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      <div class="pp_Wrap">
        <div class="pp_text" style="margin-right: 0px; text-align: right;">Last updated 26/01/2023</div><!-- 10/11/2022 - -->
        <div class="pp_text">
          <h2><span style="color: #41a044;">Privacy Policy</span></h2>
          <h3>What this Policy Covers</h3>
          <p>esbconnect is a digital marketing company. Full company details are:</p>
          <p>ESB Connect limited is a registered company in the UK under company number 08235436. To contact us by post: please write to:</p>
          <p>esbconnect, Waverley House,9 Noel St, Soho, London W1F 8GQ</p>
          <p>or via email: hello@esbconnect.com</p>
          <p>Our ICO registration number is ZA074763 </p>
          <p>We work with over 150 High St brands and provide you with personalised marketing content from these brands via email and social. Our aim is to provide you with offers and content that we believe may be relevant to you. To see a list of
            types of brands we work with, <a href="http://www.opt-me-in.com/brands-we-work-with/">CLICK HERE</a></p>
          <!-- p>To see examples of the emails we may send to you <a href="http://www.opt-me-in.com/emails-examples/">CLICK HERE</a>.</p -->
          <p>esbconnect owns and maintains the following website and emailing brands: Opt-Me-In, , WeSearch-USave, The Goody Bag, ZestPMI, Lead Switchboard, WeSearch-UCompare, Your Everyday, Sports Player, One Stop, One Compare UK, Save Compare,
            Broadstreet Digital, Universal Savings and esbauto. Our privacy policy is the same across all websites and brands we maintain, so you know it is us!</p>
          <p>&nbsp;</p>
          <p>Your data will only be on our database if you have consented to sharing your data with esbconnect, one of its’ owned websites or mailing brands, or with third-party partners.</p>
          <p>You would have opted in via one of our owned websites or via a partner website. In either case, our opt-in will be present and esbconnect or one it’s mailing brands like The Goody Bag or Opt-Me-In will be listed within their privacy
            policy ‘as somebody who your personal data may be shared with’. You can always decide to opt-out or choose to not opt-in.</p>
          <p>esbconnect is committed to transparency in terms of how we collect and use your “personal data”.</p>
          <p>&nbsp;</p>
          <p>“Personal data” is defined in Article 4(1) of the GDPR:</p>
          <p>“(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an
            identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
          </p>
          <p>That’s why we’ve developed this privacy and cookies policy (“Policy”), which:</p>
          <ul>
            <li>sets out the types of personal data that we collect</li>
            <li>explains how and why we collect and use your personal data</li>
            <li>explains when and why we will share personal data within the ESBConnect Group and with other organisations; and</li>
            <li>explains the rights and choices you have when it comes to your personal data</li>
          </ul>
          <p>ESB Connect Limited or one of its’ mailing brand (referred to in this policy as “esbconnect” or “us” or “we”) is the Data Controller as defined by the Data Protection Act 2018. The Data Controller determines the purposes for which and
            the way any personal data is or will be processed. esbconnect includes any of its associated mailing brands: Your Everyday, ESBAuto, Opt-Me-In, The Goody Bag, WeSearch-USave, WeSearch-UCompare, Sports Player, One Stop, One Compare UK,
            Hundreds of Brands, Save Compare, Broadstreet Digital and Universal Savings.</p>
          <p>&nbsp;</p>
          <h3>How We Use Your Personal Data</h3>
          <p>&nbsp;</p>
          <p>In this Section we have set out:</p>
          <p>(a) the general categories of personal data that we may process;</p>
          <p>(b) the purposes for which we may process personal data; and</p>
          <p>(c) the legal bases of the processing.</p>
          <p>&nbsp;</p>
          <h3>What Data is Collected and What Do We Process</h3>
          <p>&nbsp;</p>
          <p>esbconnect collects both non-personal and personal data on an ongoing basis.</p>
          <ol>
            <li>Non-personal data<br> Web browser details, operating system data, date and time stamps.</li>
            <li>Personal Data<br> ESB Connect collects 6 types of personal data<p></p>
              <ul>
                <li>Internet Protocol (IP) addresses</li>
                <li>Email address, Postal Address, Telephone number and consent data</li>
                <li>Demographic data – such as age, gender, home and car ownership &amp; insurance, salary bands and address</li>
                <li>Behaviour data (“service data”) – such as what you open, click on and transaction categories</li>
                <li>Device data – the types of device you use – Desktop, phone and tablet data</li>
                <li>Suppression data – This is where you have unsubscribed from us or a brand. We store this information to ensure we do not re-contact you in the future or from a brand you have chosen not to hear from.</li>
              </ul>
            </li>
          </ol>
          <p>In addition to the above, we may append publicly available data to your email address, postal address or telephone number. For instance, we may match your postal address to data publicly available through the Land Registry database. We
            may also match and append the postal address you provided via one of our websites to data held within our central database. This data may then be shared with third parties including Marketing Services Providers</p>
          <p>We may process data about your use of the emails we send and visit to our website and services. (“<strong>usage data</strong>“). The usage data may include your IP address, geographical location, browser type and version, operating
            system, referral source, which emails you open and do not open, which emails you click on and do click on, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your
            service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website, emails we send and services. The legal basis for this processing is
            legitimate interests, namely monitoring and improving our website, email sending strategy and services.</p>
          <p>We may process your information attached to your email address, for example postcode or gender, “<strong>personal data</strong>“. The profile data may include your name, address, email address, gender, date of birth, relationship status,
            interests and hobbies and employment details. The profile data may be processed for delivering you a better service by providing more relevant marketing and advertising offers. The legal basis for this processing is consent. Consent was
            obtained at the point the email was submitted on our partner websites. At any point you can opt-out by <a href="http://www.opt-me-in.com/unsubscribe/">clicking here</a>.</p>
          <p>We may process your personal data that is provided in the course of the use of our services (“<strong>service data</strong>“). The service data may include a record of the types of offers you opened, clicked or transacted on. Information
            will be aggregated into verticals e.g. clicked on a retail offer. The source of the service data is your engagement with the emails we send. The service data may be processed for the providing our services and to communicate with you in a
            more effective and relevant manner. The legal basis for this processing is legitimate interest, namely the proper administration of our business.</p>
          <p>We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“<strong>notification data</strong>“). The notification data may be processed for the purposes of sending you
            the relevant notifications and/or newsletters. The legal basis for this processing is consent.</p>
          <p>We may process information contained in or relating to any communication that you send to us (“<strong>correspondence data</strong>“). The correspondence data may include the communication content and metadata associated with the
            communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal
            basis for this processing is legitimate interest, namely the proper administration of our website and business and communications with users.</p>
          <p>We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal
            basis for this processing is our legitimate interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.</p>
          <p>We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is
            our legitimate interest, namely the proper protection of our business against risks.</p>
          <p>In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we
            are subject, or in order to protect your vital interests or the vital interests of another natural person.</p>
          <p>&nbsp;</p>
          <h3>Why We Collect Personal Data</h3>
          <p>&nbsp;</p>
          <p>We collect personal data so that we can target you with offers and content that we believe may be relevant to you. Without profiling you in this manner, we would send you less relevant marketing messages. Profiling may include basic
            information like your postcode and targeting you with local brands. It could be more detailed, such as your salary banding, so that we can send you relevant products for your income bracket. In general, profiles are grouped into segments
            to aid targeting rather than by individual targeting.</p>
          <p>We do not use data for medical or religious purposes. We do not store data to identify sexual orientation, political beliefs or religious beliefs.</p>
          <p>We do aggregate personal data to develop and improve the content we display to you on the website and send you via email. For example, as there is an increase in mobile usage, our design process has used data to understand device usage.
          </p>
          <p>We do use personal data to detect fraudulent activity on our advertising campaigns. For example, this may include detecting invalid applications for a financial product, or detecting too many clicks from the same source.</p>
          <p>We do use your personal data to pass your details onto a FCA approved insurance broker for insurance quotations, manage promotions and competitions you enter, to contact you or select you for a promotion.</p>
          <p>&nbsp;</p>
          <h3>How We Collect Personal Data</h3>
          <p>&nbsp;</p>
          <p>We collect data in 3 ways</p>
          <ul>
            <li>Data you enter by forms, either on our websites, partner websites or through an email we send.</li>
            <li>Browsing data such as views, clicks and transaction history on websites we control</li>
            <li>Open, click and transaction behaviour on emails we send.</li>
          </ul>
          <p>When you register for our Services, you may provide us with:</p>
          <ul>
