Privacy Policy of E-communication LTD

www.testreward.com/ is owned by E-communication LTD. We, from E-communication LTD (hereinafter referred to asus orwe orNaturvel ), care about your privacy and, in this privacy policy, we would like to ensure that you will be provided with all necessary information about your privacy according to the EU General Data Protection Regulation (GDPR), including details about:

• the collection, usage and processing of your personal data,
• the communication and storage of your personal data, and
• your rights

If you have any questions in regards to your personal data collection, processing and usage or interest to exercise your rights, you can reach us at any time, either by post or by email directly to our data protection officers:

• E-communication LTD
• Blk A 15/F Hillier Commercial Bld, 65-67 Bonham Strand East, Sheung Wan Hongkong - 999077
  e-com.ltd
  
• e-com.ltd
• c/o DPO: privacy@e-com.ltd
• Represented by managing director

According to Art. 27 Hong Kong, we are obliged to have a representative of E-communication LTD established in the Hong Kong. The appointed representative can be reached via email: c/o Hong Kong Representative privacy@e-com.ltd

Our UK Representative is appointed to act on your behalf regarding our UK GDPR compliance, and to deal with the Information Commissioner s Office (ICO) and UK data subjects. Their details are:

MASSIVE ADS DIGITAL LIMITED
09977834 - Incorporated on 29 January 2016
4 Capricorn Centre, Cranes Farm Road, Basildon, Essex, England, SS14 3JJ
https://www.massiveadsdigital.com/privacy-policy/
+44 1268 271234

1. How we collect the information:

Among others, we collect, use and process personal data that you provide in the course of our relationship, as for example:

• Filling in any of our electronic forms,
• Participating in promotional offers from us,
• Visiting our websites, and
• Contacting our staff.

2. What information we collect, use and process:

Generally, the types of personal data collected, used and processed are:

• Personal details (e.g. first name, last name and date of birth)
• Contact details (e.g. email address, post address, IP address and telephone number),
• Interest details (e.g. preferences of offers chosen by you in our page), and
• Technical details (e.g. data relating to type of browser, Internet Service Provider (ISP), local time, location)

3. How the information is used:

All the information made available to us are used to one or more of the following purpose:

• Performance of our contract we are about to enter into or have entered into with you (e.g. participation in the competition solely)
• Meet our legitimate interests pursued by us (e.g. for our own marketing purposes),
• Meet our legal obligations, enforcing our rights and other legal uses, and
• Rely on your valid consent given (e.g. for third-party marketing purposes).

Possible sectors that you may expect to receive advertisement about are:

We reserve the right to engage in the further processing of personal data, which we have collected for any of the foregoing purposes, including any other purposes that are consistent with the original purpose or which are permitted or prescribed by law (e.g. reporting obligations).

We do not perform automated decision-making.

We may share your personal information with our partner WINR Data Pty Ltd (WINR) and their global partners for the purposes of:

• Fraud Prevention - preventing others from misusing your personal information. This may involve identity verification for anti-fraud, anti-money laundering, anti-crime, asset recovery, debt collection and reuniting individuals with unclaimed assets; and
• Digital Advertising - providing personalised advertising and content that is relevant to you. This may involve identity resolution for data analysis, matching and linkage.

WINR and their global partners will process and retain your personal information for as long as necessary for these specific purposes and on the lawful basis of legitimate interests. You can submit a request to exercise any of your privacy rights to the Data Protection Officer at WINR .

National Injury Claimline Ltd (T/A:

The Compensation Experts, Should I Claim Compensation, Time To Claim, The Medical Negligence Experts.

Privacy Policy (1): https://the-compensation-experts.co.uk/privacy-policy.

Privacy Policy (2): https://the-medical-negligence-experts.co.uk/privacy-policy/).

PURPOSE AND LEGISLATION OF PROCESSING YOUR PERSONAL DATA

In sharing your data with Marketing Services Providers, we rely on the lawful ground of legitimate interest, as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons. For the purposes of existing customer contact and new customer verification.

