PRIVACY POLICY
1. INTRODUCTION
PTB Group Ltd is a company registered in England under company number 13710528 and whose registered office is Office One 1 Coldbath Square, Farringdon, London, England, EC1R 5HL (“PTB”, “we”, “us” or “our”) in this privacy notice (the “Privacy Notice” ).
“Push that button” is an app (the “App” ) that allows you to search for, and enter, “Competitions” being run by your favourite brands and talent (together, “Talent” ) for a chance to win exciting prizes. PTB operates the App, its related website: https://pushthatbutton.co.uk/ (the “Website” ) and the services available through the App and/or Website.
This Privacy Notice explains how we will process your personal data when we provide the “Services” which allow:
- “Users” to register for an account on our App, search the App for Competitions being run by their favourite Talent, refer friends to our App;
- “Prospective Users” to follow a referral link to our Services sent to them by a User;
- “Website Visitors” to view our Website, and sign up to our mailing list; and
- “Talent” to work with us in order to run a Competition via the App.
When we decide the purpose or means of processing your personal data, we are the ‘controller’ of that personal data. This will be the case in respect of personal data we process while providing the Services. We are committed to protecting and respecting your privacy and will comply with all applicable data protection laws (including the General Data Protection Regulation 2016/679 as it forms part of the law in the EU and UK) whenever we are a ‘controller’ of your data.
PTB does not, however, control the processing of personal data as part of a User’s entry into a Competition or administration of that Competition. The relevant Talent will be the ‘controller’ of personal data processed in relation to such Competition(s) and we will be the ‘processor’, meaning that we will act on the Talent’s instructions. Please therefore refer to the relevant Talent’s privacy notice for details of how your personal data will be processed as part of your entry into, and the administration of a Competition. We do not accept any responsibility or liability for the data processing practices of Talent or third party services that may be linked to within our Services.
If you have any questions or comments about this Privacy Notice, please contact us at privacy@pushthatbutton.co.uk
Please read this Privacy Notice carefully as it contains important information about:
- what information we may collect about you;
- how we will use information we collect about you;
- whether we will disclose your details to anyone else;
- and your choices and rights regarding the personal data you have provided to us.
We may make changes to this Privacy Notice in future, which will be posted on this page. Please check this page regularly for any updates.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
User Account Data
Information provided by you when you register for a User account
If you are a User registering for a User account on the App, we will collect your:
- first name;
- last name;
- email address;
- phone number;
- gender;
- age;
- password;
- contact details of, and referral codes sent to, Prospective Users you invite to our Services; and
- social media handles.
If you do not provide this information, we will not be able to register your User account.
Once you’ve registered for a User account, you will be given a profile page on which you may provide additional voluntary information that is made visible on your profile to other Users. You are under no obligation to provide this information, but it may include:
- profile picture
- social media channel links
- personal website links;
- bio information; and
- location
If you enter Competitions, details of the Competitions you have entered, together with any prizes or voucher codes you win, may be saved to your profile.
Talent Data
Information provided by you when working with PTB
If you are Talent, or a member of Talent’s team who runs Competitions with us, we will collect your:
- first name;
- last name;
- Talent’s name you represent (if relevant);
- address;
- email address;
- phone number;
- social media handles (or Talent social media handles, if relevant);
- Competition details; and
- prize details (including voucher codes).
If you do not provide certain of this information, we may not be able to provide our Services to you.
Enquiry and Support Data
Information provided by you when you submit an enquiry or ask us for support
We provide our support services via email. The information we may process in connection with this may include:
- first name
- last name
- email address;
- username;
- (if you are a User) information contained within your User Account (including profile page);
- (if you are Talent) information obtained when working with you to run a Competition;
- the element of our Services causing an issue for you;
- a description and / or screenshots of the issue you are experiencing;
- content files, where relevant; and
- any other information you choose to provide us when communicating with us or asking for support.
if you do not provide this information, we may not be able to support your request or answer your enquiry. If you submit and enquiry or ask us for support via social media, we may also process the information listed under ‘Social Media Data’ below.
Analytics Data
Technical information about your use of our Services
If you are a User or Website Visitor using our Services, we collect technical information about your use of them.