            <li>Your personal details, including your postal addresses, email addresses, phone numbers, gender and date of birth, title plus home and car insurance information, newsletter preferences and marketing consents. Please note this list is
              not inclusive and you may provide us with other information.</li>
          </ul>
          <p>When you visit our Websites, or open an email from us:</p>
          <ul>
            <li>Data about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it)</li>
            <li>Data about your online browsing behaviour on our Websites and information about when you click on one of our adverts</li>
            <li>Data about what emails you open, and click on.</li>
            <li>Data about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)</li>
          </ul>
          <p>To determine whether the data is relevant, we build a profile of you based on the demographic and behaviour data as described above. This allows us to profile your interests and therefore target you with relevant ads or relevant offers
            and promotions from brands we work with.</p>
          <p>You can opt-out at any point. To do this click on the link marked unsubscribe in the email received from us. Your details will be stored on our system only for suppression purposes. And if we receive your email address again, we will
            automatically remove you from any further communications from us. This suppression method ensures you will never hear from us again. Alternatively, <a href="http://www.opt-me-in.com/unsubscribe/">CLICK HERE </a>to request removal from our
            marketing activity.</p>
          <h3>Personal Email Data We Receive From Third Parties</h3>
          <p>esbconnect manages email data on behalf of third parties. Therefore, you may have signed up to receive third party marketing messages via another website or partner, who have then provided us with your details. To do this, you have
            explicitly opted in for your data to be transferred and used in this manner.</p>
          <p>We do the upmost to ensure a valid opt-in exists. The original data controller will provide us with details of the opt-in and then we will audit the opt-in process and the privacy policy. In most cases, we will be named at point of
            opt-in or you would have opted in to receive marketing messages from certain sectors e.g. charities. If you engage (open/click) on an email from us within the last 365 days, we will continue to mail you. You can opt-out at any point
            either when you receive an email from us by clicking on the unsubscribe link provided. You can also opt out or request details of where your data was originally obtained from us by
            <a href="http://www.opt-me-in.com/unsubscribe/">CLICKING HERE</a></p>
          <p>Although we do the upmost to validate that the opt-in to the original list owner is valid and correct, we can only do so much to prove this. In some cases, it may be incorrect and if you believe this to be the case, please do contact us
            and we will investigate promptly.</p>
          <p>Along with the email address, the original source may also supply us with other personal information about you, such as age, gender, postcode. This is used to help us profile you and send you relevant marketing messages. If you wish us
            to remove this information or update it, please contact us by filling in an enquiry <a href="http://www.opt-me-in.com/unsubscribe/">HERE</a>.</p>
          <h3>The Type of Marketing You Will Receive</h3>
          <p>We will send you emails which contain marketing messages from brands we work with. The headers and footers within the email will make it clear that we are sending it but the content will be provided by the brand we work with.</p>
          <p>The marketing messages you will receive will be relevant to one of the data categories listed below:</p>
          <table>
            <thead>
              <tr>
                <td width="200"><strong>Sector</strong></td>
                <td><strong>Description</strong></td>
              </tr>
            </thead>
            <tbody>
              <tr>
                <td>Retail</td>
                <td>
                  <ul>
                    <li>Online retail</li>
                    <li>General stores</li>
                    <li>Automotive (including Brochures and Test Drives)</li>
                    <li>Property</li>
                    <li>Food and Drink</li>
                    <li>Technology</li>
                    <li>Home furnishings &amp; Improvements</li>
                    <li>Fashion and clothing</li>
                    <li>Telecoms and utilities</li>
                  </ul>
                </td>
              </tr>
              <tr>
                <td>Finance</td>
                <td>
                  <ul>
                    <li>Pensions</li>
                    <li>Loans, credit cards and mortgages</li>
                    <li>Investments &amp; savings</li>
                    <li>Claims Companies</li>
                  </ul>
                </td>
              </tr>
              <tr>
                <td>Insurance</td>
                <td>
                  <ul>
                    <li>Home</li>
                    <li>Car</li>
                    <li>Travel</li>
                    <li>Pet</li>
                    <li>Personal and Life</li>
                    <li>Other insurances</li>
                  </ul>
                </td>
              </tr>
              <tr>
                <td>Travel</td>
                <td>
                  <ul>
                    <li>Holidays</li>
                    <li>Hotel</li>
                    <li>Airlines</li>
                    <li>Travel booking</li>
                  </ul>
                </td>
              </tr>
              <tr>
                <td>Lifestyle</td>
                <td>
                  <ul>
                    <li>Health &amp; Beauty</li>
                    <li>Fitness</li>
                    <li>Charities</li>
                    <li>Media &amp; publishing companies</li>
                    <li>Leisure</li>
                    <li>Gaming</li>
                    <li>Gambling</li>
                    <li>Legal Services</li>
                    <li>Educational institutions</li>
                    <li>Compensation, Legal Services and Personal Injury</li>
                    <li>Injury Compensation Services</li>
                    <li>Careers and Education</li>
                  </ul>
                </td>
              </tr>
              <tr>
                <td>Public Sector</td>
                <td>
                </td>
              </tr>
              <tr>
                <td>Mail Order</td>
                <td>
                </td>
              </tr>
              <tr>
                <td>FMCG</td>
                <td>
                </td>
              </tr>
              <tr>
                <td>Marketing Agencies &amp; Brokers</td>
                <td>
                </td>
              </tr>
            </tbody>
          </table>
          <h3>Sharing Personal Data Within the esbconnect Group</h3>
          <p>We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis set
            out in this policy.</p>
          <p>&nbsp;</p>
          <h3>Sharing Personal Data With Other Organisations</h3>
          <p>We may share personal data with other organisations in the following circumstances:</p>
          <ul>
            <li>with car, life and home insurance companies in order to deliver the quotation service you requested when you visited our website</li>
            <li>if the law or a public authority says we must share the personal data;</li>
            <li>if we need to share personal data to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk);</li>
            <li>to an organisation we sell or transfer (or enter negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the
              organisation receiving your personal data can use your personal data in the same way as us; or</li>
            <li>to any other successors in title to our business.</li>
          </ul>
          <p> We may share your data with third party partners and marketing service providers, which may use such personal data for targeted advertising, measurement, suppression management and identity resolution purposes, including for measurement
            and analytics on campaign performance, personalization, modelling, onboarding, analysis, profiling and linkage. To extend their databases by appending additional information to existing information they may already hold on you. These
            organisations will have a relationship with you or may use your data where they have a lawful reason, which may include these organisation's own legitimate interest. Use of your data may also include 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, and revenue collection.<br>
            <br>When supplying your data with third party partners for purposes including but not limited to online linkage, fraud prevention and tracing, we will rely upon legitimate interests as our legal basis for processing your data. <br>
            <br>Such third-party partners include;<br>
            <br>USM LTD – https://www.usmdigital.co.uk/privacy-policy/ <br>
            <br>Offers You Might Like – [Link: https://offersyoumightlike.com/privacy-policy/ <br>
            <br>GB Group – [Link: https://www.gbgplc.com/en/legal-and-regulatory/products-services-privacy-policy/ <br>
            <br> Roqad, Inc. and companies within it's group - https://www.roq.ad/privacy-policy-roqad/#optout <br>
            <br>Lego - https://www.lego.com/en-gb/legal/notices-and-policies/privacy-policy <br>
            <br> Direct Data Services (DDS) Ltd<br>
            <br>DDS and their partners may share your data with third parties who may use your data for analysis, profiling, linkage, or to extend their databases by appending additional information to existing information they may already hold on
            you. They may also use it for the 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, anti-fraud processes, asset recovery, asset reunification, and revenue collection. For more information on how we process your data, please visit https://www.directdataservices.co.uk/privacy-policy/<br>
            <br><strong>Data OD Ltd</strong><br><br> 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.<br> 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. .<br> 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/<br><br> Mdeg Limited - https://www.mdeg.co.uk/privacy-policy.html<br><br>
          </p>
          <p>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 </p>
          <p>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
          </p>
          <p>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
          </p>
          <p>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 </p>
          <p>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 </p>
          <p>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 </p>
          <br>Aplan Insurance - https://lloydjames.com/wp-content/uploads/2021/06/LJM-Privacy-Policy-090621.pdf <br>
