For your information, this website (“Website”) is operated and wholly-owned by Submission Technology Ltd., registered in England with the company number 04456811.
Submission Technology Ltd. ("Submission Technology," "we," or "us"), respects your privacy and is committed to protecting it through our compliance with this Privacy Polic
For the purposes of the EU General Data Protection Regulation (2016), Submission Technology Ltd. are the registered data controller with the Information Commissioner’s Office (ICO); our registration number is Z7981900.
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
Financial Data such as bank account details
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.
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.
You may give us your identity, contact, financial, 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
Raise a ticket on the HelpDesk
Give us feedback
Speak with customer service
Request information be sent to you
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). For more information regarding our use of Tracking Technologies, please refer to Section 10: Cookies and Similar Technologies below.
We will only use your Personal Data where permitted by law. The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:
Consent: In specific situations, we collect and process your data with your consent. For example, when we rely on your consent to send you direct marketing by email or via push notifications on your device. We collect your consent when applicable laws require it (including but not limited to the Privacy and Electronic Communications (EC Directive) Regulations 2003 & The EU General Data Protection Regulation). Where we rely on your consent to use your personal data, you have the right to withdraw your consent an anytime. You can do this by contacting us at firstname.lastname@example.org. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Performance of a Contract: In certain circumstances, we need your personal data for the performance of a contract to which you are a party.
Legal Obligation: If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity.
Legitimate Interest: This is when we have an interest in conducting and managing our business, to enable us to give you the best experience when using the Website, products, and services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
In the table below, we have described (i) in what context your personal data was collected, i.e., what activity you were involved in when we collected or used your personal data; (ii) the types of personal data that we hold about you; (iii) how and why we use your personal data; and (iv) what our legal basis is for using your personal data.
|When your data is collected||What data is collected||How we use that data||Our legal basis for processing|
|Account Creation and Management||Identity
Marketing & Communications
|To create and manage your account;
To communicate with you about your account;
To manage our relationship with you;
To pay you your earnings when eligible;
To respond to your questions
To send you marketing communications which may be based on your profile; and,
To manage surveys, promos or competitions you enter.
|To perform our contract with you so you can create an account, use our Services and be paid;
For our legitimate interests to (i) improve our Services; (ii) better engage with you; (iii) prevent fraud; and (iv) secure our tools; and,
Consent so you can receive marketing communications.
|Welcome Email, Newsletter, and Marketing Communications via Email and Push Notifications||Identity
Marketing & Communications
Other info you have shared whilst in contact with us
|To send you marketing communications via Email and/or Push Notifications which may be based on your profile;
To send you a welcome email to confirm your email address and validate your account;
To send you newsletters where you have provided your consent with advertising campaigns from the following sectors: Retail, Finance, Insurance, Lifestyle, Travel;
To keep your Contact Data on a suppression list if you’ve indicated you don’t want to be communicated to in a particular way; and,
To run analytics or collect statistics.
|For our legitimate interests to (i) improve our Services; (ii) better engage with you; (iii) prevent fraud; and (iv) secure our tools; and,
Consent so you can receive marketing communications.
|Cashing Out and Paying||Identity
Other info you have shared whilst in contact with us
|To manage payment (your payment information is transferred to our Bank or PayPal for processing);
To communicate with you regarding a transaction;
To secure your transaction against fraud (we may use a third-party provider’s solution to detect fraud and make sure payment is complete);
To update your transaction history in your account profile;
To perform invoicing or manage payment disputes; and,
To run analytics or collect statistics.
|The performance of a contract – so we can pay you when you are eligible to cash out;
For our legitimate interests to (i) improve our Services; (ii) better engage with you; (iii) prevent fraud; and (iv) secure our tools; and,
To comply with a legal obligation – to keep information we are required to e.g. comply with our tax and financial reporting obligations with respect to monies we owe you.
|To provide administration and IT services, network security and to prevent fraud;
To perform data analysis, testing, system maintenance, support, reporting and hosting of data;
To run analytics or collect statistics; and,
To monitor and improve our website.
|For our legitimate interests of running our business; and,
To perform our contract with you and provide services to you.
|To improve our Website service and your user experience;
To run analytics and collect statistics;
To enable our Website to function properly, create and remember your account login details, personalise the interface etc.;
To understand how you arrived at our Website;
To customise our services;
To ensure proper display of content;
To ensure our service is safe and secure; and,
To run analytics and collect statistics.
|For our legitimate interests to (i) improve our Services and Website; (ii) to provide you with a better user experience so you can optimise the use of our Services; and,
Consent, when required, to store cookies on your device
|To receive your contest entry, manage your participation in the promotion, take account of your feedback; and,
To run analytics and statistics.
|The performance of a contract – so you may enter into the promotion, receive a prize, participate in a survey, send feedback; and,
Our legitimate interests: (i) to improve our products and services; and (ii) better engage with you.
|Enquiries and Messaging||Identity
Usage such as the content of chats, messages, enquiries
|To answer and manage your enquiries;
To run analytics and statistics;
To keep track of your questions or concerns for future reference;
To troubleshoot any problems that you are experiencing; and,
We may also use scanning technology on messages to allow us to recognise patterns on our messaging platform to make our communications more efficient and informed. This will contribute to a safer and more secure experience for you.
|The performance of a contract with you;
For our legitimate interests: (i) to better engage with you; (ii) to enter into a contract with you; to secure our tools; and,
Where we need to comply with a legal or regulatory obligation (data subject access rights).
