Earn Your Swag

Privacy Policy

Last Updated: 22nd August 2023

Who Are We?

Earn Your Swag (United Kingdom)(“Earn Your Swag”, “we”, ”us”, “our”) is the registered owner of this reward website and a trading name for Lead On Digital Ltd (company number – 13244619).

Earn Your Swag owns all rights, including the sites respective IP, copyrights and trademarks. We respect your privacy and are committed to protecting it through our compliance with this Privacy Notice.

This Privacy Policy applies to the Earn Your Swag website.

uk.earnyourswag.com

EU-wide data protection legislation known as the “General Data Protection Regulation” or “GDPR” took effect from May 25th, 2018. Following the UK’s withdrawal from the European Union on 31st January 2020, the GDPR has been retained in domestic law as the UK General Data Protection Regulation “UK GDPR” (a copy of which is posted here) , but the UK has the independence to keep the framework under review. The UK GDPR sits alongside an amended version of the Data Protection Act 2018.

For the purposes of the UK GDPR, Earn Your Swag is the registered data controller with the Information Commissioner’s Office (ICO) our registration number is ZA937898.

This website Privacy Policy is intended to meet our duties of Transparency under the UK GDPR, the Data Protection Act 2018 and all other applicable privacy laws.

For further information, please visit https://ico.org.uk/.

Purpose of this Privacy Policy

This Privacy Policy clearly indicates how we manage, utilise and protect your personal data collected while using our site. We will only use or share your personal data in a manner that is in accordance with our Privacy Policy, and as stated within our registration opt-in definition. Personal data will not be shared unless your consent has been secured. Consent is obtained during the registration process, when specific and clear statements are prominently displayed on our site.

What information do we collect?

Personal Data

We collect your details when you register or visit one of our websites; subscribe to our service; correspond with us by e-mail or otherwise. ‘Personal data’ means the information you provide during the registration process and any information you provide when entering our reward program or surveys within our websites. Registration is required to participate in any program of the site, however merely browsing does not require registration.

As permitted by applicable law, we may collect, use, store and transfer different kinds of Personal Data about you when you use our services. We have grouped these into the following categories of Personal Data:

Identity Data such as first name, last name, social media profile, username
Contact Data such as billing addresses, email addresses and telephone numbers
Transaction Data such as details about payments to you and details regarding offers you have signed up to or services that you have subscribed to in relation to this Website
Technical Data such as your Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website
Profile Data such as your username, additional personal data added to your account (e.g. your home address), preferences, orders made by you, dates you cash-out
Usage Data such as information about how you use our Website, products and services
Marketing and Communications Data such as your preferences in receiving marketing from us and our third-parties

We do not require any special categories of personal data about you (e.g. religion, race, ethnic origin, politics, genetics, health, sexual orientation). Please do not provide this type of personal data to us.

Non-Personal Data

We also collect, use and share Aggregated Data such as statistical or demographic data which does not directly or indirectly reveal your identity. We use aggregate data for analysing our website usage, for example, to calculate the percentage of users accessing a specific feature on our website.

Our Legitimisation for processing your personal data

Earn Your Swag Purpose & Legal Basis for Processing User’s Personal Data -

As follows:

Your data is only processed when you consent to our website by signing up optionally and clicking the continue pathway. This creates an account.
Legitimate Interest (LI). At Earn Your Swag we have spent time carefully thinking through and activating all required Legitimate Interest Assessments to ensure they are in line with yours. This means that as well as having your consent, we will keep your email address so we can easily manage how you operate within our service. It also means that we might store data and process it to stop users or unsubscribe users. As an example, if a user wants to unsubscribe or stop receiving email or other written communication from Earn Your Swag or want to re-subscribe to the website, we need to keep their data information on record (this means name, IP address, email address) so that we can respond to any requests such as those mentioned.
A user may still remove himself or herself, in which case all personal information stored will be removed and deleted. If they re-subscribe, they will be registered as a brand-new user and can sign up with the same details as previously listed.
Personalisation and Serving of Relevant Advertising (or “ads”), sometimes referred to as “automated decision making”. We aim to provide users the best experience by analysing user activity to provide advertisements that should be of interest to you. While the Earn Your Swag website is free to use, it is funded by trusted third party partners/companies. When you visit our website and register, you will be shown relevant advertisements from time to time. If you click on an advertisement, you will be redirected from our website and then must accept the privacy policies of the website of direction. That means that we hold no risk or liability once you have left the Earn Your Swag website.
Use of your Personal Data. This is only used while participating in our reward programs. That means we only collect adequate, relevant data that is limited to what is needed to deliver our service to the user in accordance to Article 5 (1), (c) of GDPR. This includes your chosen username and email address (to enable you to participate in our service and to contact you). Should you click on a link to an external site, this means you will be bound by the privacy policies of the website of direction and we hold no risk or liability once you have left the Earn Your Swag website.
Contact and Communication. Contacting our website or our owners is done at your own discretion. Your personal information is privately and securely stored and remains private until it has no use or is no longer required (in accordance with the Data Protection Act 1998). We do our very best to maintain a safe and secure email submission process, but always advise our users that using our communication form is at their own risk. The Earn Your Swag website uses any information received to provide you with information about products and services that we offer to help you answer any queries you have submitted to us via email. This will include using your personal data to subscribe you to our email newsletter database. However, this will always be made clear to you and your permission will be requested before submitting any email form. Your personal details are never passed on to third parties. If you have previously enquired about Earn Your Swag using the email submission form, your data may also be kept and used for email newsletter purposes.
Branded Surveys with specific consent to our partners. Your registration details and any other survey information that you submit will be passed through to the clearly indicated partner. Inclusion in any branded surveys is totally optional and non- participation will not affect your use and enjoyment of the site.
Where appropriate, relevant (and with consent) communicate your data to our trusted partners. You may object to this processing at any time by emailing us: info@earnyourswag.com

