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, together with its group companies, operates the App, its related website: https://pushthatbutton.co.uk/ (the “Website”) and the services available through the App and/or Website (together with the App and Website, the “Services”).

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, and enter, Competitions being run by their favourite Talent, refer friends to our App, store the voucher codes won during a Competition, and sign up to our mailing list;
“Prospective Users”, meaning individuals who have not yet created a User Account but who may be interested in doing so, 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.

For the avoidance of doubt, 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.

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.

Capitalised terms which are not defined in this Privacy Notice shall have the same meaning as is ascribed to them in the User Agreement.

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 you, or any Prospective Users you invite to our Services
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
location

If you enter Competitions, details of the Competitions you have entered, together with any prizes or voucher codes you win, and any prizes or voucher codes you have successfully redeemed, 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
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
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 you.

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.

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
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.

Our App uses cookies and similar tracking technologies to collect and log this Analytics Data. To find out more about the use of cookies and similar technologies, please see our Cookie Policy here.

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
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.

Competition Winner Data

Information about the Identity of Competition Winner(s)

If you are a competition winner, we may collect and process your proof of identity and screenshot(s) of your social media activity for the purposes of verifying your identity as the competition winner, fulfilling the competition, and to enable the Talent to provide the competition prize to you.

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: 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; and (iii) other relevant purposes.

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.

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 any 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 18 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.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

9. INTERNATIONAL DATA TRANSFERS

Our servers are located in the EU.

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.