Swagbucks, MyPoints, Shopathome, and InboxPounds

GraceCourt

The above "make cash at home" services all involve Prodege LLC, a limited liability company incorporated in the USA, which claims to be the Data Controller for the purposes of the Data Protection Act 2018 in its "international privacy policy", published here.  It lists a business address in London (which appears to be an "accommodation address"), and claims in its terms and conditions that:

These Terms and Conditions and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.

But as the company isn't incorporated in the UK, and in its "terms of use" it states (my emphasis):

The Company makes no representation that materials on the Prodege Sites and Features are appropriate or available for use at other locations outside of the United States...

... anyone providing the company with any information, whether personal data or otherwise, has no recourse whatsoever, and the reference to English Law and the English Courts appears to be specious.  In short, whether or not it is a data controller within the meaning of Part 2 of the Data Protection Act 2018 is completely immaterial, because any information provided by a data subject is being exported by that data subject to the USA, where there is no protection whatsoever - the European Court of First Instance regards US data protection as being wholly inadequate and it struck down the so-called "Safe Harbor" and "Privacy Shield" agreements accordingly.

In short, a UK data subject cannot obtain redress for any data breach or for unlawful processing of their personal data because the company is not incorporated in any part of the UK and therefore any claim would have to be made in a US Court - where that claim would probably fail because the terms and conditions specify that English law applies!

Would I provide any information to this company?  No!  Would you?  Feel free... but don't complain here when it all goes badly wrong...   I've made all these points to the company's Press representatives by e-mail and I'll post any response here.