1. Overview.PDV Ltd operates the Free-DVD-Club and Fair Exchange Programmes and is the Data Controller. PDV Ltd takes the protection of your privacy very seriously and this Privacy Policy sets out how PDV Ltd will use the information you have provided through your interaction with any of the Fair Exchange data collection properties*. PDV is registered in the United Kingdom under the Data Protection Act 1998 (registration Z720633X) and we adhere to the Privacy and Electronic Communications (EC Directive) Regulations 2003. PDV Ltd is a full member of the Direct Marketing Association (DMA). PDV?s registered office is Monmouth House, 32 Farringdon Street, London EC4A 4HJ, is registered in England under the Companies Act 2006 under registration number Z720633X. VAT registration number is 761423151 2. Our PromiseWe promise our users that we will:
3. The collection of information.Our websites will form the Fair Exchange Programme* are: Chooseaprize.com, Thedailydraw.com, Scratchandmatch.com, Fruitillion.com,Strikermillion.com, Prizetag.com, Winaflat.com, Winferraris.com, Fair-exchange.com, free-dvd-club.com Information about you will be collected initially when you join the Fair Exchange Programme and will involve contact information (e.g. age and gender). This information will be used to identify offers that may be of interest to you. Through your interaction with the Fair Exchange Programme, there may be occasions where additional personal information is collected through surveys, Questionnaires, offers or competitions. In these circumstances this information provided by you may be shared with our commercial partners. The use of this information will always be explained to you at the time at which you are asked to provide it and will not be used without your permission. Our websites provide links to our partner sites. These links will lead you to websites operated by third parties that operate under different Privacy Policies. Should you choose one of these links you will be leaving a PDV Ltd site for a site over which we have no control and we therefore accept no liability once you have left one of our sites. PDV Ltd recommends that you read and understand this information. 4. The use of information.PDV Ltd works with many partners to deliver offers to you that we believe may be of interest given the information you have provided. By joining the Fair Exchange Programme through any of our data collection properties*, you are agreeing that you are happy for us and our partner companies to use your details to decide which offers may suit you best and then to get in touch with you about these offers, via whichever communication channels you have given us permission to use; post, e-mail, text or telephone. PDV Ltd may, from time to time, use third party suppliers to provide all of part of its service to you. PDV Ltd shall only be entitled to disclose such of your personal information as is necessary to enable them to provide the relevant service to you. In some circumstances, such outside service providers may be based in countries outside the European Economic Area whose laws provide for a different standard of protection for your personal data than that provided under English Law. In such circumstance, PDV Ltd. will have in place contractual arrangements which will require your data to be processed securely at least to a standard compliant with the Data Protection Act 1998. 5. Managing your personal information.PDV Ltd strongly supports the principles of ?permission marketing? and will only send communications from itself and its partners where we have your permission to do so. When you first register with us you agree to receive e-mails and can choose to receive postal communications, text and phone communications. We hope you will enjoy the communications we send you, but if at any time you change your mind, you may withdraw these permissions AT ANY TIME by either:
If you prefer you may change your mind by writing to: The Data Protection Compliance Officer, PDV Ltd, FREEPOST, Monmouth House, 40 Artillery Lane, London E1 7LS. If we do do not hear otherwise from you, we will assume that the information you provide to us is accurate and up-to-date and we will continue to use the information to send you the communications you have requested. Please note that PDV Ltd will act in accordance with the Data Protection Act 1998 and remove your permission as promptly as possible but you could continue to receive communications for a short period of time whilst this change is actioned. You have a right under the Data Protection Act 1998 to see what information we hold about you, subject to certain conditions. Our websites provide you with direct access to your personal data which you may update at any time but should you make an application to us in writing, we may ask you to provide us with sufficient information so that we can be sure that you are who you say you are as we cannot act on requests for access to personal data from third parties. We also reserve the right to make a small charge for providing you with the information you are requesting. If you would like to proceed with a request to see what data we hold about you, please write to the Data Protection Compliance Officer, PDV Ltd, Monmouth House, 40 Artillery Lane, London E1 7LS.. 6. Security of your personal information.When you give your personal data to PDV Ltd we will process that data in accordance with our responsibilities under the Data Protection Act 1998, and the Privacy and Electronic Communications (EC Directive) 2003 and other legislation if it is relevant. We will keep your data safe and secure. To prevent unauthorised access, maintain data accuracy and ensure the correct usage of information, we monitor and adjust our physical, electronic and managerial procedures to safegard and secure your personal data while in our care, or in the care of any outside suppliers with whom we may contract to process your data on our behalf. Whilst we strive to protect your personal information, the internet is not a 100% secure medium for communication and, accordingly, PDV Ltd cannot guarantee the security of any information you send PDV via the internet. PDV Ltd is not responsible for any loss or damage that you or others may suffer as a result of loss of confidentiality of such information. You must type in a correct password to access your Fair Exchange account and details. It is your responsibility to ensure the security of your Fair Exchange password and not to reveal this information to others. 7. Cookies, Tags and Web Beacons.Cookies are small files of letters and numbers downloaded onto your computer when you access certain websites. Cookies unlock a computer?s memory allowing sites to recognise users when they return to a site. Like a key, a cookie itself does not contain information but when it is read by a browser it can help a website identify you and your requirements. PDV Ltd uses cookies as a means of limiting the number of times you may see a certain advertisement on your screen (a process called frequency capping) to ensure that you see the best range of relevant offers and adverts. PDV Ltd also uses ?web beacons? as a means of tracking whether or not you open e-mails from us. This information is used to assess whether the message has been effective, both for you and us or our partners. The information is retained by us and used in deciding the most appropriate offers to be made to you in the future. In some cases, we also track the pages visited when you click through from Fair Exchange to one of our partner sites. Note that this information is
Some of the partners that we advertise with require us to use cookies or action tags. These action tags provide those websites with the aggregate number of registrations to enable them to evaluate the effectiveness of their advertising. In some instances, we will pass back your email address to such companies as part of this assessment and the provision of rewards to you. The specific details should be explained in the ?Privacy Policy? or ?Conditions of Use? page of the partner sites. Some of the partner websites that advertise with us via our games, competitions and e-mails may well use cookies within their sites. You may decide how you wish cookies to be used. You can make and action this decision within your computer and you can easily delete cookies that have been installed in the cookie folder of your browser. Most industry-standard web browsers have an option that allows you to turn off all cookies or have your computer inform you each time that a request to place a cookie is being made. If you turn cookies off (or refuse to accept a request to place a cookie) you may not have access to some features on our websites and our partners? websites and you may lose the functionality of locating some of our services. If you would like more information about cookies and how to control them no matter what version and which software you are using, go to PDV Ltd is not liable for information that is inaccurate due to technical defects in software used on our websites, whether induced by our systems or by software provided by third parties. 8. Changes to the Privacy Policy.By using our websites you signify your acceptance of this Privacy Policy. PDV Ltd reserves the right to modify, alter or otherwise update this policy at any time. Visitors are encouraged to review this policy from time-to-time to stay abreast of any changes. Your continued use of our websites following the posting of any changes to this policy means you accept those changes. This Privacy Policy was last updated in August 2007 and PDV Ltd will undertake to revise the ?last updated? statement at the top and bottom of the Privacy Policy in the event of any changes to the Policy in the future. Last Updated August 2007. |