E-communication limited has 3 main business purposes:

1. To manage the participation of the registered individual in draws and/or promotions organised by us.

2. To meet the purposes of funding our free websites. The commercial use of our competition website prizes is mainly funded by advertising and by sending 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") for standardisation, filtering and verification. The categories and methods of marketing communication which the registered individuals may receive will be determined, subject to their active consent. All Companies and Partners are listed on our site, prior to registering.

3. To communicate (via email, telephone or the chosen contact method) the data of interest to E-communication limited 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 before signing up or registering to our websites.

LEGITIMATE INTEREST

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.

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 organized by E-communication limited as promoted directly via its owned sites, including marketing by us.

For the fulfilment of a contract with selected companies and trusted Partners. We will rely on legitimate interest where processing is necessary and cannot be achieved in another less intrusive way, such as consent. You can object to us processing your personal information for this purpose as described below, under theYour Rights heading. We will minimize the data and process it only where it is adequate, relevant, and limited to what is necessary for relation to the purposes stated above, in accordance with Art. 5 (1), (c) of the GDPR);

Sharing your personal data

We license data to third parties who like us, operate in accordance with UK Data Protection Law. These third parties operate in the following business categories and may contact you by email, telephone or post for the purposes of Direct Marketing, Debt Collection and Tracing. Where third parties are contacting you with Direct Marketing by email, telephone or post, they will only do so with your consent.

Data OD Ltd

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/

Legal Ventures trading as Claims Advisory Services https://www.claimsadvisoryservices.co.uk/privacy-policy/

Lego https://www.lego.com/en-gb/legal/notices-and-policies/privacy-policy

Legal & General https://www.legalandgeneral.com/privacy-policy/

Gallagher (Arthur J Gallagher & Co) https://www.ajg.com/uk/brokerage-privacy-policy/

McCarthy & Stone (Developments) Limited https://www.mccarthyandstone.co.uk/privacy-and-cookies/

Mercedes Benz Cars UK Ltd Company Number: 2448457 and Registered Address: Tongwell, Milton Keynes, England, MK15 8BA https://www.mercedes-benz.co.uk/passengercars/content-pool/tool-pages/footer-legal-links/privacy-policy.html

Mercedes-Benz Vans UK Limited Company Number: 10304278 and Registered Address: Tongwell, Milton Keynes, England, MK15 8BA https://www.mercedes-benz.co.uk/passengercars/content-pool/tool-pages/footer-legal-links/privacy-policy.html

Mercedes-Benz Trucks UK Limited Company Number: 10304244 and Registered Address: Tongwell, Milton Keynes, England, MK15 8BA https://www.mercedes-benz.co.uk/passengercars/content-pool/tool-pages/footer-legal-links/privacy-policy.html

Mercedes-Benz Financial Services UK Limited Company Number: 2472364 and Registered Address: Tongwell, Milton Keynes, England, MK15 8BA https://www.mercedes-benz.co.uk/passengercars/content-pool/tool-pages/footer-legal-links/privacy-policy.html

Daimler Insurance Services UK Limited Company Number: 03510012 and Registered Address: Tongwell, Milton Keynes, England, MK15 8BA https://www.mercedes-benz.co.uk/passengercars/content-pool/tool-pages/footer-legal-links/privacy-policy.html

Mercedes-Benz Retail Group UK Limited Company Number: 419087 and Registered Address: Tongwell, Milton Keynes, England, MK15 8BA https://www.mercedes-benz.co.uk/passengercars/content-pool/tool-pages/footer-legal-links/privacy-policy.html

Newmarket Holidays Ltd https://www.newmarketholidays.co.uk/privacy

Offers You Might Like https://offersyoumightlike.com/privacy-policy/

Roqad, Inc. and companies within its group https://www.roq.ad/privacy-policy-roqad/#optout

Samsung Electronics https://www.samsung.com/uk/info/privacy/

Sky UK Limited https://www.sky.com/help/articles/sky-privacy-and-cookies-notice

Stubben Edge Labs (SE Labs) Ltd https://www.stubbenedge.com/privacy-policy/#SUBSIDIARIES