          <br>LocaliQ - https://www.newsquest.co.uk/assets/pdf/marketing-services-cookie-policy.pdf (Co Reg 00019300) - ICO Z6513805<br>
          <br>Sky UK Limited - https://www.sky.com/help/articles/sky-privacy-and-cookies-notice<br>
          <br> IG Index Ltd Registered address at Cannon Bridge House, 25 Dowgate Hill, London EC4R 2YA https://www.ig.com/uk/privacy <br>
          <p></p>
          <p><strong id="providers"><a name="MSP">Marketing Services Providers</a></strong></p>
          <p>We will share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing, testing, research &amp; 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). <br>
            <br> 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 (e.g. to check whether you have recently
            moved address). <br>
            <br>They share your data, including the profiled data they have created about you, primarily to:<br>
          </p>
          <ul>
            <li>help organisations better understand the likely characteristics of their customers (and find others like them); </li>
            <li>improve the relevancy and appropriateness of an organisation’s marketing to its customers (e.g. offers, its products and services); and </li>
            <li>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. </li>
          </ul><br> 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:<p></p>
          <p>Experian Ltd – <a href="https://www.experian.co.uk/privacy/consumer-information-portal/"> https://www.experian.co.uk/privacy/consumer-information-portal/ </a></p>
          <p>MDEG Ltd – https://www.mdeg.co.uk/how-we-process-data.html</p>
          <p>Read Group – https://www.mydatachoices.co.uk/Privacy </p>
          <p>Austinshire Partners – https://privacy.austinshirepartners.com/en/</p>
          <p>Lloyd James Media – https://lloydjames.com/wp-content/uploads/2022/02/LJM-Privacy-Policy-090222-1.pdf</p>
          <p>LiveRamp – https://liveramp.uk/privacy/web-privacy-policy/ </p>
          <p>The Data Partnership Group Ltd T/A TDP Agency (Co Reg 00612316) - ICO ZA537625; https://tdpagency.co.uk/privacy-policy/ </p>
          <p>Solved Digital - https://solved.digital/privacy </p>
          <p>Roqad, Inc. and companies within it's group - https://www.roq.ad/privacy-policy-roqad/#optout </p>
          <p> DataLabs Group– https://datalabsgroup.com/privacy </p>
          <p>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.</p>
          <p>&nbsp;</p>
          <h3>Data Protection – Accessing, Updating, Retaining and Deleting your Personal Data</h3>
          <p>&nbsp;</p>
          <p>This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.</p>
          <p>Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.</p>
          <p>We will retain your personal data as follows:</p>
          <p>(a) Postal address, telephone number and Email address will be retained for a minimum period of 2 years following last click date. We maintain a record of the postal and email address, only to maintain a file of ‘do not mail/email’. Any
            data related to the postal and email address e.g. gender, postcode will be deleted 5 years after the last click date.</p>
          <p>&nbsp;</p>
          <p>In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:</p>
          <p>(a) the period of retention of postal and email address will be determined based on the requirements to maintain a suppression file of people who have opted out.</p>
          <p>Notwithstanding the other provisions of this privacy policy, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests
            or the vital interests of another natural person.</p>
          <p>&nbsp;</p>
          <p>esbconnect adheres to the Data Protection Act 2018, GDPR and PECR. Under this legislation, you have the right to see the personal data we hold about you. This is called a Subject Access Request.</p>
          <p>If you would like a copy of the personal data we hold about you, please go to <a href="http://mydetails.opt-me-in.com/" title="http://mydetails.opt-me-in.com/">http://mydetails.opt-me-in.com/</a> </p>
          <p>&nbsp;</p>
          <p>Or alternatively write to:</p>
          <p>Data Protection Officer, Opt-Me-In, esbconnect, Waverley House, 9 Noel St, Soho, London W1F 8GQ</p>
          <p>We want to make sure that the personal data we hold about you is accurate and up to date. If any of the details are incorrect, please let us know and we will amend those details.</p>
          <p>&nbsp;</p>
          <h3>Your Rights</h3>
          <p>&nbsp;</p>
          <p>In this Section , we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and
            guidance from the regulatory authorities for a full explanation of these rights.</p>
          <p>8.2 Your principal rights under data protection law are:</p>
          <p>(a) the right to access;</p>
          <p>(b) the right to rectification;</p>
          <p>(c) the right to erasure;</p>
          <p>(d) the right to restrict processing;</p>
          <p>(e) the right to object to processing;</p>
          <p>(f) the right to data portability;</p>
          <p>(g) the right to complain to a supervisory authority; and</p>
          <p>(h) the right to withdraw consent.</p>
          <p>To exercise any of these rights, we first need to validate you are the data subject in question, so please complete a Subject Access Request here: http://mydetails.opt-me-in.com/ . Once completed, we will return you a SAR report. From
            here, please reply with details of the right you would like to exercise. Please note that the right to erasure is not an absolute right.</p>
          <p>You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the
            purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first
            copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request this by going to
            <a href="http://mydetails.opt-me-in.com/" title="http://mydetails.opt-me-in.com/">http://mydetails.opt-me-in.com/</a></p>
          <p>You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.</p>
          <p>In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or
            otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been
            unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal
            obligation; or for the establishment, exercise or defense of legal claims. We will never erase your email address, so we can maintain a record that we should not mail you</p>
          <p>In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the
            personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing
            has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of
            another natural or legal person; or for reasons of important public interest.</p>
          <p>You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the
            performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will
            cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of
            legal claims.</p>
          <p>You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to mail you.</p>
          <p>&nbsp;</p>
          <p>To the extent that the legal basis for our processing of your personal data is:</p>
          <p>(a) consent; or</p>
          <p>(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,</p>
          <p>and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely
            affect the rights and freedoms of others.</p>
          <p>If you are not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator which in the UK is the
            Information Commissioner’s Office whose address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF</p>
          <p>8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
            If you wish to withdraw your consent, you can do so by <a href="http://www.opt-me-in.com/unsubscribe/">CLICK HERE</a></p>
          <p>&nbsp;</p>
          <h3>Data Security</h3>
          <p>&nbsp;</p>
          <p>esbconnect has appropriate industry standard technology, physical and administrative procedures in place for a company of our size and complexity to protect the data that is collected and stored. Our software is kept up to date with the
            latest releases to protect against industry known vulnerabilities.</p>
          <p>From time to time we may ask other members of our group, or third party service providers, to help us manage our information technology systems. Some of these systems may be located in countries overseas, including countries located
            outside the European Economic Area (EEA).</p>
          <p>We will only transfer your information to a third party service provider or overseas, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any information being processed and
            compliance with applicable privacy and data protection laws. These measures may include the use of Standard Contractual Clauses, or your consent. You may request further information on the legal security measures used for such transfers
            via the contact details given in this Privacy Notice.</p>
          <p>&nbsp;</p>
          <h3>Social Retargeting</h3>
          <p>Facebook, Snapchat, Instagram, LinkedIn, Google and many other social platforms (marketing partners) offer a service called Custom Audiences. This is where you can upload ‘email addresses’ and target those email addresses with an advert
            via the platform.</p>
          <p>&nbsp;</p>
          <p>We may participate in using the custom audiences function on the platforms mentioned above for the purposes of serving personalised ads based on your interests. This activity is performed by collecting Usage Data and by using cookies and
            other tracking and data collection methodologies discussed above to transfer information to our marketing partners which manage personalised advertising activities.</p>
          <p>Our marketing partners may also use cookies and other tracking and data collection methodologies discussed above to measure advertisement effectiveness and for other purposes that are disclosed in their own privacy policies. We have no
            access or control over these cookies and other tracking and data collection methodologies that may be used by our marketing partners, and we have no responsibility or liability for the privacy policies and practices of these sites.</p>
          <p>AdWords (Google) – We may participate in AdWords program which is a personalized ad service provided by Google Inc. that connects the activity of this site with the Adwords advertising network and the Doubleclick cookie. Information
            collected: cookie and Usage Data. For the opt-out, visit –&gt; https://support.google.com/ads/answer/2662922?hl=en</p>
          <p>Google Analytics for Display Advertising (Google) – We may participate in any and all of the following Google Analytics Advertising Features provided by Google: Google Analytics, Google Display Network Impression Reporting, the
            DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. These features use first party cookies (such as the Google Analytics cookie) for connecting the tracking activity performed by Google
