PRIVACY POLICY
Privacy Policy – Lloyd James Europe Limited (trading as Click Fuel Media)
Last updated 3rd March 2020, in accordance with the requirements of the General Data Protection Regulation (GDPR) and Data Protection Act 2018.
This is the Privacy Policy of Lloyd James Europe Limited, a company registered in England and Wales (Registered Number 09884309) whose registered address is Swinford House, Albion Street, Brierley Hill, West Midlands, DY5 3EE.
Lloyd James Europe Limited (trading as Click Fuel Media) is committed to acting in compliance with the General Data Protection Regulation and Data Protection Act 2018. Our ICO Registration number is ZA155084.
Click Fuel Media is the registered owner of these websites. This privacy policy applies to the following websites owned and operated by us (collectively to be called, Click Fuel Media):
Click Fuel Media is a marketing services company. We hold your personal data in our database and process it so that we can contact you and so that our partners and clients can send you direct marketing campaigns that we believe will be of interest to you. We are committed to protecting your privacy and maintaining the security of any personal information received from you. We follow strict security procedures in the storage of your data and the disclosure of your information, which you may have given us, to prevent unauthorised access in accordance with stringent requirements of the General Data Protection Regulation and Data Protection Act 2018.
The purpose of this statement is to explain to you what personal information we collect and how we may use it.
Our lawful basis for processing personal data
The data we collect from you is for marketing purposes. We may also supply your information to our partners and clients for marketing or relationship management purposes.
The main purposes for which your data is processed are:
- To manage your participation in prize draws and promotions promoted by Click Fuel Media via its sites;
- To provide you with information about the products and services we offer, including prize draws and promotions;
- To communicate your data to companies that you have actively consented to receive further marketing campaigns from;
- To allow our partners and clients to provide you with information about goods and services which they think may be of interest to you and/or to maintain any existing relationship they may have with you; based on our clients’ organisations’ own lawful purpose including their own legitimate interest. Such information may be provided by marketing communications or advertising which is tailored to your interests;
- To conduct market research with you;
- To build data products or for analysis purposes, where your information is aggregated and wherever possible anonymised. These products and services are for marketing purposes only;
- ID protection and tracing – we will also share your details with credit reference and identity verification organisations which help other organisations to verify your identity and prevent others from misusing your details
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 statements that are part of the registration process on the sites and can be withdrawn at any time by you;
We may process your personal data ourselves or through data processors who process data on our behalf. We will do so retaining full responsibility and accountability for ensuring the data processor complies with this Privacy Policy, the General Data Protection Regulation and Data Protection Act 2018.
We process your data using either Consent or Legitimate Interest as the lawful basis
Consent:
When you register with our websites you give your consent for Click Fuel Media to send you marketing communications via email, SMS, telephone and post. You are also asked to provide your consent for our named partners and clients to contact you by email, phone (where you are registered with the Telephone Preference Service) and SMS.
You can fine tune your preferences during the registration process. You also have the right to withdraw your consent at any time, at the end of this document we will tell you how you can do this.
Legitimate Interest:
In accordance with the General Data Protection Regulation we can use personal information where the benefits of doing so are not outweighed by the interests or fundamental rights or freedoms of individuals.
Our lawful basis for processing personal data for direct marketing by post and by telephone (where you are not registered with the Telephone Preference Service) is known as Legitimate Interest. This means that your information may be shared with marketing services providers, credit reference agencies and third parties in the industry sectors as described later in this privacy policy.
Our organisation’s legitimate interest is the running of a marketing services and data business.
What data we may collect from you and how we will use your data
Click Fuel Media runs prize draws, quizzes, surveys or competitions to collect information from you for marketing communication purposes. This helps us ensure that the goods and services offers which we and our clients wish to make to you are relevant and tailored to your responses and what we know about you.
The categories of personal data we may collect from you upon registration on our sites include:
- Name
- Date of birth
- Address
- Contact information, including email and phone numbers
- Demographic information
IP address or other online identifiers including cookies. We will never ask you for your bank account details, nor do we collect sensitive information about your medical history, religious or political belief.
The marketing communications may be through:
- Email marketing
- Live Telemarketing
- Online Digital/Social Media Advertising
- Postal /Mailing Marketing
- SMS/MMS Mobile Message Marketing
In accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 any marketing communication we make to you through marketing calls, emails and texts are only where we have been given explicit permission to do so.
Telemarketing data will be checked against the Telephone Preference Service (TPS) register. Mailing data will be checked against the Mailing Preference Service (MPS) register. Please note that if you have actively consented to receive further marketing campaigns from Click Fuel Media or our partners and client companies, this will override the Telephone Preference Service.
Your information may be shared through single or multiple use data licences, with selected partners and clients who may then contact you by email, telephone, SMS or post depending on the channels you have chosen at the time of registration or through subsequent contact with us.
