Privacy Policy of E-communication LTD

www.testreward.com/ is owned by E-communication LTD. We, from E-communication LTD (hereinafter referred to as us or we or Naturvel), 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:

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:

According to Art. 27 Hong Kong, we are obliged to have a representative of E-communication LTD established in 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:

2. What information we collect, use and process:

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

3. How the information is used:

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

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

Industry Sector include, but not limited to
Charity e.g. animal welfare, disaster relief, children’s medical, elderly, environmental, health
Gaming e.g. bingo, betting, competitions, lottery
Leisure e.g. food & drink, events, museums, cinema
Financial Products e.g. pensions, banking, credit cards, investments, loans, mortgages
Insurance e.g. car, home, life, medical, pet, income protection, travel, warranty products
Health / Lifestyle e.g. fitness, beauty, opticians, hearing, care homes, mobility, leisure, pharmaceuticals
Home Improvements e.g. house moving, blinds & curtains, insulation, boilers, conservatories, doors & windows, extensions, gardens, solar panels.
Funeral Plans e.g. to arrange and pay for a funeral in advance
Legal Services e.g. claims, will writing, will reviews
Mail Order e.g. catalogues, online retailers
Market Research e.g. to gather information about consumers' opinions and preferences
Media e.g. online, television, radio, newspapers, magazines
Retail e.g. online retail, electrical goods, comparison sites, discounts, FMCG, automotive, home improvement, Home Services
Telecoms e.g. landline, mobile phones, broadband, digital TV
Travel e.g. holidays, city breaks, airlines, Hong Kong breaks, accommodation
Utilities e.g. gas & electricity switching, other household utilities such as water

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 https://www.winrdata.com/privacy-policy/

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:

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 the "Your 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 create predictive 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:

They share your data, including the profiled data they have created about you, primarily to:

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 called “legitimate 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:

Purpose/Activity Type of data Lawful basis for processing
To perform the competition that you have entered in our page. (a) Personal details
(b) Contact details
(a) Performance of a contract with you
To communicate with you and to keep you informed of our latest updates:
(a) Notifying you about changes to our Terms and Conditions or Privacy Policy
(b) Notifying you in case you are the winner
(c) Contact you in response to a contact request
(a) Personal details
(b) Contact details
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To support and troubleshoot our Services and to respond to your queries (a) Personal details
(b) Contact details
(c) Technical details
(a) Necessary for our legitimate interests:
  • for running our business
  • provision of administration and IT services
  • network security
  • to prevent fraud
  • in the context of a business reorganization or group restructuring exercise
To perform a research or to conduct analytics in order to improve and customize our Services to your needs and interests (a) Personal details
(b) Contact details
(c) Interest details
(d) Technical details
(a) Necessary for our legitimate interests:
  • to study how customers use our products/services
  • to develop products/services
  • to define types of customers for our products and services
  • to keep our website updated and relevant
To inform you about our other websites and services via email, push notification, mail, telephone and/or text/SMS messages (a) Personal details
(b) Contact details
(c) Interest details
(d) Technical details
(a) Necessary for our legitimate interests:
  • to develop our products/services
  • to grow our business
(b) Consent
To inform you about our partner offers and opportunities via email, push notification, mail, telephone and/or text/SMS messages (a) Personal details
(b) Contact details
(c) Profile details
(d) Technical details
(a) Consent
To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority (a) Personal details
(b) Contact details
(c) Profile details
(d) Technical details
(a) Necessary to comply with a legal obligation

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

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

6. International Transfers

To countries inside or outside the European Economic Area in order to be able to provide the service associated with the promotional purpose consented to by means of services required by the recipients. The recipient companies of the personal data may be located in countries outside the European Economic Area.

7. 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.

8. What data protection rights you have:

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

Right to object (art. 21, GDPR): you have the right to object, on grounds relating to your particular situation, without any formal requirements, to the processing of personal data concerning you, if such processing is in the public interest or in pursuit of legitimate interests of the Company or a third party. You also have the right to object, without any formal requirements, to the use of personal data for marketing purpose (e.g. if you object to the processing of your personal data for direct marketing purposes, we will discontinue processing your personal data for this purpose).

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

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 include social media plug-ins (also often known as "social media buttons") in some areas of our web pages. These types of plug-ins are indicated on our pages by buttons (hence the term "buttons"), 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 or recommended 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.

10. 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.

11. 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.

12. Bloctel

You can register for the Bloctel opposition list. If you click in the second box, you authorize 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.

13. CHANGES TO THIS PRIVACY POLICY

We want to be as transparent as possible about the changes we make to our Privacy Policy. We may change this Policy from time to time. We advise you to regularly review this Policy for any amendments. You should check this page regularly to see our most up-to-date policy.



This privacy policy was last updated 31 Jul 2024.