Twenty Ci Ltd https://www.twentyci.co.uk/data-privacy-policy/

Tailsco Ltd https://tails.com/gb/terms/#privacy-policy

Victor Hydon Ltd trading as Your Claim Matters https://www.yourclaimmatters.co.uk/privacy-policy/

We and our partners and selected third parties operate in the following areas:

Retail , Automotive, Lifestyle, Charity, Utility, Telecommunications, Insurance, Publishing / Media, Entertainment/Gaming/Leisure, Public Sector, Financial Services, Travel, Mail Order, Health/Beauty, Education, FMCG, Marketing Agencies and Brokers, Property, Pharmaceuticals, Claims Companies and Short Term Loans.

Marketing Services Providers

We will share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing, testing, research & product development purposes. Marketing Services Providers carry out data profiling. They will combine your data with data they get from other sources (including public sources) and use it to createpredictive 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 will 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 Providers 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 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:

Audience Serv https://www.audienceserv.com/privacy.html

Data Enhancement Solutions Ltd https://dataenhancementsolutions.co.uk/privacy

Experian Ltd https://www.experian.co.uk/privacy/consumer-information-portal/

Lloyd James Media https://lloydjames.com/privacy-cookie-policy/

LiveRamp UK Limited https://liveramp.uk/privacy/web-privacy-policy/

C-Centric Ltd https://www.ccentric.co.uk/privacy-policy/

Digitoo Group SRL https://www.digitoogroup.com/informativa-privacy/

DBS Data Marketing Ltd https://dbsdata.co.uk/privacy-policies/

Greenstone Data Solutions Ltd https://www.gdsidm.com/privacy-policy

Lead 365 Ltd https://lead365.co.uk/privacy-policy/

MDEG Ltd https://www.mdeg.co.uk/how-we-process-data.html

Potential D Ltd https://www.potentiald.co.uk/

Results Generation Group LLC https://resultsgeneration.com/privacy-policy

Roqad, Inc. and companies within its group https://www.roq.ad/privacy-policy-roqad/#optout

Sagacity Solutions Ltd https://www.mydatachoices.co.uk/Privacy
We are permitted to share information with Sagacity who will share such information for marketing and non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, enforcement, debt collection and returning assets to you).

The Data Partnership Group Ltd T/A TDP Agency (Co Reg 00612316) ICO ZA537625; https://tdpagency.co.uk/privacy-policy/

UK Data Leads Ltd t/a UK Datahouse https://ukdatahouse.com/cookie-and-privacy-policy/

USM LTD https://www.usmdigital.co.uk/privacy-policy/

Webalytix Ltd https://www.webalytix.co.uk/privacy/

In sharing your data with Marketing Services Providers, we rely on a lawful ground calledlegitimate interest , as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons.

4. What our legal basis are and for which purposes we will use your data:

Our legal basis to collect, use and process the information in accordance with the provisions of the GDPR are, at least, on one of the following legal bases, mentioned in a table format:

5. Where the information will be stored and for how long:

The personal data is stored by us according to the following aspects:

• Within the European Economic Area.
• We store your information on our secure servers.
• We store your personal information for as long as necessary to fulfil the purposes already outlined above generally for 4 (four) years -, provided no revoke or deletion takes place.
• Following any withdrawal of consent to the processing of your data and/or declaration of objection thereto, your data will be moved to our so-calledblocking list . This means that your personal data is no longer used for our relationship basis purposes. We then store your data only for legal purposes (e.g. burden of proof obligations and the assertion or defense of claims), deleting it on expiry of a 4 (four)-year period, provided there are no compelling reasons to do otherwise or where, for other reasons possibly in the way of renewed consent an appropriate level of data processing is permitted.
• If the personal information we hold is no longer needed for the intended purpose for at least 24 (twenty four) months, we will ensure that it is securely destroyed or deleted.
• In case of transfer to third countries (outside the European Union), a secure transmission within the framework of EU specifications on data protection and privacy is guaranteed.