How your data is collected

Directly

You may give us your identity, contact, profile data, and marketing and communications data by filling in a form or corresponding with us by post, phone, e-mail or otherwise.

This includes Personal Data you provide when you:

Create an account on our website
Update your profile
Choose your marketing preferences for both email and push notifications
Give us feedback
Email customer service
Request information be sent to you

Indirectly

We may collect your transaction data, technical data and usage data when you interact with our website. We collect this Personal and Non-Personal Data by using cookies, server logs and other similar technologies. We may receive this data from various third-parties such as analytics providers or advertising networks.

We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies or Tracking Technologies (defined below).

Disclosure of your Personal Data

We require all parties who process your data to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purpose and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Internal Parties

Employees of Earn Your Swag will process your Personal Data when you need to speak to the customer service team or our Data Protection Officer. Access to your Personal Data will be controlled and only granted where necessary to provide our services to you and/or allow us to perform any necessary or legitimate functions.

External Parties

Service providers who process your Personal Data on our behalf to support our business and help provide our services to you.
Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of World Web Channels, our customers or others.
Professional advisers such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, financial, auditing, and accounting services to us so we can operate our business.
Third parties where you have expressly consented to the disclosure of your Personal Data, for example, for direct marketing purposes.
Law enforcement agencies, courts, supervisory authorities, regulatory bodies and related third-parties, to the extent that we are permitted or required to do so by law, or in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity.
From time-to-time, we may run contests, special offers, or other events or activities with a third-party sponsor. If you provide information to the third-party, you give them permission to use it for the purpose of that promotion. We cannot control the use of your Personal Data after you have submitted it to the third-party. If you do not want your information to be processed by the third-party, you can choose not to participate in the promotion.
These third-party sponsors operate in the Utilities, Media, Telecoms, TV, Retail, Finance, Insurance, Travel and Gambling sectors
Third-party sponsors may use Marketing Services Providers to process your Personal Data on their behalf, these Marketing Services Providers include:

Lead365 Ltd - https://lead365.co.uk/privacy-policy/

Parties we do not transfer your data to

Our Website contains affiliate links to third-party websites. You may click on these to complete offers provided by third parties. Please note, if you follow a link to any such website, we do not accept any liability or responsibility, because these websites have their own Terms & Conditions and Privacy Policies.

We do not transfer your data to these third-parties but to improve your user experience when you click on a third-party offer and are transferred to the third-party website, we may pre-populate the third-party form with your Personal Data. It is your choice to submit this data to the third-party, we will never do this for you.

We strive to only use high quality, relevant and reliable external links (these include text/banners and images that link to other, external websites) however we advise all users to be cautious when accessing any external web links via Earn Your Swag. This is because we cannot guarantee the content of externally linked websites. Any user clicking on an external link does so at their own risk. Earn Your Swag will not be held responsible for any damage caused or implications as a result of clicking on an external web link.

Advertising and Sponsored Links on Earn Your Swag

The Earn Your Swag website may from time to time, contain adverts and sponsored links. These adverts are served via our own advertising partners and they may have their own privacy policies that relate to their advertising. When a user clicks onto an advert they will be sent to the advertiser’s website and this is usually via a referral program. That program may well include Cookies and these Cookies may well be saved onto your computer hard drive. Should you click on a sponsored external link on Earn Your Swag, you do so at your own risk and Earn Your Swag will not be held responsible for any implications or damage caused in doing so.