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.
Employees of Submission Technology will process your 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.
Service providers who process your Personal Data on our behalf to support our business and help provide our services to you. These include, but are not limited to, our Email Service Provider (ESP) Get Response, push notification provider One Signal, PayPal and Freshworks. Please read their Privacy Policies for more information on how they secure your Personal Data:
Get Response: https://www.getresponse.com/legal/privacy.html
Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of Submission Technology, 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.
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.
Parties we do not transfer your data to
Our Website contains affiliate links to third-party websites. You will click on these to complete offers and earn cashback. 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.
Where in the world your data is transferred
Submission Technology 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.
Where any Personal Data is transferred to the USA, we also rely on the EU-US Privacy Shield Frameworks (“Privacy Shield”) to ensure recipients adhere to the Privacy Shield Principles.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
In some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you no longer have a relationship with us, we will retain and 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 basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.
|YOUR RIGHTS||WHAT YOU CAN REQUEST|
|Right to Information||The right to know what Personal Data we hold about you and how we use it.|
|Right to Access||The right to be provided with a copy of your Personal Data (subject to certain restrictions).
We will confirm what data is being processed, provide you with a copy of your data in addition to confirming your data rights. If you wish to access your data, please submit a Subject Access Request (“SAR”) to our Data Protection Officer using reasonable means. If you make the request by email, the Data Protection Officer will provide your information in a commonly used electronic format unless you instruct them otherwise. Your request will remain confidential.
When making your request, please include:
|Right to Rectification||The right to require us to correct any incomplete or inaccurate Personal Data we hold about you, though we may need to verify the accuracy of the new data you provide to us. If you have a user account with us, you also have the option of correcting your information directly in your account. We encourage you to rectify inaccurate data to ensure our records are up to date.|
|Right to Erasure||This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. Note, however, that we may not always be able to comply with your request for erasure and in such circumstances, will notify our reasons to you.|
|Right to Restrict Processing||The right to require us to restrict processing of your Personal Data, i.e., you can request that we suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.|
|Right to Request Data Portability||In certain circumstances, you have the right to request the transfer of your Personal Data to you or to a third party in a commonly used machine-readable format. Note, however, that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.|
|Right to Object to Processing||You have the right to object to the processing of your Personal Data in the following circumstances: (i) at any time to your Personal Data being processed for direct marketing (including profiling); or (ii) in certain other situations, to our continued processing of your Personal Data, e.g., our processing of your Personal Data when such processing is based on our legitimate interests. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.|
|Right to Withdraw Consent at Any Time||You have the right to withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.|
|Right not to be subject to a decision based solely on automated decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. However, your right does not apply if: (i) you gave us your explicit consent to use your personal data to make our decision; (ii) we are allowed by law to make our decision; or (iii) our automated decision was necessary to enable us to enter into a contract with you.|
How to make a request
If you would like to exercise any of the data subject access rights in the table above (each, an “Access Request”) please send an email to email@example.com. We will respond to your request without undue delay and no later than one month.
You will not usually be required to pay a fee to exercise your rights unless your request is manifestly unfounded or excessive.
We may need to confirm your identity before fulfilling your request and ensure your right to access your Personal Data (or exercise other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can make a complaint to the UK Supervisory Authority, the Information Commissioner’s Office (ICO). You can contact the ICO through their website: https://ico.org.uk/concerns/ or by telephone: 0303 123 1113.
If you have an account with 20Cogs you can unsubscribe from marketing emails by clicking the ‘unsubscribe’ link at the bottom of our emails, or you can contact us via our Helpdesk. Please allow up to 48 hours for changes to take effect. When you unsubscribe we will store your name and email address on a separate database to ensure we do not contact you again.
To delete your account, please sign in to your account, select menu and click on your profile. At the bottom of your profile page, there is an option to delete your account. You will need to enter your account password. If you cannot remember your password, please contact our customer service team at firstname.lastname@example.org. Deleting your account will not delete your personal data. If you wish to exercise your right to erasure ("be forgotten"), please contact our Data Protection Officer at email@example.com.
To unsubscribe from 20Cogs push notifications, please follow the advice given by One Signal, our push notification provider, here: https://documentation.onesignal.com/docs/unsubscribe-from-notifications. Push notifications will only ever come from 20Cogs and not third parties. You are free to opt-out of push notifications at any time.