            Analytics and its cookies with the Adwords advertising network and the DoubleClick cookie (a third-party cookie). Information collected: cookie and Usage Data, including audience data such as age, gender, and interests. For the opt-out,
            visit –&gt; <a href="https://support.google.com/ads/answer/2662922?hl=en">https://support.google.com/ads/answer/2662922?hl=en</a> You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at –&gt;
            https://tools.google.com/dlpage/gaoptout</p>
          <p>For information in general about Google’s personalised ad campaigns, and specifically about information regarding DoubleClick cookies and how to control and manage Google’s advertising cookies for these campaigns, visit –&gt;
            http://www.google.com/policies/technologies/ads/</p>
          <p>For another Google resource for opting out of Google’s use of cookies, visit –&gt; http://www.google.com/settings/ads</p>
          <p>For information regarding how Google uses data when you use Google’s partners’ sites or apps, visit –&gt; http://www.google.com/policies/privacy/partners/</p>
          <p>For an additional resource recommended by Google for opting out of a third party vendor’s use of cookies, visit –&gt; http://www.networkadvertising.org/managing/opt_out.asp</p>
          <p>Custom Audience (Facebook). We may participate in Facebook.com’s Custom Audience program which enables us to display personalised ads to persons on our email lists when they visit Facebook.com. We provide Personal Information such as
            your email address and phone number to Facebook to enable Facebook to determine if you are a registered account holder with Facebook. You may opt-out of participation in our Facebook Custom Audience by sending an email, from the email
            address you are opting out of, to the email address provided in our contact information below. For your opt-out to be effective, you must: (i) place the following text in the subject line of the email – “Opting Out of Facebook.com Website
            Custom Audience Ads”, and (ii) in the body of the email, include your name and email address. We will forward your name and email address to Facebook.com with a request to delete you from all of our Facebook Custom Audience Ads.</p>
          <p>Other Personalized and Behavioural Advertising Services. We may participate in additional retargeting and behavioural advertising services that will be similar to the services described above.</p>
          <p>&nbsp;</p>
          <h3>Cookies and Similar Technologies</h3>
          <p>&nbsp;</p>
          <p>We use cookies and similar technologies, such as tags and pixels (“Cookies”) on both our websites and emails we send you. These are used to personalise and improve your customer experience and to provide you with relevant online
            advertising on websites and via email.</p>
          <p>Cookies are small data files that allow us to store settings and identifiers on your desktop computer, laptop or mobile device.</p>
          <p>Cookies help us to provide important features and functionality on our Websites and Mobile Apps, and we use them to improve your customer experience. For example, we use Cookies to do the following:</p>
          <ul>
            <li>Personalise our websites and Mobile Apps for you by remembering your preferences so that you can continue where you left off if you return to a site. This data is stored locally and we do not store this data on our servers.</li>
          </ul>
          <p>We also use cookies for Site Abandonment. This is where we place a script on a partner’s website and when you visit their website, our script looks to see if an esbconnect owned cookie exists on your browser. If it exists it triggers an
            email to be send on the behalf of the advertiser but we will be identified as the data controller and sender. These emails will only be triggered if you have accepted cookies on their site and we have a valid opt-in for you. These will be
            marketing messages from the owner of that website aimed at improving your interaction with their website.</p>
          <p>We may also use cookies for trigger paths, this is where we send a marketing email that has been designated as relevant to individuals that have interacted with an email of ours that you have opened or clicked on.</p>
          <h3>Deliver Relevant Online Advertising</h3>
          <p>Cookies help us to deliver online advertising we believe is relevant to you on our Websites, other organisations’ websites and through emails we send you.</p>
          <p>Cookies used for this purpose are placed on your device by one of our websites or partner websites, emails we send you or on our Websites by other organisations, and always with your permission. These Cookies store information about your
            online activity, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. They may also contain an identifier that links to your email address.</p>
          <p>These cookies enable us to control the frequency and the number of times you may see an advert on your different devices. The cookies also help our advertisers identify potential customers who they feel are relevant for their products.
          </p>
          <p>This means that you may see our adverts or adverts from brands we work with on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.</p>
          <p>To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected, for example what
            emails you have opened or the postcode you provided to us or through one of our partners when you opted-in.</p>
          <p>&nbsp;</p>
          <h3>Measuring the effectiveness of our marketing and advertising</h3>
          <p>Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are
            shown an advert.</p>
          <p>We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you and if this email was advertising a partner, whether you have then
            clicked through onto the partner’s website and made a purchase.</p>
          <p>Cookies we use:</p>
          <table>
            <thead>
              <tr>
                <td width="20"><strong>Cookie</strong></td>
                <td><strong>Purpose</strong></td>
              </tr>
            </thead>
            <tbody>
              <tr>
                <td>Google Analytics</td>
                <td>These cookies allow us to collect information about how visitors use the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and
                  the pages they visited. Click here for an overview of privacy at Google</td>
              </tr>
              <tr>
                <td>Google Adsense</td>
                <td>Google uses cookies to serve more relevant ads across the web and limit the number of times a given ad is shown to you. When you visit a website, view an ad, or click an ad supported by Google’s advertising services, Google may
                  set a cookie on your browser. This advertising cookie will appear in your browser as coming from the domain “doubleclick.net”. Learn more about Googles Policies</td>
              </tr>
              <tr>
                <td>Lotame</td>
                <td>Data management platform, for the purpose of gaining audience insights and enabling consented audience data to be activated on the below platforms. Lotame uses cookies and other identifiers to track online behavioural, demographic
                  and technographic data; they don’t receive information such as your name and email. Lotame can also receive anonymous data segments that The Race sends, such as user IDs associated with people who have been registered members for a
                  certain length of time. Lotame stores data on average for 9 months, and in special cases for up to 18 months. Lotame’s privacy policy: https://www.lotame.com/about-lotame/privacy/lotames-products-services-privacy-policy</td>
              </tr>
              <tr>
                <td>LiveRamp (Acxiom Limited)</td>
                <td>When you use our website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating LIVERAMP CONFIDENTIAL 4 system, with our
                  partner, LiveRamp Inc and its group companies (‘LiveRamp’). LiveRamp may drop a cookie on your browser or directly in our emails and match your shared information to their on- and offline marketing databases and those of its
                  advertising partners to create a link between your browser and information in those other databases. Similarly, when you use our mobile apps, we may also share hashed and de-identified email addresses, mobile device ID, location
                  data, and advertising identifiers with LiveRamp, which uses that information to create a link between your mobile device and its databases. This link may be shared by our partners globally for the purpose of enabling interest-based
                  content or advertising throughout your online experience (e.g. cross device, web, email and in app etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based
                  information to your browser. You have the right to exercise your rights under GDPR including opting out of LiveRamp’s Cookie or Mobile Identifiers and can easily do so by clicking on this link:
                  <a href="https://your-rights.liveramp.uk/home">https://your-rights.liveramp.uk/home</a>
                  <p></p>
                  <p>your connection. You can at any time easily oppose the deposit of our cookie by clicking on this link: <a href="https://liveramp.uk/cookies-101/">https://liveramp.uk/cookies-101/</a>. </p>
                </td>
              </tr>
              <tr>
                <td>ESBConnect Limited</td>
                <td>ESBConnect’s cookies set an identifier linked to your email address this enables us to identify visitors to our advertising clients’ websites and send them a personalised email or serve them personalized ads via display, social,
                  video or mobile. To opt out of ESB Connect Email please <a href="http://www.opt-me-in.com/unsubscribe/">CLICK HERE</a></td>
              </tr>
            </tbody>
          </table>
          <p>You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or another device. You can find more detailed
            information about how you can manage Cookies at the <a href="http://www.allaboutcookies.org/">All About Cookies</a> and <a href="http://www.youronlinechoices.com/uk/">Your Online Choices websites</a>.</p>
          <p>&nbsp;</p>
          <h3>How to Contact us</h3>
          <p>If you have any questions, complaints or suggestions regarding this policy or our data practices, please email, call or mail us:</p>
          <p>Email: <a href="mailto:data@esbconnect.com">data@esbconnect.com</a><br> Telephone: (+44) (0) 2074594985<br> Mail: ESBConnect Ltd, Waverley House, 9 Noel St, Soho, London W1F 8GQ </p>
          <p>&nbsp;</p>
          <h3>Changes to this Privacy Policy</h3>
          <p>ESB Connect will occasionally update this privacy policy. When we do, we will also revise the last updated date.</p>
          <p>Last update: 10/11/2022/p&gt; </p>
        </div>
      </div>
    </div>
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Text Content

