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DATA PROTECTION AND PRIVACY STATEMENT OF DAILYMAILZ

Data protection and privacy is very important to us, VIP Response (hereinafter
"Dailmyailz" or "we"), Parijsboulevard 143C, 3541 CS, Utrecht, The Netherlands,
represented by the Managing Director Mr. Daniel Franklin. In our position as
data controller we would like to inform you of the nature, scope, and purposes
of any collection, storage, transfer, and/or use of personal data, complying in
the process, already at this time, with the specifications of the EU General
Data Protection Regulation (GDPR). For this reason, the relevant standards are
already mentioned at this time in this data protection and privacy statement.
You can contact us anytime either via our postal address or by e-mail at the
following address: info@dailymailz.nl.

You can reach our data protection officer at: info@dailymailz.nl

This statement provides you with information on all aspects of our offering that
are relevant in terms of data protection and privacy, particularly:

 * the collection and storage of your personal data,
 * the transfer and use of your personal data, and
 * your rights


1. WHICH PERSONAL DATA WE COLLECT AND STORE

If you utilise our offering and/or use our website by filling out the entry
fields and/or contact us and/or merely visit our website, we may collect
personal data as follows:

 * Personal data that you provide us by utilising our offering and/or using our
   website may be collected. If one or several provisions of this Agreement
   should be or become lawfully ineffective, this shall not impair the validity
   of the other provisions. The invalid provision will be replaced as quickly as
   possible with another provision most closely approximating the economic
   intent and content of the invalid provision. “Personal data” include, in
   particular, your name, address, e-mail address, phone number, and any
   interests, etc., that may be identified in surveys.
 * To the extent when you enter into a contract on our website or issue a
   declaration of intent, we store the information for an order and, if any,
   payment details associated therewith.
 * To the extent that you answer any questions regarding your preferences,
   interests, user behavior, etc. after participating in the prize draw and/or
   your interests become apparent because you sign up for a sample subscription
   or similar items, we will also store this information in order to establish a
   personal user profile. This user profile enables interest-driven, optimised
   direct marketing which seems reasonable for both sides to ensure that you
   will only receive offers that are relevant to you and fit within the context
   of your lifestyle and available purchasing power. For example, if you have
   provided your gas provider and have consented for third parties to contact
   you, we will work with third party brand partners to send you a utility quote
   tailored to your needs – thus saving you time researching the entire market.
 * We also collect and process personal data that you provide to us by
   contacting us.
 * Personal data that may be collected through your visit to our page,
   particularly data traffic, location and time information, IP addresses,
   browser and device ID and other communication information provided through
   the use of your computer.

Further data – such as, in particular, local times, time zones, and usage data –
may also be stored in addition to the data specified above.

Statistical data may be collected and used in the case of a visit to our
website. “Statistical data” means, among other things, data regarding the use of
a particular Internet browser and the browser version.


2. HOW AND WHY WE PROCESS AND TRANSFER YOUR PERSONAL DATA, AND WHAT IT IS USED
FOR

The data collected during registration to the prize draw is used to conduct the
prize draw, determine the winner, handle the awarding of prizes and notify the
winner and transmit the prize (Article 6(1)(b) GDPR).

If, after the conclusion of the prize draw, declarations of intent for purchase,
service, or other contracts with external companies are received, the data
collected, where applicable, and further data collected on a contract-specific
basis will be disclosed to the external company or companies in question.
Otherwise those companies cannot use the data to establish or perform a contract
or contracts (Article 6(1)(b) and (f) GDPR).

Based on the participation agreement that is entered into and in the event of an
online participation in a prize draw, Dailymailz will collect and process your
personal data. This agreement requires that you provide your personal data if
and insofar as you wish to participate in our prize draw offering. The data
processing takes place for both our own direct marketing (Article 6(1)(b) GDPR)
as well as for our sponsors to also enable them to engage in individual,
demand-driven direct marketing that is tailored to you via the channels of
e-mail, push notifications, mail, phone, and text message (Article 6(1)(b)
GDPR).