We use appropriate technical and organizational measures to protect Personal Data we process about you.
However, no transmission of information via the Internet or wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, you acknowledge that there are security and privacy limitations of the Internet which are beyond our control and accordingly, the security, integrity and privacy of data exchanged between you and us through the Website cannot be guaranteed.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Other storage technologies you may come across include web beacons and pixels. A web beacon is an often-transparent graphic image that is placed on our website or in an email that is used to monitor the behaviour of users visiting our sites or receiving our emails. Web beacons are usually used in conjunction with cookies to check that you can see our content. A pixel refers to the code that is placed on our website that triggers a cookie. A pixel is essentially an image but instead of calling an image to be displayed, it calls an application on a media buying platform that will cause a cookie to be downloaded to your browser if your browser settings allow.
To find out how to opt-out of the collection and use of your information via storage technologies, see our section below on Blocking or Declining Cookies.
For further information about behavioural advertising, cookies and other storage technologies, and the steps you can take to protect your privacy online visit http://optout.aboutads.info/?c=2#!/ or http://www.youronlinechoices.eu/
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
|ci_session||20cogs.co.uk||This cookie is normally associated with the CodeIgniter framework for building PHP based applications. Usually used to maintain a user state during a browser session for consistency of user experience. By default, this cookie is destroyed when the browser session ends.||2 hours|
|PHPSESSID||20cogs.co.uk||This cookie is generated by applications based on the PHP language. This is a general-purpose identifier used to maintain user session variables. It is normally a randomly generated number, it is used to maintain a logged-in status for a user between pages.||Session|
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.
All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
|_hjIncludedInSample||20cogs.co.uk||This cookie is associated with web analytics functionality and services from Hot Jar, a Malta-based company. It uniquely identifies a visitor during a single browser session and indicates they are included in an audience sample.||Session|
|_gat||20cogs.co.uk||This cookie name is associated with Google Universal Analytics, it is used to ensure efficiency - limiting the collection of data on high traffic sites.||Session|
|_gid||20cogs.co.uk||This cookie name is associated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017, no information is available from Google. It appears to store and update a unique value for each page visited.||Session|
|_ga||20cogs.co.uk||This cookie name is associated with Google Universal Analytics. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.||2 years|
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.
They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising but equally, you will not be able to experience the site fully.
|id||doubleclick.net||This cookie is used to improve advertising. Some common applications are to target advertising based on what's relevant to a user, to improve reporting on campaign performance, and to avoid showing ads the user has already seen.||90 days|
|These are a range of cookies used by Google to improve your user experience and keep your data secure. Preference cookies are typically used to store user preferences, such as your preferred region, language, font size etc.; security cookies that encrypts data users enter into online forms to prevent data from being stolen; process cookies which help the user navigate our site; advertising cookies to make advertising more engaging for users and more valuable to publishers and advertisers; session state cookies to improve the user browsing experience by analysing how many times a user visits a page and whether users receive error messages from certain pages; and, analytics cookies which are sent as part of the Google Analytics tool which helps us understand how users engage with our websites.
|datr||Facebook.com||This is a verification cookie used to ensure your Facebook account and activity is not fraudulent if you choose to visit our Facebook site.||2 years|
|fr||A cookie used for advertising purposes.|
|lu||This cookie is set the first time a user visits facebook.com and is used to identify the browser – it helps protect people using public computers.|
|__qca||Quantcast||This cookie may use your IP address, pixel code, referring HTTP location and current HTTP location, search string, time of access, browser’s time and any searches made on the website and combine it with non-personally identifiable information to produce reports on users that provide information about what audience segments are the most appropriate for the services we offer.||1 year|
|SID||Youtube.com||We embed videos from YouTube and by doing this it may set cookies on your computer once you click on the YouTube video player.
These cookies help track the number of views for a particular video. The PREF cookie will track user preferences and serve up related content or adverts within an embedded YouTube video.
Read more at YouTube’s embedding videos information page. Visit YouTube’s privacy guidelines at https://www.youtube.com/t/privacy_guidelines
|Id||Yieldlab.net||This cookie is sourced from a German-based online advertising platform provider used for measuring user engagement.||1 year|
|__utmz||Pinterest.com||These cookies are used for social content sharing.||2 months|
BLOCKING OR DECLINING COOKIES
Safari iOS (iPhone, iPad)
For further information about behavioural advertising, cookies and other storage technologies, and the steps you can take to protect your privacy online visit http://www.youronlinechoices.eu/. If you wish to opt-out of any interest-based advertising visit https://preferences-mgr.truste.com/. Please note, you will continue to receive generic ads.
|Type of Enquiry||Email Address||Telephone||Postal Address|
|Data Subject Information / Access Requestsfirstname.lastname@example.org||+44 (0)20 7183 5039||The Beater House
|Customer Service Enquiriesemail@example.com||+44 (0)20 7183 1653||The Beater House
Last Updated 06.12.2019