Earn Your Swag Social Media Platforms

Any communication, actions and engagement directed through external social media platforms that Earn Your Swag participate on are all subject to the terms and conditions and privacy policies held with each individual social media platform.

Please always use social media platforms carefully and communicate within them with caution regarding your own personal details and privacy. Earn Your Swag will never request personal or sensitive information via social media platforms. If you are encouraged to discuss sensitive details through social media platforms relating to Earn Your Swag it is best to discuss these through our primary communication channels, for example, email (info@earnyourswag.com).

Social Sharing Buttons

Earn Your Swag occasionally uses social sharing buttons. These are there to help share web content directly from web pages straight to the relevant social media platform. You are advised that by using our social sharing buttons, you do so at your own discretion. The social media platform may track and save your request to share a web page through your own social media account, depending on the platform and their policies.

Shortened Links through Social Media Platforms

Earn Your Swag may share web links to web pages deemed relevant. Some social media platforms shorten long URLs (for example, http://bit.ly/xxxxxxx). We would advise that all Earn Your Swag users must be cautious when accessing shortened URLs published on social media platforms on our website. We try our very best to make sure that only real URLs are published but even so, many URLs may have been subjected to hacking and/or SPAM so Earn Your Swag cannot be held responsible for any implications relating to clicking on shortened URLs.

Branded Surveys on the Site

If you take part in a branded Survey on the site, then we will, in addition to the Registration Details referred to above, provide the Survey Sponsor (who will be clearly named) with your personal data as follows ('Survey Details'):
IP address (the unique numbers that identify the computer you are using to participate in the Survey)
Your responses to the Survey and date of response and any other information specific to the Survey that you are asked to provide
Cookies captured from your use of the Site generally and in completing the Survey.
The Survey Sponsor will use your responses and the Registration Details to identify what future competitions, surveys, offers, and information about their products and services you may be interested in, and to contact you by the methods referred to above. We do not place a specific time frame on their use of the Registration and Survey Details.
Please note as part of the registration process and completing the branding surveys and giving your consent you are agreeing to be contacted by the companies running the Branded Surveys by the methods referred to in 6.2, including by telephone. This will take preference over any registration that you may have with the TPS (Telephone Preference Service) of the number you have provided to us or updated with us. It is always your choice as to whether you want to receive such calls, so if you are registered with the Telephone Preference Service and decide you no longer wish to hear from Earn Your Swag, you can leave Earn Your Swag at any time.
If you no longer wish to hear from any of the companies running the Surveys who have received your personal data, you will need to contact each of them directly to request this. This also applies to any other preference service you may have registered with such as the Mailing Preference Service.

Where in the world your data is transferred

Earn Your Swag is headquartered in the UK. The information that you provide or that we collect as a result of your interaction with the Website and/or the user of the Services will only be transferred to parties located within the EU that have been recognised by the European Commission as providing an adequate level of data protection. In rare circumstances, when transfers need to take place to countries outside of this consideration, we have put in place measures, including ensuring the recipient is bound by EU Standard Contractual Clauses, to protect your Personal Data.

The list of companies and services below are used by Earn Your Swag to help us to deliver our services. These companies host our website and store all the data on our website:

Web Hosting: Microsoft Azure, Western Europe.

Any personal data is housed securely in West Europe.

Data Safety Outside the European Union

We would like to make you aware of the fact that certain external data processors may be based outside the European Union. Their laws might provide a different protection standard than that provided under UK law. Your data will not be shared with a non-EU country processor without proper due diligence performed as to the standards of data protection within the specified country, as well as the necessary proof of compliance with the standards of the UK Data Protection Act 2018 and other related and pertinent legislation. Such requirements will form part of a formal and legally binding Data Processing Agreement.

Legitimate interest and your consent

Your data must be processed by us using one of the valid legal bases defined by the Regulations. This is summarised in the table below:

Purpose	For Use by ourselves	For use by third parties
Marketing - by email	Consent	Not applicable, unless you provide explicit consent for a named organisation
Marketing - By SMS	Not applicable	Not applicable
Marketing - telephone	Not applicable	Not applicable
Marketing - by post	Not applicable	Not applicable

Consent

In short this is where you consent to a specific organisation, to contact you by a communication channel or channels which you have agreed to, for specific reasons, which in the context of our processing will be for marketing purposes. When we ask for your consent for a specific organisation, we will do so by giving you the opportunity to tick a box online or answer a question on the phone.

You can of course withdraw your consent at any time and we will describe how later on in this policy.

