Privacy Policy

When you use our employee recognition programs and services, it is important to us that your privacy remains a priority.

Our Commitment To Privacy
Your privacy is important to us. To protect your privacy Terryberry provides this notice explaining Terryberry’s online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.


Privacy Policy

Effective: October 8, 2021

Terryberry Company, LLC ("Terryberry" or "We") respects your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit  our website, (“Website”), our 360 Recognition, Awardchoice, and Give a WOW platforms, 360 Recognition’s mobile application, or other integrations (our "Services") and our practices for collecting, using, maintaining, protecting, and disclosing that information. By accessing or using the Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of these Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

This policy applies to information we collect:

  • In the course of providing the Services.
  • In email, text, and other electronic messages between you and the Services.
  • When you register for events, subscribe to a newsletter or provide feedback in an online survey.
  • When you receive our communications or participate in our online or offline activities or events.
  • When you receive our services.

This Policy applies only to information collected by Terryberry and does not apply to any other information or websites not owned or operated by Terryberry.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information:

  • By which you may be personally identified, such as:
    • Employee name, including preferred name;
    • Job title;
    • Email address
    • Date of birth/birthday
    • Start date
    • Award qualification date
    • Cost center name
    • Department
    • Home address
    • Business address
    • Address for delivery of Rewards
    • Telephone number
    • Line manager name
    • Line manager address
    • Employee number/ID
    • Length of service
    • Reward Points
    • Award value
    • Profile picture
    • Payment data, including billing address, and
    • Such other information as may be collected by our customers from their employees and provided to us from time to time

We will refer to all of the above information as “Personal Information” in this policy.

  • About your internet connection, the equipment you use to access our Services, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

The information we collect through our Services may include:

  • Information that you provide by filling in forms on our Services. This includes information provided when requesting services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Services.
  • Information about you when you request information, respond to surveys or otherwise correspond with us.
  • Details of transactions you carry out through our Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Services.
  • Your search queries on the Services.
  • We may collect other information from you that is not specifically listed here. We may use such information in accordance with this policy.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

  • To present our Services and their contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection.
  • To notify you about changes to our Services.
  • To allow you to participate in interactive features on our Services.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
  • Investigate or prevent violation of the law or your agreements with us; protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims) and protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity;
  • Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and where permitted by law in connection with a legal investigation.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect, or you provide as described in this privacy policy:

  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Terryberry's assets.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To government or law enforcement officials or private parties for compliance, fraud prevention and safety and to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We use Google Analytics to help us gather statistical information about the visitors to our Services and how they use the Services on an anonymous, aggregate basis. However, we will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law.

We may use this information to gain a better understanding of the users of our Services, to improve our Services. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics use. To understand how Google Analytics collects and processes data, please visit

It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Services according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Services.

Technologies we use for automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Web Beacons. Areas of our Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Cookies.

In addition to our own cookies, we collaborate with various third-party service providers who also use cookies to help us optimize our Website and understand more about the visitors to our Website. For example, we use Google Analytics to provide us with demographic information about our visitors and to help us analyze how people use our Services. Our third-party service providers include: GoogleAnalytics, GoToMeetings, YouTube, Microsoft; Facebook, LinkedIn Pardot, TopSpot. Live Chat, Zendesk, Twilio, Xplenty, and Capterra.

To learn more about how these providers use cookies, please click the links above or visit their respective websites to view their privacy policies.

How Can You Disable Cookies and Other Tracking Technology?

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit and

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own products or services, you can opt-out by or sending us an email stating your request to If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

Consequences of Not Providing Personal Information.

You are not required to provide all Personal Information identified in this Policy to use our Services or to interact with us offline, but certain functionality will not be available if you do not provide Personal Information. For example, if you do not provide Personal Information, we may not be able to respond to your request, perform a transaction with you, consider you for employment, or provide you with marketing that we believe you would find valuable.

Accessing and Correcting Your Information

You can review and change your Personal Information by logging into the Services and visiting your account profile page.

You may also send us an email at to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.