Processing your personal data would be in accordance with declaration of consent
for advertising and marketing purposes, via phone, text messages, email, push
notifications, mail and/or the disclosure of data for direct marketing purposes
for the mentioned sponsors of the prize draw that may have been issued
separately; this also takes place within the scope of our legitimate interests
as established by your relevant consent (Article 6(1)(f) GDPR).

Dailymailz assumes that the consent to receive advertising by phone, text
message, e-mail, push notifications and mail from us and our sponsors, which is
to be declared separately, also constitutes consent for purposes of data
protection and privacy law to the processing of your personal data with the
result that – in addition – the relevant, aforementioned data processing is also
permitted pursuant to (Article 6(1)(a) GDPR).

Possible sectors that you may expect to receive advertisement about are:

Sector Description and examples Retail
 * Online retail
 * General stores
 * Automotive (including dealership and accesoires)
 * Property
 * Home furnishings
 * HOme improvement
 * Fashion and clothing
 * Telecoms and utilities

Finance
 * Pensions
 * Loans, credit cards,and mortgages
 * Investeringar & sparande
 * Fodringsföretag
 * Finansiella tjänster

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

Travel
 * Holidays
 * Hotel
 * Airlines
 * Travel booking

Lifestyle
 * Health and Well-being
 * Fitness
 * Charities
 * Media & publishing companies
 * Leisure
 * Gaming
 * Educational institutions

Legal Services
 * Claims
 * Personal Injury Claims Management

Gambling
 * Online Betting
 * Online Casino
 * Online Poker
 * Lottery

It may be the case that an analysis of your affinities, interests, and
preferences is performed before the data is used for direct marketing and/or
disclosed to sponsors. To this end, the answers that you will provide after
registering to the prize draw may also be analysed, and a profile may be
established in order to enable more targeted performance of direct marketing
measures by us and our sponsors, if any (Article 6(1)(f) GDPR).

Using the data obtained, particularly those from our surveys following the prize
draw registration page, we will create a “user profile” of you in order to be
able to offer you an interest-driven service that is geared towards your
individual needs and requirements. By creating this profile, we may categorise
personal aspects, such as your interests and preferences, through automated
processing of your data in order to make it possible for both us and our
sponsors to send you exclusive advertising and offers that match you profile.

Dailymailz frequently receives – provided that your end device supports this
function – confirmation of which e-mails from us you open and how you proceed
with the e-mail. This helps us to understand your interests and supports us in
making the offers more useful interesting, tailor-made to you in the future
(Article 6(1)(f) GDPR).

Assertion, if any, of your rights (Article 6(1)(c) and (f) GDPR) as provided in
Sec. 5 of this data protection and privacy statement also leads to collection
and processing of your personal data.

Disclosure of your personal data may take place in cases in which we are under a
legal obligation of disclosure (Article 6(1)(c) GDPR) or to the extent that
disclosure should be necessary to enforce other rights/demands or for purposes
of legal defense, if and insofar as these are based on the legitimate interests
of the organiser or other third parties (Article 6(1)(f) GDPR). The same applies
in the event of (also partially) purchase or sale of business assets and/or
other assets, in the event that our business is otherwise acquired by a third
party, in the event of initiation of insolvency proceedings, or if a request for
initiation of insolvency proceedings is denied for lack of sufficient assets
(Article 6(1)(f) GDPR).


3. WHERE WE STORE YOUR PERSONAL DATA AND FOR HOW LONG; AND TO WHERE YOUR DATA
MAY BE EXPORTED

a) We store your personal data within the European Economic Area.

