Money Bubble Ltd – €140,400 Fine (United Kingdom, 2024)

MBL was incorporated on 24 January 2019, with its registered address at 137a Featherstall Road North, Oldham, England, OL9 6QB. MBL's stated business activities were 'financial intermediation not elsewhere classified' and 'other business support service activities not elsewhere classified'. MBL was investigated as part of a wider Operation initiated by the Commissioner, which focused on a rise in unsolicited marketing activity related to life insurance and later life planning. The Commissioner first became aware of potential unsolicited marketing activity after reviewing complaints received directly and through the TPS during October and November 2021. The investigation revealed that between 16 September 2021 and 10 November 2021, a total of 195 complaints were received, either directly by the Commissioner or by the TPS. A warrant was subsequently issued to further the investigation. On 14 March 2023, the warrant was executed and served on the office manager. Upon execution of the warrant, the Commissioner observed that at least three companies were operating from the premises, and none of the individuals present accepted responsibility for the account of the warrant. On 21 March 2023, following the execution of the warrant, the Commissioner sent an investigation letter to MBL. This correspondence included a list of complaints for MBL to review and provide explanations for. After a series of communications with MBL, the Commissioner concluded that MBL either initiated these calls or allowed its lines to be used to make them. MBL failed to provide any evidence demonstrating that these calls were made in compliance with the PECR. In reaching a decision, the Commissioner was satisfied that all 168,852 calls were made for the purposes of direct marketing as defined by section 122(5) of the DPA 2018. Furthermore, it was determined that MBL contravened regulations 21 and 24 of the PECR. Specifically, between 1 October 2022 and 30 November 2022, MBL permitted its lines t