The Services are not intended for use by anyone under the age of 18, nor do we knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, you should not attempt to use the Services or send any information about yourself to us.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' Personal Information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices:

Terryberry Company

Customer Marketing

2033 Oak Industrial Dr. NE

Grand Rapids, MI 49505

Attn: Privacy Officer


Supplemental Privacy Notice for California


Effective Date: January 1, 2020

Last Reviewed on October 8, 2021

This Supplemental Privacy Notice for California Residents supplements the information contained in Terryberry’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

We collect Personal Information as defined above, which is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.

We have collected the following categories of Personal Information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:

Category of Personal Information Collection Business Purpose of Collection
Identifiers, including real name, alias, mailing address, email address, account name, telephone numbers, and unique personal identifiers such as online identifiers and IP address, or other similar identifiers. To provide services and marketing.
Characteristics of protected classifications under California or federal law, including age or date of birth, race, color, national origin, physical disabilities, mental disabilities, medical condition, gender, gender identity, gender expression, sexual orientation, military or veteran status, and criminal conviction history If you choose to disclose this information, we collect it as part of our employment application process.

We also collect gender information to assist in relationship management and ensuring we properly address individuals in our communications (e.g., whether to call someone Ms., Mrs., Mr., etc.)

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. As relevant and necessary to provide our services.
Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an internet site, application, or advertisement To provide you more relevant content, track original Website visits, and optimize your Website experience as well as to ensure our systems are properly functioning.
Geolocation data To assist in marketing and identify Website traffic patterns.
Occupation, professional, or employment-related information To market and provide our services to you and to communicate with you.  In addition, if you choose to disclose this information, we collect it as part of our employment application process.
Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes. As relevant and necessary to provide our services.


We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Services.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Services, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Services experience and to deliver content and product and service offerings relevant to your interests, including targeted offers through our Services and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Services, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Services, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:

  • Service providers.
  • Product vendors.

Sales of Personal Information

Company does not sell Personal Information.

Your Rights

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information.

Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific Personal Information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).

Right to Delete. You may request that we delete certain Personal Information we have collected about you, with certain exceptions.

Exercising Your Rights. To exercise your rights above, please submit a request to. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide the following information: name, email address, and the type of request you wish to make. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request.

After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request.

Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your Personal Information.

We may not discriminate against you if you choose to exercise your rights.

Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. We will deliver our written response by mail or electronically, at your option. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable.

We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.

How to Contact Us

If you have any questions or comments about our Privacy Policy or practices:

Terryberry Company

Customer Marketing

2033 Oak Industrial Dr. NE

Grand Rapids, MI 49505

Attn: Privacy Officer


Supplemental Notice to European Users

The following applies to individuals in the European Economic Area.

Legal bases for processing. We are required to inform you of the legal bases of our processing of your Personal Information, which are described in the table below. If you have questions about the legal basis of how we process your Personal Information, contact us using one of the methods detailed at the end of this Policy.

Processing Purpose Legal Basis
To provide the Site and communicate with you. You are subject to a contract with us and we need to use your Personal Information to provide services you have requested or take steps that you request prior to providing services.
To send you marketing communications.

For compliance, fraud prevention, and safety.

These processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information 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).
For compliance with law. Processing is necessary to comply with our legal obligations.
With your consent. If we expressly ask for your consent prior to processing your information, our processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Site.
To share your Personal Information as described in this Policy. This sharing constitutes our legitimate interests, and in some cases may be necessary to comply with our legal obligations.

Retention. We will only retain your Personal Information for as long as necessary to fulfill 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 Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Rights. European data protection laws give you certain rights regarding your Personal Information. You may ask us to take the following actions in relation to your Personal Information that we hold:

  • Access. Provide you with information about our processing of your Personal Information and give you access to your Personal Information.
  • Correct. Update or correct inaccuracies in your Personal Information.
  • Delete. Delete your Personal Information.
  • Transfer. Transfer a machine-readable copy of your Personal Information to you or a third party of your choice
  • Restrict. Restrict the processing of your Personal Information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your Personal Information that impacts your rights.

You may submit these requests by contacting us as detailed at the end of this Policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your Personal Information or response to your requests regarding your Personal Information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.

Cross-Border Data Transfers. Any information you provide to us through the use of the Site may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of Personal Information as the one in which you reside. However, we will handle your Personal Information in accordance with this Policy regardless of where your Personal Information is kept. Regarding transfers from the European Economic Area ("EEA") to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions outside the EEA, your use of the Site or provision of any Personal Information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed below.


Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.


Contact Us

If you have any questions about this Policy or would like to request access to your Personal Information, please contact us as follows:


Postal Address:

Terryberry Company

Attn: Privacy Officer

2033 Oak Industrial Drive NE

Grand Rapids, MI 49505


Changes to This Policy

We reserve the right to amend this Policy from time to time.

Effective Date: January 1, 2020

Last modified: October 8, 2021


iCOM Works Privacy Policy                                                                                                   



iCOM Works Limited (collectively referred to as “We”, “Us” or “Our” in this Privacy Policy) understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.


Please read this Privacy Policy carefully and ensure that you understand it. We may at any time modify this Privacy Policy. The most current version of the Privacy Policy will supersede all previous versions.  If you do not agree with this Privacy Policy, you must stop using Our Site immediately.


  1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:







means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 14, below;


“personal data”








“Retail partner and

service provider”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);


means any retail partner and service provider of content, good or services in connection with Our site


  1. Information About Us
    • We are a limited company registered in England and Wales under company number 3419460 whose registered address is 8 Ash Tree Court Woodsy Close Cardiff Gate Business Park Cardiff CF23 8RW
    • iCOM Works Limited is the controller and responsible for your personal data
    • Reward Works, Saving Works, Vectis Card are trading names of Ours
    • Our Site is owned and operated by iCOM Works Limited part of Terryberry UK.
    • Our VAT number is GB 701153490
    • Our Data Protection Officer is responsible for overseeing questions in relation to this Privacy Policy and can be contacted at Data Protection Officer, iCOM Works Limited, 8 Ash Tree Court, Woodsy Close, Cardiff Gate Business Park, Cardiff CF23 8RW.
    • We are registered under the Data Protection Act (No. Z566699X)
    • We are International Organisation for Standardised (ISO) 9001 and 14001 certified
    • We are accredited Investors in People Silver


  1. Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how We collect and process your personal data through your use of Our Site. It is important that you read this policy together with any other policy or fair processing policy that we provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy supplements other privacy policies and is not intended to override them. This Site is not intended for children and We do not knowingly collect data relating to children.


  1. Third Party Links

3.1          Our Site may contain links to Our other websites and other third-party websites. Clicking on those links or enabling those connections may allow third parties to collect, store, use or share data about you.  We do not control these third-party websites and are not responsible for their privacy policies. When you leave Our Site We advise you to check the privacy policies of any such websites before providing any data to them.

3.2          Any retail partner and service providers that feature on this Site have been chosen for their service, product quality, reputation, and commitment to customer satisfaction. Any transaction you make is between you and the retail partner and service provider, and although they meet our required standards, we cannot guarantee the privacy of your information once you leave Our Site. You may be required to register with the retail partner and service providers to enable you to access their website.


  1. Your Legal Rights
    • As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
      • The right to be informed about Our collection and use of personal data;
      • The right of access to a copy of the personal data We hold about you (see section 13);
      • The right to request rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 8);
      • The right to be forgotten – i.e. the right to ask Us to delete or remove any personal data We hold about you where there is no good reason of us continuing to hold it. Note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request (We only hold your personal data for a limited time, as explained in section 8 but if you would like Us to delete it sooner, please contact Us using the details in section 15);
      • The right to restrict (i.e. prevent) the processing of your personal data in the following scenarios: if you want to establish the data’s accuracy, where Our use of the data is unlawful but you do not want Us to erase it, where you need Us to hold the data even if We no longer require it as you need to establish, exercise or defend legal claims, or, you have objected to Our use of the data but We need to verify whether We have overriding legitimate grounds to use it;
      • The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note 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.;
      • The right to object to Us using your personal data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You may also have the right to object where We are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms; and
      • Rights with respect to automated decision making and profiling.
    • If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 15 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
    • For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.


  1. How Do We Collect Your Data?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, Secure File Transfer Protocol (SFTP) or corresponding to us via email or otherwise. This includes personal data that you provide when you:

request marketing to be sent to you;

subscribe to our service or publications

give us some feedback; and

apply for our products or services.