However, in agreement with the sponsors named in the prize draw’s sponsor list,
which also shows the respective country of the establishment as the destination
location for any transfer of data, it is also possible that data will be
transferred to “third countries.” Third countries are countries located outside
the European Union. With regard to such data transfers, we point out that with
regard to all of the destination countries mentioned in the sponsor list, a
secure transfer within the scope of EU specifications on data protection and
privacy is ensured. The European Commission has issued corresponding adequacy
decisions for the third countries of Andorra, the Faroe Islands, Guernsey,
Israel, the Isle of Man, Jersey, Canada (commercial organisations), and
Switzerland. These decisions confirm that based on their own domestic legal
provisions or international obligations, the aforementioned third countries
ensure an adequate level of protection of personal data. To the extent that
datasets are transferred to third countries, for which an adequacy decision has
not yet been issued, we have entered into contracts based on the standard
clauses issued by the EU. These standard clauses were published by the EU to
ensure the relevant level of protection - with the corresponding partners that
are based or headquartered in these countries. These agreements ensure adequate
and uniform protection of data at the level provided by European specifications.
You can review the content of these agreements here.

In addition, we would like to draw your attention to the fact that, after
registration, it is possible to accept offers provided by Sovendus GmbH.
However, a data transfer in this context arises out of so-called prefilling. In
this regard, the information you provide during the registration process will be
used to fill in the information fields on the Sovendus website. However, data
transfer to Sovendus GmbH will not take place until you confirm it by clicking
on the appropriate button and submit it yourself. In this context, the following
privacy notices apply:

Voucher offers of Sovendus GmbH: In order to select a currently interesting
voucher offer for you, we will transmit your pseudonymised hash value of your
e-mail address and your IP-address in encrypted form to Sovendus GmbH,
Moltkestrasse 11, D-76133 Karlsruhe (Sovendus) (Art. 6 par. 1 f GDPR). The
pseudonymised hash value of your e-mail address is used to consider a possibly
existing objection to receive offers from Sovendus (Art. 21 par.3, Art. 6 par. 1
c GDPR). The IP-address will be exclusively used for data security purposes and
as a rule the same will be anonymised after seven days (Art. 6 Abs.1 f DSGVO).
Furthermore, we will transmit order number, order value with currency, session
ID, coupon code, and time stamp in pseudonymised form to Sovendus for billing
purposes (Art. 6 Abs.1 f DSGVO). If you are interested in a voucher offer of
Sovendus, while there is no objection existing to receive such offers, and if
you click on the voucher banner, we will transmit your form of address, your
name and your e-mail address in encrypted form to Sovendus to prepare a voucher
(Art. 6 par. 1 b, f GDPR). You will find further information about the
processing of your data by Sovendus in their Online Data Protection Notice at
www.sovendus.co.uk/privacy_policy.

b) Unless the data is erased or blocked pursuant to your exercise of the rights
specified in Sec.°5, your data will be stored permanently for the purposes
mentioned above.

After you have revoked any consent to the processing of data that may have been
issued and/or have objected thereto, we will put you on our “blocking list.”
This means that we will no longer use your personal data for marketing purposes,
nor will we disclose them any longer. We will then only store your data for
legal purposes (e.g. documentation obligations, defending against and asserting
claims, etc.), and will erase the data after a further period of four years
unless compelling reasons argue against our doing so or the processing of this
data is permitted for other reasons, for example by way of new consent.

Furthermore, we will proceed in the same manner if we have not used your
personal data for a period of 24 months, meaning that we have not used the data
for our own marketing purposes or disclosed them to sponsors.


