ways:

Our registration forms will always have an unticked box for third party marketing, which you can optionally select to allow your personal data to be sent to our partners for direct marketing purposes.

You can control the channels of which you receive marketing, whether by email, phone, SMS or post by selecting the appropriate unticked box in our website forms, which determine the method by which you wish to be contacted.

Where consent has been previous obtained to us or our trusted partners to using your personal data for direct marketing purposes, you can change your mind at any time by going to the Marketing Preferences section of the website or emailing our Data Protection Officer at info@wrm-media.com

Your Rights

You have the right to:

• Obtain access to your personal data;
• Receive information about us and the purposes for which we process your personal data;
• Prevent processing which may cause you damage or distress;
• Object to direct marketing and select the contact channels by which we market;
• Object to purely automated decision-making in certain cases;
• You have the right to seek compensation through the civil courts for a breach of a data controller’s obligations;
• Ask us to correct any errors and/or delete the information we hold;
• Be forgotten by requesting all personal data collected from you, by us, be deleted completely from our database, systems and servers *;
• Opt out of any further contact by us or selected brand partners or sponsors;
• Be notified in the event of a data breach, where data lost or stolen involves your personal data; and
• Write to, report, or complain to your relevant supervisory authority, depending on your EU Member State (for UK data subjects, it is the ICO).

If you would like to amend/delete details or contact us in relation to the above, please contact using the ‘Contact Us’ page, alternatively send an email to info@wrm-media.com

Entering a Prize Draw

Your Registration Details, that you submit when entering the competition will be used to administer the competition and as follows:

If you enter a prize draw which is sponsored by us, this personal data may be, subject to your consent, shared with our Marketing Services Providers.

Opting In / Opting Out

You have the option of Opting In or Out of receiving marketing communications from ourselves and our partners at any time, including at registration.

When registering your details, your permission will be sought to:

• Receive offers and updates by email, telephone and post from selected third party companies which we believe will be of interest.
• Agree that our trusted partners may contact you with more interesting offers by telephone.

You will be required to acknowledge that you have read, understood and agreed to our terms prior to registration.

WRM will always remain transparent in disclosing how we intend to process your data, and where your data may be passed on, subject to your consent and preferences upon registration. All companies and partners we work with will be named, and the categories in which they operate in will be made available to you. These opt-ins are optional and only when you put a tick in the box will you consent to receive additional marketing communication.

You may change your preferences at any time via the "Account Details" pages once you are registered.

Third-party providers are able to send you communications via email, post, SMS or telephone only until such time as you exercise your right to opt out of receiving such communications. However please be aware that marketing campaigns are often planned well in advance, so your changes will be accepted immediately, but may not be effective immediately.

Opting Out – Additional Information

You can unsubscribe or opt out from any communications from our scheme or any third-party brand at any time as indicated above, but you may also wish to consider the following for a more general Opt-Out.

Opting Out – Postal Contact

You can withdraw your consent for postal marketing from anyone by adding your details to the Mail Preference Service. For more details please go to www.mpsonline.org.uk

Opting Out – Email or SMS (text message) Contact

You can unsubscribe from receiving e-mail or SMS marketing communications from any individual third-party by using the instructions in any email communication such third-party sends you (usually an ‘unsubscribe’ or ‘STOP’ link).

Opting Out – Telephone calls

To withdraw your consent for live or automated calls from anyone, you can add your name to the Telephone Preference Service which is maintained at this website address: www.tpsonline.org.uk

Opting Out – Social Media

You can configure your advertising preferences on social media such as Facebook, Twitter, Instagram or Pinterest by accessing your settings or preference options on the relevant platform.

Data Safety Outside the European Union

You should be aware that some external data processors may be based outside the European Union, whose laws provide a different standard of protection than that provided under English law. We will not release your data to a non-EU country processor without performing proper due diligence as to the standards of data protection within the specified country and proof of compliance with the standards of the UK Data Protection Act 2018 and other relevant legislation. Such requirements will be part of a formal and legally binding Data Processing agreement.

Current processors

• Leadbyte (UK) - Phone number validation
• Data8 (UK) - Phone number validation
• Kickbox (UK, US) - Email Address validation

Security and Storage of Your personal data

We store all data collected in a secure environment on servers located within the EU and only for as long as is necessary 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.

IP Address/Cookies

We automatically collect your IP address and record the web page from which you originated if you are using the service’s website.

Cookies are used to increase your security, not infringe on your privacy. Cookies are needed to monitor, facilitate, administer and optimise the website and service for users and to earmark any possible technical issues that may arise within the website or the service. We may use your IP address to help identify you, tend to any difficulties and to gather demographic and profile information. We also use the ‘cookies’ to collect information about your online activity on our website, such as the web pages you visit, the links you click, and the searches you conduct on our website.

Most browsers automatically accept cookies, but you can modify your web browser setting to decline cookies. If you choose to do this, you may not be able to avail yourself of some or all of the functionalities that the website or the service may offer.

Third party cookies that we use:

Google Analytics We use cookies from Google Analytics to track performance across our website, just like many other websites online. We use this cookie to help us with analytical tasks such as seeing how many people are viewing certain webpages and which parts of the site are most popular. The cookies that Google use are called __utma Cookie, __utmb Cookie, __utmc Cookie, __utmz Cookie and __utmv Cookie. You can find Google's privacy policy here: https://www.google.com/intl/en/policies/privacy/

Doubleclick by Google We use cookies from Doubleclick to allow us to show relevant and engaging display ads to our users. You can find Google's privacy policy here: https://www.google.com/intl/en/policies/privacy/

Facebook We use advertising within Facebook to promote our website and use cookies to help us know who has visited our site from Facebook and to track user behaviour on the site. You can find Facebook's cookie policy here: https://www.facebook.com/policies/cookies/

Pingdom We use Pingdom to help monitor the performance of the website and to ensure that it's always fully operational. See the following link for further information: https://www.pingdom.com/legal/cookie-policy

LiveRamp Inc. LiveRamp Inc., will drop a cookie on your browser and match the shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and those other databases; this link shall be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (cross device, web, email and in app…) by third parties unaffiliated with our website who may in turn link further demographic or interest-based information to your browser. Please click here if you wish to opt out of your data being used for this purpose.

Access, Rectification and Erasure of your personal data

You may request access to, rectification and/or erasure of any personal data which we hold about you under the Data Protection Act 2018 and the GDPR.

If you believe that any information we are holding on you is incorrect or incomplete, or you would any data we may hold about you to be completely deleted, please write to or email us as soon as possible, at the address below. We will promptly endeavour to correct any information found to be incorrect.

You may at any time unsubscribe with the site by visiting http://prizereactor.co.uk/unsubscribe There will also be information on how you can unsubscribe at the bottom of each email that WRM sends out on behalf of ourselves or our sponsors.

If you have questions regarding this Privacy Policy, please contact us by any of the following means:
Email: enquiries@wrm-media.com
Tel: 01924 229200
Post:

Right to complain

The Data Protection Act 2018 gives you the right to complain to the data protection supervisory authority where you live, where you work or where the infringement took place. In the UK, this is the ICO, and their contact details are below:

Website: https://ico.org.uk/global/contact-us/

Telephone: 0303 123 1113

Changes to this Policy

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. If we make substantial changes to this policy, we will notify you via email.