Those partners and clients who would wish to send you marketing communications or to advertise to you will fall into the following business categories:
| Sector | Description and examples |
| Retail |
|
| Home |
|
| Finance |
|
| Insurance |
|
| Travel |
|
| Lifestyle |
|
| Legal Services |
|
| Marketing
Companies |
|
Click Fuel Media also shares your data with:
Lloyd James Europe Limited’s associated companies and brands:
- Click Fuel Media
- supersavvyyou
- Tele Prospects Ltd
- Lloyd James Media Group
- TPL Media
- Lifestyle Research
- Lloyd James Media Ltd
- Data Baby Direct Marketing Ltd
Marketing Services Providers
We will share your data with Marketing Services Providers, some of them are listed below, who will use it to create products and services to help organisations better understand the likely characteristics of their customers; communicate with them more effectively; and find others like them across a range of marketing channels. This may mean that you receive advertising that is more relevant to you via direct mail or when you visit a website. To understand more please click through to the websites of the companies below:
- Experian Ltd
- The Read Group
- Lloyd James Media
- Indicia
- TPL Media
- Data Baby
Claims Management Services
Click Fuel Media may share your data with organisations specialising in claims managements (Unenforceable Credit Agreements, Mis Sold Financial Products including Payment Protection Insurance, Package Bank Accounts, investments, Mortgage and Pension; Unfair Credit Card or Bank Charges). We work only with organisation that are authorised by the Claims Management Regulator or the Financial Conduct Authority.
Analysis and derivative data products
Sometimes your data will be used for analysis purposes or to build data products. In these instances, the information is aggregated and wherever possible anonymised in line with the Information Commissioner‚ code of practice. Again, these products are of a marketing nature.
Profiling
Click Fuel Media may use your data to group consumers into profiles, who are more likely to have common habits and interests. Profiling is summarising consumer data which include lifestyles, preferences, demographics, and purchasing patterns. It offers additional insight into customers and to help our clients to identify and gain a deeper understanding of their target market, enabling relevant and tailored marketing. Our clients may extend their databases by adding the additional information we provide, to existing information they may already hold on you as their customer. We do not use profiling or any of the data we hold to make automated decisions about you.
How we use cookies
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to analyse aggregate information. A cookie is a small file of letters and numbers that we put on your computer. These cookies allow us to distinguish you from other users of our websites, which helps us to provide you with a better experience when you browse our websites and allows us to improve our sites. The cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the sites when they are using them. This helps us to improve the way our websites work, for example by ensuring that users are finding what they are looking for easily. Our cookies are not used to collect personally identifiable information about you.
We list below the cookies we use on each of our websites and provide a brief explanation of what those cookies do. Most web browsers allow some control of most cookies through the browser settings. For more information on this, and more information about cookies in general, you may wish to visit www.aboutcookies.org. For information about how to delete cookies from your mobile ‘phone you will need to refer to your handset manual. Please be aware that restricting cookies is likely to impact on your ability to use our websites effectively and may make areas of our websites inaccessible or inoperable. The cookies we use are as follows:
utma (Unique visitor cookie)
utmb (Session cookie)
utmz (Campaign cookie)
utmv (Visitor segmentation cookie)
utmx (Google website optimizer cookie)
Data retention and how we retain data
In accordance with the GDPR, personal data shall be kept for no longer than is necessary for the purposes for which it is being processed.
Click Fuel Media systems store personal data therefore all reasonable precautions shall be taken to ensure that appropriate confidentiality and control procedures are in place. We take the security of your data and the accessibility to our systems very seriously, with an emphasis on physical security, network and application security.
Transferring your data outside of the EU: Please note that personal information may be transferred, accessed and stored globally as necessary for the uses and disclosures stated above in accordance with this policy. This will only be done with a contract that has been approved by the European Commission with the recipient of your personal information that provides a suitable level of high quality protection.
Data Breach
Click Fuel Media has a procedure in place if a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
We will assess the scope and impact of the breach. If, due to the nature of the breach that Click Fuel Media is required to inform the ICO, we will do so within 72 hours of becoming aware of the essential facts of the breach.
Based on the assessment of the likely risks to individuals, we will notify the individuals and/or their connected organisations that a data breach has occurred where this may result in a significant risk to the rights and freedoms of individuals, or where we may be in breach of a contractual obligation. Any such notification to individuals will be carried out as soon as reasonably possible and will include information on the nature of the breach, the name and contact details of our Data Protection representative, the likely consequences of the breach, measures taken or proposed by Click Fuel Media to address it, and recommendations for affected individuals to mitigate any potential adverse effects. Such individuals will also be provided advice on how to make a complaint to the ICO.
Your rights
Click Fuel Media respects your rights to your personal data. The GDPR provides the following rights for individuals:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
How you can obtain data we hold about you
You have the right to know what information we hold on our system about you at any given time. To obtain details of the information we hold as it relates specifically to you, you may contact Click Fuel Media using the address details shown at the end of this document.
When contacting us to ascertain the information we hold about you, it would be helpful if you could provide us with details of your full name, address and contact details.
How to withdraw your permission for us to process your data:
If you want Click Fuel Media to stop using your personal data for direct marketing of our goods and services, you have the right to withdraw your permission at any time and can unsubscribe using the link in any email you have received from us. Alternatively you can notify us in writing using the contact details provided at the end of this document.
How you can make a complaint:
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details provided at the end of this document.
How to contact us
If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to make a complaint or make any general enquiry, please contact us at the address below:
The Compliance Officer
Click Fuel Media
Compliance Department
2nd Floor
84 Salop Street
Wolverhampton
WV3 0SR
E-mail: compliance@clickfuelmedia.com
Telephone: 0247 699 2899
Changes to this privacy policy
Click Fuel Media reserves the right to modify or update this Privacy Policy from time to time. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.
Last updated 3rd March 2020