4. PROTECTION OF YOUR PERSONAL DATA

We take corresponding precautions – administrative/organisational, technical,
and physical – to protect your personal data against loss, theft, abuse,
unauthorised access, unauthorised disclosure, unauthorised modification, and
destruction. For example, your data is protected in particular within the scope
of physical access control (secure location of servers, to which physical access
is granted only following to a defined security procedure), systems access
control (128-bit encryption of data transfers, individual assignment of
passwords, menus, and authorisations for employees, up-to-date virus software),
information access control (individual access authorisation for employees
through personal accounts, identification and authentication requirements),
transmission control (ongoing monitoring and notifications to authorised
parties, no local storage of data, logging of all data exports and transfers),
input control (account-linked reviews, logging with time stamps and host), job
control (continuous monitoring by managing director(s) and data protection
officer, clear drafting of contracts with regard to the specifications pursuant
to Sec.°11 of the German Federal Data Protection Act (Bundesdatenschutzgesetz –
BDSG) respectively Art. 28 GDPR in coordination with the data protection officer
and executive management) and availability control (general safeguarding
measures by the hoster constant power supply (UPS), halon gas system, etc.],
backup streaming involving other general safeguarding measures by the hoster
[e.g. UPS, halon gas system, etc.], backup streaming at another location [with
all security precautions; see physical access control] every night, mirroring on
two additional hard drives, virus protection programs).

Despite these precautions, the insecure nature of the Internet means that we
cannot guarantee the security of your data transfer to our website. Therefore,
any and all transfers of data by you to our website take place at your own risk.


5. YOUR RIGHTS

You have the right to obtain information regarding the personal data stored
regarding you, including the origin and recipients of your data and the purpose
of data processing, at any time pursuant to Article 15 GDPR.

You also have the right to demand, at any time, that we correct inaccurate
personal information concerning you (Article 16 GDPR). You can restrict the
processing of data if any of the prerequisites mentioned in Article 18(1) GDPR
are met, e.g. in the event of a dispute concerning the accuracy of your personal
data.

Moreover, you have the right to revoke any declaration(s) of consent to the
processing of your personal data that may have been issued, with effect for the
future (Article 7 GDPR). Such a revocation does not, however, affect the
legality of the processing that has taken place up until then.

In addition, you are entitled to demand that we provide the personal data
transferred to us in a format that permits the transfer thereof to another body
(Art. 20 GDPR).

Subject to the prerequisites set out in Article 21(1), (2), and (3) GDPR, you
can object to the processing of data for reasons that arise from your particular
personal situation.

Furthermore, you have the right to demand the erasure of your data and assert
your right to be forgotten pursuant to Article 17 GDPR. If the statutory
prerequisites are met, we will proceed in this regard even without such a
request having been issued on your part and will erase your personal data.

To assert your rights as enumerated above in this section, please contact us at
Dailymailz by e-mail at info@dailymailz.nl

If you have a complaint, you can contact the supervisory authority with
jurisdiction over Dailymailz, the Data Protection Official for Utrecht (Chamber
of Commerce) (St Jacobsstraat 300, 3511 BT Utrecht, The Netherlands), or any
other supervisory authority which in the UK is the Information Commissioner’s
Office (ICO) whose contact details are: The Information Commissioner’s Office.
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
https://ico.org.uk/
Telephone: 00 44 303 123 1113


6. USAGE DATA AND COOKIES

You can view our Internet pages without providing personal information. However,
certain technical data, known as "usage data", are generated whenever our pages
are visited. In addition, we may use one or more cookies and integrate social
media plugins in some cases. The text below is intended to provide you with
information regarding this as well.


USAGE DATA:

When you visit our Web pages, the only items of information we store by default
are the website from which you reached our page, the name of your Internet
service provider, which Web pages you visited within our Internet presence, and
the date and duration of your visit. The data obtained is fully anonymous.

Your IP address and a time stamp are also stored for security reasons and used
for internal purposes. The IP address is a machine-related code that provides
information of the computer or Internet gateway used to access the Internet at
the time of online retrieval. A time stamp is a value in a defined format that
assigns a certain point in time to an event (for example, sending or receiving a
message, modification of data, etc.). The purpose of a time stamp is to make it
clear to people or computers when events occurred.


SOCIAL MEDIA PLUGINS

We integrate "social media plugins" (often also known as "social media buttons")
into some areas of our Web pages. These kinds of plugins are marked on our pages
by buttons (hence the term "buttons"), each of which shows the provider of the
plugin through corresponding colours and symbols. Clicking these buttons allows
you to do things like notify your friends in the social networks you use that
you like one of our pages or share a link to a website with other Internet
users, depending on the button.