We may collect the following data points from people who use our Platforms: [average pages per session, which website our Users or Website Visitors have come from, Users’ / Website Visitors’ device and operating system, time of day that the Services are used, general location, average time on a Service page, button clicks, number of views on a Service page, depth of scroll down a Service page, number of Competitions entered, email open and click-through rate, and whether a visitor is a new or returning visitor].
We may aggregate this information so that it is no longer possible to identify you from it in connection with the insights we may provide to Talent. See ‘To anonymise and aggregate data'; in section 3 below for further information.
You are under no obligation to provide your consent to us placing cookies or similar tracking technologies, (and therefore collecting this information), and if you do not provide your consent, we shall not process this information.
Social Media Data
Information processed in relation to your social media account(s), pages or channels
Where you follow PTB’s social media accounts, interact with our content, or choose to add your social media handles to your account with us, we may be able to see personal data from your social media profile (depending on your social media privacy settings), including:
- name (and/or your social media unique username);
- email and/or postal address;
- location;
- telephone number(s);
- IP or MAC address;
- gender and/or age;
- correspondence with us through those channels; and
- general interests and preferences (e.g. Likes, Follows, Shares, Posts).
You are under no obligation to interact with PTB’s social media accounts.
If you post or upload any content about a specific Competition to your social media channels in order to obtain additional entries to the Competition, PTB processes any personal data in connection with this as a processor on behalf of Talent. Please therefore refer to the relevant Talent’s privacy notice for details.
When you use social media platforms, your information will be processed under those social media platforms’ respective privacy policies which can be found on their websites.
Marketing Data
Information about your marketing preferences
When Users or Website Visitors sign-up to receive updates, newsletters or other information from us, we will collect your name, email address and information about whether or not you have provided, or declined to provide, consent to receive marketing from us.
You are under no obligation to sign up to receive marketing from us.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide Services to you
We may use User Account Data, Talent Data, Enquiry and Support Data and (to the extent you submit an enquiry or request for support through social media), Social Media Data to deliver Services to you in accordance with the terms agreed between us (the User Agreement if you are a User or Website Visitor, or the Talent Agreement if you are Talent). The processing of information in this way is necessary for us to deliver our Services to you, understand how best we can support you via the provision of our Services and communicate with you.
Legal basis under UK GDPR: performance of contract.
To manage our relationship with you, respond to your enquiries and requests for support
We may process User Account Data, Talent Data, Enquiry and Support Data and (to the extent you submit an enquiry or request for support through social media), Social Media Data to respond to your questions, enquiries, complaints and support requests.
This processing is necessary for us to pursue our legitimate interests of: (i) ensuring that our Services function properly so that you and others have the best support and experience; (ii) improving the quality of our Services; and (iii) identifying and correcting any issues experienced in relation to our Services or the App.
Legal basis under UK GDPR: legitimate interests (listed above).
To send you our direct marketing
We may process Marketing Data, User Account Data and Talent Data for our mailing lists and to keep you updated with information on news, offers, and updates about our Services. You can revoke your consent at any time – if you’d like to do so, please let us know by clicking “unsubscribe” at the bottom of any marketing email that you receive, or by sending an email to privacy@pushthatbutton.co.uk.
Legal basis under UK GDPR: consent.
To help us improve the services and fix any problems
We may process Analytics Data, User Account Data, Talent Data, Enquiry and Support Data and Social Media Data so that we can analyse and improve our Services, through knowledge of how the Services are used.
Where the relevant information has been collected using cookies, this processing is based on your consent. To find out more about the use of cookies and similar technologies, please see our Cookie Policy here
Otherwise, we rely on the legal basis of our legitimate interests in: (i) ensuring that our Services function properly so that you and other Users and Website visitors have the best experience; (ii) improving the quality of our Services; and (iii) identifying and correcting any bugs.
Legal basis under UK GDPR: (a) Consent, where we have collected personal data via cookies or similar tracking technologies; and (b) otherwise, legitimate interests (listed above).
To anonymise and aggregate data
We may anonymise and aggregate Analytics Data, User Account Data, Talent Data, Enquiry and Support Data and Social Media Data so that we can produce information about general trends and insights about the use of our Services to Talent. This processing is based on our (and your) legitimate interests of: (i) protecting your privacy, by ensuring that you cannot be identified by trends/insights information shared with Talent; and (ii) maintaining effective relationships with Talent, by providing aggregated and anonymised data.