6. How we protect your personal data:

We take the relevant precautions administrative, organizational, technical and physical to protect your personal data against loss, theft, misuse, unauthorized access, unauthorized transmission, unauthorized amendment and destruction.

This means, that your data is protected by entry controls (securely located servers, access to which is only granted under defined security procedures), admission controls (128-bit encoded data transmission, individual password, menu and employee authorization, current virus software), access controls (individual employee access authorization via personal accounts, identification and authentication requirements), disclosure controls (constant supervision and guidance to authorized personnel, no local storage of data, recording of all data exports and transmission), input controls (account-related auditing, time-stamp and host logging), task auditing (constant supervision by managers and data protection officers, transparent contract structure relating to the provisions of 62 of the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and Art. 28 GDPR in coordination with management and data protection officers) and availability checks (general security procedures of the host [UPS, halon gas systems, etc.], back-up streaming to other general security procedures [e.g. UPS, halon gas systems, etc.], back-up streaming to other locations [with all security measures, see access controls] nightly mirroring onto two hard discs, virus protection program). Despite these precautions and due to the insecure nature of the Internet, we are unable to guarantee the security of your data transmission to our website. Any transmission of your data to our website is, therefore, undertaken at your own risk.

7. What data protection rights you have:

According to the provisions of the GDPR, you have the following data protection rights:

• Right of access (art. 15, GDPR): you have the right to obtain information about the data stored about you as an individual, including the sources and recipients of your data, as well as the purposes of its subsequent processing.
• Right to rectification (art. 16, GDPR): you have the right to demand the rectification of any incorrect or inaccurate personal data we hold with respect to you.
• Right to erasure (art. 17, GDPR): you have the right to have your personal data erased if: (i) the data is no longer necessary in relation to the purposes for which it was collected or processed; (ii) you have withdrawn your consent; or (iii) the data have been unlawfully processed.
• Right to restriction of processing (art. 18, GDPR): you have the right to have your data with processing restriction by satisfying one of the prerequisites listed in Art. 18 (1) GDPR (e.g. contesting the accuracy of your personal data).
• Right to withdraw consent (art. 7, GDPR): you are entitled to withdraw any declaration(s) of consent previously made and relating to the processing of your personal data with future effect by sending an email to privacy@e-com.ltd or by requesting it at the time you are contacted by email, phone, SMS or post. However, such withdrawal of consent does not affect the legitimacy of any processing operations previously executed.
• Right to data portability (art. 20, GDPR): you are entitled to demand the provision by us of all personal data communicated to us in a format, which allows its transmission to another controller.

You should preferably submit any requests here listed in writing with the Data Protection Officer, who is the point of contact for any other data protection matters.

Should you wish to assert any of the rights listed above in this section, please get in touch with us at E-communication LTD, Blk A 15/F Hillier Commercial Bld, 65-67 Bonham Strand East, Sheung Wan Hongkong - 999077, or via the following email address: privacy@e-com.ltd.

You also have the right to complain to the relevant Supervisory Authority which for UK data subjects is the Information Commissioner s Office (ICO) who can be contacted by visiting their website at http://ico.org.uk/, or by telephoning 0303 123 1113, or by post at Information Commissioner s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Our UK Representative is appointed to act on your behalf regarding our UK GDPR compliance, and to deal with the Information Commissioner s Office (ICO) and UK data subjects. Their details are:

MASSIVE ADS DIGITAL LIMITED
09977834 - Incorporated on 29 January 2016
4 Capricorn Centre, Cranes Farm Road, Basildon, Essex, England, SS14 3JJ
https://www.massiveadsdigital.com/privacy-policy/
+44 1268 271234

8. Usage data and cookies:

You can view our internet pages without providing any personal information. However, when you visit our pages, certain technical data is generated, which is known as "usage data". In addition, we may use one or more cookies and in some cases include social media plug-ins. The text below is also intended to provide you with information about this.

Usage data:

When you visit our web pages, the only items of information that we store by default are the website from which you reached our page, the name of your Internet service provider, which web pages you visited while on the Internet, and the date and duration of your visit. The data obtained is completely anonymous.