Last updated 26/01/2023

WHAT THIS POLICY COVERS

esbconnect is a digital marketing company. Full company details are:

ESB Connect limited is a registered company in the UK under company number
08235436. To contact us by post: please write to:

esbconnect, Waverley House,9 Noel St, Soho, London W1F 8GQ

or via email: hello@esbconnect.com

Our ICO registration number is ZA074763

We work with over 150 High St brands and provide you with personalised marketing
content from these brands via email and social. Our aim is to provide you with
offers and content that we believe may be relevant to you. To see a list of
types of brands we work with, CLICK HERE

esbconnect owns and maintains the following website and emailing brands:
Opt-Me-In, , WeSearch-USave, The Goody Bag, ZestPMI, Lead Switchboard,
WeSearch-UCompare, Your Everyday, Sports Player, One Stop, One Compare UK, Save
Compare, Broadstreet Digital, Universal Savings and esbauto. Our privacy policy
is the same across all websites and brands we maintain, so you know it is us!

Your data will only be on our database if you have consented to sharing your
data with esbconnect, one of its’ owned websites or mailing brands, or with
third-party partners.

You would have opted in via one of our owned websites or via a partner website.
In either case, our opt-in will be present and esbconnect or one it’s mailing
brands like The Goody Bag or Opt-Me-In will be listed within their privacy
policy ‘as somebody who your personal data may be shared with’. You can always
decide to opt-out or choose to not opt-in.

esbconnect is committed to transparency in terms of how we collect and use your
“personal data”.

“Personal data” is defined in Article 4(1) of the GDPR:

“(1) ‘personal data’ means any information relating to an identified or
identifiable natural person (‘data subject’); an identifiable natural person is
one who can be identified, directly or indirectly, in particular by reference to
an identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person”.

That’s why we’ve developed this privacy and cookies policy (“Policy”), which:

* sets out the types of personal data that we collect
* explains how and why we collect and use your personal data
* explains when and why we will share personal data within the ESBConnect Group
and with other organisations; and
* explains the rights and choices you have when it comes to your personal data

ESB Connect Limited or one of its’ mailing brand (referred to in this policy as
“esbconnect” or “us” or “we”) is the Data Controller as defined by the Data
Protection Act 2018. The Data Controller determines the purposes for which and
the way any personal data is or will be processed. esbconnect includes any of
its associated mailing brands: Your Everyday, ESBAuto, Opt-Me-In, The Goody Bag,
WeSearch-USave, WeSearch-UCompare, Sports Player, One Stop, One Compare UK,
Hundreds of Brands, Save Compare, Broadstreet Digital and Universal Savings.

HOW WE USE YOUR PERSONAL DATA

In this Section we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

WHAT DATA IS COLLECTED AND WHAT DO WE PROCESS

esbconnect collects both non-personal and personal data on an ongoing basis.

1. Non-personal data
Web browser details, operating system data, date and time stamps.
2. Personal Data
ESB Connect collects 6 types of personal data

* Internet Protocol (IP) addresses
* Email address, Postal Address, Telephone number and consent data
* Demographic data – such as age, gender, home and car ownership &
insurance, salary bands and address
* Behaviour data (“service data”) – such as what you open, click on and
transaction categories
* Device data – the types of device you use – Desktop, phone and tablet data
* Suppression data – This is where you have unsubscribed from us or a brand.
We store this information to ensure we do not re-contact you in the future
or from a brand you have chosen not to hear from.

In addition to the above, we may append publicly available data to your email
address, postal address or telephone number. For instance, we may match your
postal address to data publicly available through the Land Registry database. We
may also match and append the postal address you provided via one of our
websites to data held within our central database. This data may then be shared
with third parties including Marketing Services Providers

We may process data about your use of the emails we send and visit to our
website and services. (“usage data“). The usage data may include your IP
address, geographical location, browser type and version, operating system,
referral source, which emails you open and do not open, which emails you click
on and do click on, length of visit, page views and website navigation paths, as
well as information about the timing, frequency and pattern of your service use.
The source of the usage data is our analytics tracking system. This usage data
may be processed for the purposes of analysing the use of the website, emails we
send and services. The legal basis for this processing is legitimate interests,
namely monitoring and improving our website, email sending strategy and
services.