For more information about how we share anonymised and aggregated information with Talent, please see section 4, “Data Sharing” below.
Legal basis under UK GDPR: legitimate interests (listed above).
To prevent fraud and illegal activity
We may process any of the categories of personal data listed above for our legitimate interests of: (i) ensuring that any use of the Services is lawful and non-fraudulent, does not disrupt the operation of our Services, does not harass our personnel or other individuals, (ii) enforcing our legal rights, and (iii) investigating complaints. We also process personal data to comply with our regulatory and corporate governance obligations.
Where we reasonably believe that you are, or may be, in breach of any applicable laws or our terms of use, we may use your personal data to inform relevant third parties such as law enforcement agencies about the breach.
Legal basis under UK GDPR: legitimate interests (listed above) and legal obligation.
4. DATA SHARING
We will share your information with third parties only in the ways that are described in this Privacy Notice
Personnel: We seek to keep your information confidential but may disclose it to our personnel insofar as it is reasonably necessary for the purposes set out in this Privacy Notice.
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may be required to share your personal data with the parties involved in the transaction. You will be notified via [an account message, email and/or a prominent notice on our Services] of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data in such instances.
Required by law: We may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, Users, Talent or others.
Third Party Suppliers: We use a range of suppliers to operate our business and provide our Services. Suppliers who may receive your personal data for the reasons set out in this Privacy Notice include:
IT Service Providers: We use a range of suppliers to provide our business infrastructure, including email service providers, web hosts, IT support consultants, and suppliers of security technology.
Aggregated data: We may disclose aggregated and anonymised data to Talent (and their teams) about trends and insights relating to our Services. We won’t share information about any one person’s activity on the App, nor will it be possible to identify any one person from the aggregated data that is shared.
Talent: We may share relevant data to Talent for the purposes of you receiving prizes under a competition
5.YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, although each right is subject to certain qualifications, requirements and exemptions. You can contact us to make a request to exercise one of your rights (including by sending an email to privacy@pushthatbutton.co.uk.
- Right to be informed: A right to be informed about the collection and use of your personal data (as explained in this Privacy Notice).
- Right to access and rectification: A right to ask for a copy of data we are processing about you and have inaccuracies corrected.
- Right to object, erasure and restrict processing: You can ask us to restrict, stop processing, or to delete your personal data.
- Right to data portability: A right to obtain a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer.
- Right to complain: You may make a complaint to a data protection regulator, contact information for the Information Commissioner’s Office, the UK’s independent authority setup to uphold information rights, is available here: https://ico.org.uk/make-a-complaint/.
6.Data Retention
We will hold your personal data for as long as is necessary for the relevant purpose and to maintain business records for tax, legal and regulatory reasons, or as otherwise described in this Privacy Notice.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
Where we anonymise and aggregate your personal data (so that it can no longer be associated with you), we may retain this information for a longer period and use this information for research or statistical purposes, as well as sharing it with Talent as described above.
7.CHILDREN
We do not use our Services or App to knowingly solicit information from, or market to, children under the age of 18. Our terms of use prohibit users aged under 18 years from using our App. If we learn that we have collected personal data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that we might have any personal data from or about a child under 13 years of age, please contact us at privacy@pushthatbutton.co.uk
8.SECURITY
We will take all reasonable technical and organisational precautions to prevent the loss, misuse or unauthorised alteration of your personal data.
We will take all reasonable technical and organisational precautions to prevent the loss, misuse or unauthorised alteration of your personal data.
9.INTERNATIONAL DATA TRANSFERS
Our servers are located in Ireland.
Where we transfer your information outside of the UK, we will have agreements in place with the recipient which include standard data protection clauses adopted by the Information Commissioner’s Office to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by emailing privacy@pushthatbutton.co.uk
It is possible that your personal data may be transferred outside of the UK by Talent or other third parties, such as social media providers. We recommend that you refer to the privacy policies and/or terms and conditions of these parties if you are concerned about your data being transferred internationally.
CONTACT INFORMATION
All questions, comments or enquiries should be directed to us at privacy@pushthatbutton.co.uk