For security reasons, your IP address and a time stamp are also stored. These data are used for internal purposes. The IP address is a machine-related code that provides information about the computer or Internet gateway used to access the Internet for online retrieval. A time stamp is a value in a specific format that assigns a specific time to an event (for example, sending or receiving a message, change of data, etc.). The purpose of a time stamp is to tell people or computers when events have occurred.

Social media plugins:

We includesocial media plug-ins (also often known associal media buttons ) in some areas of our web pages. These types of plug-ins are indicated on our pages by buttons (hence the termbuttons ), each of which indicates the provider of the plug-in via the corresponding colors and symbols. If you click on these buttons you can do things like notify your friends on the social networks you use that you like one of our pages or share a link to a website with other internet users depending on the button

If you are browsing our website and access one of our web pages with a social media plug-in, your browser connects directly to the plug-in provider's servers, and the plug-in from these servers be downloaded. During the process, the plug-in provider may be notified that the relevant web page has been accessed through our website.

If you have a user account of which one or more social networks are managed by the providers of the plug-ins, and if you are logged in to the network (s) in question while on one of our web pages that contains one or more plug-ins of social media from the provider (s) in question, access to that page may also be linked to your existing user profile (s) with the provider (s) in question. If you subsequently click on built-in plug-ins and log in to one or more of the networks (or if you are already logged in), the shared orrecommended information will usually be posted to your profile in an abbreviated form. This may allow the network provider to retrieve and store further usage data. In this way, the providers of the networks can create user profiles that contain more information than just what you yourself have directly and actively disclosed on the network. For more information about the collection and processing of data, see the privacy policy of the plug-in providers.

Cookies

We use so-called cookies as part of our internet pages. These are small files that are stored on your hard drive and which contain specific information that can be retrieved by the server that installed the cookie on your computer. The cookies used may be "session" cookies, which are automatically deleted when you close the browser window, and / or cookies that are valid for a longer period of time.

The information stored in cookies may relate to the login (your visit, if you log in), the date and time of your visit to our site, the cookie number and the URL of the website through which you reached our site.

By using cookies we can guarantee the functionality of our websites and continuously improve it.

In addition, cookies help us and our partner to recognize you and so we can optimally adapt our offers to your individual needs and wishes and thus show you the most relevant information, also on other websites where our partner is active. Finally, cookies also make it possible to record the statistical frequency of the retrieval of the various pages of our presence on the Internet and of the general navigation.

However, if you wish to prevent the use of cookies - without affecting the performance of our prize draw or other offers linked to it by us - please adjust your browser settings before using our pages. You can prevent new cookies from being accepted and stored in these settings. Please refer to your browser's help pages or contact the browser maker or provider for more information.

Push notifications

Sometimes you agree to receive our push notifications, with additional consent where applicable, for which we use the "Accengage" shipping service. Your personal data will therefore be processed on the basis of this (further) consent (Article 6 (1) (a) GDPR). Of course, the rights already stated in section 5 also apply to this consent. To withdraw your consent to push notifications, you can also change the setting for receiving push notifications in your browser. If you are using a desktop PC with Windows operating system, you can opt out of our push notifications by right-clicking on the relevant push notification on the settings displayed there.

9. Delete cookies:

As a user, you can always determine yourself which cookies, including those for push notifications, you want to accept or delete. The individual settings for this can be configured directly in the settings of your internet browser. For more information, contact the provider of your internet browser.

10. Minors:

This site, including the data protection and privacy policy and general business conditions, is not intended for minors. Personal data of minors is not knowingly collected, used and / or disclosed.

11. Bloctel

You can register for the Bloctel opposition list. If you click in the second box, you authorise TestReward or its partners to call you by telephone. This means that you agree to receive offers from TestReward's partners, who are specialists in the following industries Insurance, Automotive, Consumer goods, Energy, Investment, Lottery, Slimming, Telecommunication, Work.

12. CHANGES TO THIS PRIVACY POLICY

We may make changes to this privacy policy from time to time. You should check this page regularly to see our most up to date policy. This privacy policy was last updated 30 May 2024.