We may process your information attached to your email address, for example
postcode or gender, “personal data“. The profile data may include your name,
address, email address, gender, date of birth, relationship status, interests
and hobbies and employment details. The profile data may be processed for
delivering you a better service by providing more relevant marketing and
advertising offers. The legal basis for this processing is consent. Consent was
obtained at the point the email was submitted on our partner websites. At any
point you can opt-out by clicking here.

We may process your personal data that is provided in the course of the use of
our services (“service data“). The service data may include a record of the
types of offers you opened, clicked or transacted on. Information will be
aggregated into verticals e.g. clicked on a retail offer. The source of the
service data is your engagement with the emails we send. The service data may be
processed for the providing our services and to communicate with you in a more
effective and relevant manner. The legal basis for this processing is legitimate
interest, namely the proper administration of our business.

We may process information that you provide to us for the purpose of subscribing
to our email notifications and/or newsletters (“notification data“). The
notification data may be processed for the purposes of sending you the relevant
notifications and/or newsletters. The legal basis for this processing is
consent.

We may process information contained in or relating to any communication that
you send to us (“correspondence data“). The correspondence data may include the
communication content and metadata associated with the communication. Our
website will generate the metadata associated with communications made using the
website contact forms. The correspondence data may be processed for the purposes
of communicating with you and record-keeping. The legal basis for this
processing is legitimate interest, namely the proper administration of our
website and business and communications with users.

We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure. The legal
basis for this processing is our legitimate interest, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice. The legal basis for this
processing is our legitimate interest, namely the proper protection of our
business against risks.

In addition to the specific purposes for which we may process your personal data
set out in this section, we may also process any of your personal data where
such processing is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.

WHY WE COLLECT PERSONAL DATA

We collect personal data so that we can target you with offers and content that
we believe may be relevant to you. Without profiling you in this manner, we
would send you less relevant marketing messages. Profiling may include basic
information like your postcode and targeting you with local brands. It could be
more detailed, such as your salary banding, so that we can send you relevant
products for your income bracket. In general, profiles are grouped into segments
to aid targeting rather than by individual targeting.

We do not use data for medical or religious purposes. We do not store data to
identify sexual orientation, political beliefs or religious beliefs.

We do aggregate personal data to develop and improve the content we display to
you on the website and send you via email. For example, as there is an increase
in mobile usage, our design process has used data to understand device usage.

We do use personal data to detect fraudulent activity on our advertising
campaigns. For example, this may include detecting invalid applications for a
financial product, or detecting too many clicks from the same source.

We do use your personal data to pass your details onto a FCA approved insurance
broker for insurance quotations, manage promotions and competitions you enter,
to contact you or select you for a promotion.

HOW WE COLLECT PERSONAL DATA

We collect data in 3 ways

* Data you enter by forms, either on our websites, partner websites or through
an email we send.
* Browsing data such as views, clicks and transaction history on websites we
control
* Open, click and transaction behaviour on emails we send.

When you register for our Services, you may provide us with:

* Your personal details, including your postal addresses, email addresses,
phone numbers, gender and date of birth, title plus home and car insurance
information, newsletter preferences and marketing consents. Please note this
list is not inclusive and you may provide us with other information.

When you visit our Websites, or open an email from us:

* Data about your online purchases (for example, what you have bought, when and
where you bought it and how you paid for it)
* Data about your online browsing behaviour on our Websites and information
about when you click on one of our adverts
* Data about what emails you open, and click on.
* Data about any devices you have used to access our Services (including the
make, model and operating system, IP address, browser type and mobile device
identifiers)

To determine whether the data is relevant, we build a profile of you based on
the demographic and behaviour data as described above. This allows us to profile
your interests and therefore target you with relevant ads or relevant offers and
promotions from brands we work with.

You can opt-out at any point. To do this click on the link marked unsubscribe in
the email received from us. Your details will be stored on our system only for
suppression purposes. And if we receive your email address again, we will
automatically remove you from any further communications from us. This
suppression method ensures you will never hear from us again. Alternatively,
CLICK HERE to request removal from our marketing activity.

PERSONAL EMAIL DATA WE RECEIVE FROM THIRD PARTIES

esbconnect manages email data on behalf of third parties. Therefore, you may
have signed up to receive third party marketing messages via another website or
partner, who have then provided us with your details. To do this, you have
explicitly opted in for your data to be transferred and used in this manner.

We do the upmost to ensure a valid opt-in exists. The original data controller
will provide us with details of the opt-in and then we will audit the opt-in
process and the privacy policy. In most cases, we will be named at point of
opt-in or you would have opted in to receive marketing messages from certain
sectors e.g. charities. If you engage (open/click) on an email from us within
the last 365 days, we will continue to mail you. You can opt-out at any point
either when you receive an email from us by clicking on the unsubscribe link
provided. You can also opt out or request details of where your data was
originally obtained from us by CLICKING HERE

Although we do the upmost to validate that the opt-in to the original list owner
is valid and correct, we can only do so much to prove this. In some cases, it
may be incorrect and if you believe this to be the case, please do contact us
and we will investigate promptly.

Along with the email address, the original source may also supply us with other
personal information about you, such as age, gender, postcode. This is used to
help us profile you and send you relevant marketing messages. If you wish us to
remove this information or update it, please contact us by filling in an enquiry
HERE.

THE TYPE OF MARKETING YOU WILL RECEIVE

We will send you emails which contain marketing messages from brands we work
with. The headers and footers within the email will make it clear that we are
sending it but the content will be provided by the brand we work with.

The marketing messages you will receive will be relevant to one of the data
categories listed below:

Sector Description Retail
* Online retail
* General stores
* Automotive (including Brochures and Test Drives)
* Property
* Food and Drink
* Technology
* Home furnishings & Improvements
* Fashion and clothing
* Telecoms and utilities

Finance
* Pensions
* Loans, credit cards and mortgages
* Investments & savings
* Claims Companies

Insurance
* Home
* Car
* Travel
* Pet
* Personal and Life
* Other insurances

Travel
* Holidays
* Hotel
* Airlines
* Travel booking

Lifestyle
* Health & Beauty
* Fitness
* Charities
* Media & publishing companies
* Leisure
* Gaming
* Gambling
* Legal Services
* Educational institutions
* Compensation, Legal Services and Personal Injury
* Injury Compensation Services
* Careers and Education

Public Sector Mail Order FMCG Marketing Agencies & Brokers

SHARING PERSONAL DATA WITHIN THE ESBCONNECT GROUP

We may disclose your personal data to any member of our group of companies (this
means our subsidiaries, our ultimate holding company and all its subsidiaries)
insofar as reasonably necessary for the purposes, and on the legal basis set out
in this policy.

SHARING PERSONAL DATA WITH OTHER ORGANISATIONS

We may share personal data with other organisations in the following
circumstances:

* with car, life and home insurance companies in order to deliver the quotation
service you requested when you visited our website
* if the law or a public authority says we must share the personal data;
* if we need to share personal data to establish, exercise or defend our legal
rights (this includes providing personal data to others for the purposes of
preventing fraud and reducing credit risk);
* to an organisation we sell or transfer (or enter negotiations to sell or
transfer) any of our businesses or any of our rights or obligations under any
agreement we may have with you to. If the transfer or sale goes ahead, the
organisation receiving your personal data can use your personal data in the
same way as us; or
* to any other successors in title to our business.

We may share your data with third party partners and marketing service
providers, which may use such personal data for targeted advertising,
measurement, suppression management and identity resolution purposes, including
for measurement and analytics on campaign performance, personalization,
modelling, onboarding, analysis, profiling and linkage. To extend their
databases by appending additional information to existing information they may
already hold on you. These organisations will have a relationship with you or
may use your data where they have a lawful reason, which may include these
organisation's own legitimate interest. Use of your data may also include
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, and revenue
collection.