If you are surfing on our website and access one of our Web pages that contains
a social media plugin, your browser makes a direct connection with the servers
of the provider of the plugin, and the plugin is loaded from there. In the
process, the provider of the plugin may be notified that the relevant Web page
has been accessed from our website.

If you have a user account with one or more of the social networks operated by
the providers of the plugins and are logged into the network(s) in question
while you are on one of our Web pages that contains one or more social media
plugins of the provider(s) in question, it may also be possible to associate the
access to that page with your existing user profile(s) with the provider(s) in
question. If you click on integrated plugins and log into one or more of the
networks afterward (or are already logged in), the shared or "recommended"
information is generally posted in short form in your profile. This may allow
the provider of the network to collect and store further usage data. In this
way, the providers of the networks can create user profiles that go beyond what
you yourself directly and actively disclose in the network. For further
information on the collection and processing of data, please see the privacy
policies of the providers of the plugins.


COOKIES

We use so-called cookies on our Internet pages. These are small files that are
stored on your hard drive and in which certain information is stored that a
server can read out again. These cookies can be so-called session cookies, which
are automatically deleted as soon as you close your browser, on the one hand,
and cookies with a longer, predefined runtime, on the other. Furthermore, when
you visit one of our websites, our partner AppNexus sets cookies (click here for
more info) which allow communicating tailor-made offers – for example by
displaying so-called banners – also on other websites on which the AppNexus
technology is implemented.

The information stored in cookies may include your login (your visit when you
register), the date and time of your visit, your other behaviour on our
sweepstakes pages, the cookie number and the URL of the website from which you
accessed our offer pages.

The use of certain cookies enables us, on the one hand, to guarantee the
functionality of our websites and to continuously improve their performance. In
addition, cookies help us and our partner to recognise you and in this way to
adapt our offers – also on the other pages on which our partner is active –
optimally to your individual needs and thus to display the most relevant
information for you. This technology enables us to pass on the personal data you
have previously entered in one of our competitions and which you have released
for commercial use directly and conveniently to those of our sponsors whose
services you are interested in. Finally, cookies make it possible to record the
statistical frequency of visits to the various pages of our website and the
general navigation.

If, however, you wish to prevent the use of cookies, which has no influence on
the perception of our competition or other related offers on our part, we ask
you to make the appropriate setting in your browser before using our pages.
There you can prevent the acceptance and storage of new cookies. You can find
out more about this on the help pages of your browser or by contacting its
service provider.


PUSH NOTIFICATIONS

Occasionally, you may be asked to give your further consent to the receipt of
push notifications from our push notifications dispatch service partner
“Accengage”. Your personal data will then be processed on the (additional) basis
of this consent, in accordance with Art. 6 (1)(a) GDPR. In this case, the giving
of your consent is, of course, also covered by the rights as set out in Clause 5
of this declaration. In addition to the above-named provisions you can – for the
purposes of withdrawing your consent to the receipt of push notifications – also
change the relevant push notification settings in your browser. If you are using
a desktop PC with a “Windows” operating system, you can unsubscribe by
right-clicking on the relevant push notification in the settings list.

In order to be able to display the list of push notifications, “Accengage”
collects and processes on our behalf your browser ID and (in the case of mobile
access) your device ID. Accengage also collects and evaluates on our behalf
statistical data related to push notifications; Accengage does not collect or
evaluate any personal data.

You will find detailed information on Accengage push notifications at:
Accengage_FAQ.pdf


7. DELETION OF COOKIES

As a user, you have the right at any time to decide which cookies – including
those for push notifications – you wish to accept or delete. You can adjust the
individual settings thereto in the settings menu of your Internet browser. For
further information, please contact the provider of your Internet browser.


8. MINORS

This site, including the data protection and privacy policy and the general
terms and conditions of business, is not aimed at minors. No personal data of
minors are knowingly collected, used, and/or disclosed.

Current as of: December 2020