We obtain consent for our brands to contact you by telephone where your number is registered on the Telephone Preference Service (TPS) or by email and SMS.
To pass your contact details to named third parties where Privacy and Electronic Communications Regulation (PECR) applies such as email marketing or where your telephone number is registered with the TPS
To pass your contact details to named third parties where your postal address is registered with the Mailing Preference Service (MPS).
Where our client has specifically asked us to gain your consent to pass on your details.
We obtain your consent for using your personal information for promotional purposes. If you enter a competition on our website and are a winner, we will publish your name, picture and comment on our website.
All cookies & similar technologies which do not meet the "strictly necessary" exemption under PECR.

Legitimate Interest

As a direct marketing business we process personal information for various legitimate business purposes which include some or all of the following:

To enhance our services for the benefit of our customers including verification and validation
To help make the communication more relevant and contextual
To better understand how our customers interact with our services
To provide direct marketing communications which we think will be of interest to you
To determine the effectiveness of our and our clients promotional campaigns
To identify and prevent fraud

These legitimate business purposes relate to the following activities:

Direct Marketing - Postal and telephone marketing by both EarnYourSwag and other third parties, but in either case communications will be in relation to products or services which we believe are of interest to you based upon information which you have provided us.
Profiling - We will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you (for more information, please refer to the profiling section)

We process your data in the following ways:

To pass on your personal information to our clients for marketing purposes who will send postal marketing to you, (except where you are registered with the MPS) or contact you by telephone (except where you are registered with the TPS). Marketing will only ever be from organisations operating within the industry sectors described below.
To call you where your telephone number is not registered on the TPS.
To call you where we have obtained your details from a third party. We will always be named within their privacy policy as a party to whom they share your information; once contact is made we will obtain your consent at the earliest opportunity. You will always be given the option to opt out should you not wish to hear from us again.
To process your personal information for the purposes of customer analysis, non-automated profiling and direct marketing, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
To pass to our clients for use including 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 and asset reunification. More information on this can be found in the Credit References and other Agencies section.
To determine the effectiveness of our clients promotional campaigns and advertising, and to develop our products, services, systems and relationships with you.
Processing your information to protect you against fraud when using our website, and to ensure our websites and systems are secure.
To pass on your details to companies to help their clients tailor products and services which best suit your needs. They will also use your data for fraud prevention.
Provide you with information about the products and services we offer

As with all your data you can also object to us processing your data in this way. Your rights are detailed below.

You have the control

You may choose to restrict the collection or use of your personal data in the following ways:

You can opt out from any of our e-communications at any time by clicking UNSUBSCRIBE, replying STOP or contacting us directly.
Where consent has been previously obtained to us or our trusted partners to using your personal data for direct marketing purposes, you can change your mind at any time by going to the Preferences section of the website: Protection Officer at info@earnyourswag.com
Push Notifications - When joining our push notification list for sending offers you provide us with direct consent to send you push notifications by explicitly turning on this browser-level permission.

You have rights

Under data protection law, you have the following rights regarding how we process your data.

Right of access - you have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
Right of rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing - where certain conditions apply you have a right to restrict the processing.
Right of portability - you have the right to have the data we hold about you transferred to another organisation.
Right to object - you have the right to object to certain types of processing such as direct marketing.

You also have the right to complain to your relevant supervisory authority, depending on your EU Member State. For UK data subjects, it is the Information Commissioner's Office (ICO) whose details are as follows:

The Information Commissioner's Office
Wycliffe House, Water Lane,
Wilmslow, Cheshire
SK9 5AF.

http://ico.org.uk/

0303 123 1113

If you would like to amend/delete details or contact us in relation to the above or have any questions about this privacy policy, please contact using the contact details below. We may reserve the right to retain personal data where a reasonable expectation exists in order to fulfil an obligation. This may include suppression, ie. to “block” future communications received by request of the data subject, a regulatory authority or by law. In this event, the data subject will be informed accordingly of our reliance on this expectation(s).

Email - info@earnyourswag.com

Postal Address -

Earn Your Swag
Lytchett House,
13 Freeland Park,
Wareham Road,
Poole,
Dorset,
BH16 6FA

Unsubscribe/opt out of deleting your account

You have the option of Opting In or Out of receiving marketing communications from ourselves and our various partners at any time - including at registration by choosing the To enter without receiving marketing messages.
When registering your details, you will be required to actively opt in to;

Receive offers and updates by email, telephone and post from selected third party companies which we believe will be of interest.

Acknowledge that you have read, understood and agreed to our terms prior to registration.