When supplying your data with third party partners for purposes including but
not limited to online linkage, fraud prevention and tracing, we will rely upon
legitimate interests as our legal basis for processing your data.

Such third-party partners include;

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

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

GB Group – [Link:
https://www.gbgplc.com/en/legal-and-regulatory/products-services-privacy-policy/

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

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

Direct Data Services (DDS) Ltd

DDS and their partners may share your data with third parties who may use your
data for analysis, profiling, linkage, or to extend their databases by appending
additional information to existing information they may already hold on you.
They may also use it for the 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, anti-fraud processes, asset recovery, asset reunification, and
revenue collection. For more information on how we process your data, please
visit https://www.directdataservices.co.uk/privacy-policy/

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/

Mdeg Limited - https://www.mdeg.co.uk/privacy-policy.html

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

Aplan Insurance -
https://lloydjames.com/wp-content/uploads/2021/06/LJM-Privacy-Policy-090621.pdf

LocaliQ -
https://www.newsquest.co.uk/assets/pdf/marketing-services-cookie-policy.pdf (Co
Reg 00019300) - ICO Z6513805

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

IG Index Ltd Registered address at Cannon Bridge House, 25 Dowgate Hill, London
EC4R 2YA https://www.ig.com/uk/privacy

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 (e.g. to check whether you have recently moved
address).

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:

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

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

Read Group – https://www.mydatachoices.co.uk/Privacy

Austinshire Partners – https://privacy.austinshirepartners.com/en/

Lloyd James Media –
https://lloydjames.com/wp-content/uploads/2022/02/LJM-Privacy-Policy-090222-1.pdf

LiveRamp – https://liveramp.uk/privacy/web-privacy-policy/

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

Solved Digital - https://solved.digital/privacy

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

DataLabs Group– https://datalabsgroup.com/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.

DATA PROTECTION – ACCESSING, UPDATING, RETAINING AND DELETING YOUR PERSONAL DATA

This Section sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation to
the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for
longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

(a) Postal address, telephone number and Email address will be retained for a
minimum period of 2 years following last click date. We maintain a record of the
postal and email address, only to maintain a file of ‘do not mail/email’. Any
data related to the postal and email address e.g. gender, postcode will be
deleted 5 years after the last click date.

In some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will determine the
period of retention based on the following criteria:

(a) the period of retention of postal and email address will be determined based
on the requirements to maintain a suppression file of people who have opted out.

Notwithstanding the other provisions of this privacy policy, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.

esbconnect adheres to the Data Protection Act 2018, GDPR and PECR. Under this
legislation, you have the right to see the personal data we hold about you. This
is called a Subject Access Request.

If you would like a copy of the personal data we hold about you, please go to
http://mydetails.opt-me-in.com/

Or alternatively write to:

Data Protection Officer, Opt-Me-In, esbconnect, Waverley House, 9 Noel St, Soho,
London W1F 8GQ

We want to make sure that the personal data we hold about you is accurate and up
to date. If any of the details are incorrect, please let us know and we will
amend those details.

YOUR RIGHTS

In this Section , we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant laws
and guidance from the regulatory authorities for a full explanation of these
rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

To exercise any of these rights, we first need to validate you are the data
subject in question, so please complete a Subject Access Request here:
http://mydetails.opt-me-in.com/ . Once completed, we will return you a SAR
report. From here, please reply with details of the right you would like to
exercise. Please note that the right to erasure is not an absolute right.

You have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the
purposes of the processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of others are
not affected, we will supply to you a copy of your personal data. The first copy
will be provided free of charge, but additional copies may be subject to a
reasonable fee. You can request this by going to http://mydetails.opt-me-in.com/

You have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete
personal data about you completed.

In some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have been
unlawfully processed. However, there are exclusions of the right to erasure. The
general exclusions include where processing is necessary: for exercising the
right of freedom of expression and information; for compliance with a legal
obligation; or for the establishment, exercise or defense of legal claims. We
will never erase your email address, so we can maintain a record that we should
not mail you

In some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the personal
data; processing is unlawful but you oppose erasure; we no longer need the
personal data for the purposes of our processing, but you require personal data
for the establishment, exercise or defence of legal claims; and you have
objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent;
for the establishment, exercise or defence of legal claims; for the protection
of the rights of another natural or legal person; or for reasons of important
public interest.

You have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate interests
pursued by us or by a third party. If you make such an objection, we will cease
to process the personal information unless we can demonstrate compelling
legitimate grounds for the processing which override your interests, rights and
freedoms, or the processing is for the establishment, exercise or defence of
legal claims.

You have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to mail you.

To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which
you are party or in order to take steps at your request prior to entering into a
contract,

and such processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.

If you are not satisfied with the way any complaint you make in relation to your
personal information is handled by us then you may be able to refer your
complaint to the relevant data protection regulator which in the UK is the
Information Commissioner’s Office whose address is Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF

8.12 To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any time.
Withdrawal will not affect the lawfulness of processing before the withdrawal.
If you wish to withdraw your consent, you can do so by CLICK HERE

DATA SECURITY

esbconnect has appropriate industry standard technology, physical and
administrative procedures in place for a company of our size and complexity to
protect the data that is collected and stored. Our software is kept up to date
with the latest releases to protect against industry known vulnerabilities.

From time to time we may ask other members of our group, or third party service
providers, to help us manage our information technology systems. Some of these
systems may be located in countries overseas, including countries located
outside the European Economic Area (EEA).

We will only transfer your information to a third party service provider or
overseas, where we are satisfied that adequate levels of protection are in place
to protect the integrity and security of any information being processed and
compliance with applicable privacy and data protection laws. These measures may
include the use of Standard Contractual Clauses, or your consent. You may
request further information on the legal security measures used for such
transfers via the contact details given in this Privacy Notice.

SOCIAL RETARGETING

Facebook, Snapchat, Instagram, LinkedIn, Google and many other social platforms
(marketing partners) offer a service called Custom Audiences. This is where you
can upload ‘email addresses’ and target those email addresses with an advert via
the platform.

We may participate in using the custom audiences function on the platforms
mentioned above for the purposes of serving personalised ads based on your
interests. This activity is performed by collecting Usage Data and by using
cookies and other tracking and data collection methodologies discussed above to
transfer information to our marketing partners which manage personalised
advertising activities.

Our marketing partners may also use cookies and other tracking and data
collection methodologies discussed above to measure advertisement effectiveness
and for other purposes that are disclosed in their own privacy policies. We have
no access or control over these cookies and other tracking and data collection
methodologies that may be used by our marketing partners, and we have no
responsibility or liability for the privacy policies and practices of these
sites.

