Privacy Policy

UK Privacy Policy

This Privacy Policy describes how Elti Traders LP ("we," "us," or "our") collects, uses, processes, and protects your personal information when you use the website freebeautyadvice.com (the "Website"). We are committed to protecting your privacy in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

If you have any questions regarding the processing of your personal data or wish to exercise your rights, you may contact us at any time using the details provided below.

Our Contact Information

Elti Traders LP
6 Inns Court,
Winetavern Street,
Dublín, D08 DV20,
Irlanda

Data Protection Officer:
You can contact our privacy team via email at: privacy@freebeautyadvice.com

1. Information Collection

We collect information that you provide to us directly during your interaction with our services, including when you:

  • Complete any forms or registrations on our Website.
  • Take part in promotional activities, competitions, or draws.
  • Browse and interact with our Website.
  • Contact our customer service team for support.

2. Categories of Personal Data Processed

The personal data we collect, use, and process may include, but is not limited to:

  • Identification Data: Your first name, last name, and date of birth.
  • Contact Data: Your email address, postal address, telephone number, and IP address.
  • Preference Data: Your selected interests and marketing preferences as indicated on our Website.
  • Technical Data: Information related to your browser type, Internet Service Provider (ISP), approximate location, and local time.

3. Purposes of Data Processing

We use your personal information for specific, lawful purposes, which include:

  • Contractual Performance: To administer your participation in competitions or promotions we organise, fulfilling our contract with you.
  • Legitimate Interests: To conduct our business operations, including direct marketing for our own similar products or services, and to fund the operation of our free websites through advertising. We ensure our interests are not overridden by your data protection rights.
  • Legal Obligation: To comply with legal and regulatory requirements.
  • Consent: Where you have given us your clear, explicit consent, we will process your data for specific purposes such as sharing it with trusted third-party partners for their marketing communications.

Marketing Sectors: If you provide consent, you may receive marketing from trusted partners in sectors such as:

  • Charity
  • Gaming & Leisure
  • Financial Services & Insurance
  • Health, Lifestyle & Beauty
  • Home Improvements & Retail
  • Travel, Telecoms, and Utilities
  • Legal Services and Market Research

We reserve the right to further process your data for purposes consistent with the original collection purpose or as permitted by law.

We do not engage in automated decision-making, including profiling, that produces legal effects concerning you.

4. Sharing Your Personal Data

To provide our services, we may share your data with carefully selected third parties who operate under strict data protection agreements. This sharing is based on the lawful grounds of legitimate interest or your consent, as applicable.

Key Third-Party Partners include:
We may share your personal information with our partner WINR Data Pty Ltd (WINR) and their global partners for the purposes of:

  • Fraud Prevention - preventing others from misusing your personal information. This may involve identity verification for anti-fraud, anti-money laundering, anti-crime, asset recovery, debt collection and reuniting individuals with unclaimed assets; and
  • Digital Advertising - providing personalised advertising and content that is relevant to you. This may involve identity resolution for data analysis, matching and linkage.

WINR and their global partners will process and retain your personal information for as long as necessary for these specific purposes and on the lawful basis of legitimate interests.

You can submit a request to exercise any of your privacy rights to the Data Protection Officer at WINR https://www.winrdata.com/privacy-policy/

Trusted Marketing Partners: Our business model involves partnering with third-party marketing service providers. With your consent, we may communicate your data to selected companies so they may contact you with offers. A list of these partners is available on our Website prior to registration.

A non-exhaustive list of example partners we have worked with includes:

  • National Injury Claimline Ltd (trading as The Compensation Experts, The Medical Negligence Experts)
  • Legal & General
  • Pharmacy2U
  • Newmarket Holidays Ltd
  • Various companies in the retail, gaming, and home services sectors.

5. Legal Basis for Processing

Our processing of your personal data is conducted on the following legal bases under Irish and EU law:

  • Legitimate Interest (Article 6(1)(f) GDPR): This is our primary basis for processing data to manage competitions, fund our website through advertising, and for our own marketing. We have conducted a balancing test to ensure our interests do not infringe on your fundamental rights and freedoms. You have the right to object to processing based on legitimate interest (see "Your Rights" below).
  • Contract (Article 6(1)(b) GDPR): To perform our obligations under the terms and conditions when you enter a competition.
  • Consent (Article 6(1)(a) GDPR): For sending third-party marketing communications. You may withdraw your consent at any time.
  • Legal Obligation (Article 6(1)(c) GDPR): To meet our regulatory and compliance duties.

6. Your Data Protection Rights

Under data protection law, you have important rights, including:

  • Right of Access: You can request a copy of the personal data we hold about you.
  • Right to Rectification: You can ask us to correct inaccurate or incomplete data.
  • Right to Erasure ('Right to be Forgotten'): You can ask us to delete your personal data in certain circumstances.
  • Right to Restrict Processing: You can ask us to temporarily halt the processing of your data.
  • Right to Data Portability: You can request a copy of your data in a structured, machine-readable format.
  • Right to Object: You have the right to object, on grounds relating to your particular situation, to processing based on our legitimate interests. You also have an absolute right to object to direct marketing at any time.
  • Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, please contact us at privacy@freebeautyadvice.com. We will respond to your request within one month.

If you are not satisfied with our response, you have the right to lodge a complaint with the Irish Data Protection Commission, the supervisory authority in Ireland:

Data Protection Commission
21 Fitzwilliam Square South,
Dublin 2,
D02 RD28,
Ireland
Website: www.dataprotection.ie

7. Policy Updates

We may update this Privacy Policy from time to time. The latest version will always be posted on this webpage with an updated effective date. We encourage you to review this policy periodically.

This Privacy Policy is governed by and shall be construed in accordance with the laws of Ireland.