Additional Information

You are able to unsubscribe or opt out of any of our scheme’s communications or any third-party brand, at any time, as indicated above. Please consider the following for a more general Opt-Out:

Opting Out – Postal Contact: To withdraw your consent for postal marketing from anyone, please add your details to the ‘Mail Preference Service’. For more details, please visit: www.mpsonline.org.uk

Opting Out – Email: To unsubscribe from receiving email communication from ourselves or an individual third-party, please follow the instructions as stipulated in any electronic communication such parties sends you. This is usually a “Unsubscribe” or “STOP” link.

Opting Out – Social Media: To configure your advertising preferences on social media such as Facebook, Twitter, Instagram or Pinterest, simply access your settings or preference options within the various chosen platforms.

Earn Your Swag will always remain transparent in disclosing how we intend to process your data, and where your data may be passed on, subject to your consent and preferences upon registration. All companies and partners we work with will be named, and the categories in which they operate will be made available to you. These opt-ins are optional and only when you put a tick in the box will you consent to receive additional marketing communication.

By registering or signing up, it is made clear, in plain English that by doing so you have read, acknowledged and agreed to the terms and conditions and this privacy policy, which governs how your information will be processed, and given consent upon registration to receive marketing communications from Earn Your Swag .

You may change your preferences at any time via the “How to Unsubscribe” pages once you are registered.

Third-party providers are able to send you communications via email, post or telephone only until such time as you exercise your right to opt out of receiving such communications. However please be aware that marketing campaigns are often planned well in advance, so your changes will be accepted immediately, but may not be effective immediately.

In addition, Website Sponsors have their own privacy policies and some have their own opt-in statements. It is strongly recommended that you read and understand this information.

How long do we retain your data for?

We do not retain your personal data for longer than necessary for the purposes set out in this report. The length of time we hold your data will depend on our ongoing relationship with you, our legal obligation, any request you may make to delete your personal data, and our legitimate interest in relation to the management of our own rights.

Typically, we store Identity Data, Contact Data, Marketing Data and Profile Data for a period of 24 months since your most recent activity in your account to answer customer queries, maintain an account in case you wish to come back to our website and monitor the site for fraudulent activity.

Once we no longer have a purpose to retain your personal data, we will securely destroy your personal data subject to the foregoing and in accordance with applicable laws and regulations. If you request to receive no further contact from us, we will keep some of your basic Identity and Contact Data on a suppression list to avoid sending you unwanted communication in the future.

Security and Storage of your Personal Data

Earn Your Swag is committed to protecting the security of your personal data. We protect your data with security measures under the laws that apply and we meet international standards. We use a variety of technologies to help protect your personal data from unauthorised access, use, or disclosure.

Unfortunately, the Internet is not a 100% secure medium for communication and, accordingly, Earn Your Swag cannot guarantee the security of any information you send to us via the Internet. In the event of a data breach that affects your data, we will notify you when legally required to do so.

To access your Earn Your Swag account, you must type in the correct password. It is your responsibility to keep this password secure. Please consider changing your password every 3-6 months. Ideally, your password should be at least 8 characters long, contain at least one capital letter, some numbers and a special character (e.g. ? ! , _) and should not be disclosed to anyone. If you believe that your login details have been compromised, please contact us immediately.

Earn Your Swag is not responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of your data.

The safety and security of your Personal Data also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your login or account credentials with anyone and keep your account information secure. We urge you to be careful about giving out information in public areas of the Website like message boards, where information will be available to other users of the Website. If you believe that your access credentials or Personal Data have been compromised, please contact us immediately.

Marketing to Minors

We do not knowingly, deliberately or aim to, collect personal data from minors under the age of 18, either for registration or for marketing purposes. Our site ensures that a ‘You Must Be 18+ To Enter’ disclaimer is included in the registration section.

IP Address / Cookies and Similar Technologies

Earn Your Swag automatically collects all users’ IP addresses and records web pages of origination when using the website. These Cookies are used only to increase security levels and they are not there to invade privacy. There is a need for Cookies, to administer, monitor and facilitate our website as well as optimise it for users. Cookies also notify us of any technical problems within the service we provide. Sometimes, Earn Your Swag might use your IP address to identify you and respond to technical difficulties to rectify them. Cookies also collect information about a user’s activity on our website including the web pages you might click on and further searches conducted from our website. Here is a list of the Cookies we use on Earn Your Swag:

Changes to this Policy

This policy might be amended and updated once in a while. Please ensure that you check it occasionally to ensure that you are happy with any new additions or changes made. This policy is effective from 22nd March 2021 and was last updated on 22nd August 2023.