AdWords (Google) – We may participate in AdWords program which is a personalized
ad service provided by Google Inc. that connects the activity of this site with
the Adwords advertising network and the Doubleclick cookie. Information
collected: cookie and Usage Data. For the opt-out, visit –>
https://support.google.com/ads/answer/2662922?hl=en

Google Analytics for Display Advertising (Google) – We may participate in any
and all of the following Google Analytics Advertising Features provided by
Google: Google Analytics, Google Display Network Impression Reporting, the
DoubleClick Campaign Manager integration, and Google Analytics Demographics and
Interest Reporting. These features use first party cookies (such as the Google
Analytics cookie) for connecting the tracking activity performed by Google
Analytics and its cookies with the Adwords advertising network and the
DoubleClick cookie (a third-party cookie). Information collected: cookie and
Usage Data, including audience data such as age, gender, and interests. For the
opt-out, visit –> https://support.google.com/ads/answer/2662922?hl=en You may
opt-out of the Google Analytics service with the Google’s Browser Add-on that’s
available at –> https://tools.google.com/dlpage/gaoptout

For information in general about Google’s personalised ad campaigns, and
specifically about information regarding DoubleClick cookies and how to control
and manage Google’s advertising cookies for these campaigns, visit –>
http://www.google.com/policies/technologies/ads/

For another Google resource for opting out of Google’s use of cookies, visit –>
http://www.google.com/settings/ads

For information regarding how Google uses data when you use Google’s partners’
sites or apps, visit –> http://www.google.com/policies/privacy/partners/

For an additional resource recommended by Google for opting out of a third party
vendor’s use of cookies, visit –>
http://www.networkadvertising.org/managing/opt_out.asp

Custom Audience (Facebook). We may participate in Facebook.com’s Custom Audience
program which enables us to display personalised ads to persons on our email
lists when they visit Facebook.com. We provide Personal Information such as your
email address and phone number to Facebook to enable Facebook to determine if
you are a registered account holder with Facebook. You may opt-out of
participation in our Facebook Custom Audience by sending an email, from the
email address you are opting out of, to the email address provided in our
contact information below. For your opt-out to be effective, you must: (i) place
the following text in the subject line of the email – “Opting Out of
Facebook.com Website Custom Audience Ads”, and (ii) in the body of the email,
include your name and email address. We will forward your name and email address
to Facebook.com with a request to delete you from all of our Facebook Custom
Audience Ads.

Other Personalized and Behavioural Advertising Services. We may participate in
additional retargeting and behavioural advertising services that will be similar
to the services described above.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies, such as tags and pixels (“Cookies”) on
both our websites and emails we send you. These are used to personalise and
improve your customer experience and to provide you with relevant online
advertising on websites and via email.

Cookies are small data files that allow us to store settings and identifiers on
your desktop computer, laptop or mobile device.

Cookies help us to provide important features and functionality on our Websites
and Mobile Apps, and we use them to improve your customer experience. For
example, we use Cookies to do the following:

* Personalise our websites and Mobile Apps for you by remembering your
preferences so that you can continue where you left off if you return to a
site. This data is stored locally and we do not store this data on our
servers.

We also use cookies for Site Abandonment. This is where we place a script on a
partner’s website and when you visit their website, our script looks to see if
an esbconnect owned cookie exists on your browser. If it exists it triggers an
email to be send on the behalf of the advertiser but we will be identified as
the data controller and sender. These emails will only be triggered if you have
accepted cookies on their site and we have a valid opt-in for you. These will be
marketing messages from the owner of that website aimed at improving your
interaction with their website.

We may also use cookies for trigger paths, this is where we send a marketing
email that has been designated as relevant to individuals that have interacted
with an email of ours that you have opened or clicked on.

DELIVER RELEVANT ONLINE ADVERTISING

Cookies help us to deliver online advertising we believe is relevant to you on
our Websites, other organisations’ websites and through emails we send you.

Cookies used for this purpose are placed on your device by one of our websites
or partner websites, emails we send you or on our Websites by other
organisations, and always with your permission. These Cookies store information
about your online activity, such as your IP address, the website you arrived
from and information about your purchase history or the content of your shopping
basket. They may also contain an identifier that links to your email address.

These cookies enable us to control the frequency and the number of times you may
see an advert on your different devices. The cookies also help our advertisers
identify potential customers who they feel are relevant for their products.

This means that you may see our adverts or adverts from brands we work with on
our Websites and on other organisations’ websites. You may also see adverts for
other organisations on our Websites.

To help us to deliver online advertising that is relevant to you, we may also
combine data we collect through Cookies in the browser of your desktop computer
or other devices with other data that we have collected, for example what emails
you have opened or the postcode you provided to us or through one of our
partners when you opted-in.

MEASURING THE EFFECTIVENESS OF OUR MARKETING AND ADVERTISING

Cookies can tell us if you have seen a specific advert, and how long it has been
since you have seen it. This information allows us to measure the effectiveness
of our online advertising campaigns and control the number of times you are
shown an advert.

We also use Cookies to measure the effectiveness of our marketing
communications, for example by telling us if you have opened a marketing email
that we have sent you and if this email was advertising a partner, whether you
have then clicked through onto the partner’s website and made a purchase.

Cookies we use:

Cookie Purpose Google Analytics These cookies allow us to collect information
about how visitors use the website. The cookies collect information in an
anonymous form, including the number of visitors to the site, where visitors
have come to the site from and the pages they visited. Click here for an
overview of privacy at Google Google Adsense Google uses cookies to serve more
relevant ads across the web and limit the number of times a given ad is shown to
you. When you visit a website, view an ad, or click an ad supported by Google’s
advertising services, Google may set a cookie on your browser. This advertising
cookie will appear in your browser as coming from the domain “doubleclick.net”.
Learn more about Googles Policies Lotame Data management platform, for the
purpose of gaining audience insights and enabling consented audience data to be
activated on the below platforms. Lotame uses cookies and other identifiers to
track online behavioural, demographic and technographic data; they don’t receive
information such as your name and email. Lotame can also receive anonymous data
segments that The Race sends, such as user IDs associated with people who have
been registered members for a certain length of time. Lotame stores data on
average for 9 months, and in special cases for up to 18 months. Lotame’s privacy
policy:
https://www.lotame.com/about-lotame/privacy/lotames-products-services-privacy-policy
LiveRamp (Acxiom Limited) When you use our website, we share information that we
may collect from you, such as your email (in hashed, de-identified form), IP
address or information about your browser or operating LIVERAMP CONFIDENTIAL 4
system, with our partner, LiveRamp Inc and its group companies (‘LiveRamp’).
LiveRamp may drop a cookie on your browser or directly in our emails and match
your shared information to their on- and offline marketing databases and those
of its advertising partners to create a link between your browser and
information in those other databases. Similarly, when you use our mobile apps,
we may also share hashed and de-identified email addresses, mobile device ID,
location data, and advertising identifiers with LiveRamp, which uses that
information to create a link between your mobile device and its databases. This
link may be shared by our partners globally for the purpose of enabling
interest-based content or advertising throughout your online experience (e.g.
cross device, web, email and in app etc.) by third parties unaffiliated with our
website. These third parties may in turn link further demographic or
interest-based information to your browser. You have the right to exercise your
rights under GDPR including opting out of LiveRamp’s Cookie or Mobile
Identifiers and can easily do so by clicking on this link:
https://your-rights.liveramp.uk/home

your connection. You can at any time easily oppose the deposit of our cookie by
clicking on this link: https://liveramp.uk/cookies-101/.

ESBConnect Limited ESBConnect’s cookies set an identifier linked to your email
address this enables us to identify visitors to our advertising clients’
websites and send them a personalised email or serve them personalized ads via
display, social, video or mobile. To opt out of ESB Connect Email please CLICK
HERE

You can use your browser settings to accept or reject new Cookies and to delete
existing Cookies. You can also set your browser to notify you each time new
Cookies are placed on your computer or another device. You can find more
detailed information about how you can manage Cookies at the All About Cookies
and Your Online Choices websites.

HOW TO CONTACT US

If you have any questions, complaints or suggestions regarding this policy or
our data practices, please email, call or mail us:

Email: data@esbconnect.com
Telephone: (+44) (0) 2074594985
Mail: ESBConnect Ltd, Waverley House, 9 Noel St, Soho, London W1F 8GQ

CHANGES TO THIS PRIVACY POLICY

ESB Connect will occasionally update this privacy policy. When we do, we will
also revise the last updated date.

Last update: 10/11/2022/p>

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