Automated technologies or interactions. As you interact with Our Site, we may automatically collect data about your browsing actions and patterns. We collect this data by using Cookies, server logs and other similar technologies.


  1. What Data Do We Collect?

Depending upon your use of Our Site, we may collect, use, store and transfer some or all of the following data about you which we have grouped together as follows (please also see section 14 on Our use of Cookies and similar technologies):

  • Identity Data includes first name, last name, title, date of birth and gender
  • Contact Data includes billing address, delivery address, email address and phone number.
  • Financial Data includes bank details and payment card details
  • Profile Data includes your preferences, feedback and survey responses.
  • Usage Data includes information about how you use Our Site, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.


Where we need to collect personal data by law, or under the terms of Our contract we have with Our Client and you fail to provide that data as requested, we may not be able to perform the contract that we have.


  1. How Do We Use Your Data?
    • All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 9, below.
    • Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in legitimate interests. Specifically, we may use your data for the following purposes:
      • Personalising and tailoring your experience on Our Site;
      • Supplying Our product to you (please note that We require your personal data in order to provide our product to you);
      • Personalising and tailoring Our product for you;
      • Replying to emails from you;
      • Supplying you with emails that you have opted into (for opt out please see section 16 below);
      • Supplying you with important service emails on Site maintenance, downtime and closure
      • Providing events such as competitions or free prize draws. Participation in these events is entirely voluntary; full details of the information requested and potential uses and disclosures of that information will be given with the notice of the event.
    • With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
    • We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.
    • You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
    • We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
      • For the duration of our contract or agreement with the Client.
      • Once our contract or agreement with the Client ceases or is terminated, your personal data will be deleted within 30 days.
      • Should dialogue cease, your personal data will be deleted after 5 years.


  • We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us.
  • If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
  • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


  1. How and Where Do We Store Your Data?
    • We only keep your personal data for as long as We need to in order to use it as described above in section 8, and/or for as long as We have your permission to keep it.
    • Your data will only be stored and processed in the UK
    • We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Data security is very important to Us, and to protect your data
    • 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.
  2. Do We Share Your Data?
    • We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing and delivery of goods. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
    • We expect these third parties to have the same level of information protection that we have
    • We use third parties to supply the following products and services and share personal data with:
      • Provision of Employee and Member Benefit Schemes
      • Provision of Reward and Incentives Provision of print related products
      • Provision of Online Solutions
      • Provision of Logistics
      • Provision of Print related products and electronic solutions
      • Provision of warehousing and pallet/courier service
    • We may need to share your personal details with a retail partner and service provider where it is part of providing a service for you, such delivery of an item or resolution of an enquiry. When required we will only share the information which is essential to providing that service and any third parties that we use will never use your personal information for their own emails unless you've given your express consent.
    • We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with our Client and third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
    • In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.


  1. What Happens If Our Business Changes Hands?
    • We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
    • In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.


  1. How Can You Control Your Data?
    • In addition to your rights under the GDPR, set out in section 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account.
    • You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.


  1. How Can You Access Your Data?
    • You have the right to ask for a copy of any of your personal data held by Us (where such data is held) Under the GDPR, No fee is payable under normal circumstances.          We reserve the right to charge a reasonable fee for requests that are manifestly                      unfounded, excessive, or repetitive. Such charges will be based only on the                     administrative cost that we will incur in order to respond. Alternatively, We may           refuse to comply with your request in these circumstances.


  • We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal data (or to exercise any of your 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. We may also contact you to ask you for further information in relation to your request to speed up our response.


  • Please contact Us using the contact details below in section 15. Alternatively, please refer to Our Data Protection Policy.


  • We try to respond to all legitimate requests within one month. Occasionally it may take longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


  1. Our Use of Cookies
    • Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use                             Cookies to facilitate and improve your experience of Our Site and to provide and                                improve Our products and services. You can set your browser to refuse all or some                           browser Cookies, or to alert you when websites set or access Cookies. If you disable                             or refuse Cookies, please note that some parts of Our Site may become inaccessible                                or not function properly.


  1. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at or by post at Data Protection Officer, iCOM Works Limited, 8 Ash Tree Court, Woodsy Close, Cardiff Gate Business Park, Cardiff CF23 8RW. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 13, above).



  1. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This version was last updated on 21st December 2021.