0330 124 2019

Privacy Policy Overview

This privacy policy sets out how Peppy Marketing Ltd collects, uses and protects Personal Data, which you agree to when you give us this data.

We are committed to ensuring that your privacy is protected. Your Personal Data will only be used in accordance with this privacy policy. We will also advise you of your Personal Data rights and how to register a complaint to the relevant authorities, namely the Information Commissioner’s Office (UK).

We may change this policy. You should check this page periodically to review any changes. This policy is effective from <insert date> and complies with the General Data Protection Regulation (GDPR) from May 25th 2018.

If you choose not to give us Personal Data, it may delay or prevent us from fulfilling our contract with you, or doing what we must do by law. If it means we cannot provide a service or product, it could mean that we cancel a product or service you have with us.

Who are we and how to contact us

References in this Privacy Policy to Peppy Marketing Ltd, “we”, “us” or “our” relate to Peppy Marketing Ltd (Registration number 11227738).

We control the ways your Personal Data is collected and the purposes for which your Personal Data is used by Peppy Marketing Ltd, acting as a “data controller” in line with GDPR and the Data Protection Act 1998.

Where we act on behalf of a client, we act as a “data processor” under their strict instruction and in line with applicable European data protection legislation and under the Data Protection Act 1998.

For any privacy policy related enquiries you can contact us via:

Protecting your Personal Data

Your Personal Data is protected by regulations and laws. These state that we can only process your Personal Data for one of the following genuine reason types:

The law and other regulations treat some types of sensitive Personal Data as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data and criminal records. We will only collect or use these types of data with your consent unless the law allows us to do so.

Legitimate Interests for using your Personal Data

When we have a business or commercial reason to process your Personal Data this is referred to as a legitimate interest. Your Personal Data is still protected and we must not process it in a way that would be unfair to you or your interests.

Here are our reasons for using your data:

Serving you as a customer

Personal Data Use

To manage our relationship with you or your business

To develop and carry out marketing activities

To study how our customers use products and services from us and other organisations

To communicate with you about our products and services

Genuine Reason

Your consent

Fulfilling contracts

Our legitimate interests

Our legal duty

Our Legitimate Interest

Keeping our records up to date, working out which of our products and services may interest you and telling you about them

Developing products and services, and what we charge for them

Defining types of customers for new products or services

Seeking your consent when we need it to contact you

Being efficient about how we fulfil our legal and contractual duties

 

Business Improvement

Personal Data Use

To test new products

To manage how we work with other companies that provide services to us and our customers

To develop new ways to meet our customers’ needs and to grow our business 

Genuine Reason

Fulfilling contracts

Our legitimate interests

Our legal duty

Our Legitimate Interest

Developing products and services, and what we charge for them

Defining types of customers for new products or services

Being efficient about how we fulfil our legal and contractual duties

 

Managing our Operations

Personal Data Use

To deliver of our products and services

To make and manage customer payments

To manage fees, charges and recover money owed to us

Genuine Reason

Fulfilling contracts

Our legitimate interests

Our Legitimate Interest

Being efficient about how we fulfil our legal and contractual duties

Complying with rules and guidance from regulators

 

Managing security, risk and crime prevention

Personal Data Use

To detect, investigate, report, and seek to prevent financial crime

To manage risk for us and our customers

To obey laws and regulations that apply to us

To respond to complaints and seek to resolve them

Genuine Reason

Fulfilling contracts

Our legitimate interests

Our legal duty

Our Legitimate Interest

Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect

Complying with rules and guidance from regulators

Being efficient about how we fulfil our legal and contractual duties

 

Business Management

Personal Data Use

To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit

To exercise our rights set out in agreements or contracts

Genuine Reason

Our legitimate interests

Our legal duty

Fulfilling contracts

Our Legitimate Interest

Complying with rules and guidance from regulators

Being efficient about how we fulfil our legal and contractual duties

For Processing Special Categories of Personal Data

Substantial public interest: Using criminal records data to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour

Using criminal and health information as needed to provide insurance products

Responding to regulatory requirements: Showing whether we have assessed your situation in the right way

Passing information to the regulator as needed to allow investigation into whether we have acted in the right way

Legal claims: Using any special categories of data as needed to establish, exercise or defend legal claims

Consent: Telling you that we need your consent to process special categories of Personal Data, when that is what we rely on for doing so

Groups of Personal Data

This explains what all the different types of Personal Data mean which are covered by data protection law.

Personal Data Type: Description

Financial: Your financial position, status and history

Contact: Your name, where you live and how to contact you

Socio-Demographic: Details about your work or profession, nationality, education and where you fit into general social or income groupings

Transactional: Details and transactions to and from your interactions with us including payment

Contractual: Details about the products or services we provide to you

Locational: Data we get about where you are. This may come from your mobile phone or the place where you connect a computer to the internet

Behavioural: Details about how you use products and services from us and other organisations

Technical: Details on the devices and technology you use

Communications: What we learn about you from letters and emails you write to us and conversations between us

Social Relationships: Your family, friends and other relationships

Open Data & Public Records: Details about you that are in public records, such as the Electoral Register, and information about you that is openly available on the interne

Usage Data: Other data about how you use our products and services

Documentary Data: Details about you that are stored in documents in different formats, or copies of them

Special types of data: The law and other regulations treat some types of Personal Data as special. We will only collect and use these types of data if the law allows us to do so:

Data relating to criminal convictions and offences: The law and other regulations treat this information as extra special. We will only collect and use it if the law allows us to do so.

Consents: Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you, whether you get paper statements, or prefer large-print formats

National Identifier: A number or code given to you by a government to identify who you are, such as a National Insurance number or social security number, or Tax Identification Number (TIN)

How we store and process your data

Your Personal Data will be collected, processed and stored in the EU for up to 60 days unless data controller instructs otherwise.

Who we share your information with

In order to provide updates and offers that may be of interest to you, we may use recognised third parties to manage and provide services that enable us to meet and provide the services we’ve outlined in this privacy policy. These businesses operate within the EU.

Where services and processes are completed by our partners and 3rd parties, we ensure they operate to our strict guidelines in accordance with this privacy policy and we take reasonable precautions to safeguard your Personal Data and ensure our partners do the same.]

Here we list all the types of organisation that we may share your Personal Data with.

Authorities – This means official bodies and includes:

Security

In an unlikely event of a data breach we will notify the appropriate authorities as per applicable regulations and laws. If the incident affects you, we will contact you also.

Cookies

Cookies are small files containing information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs such as remembering your preferences, tailoring web-site content and generally improving your online experience.

By using our website, you agree that we can place these types of cookies on your device. You can block cookies using your browser settings. How to guides can be found online on how to do this for most web browsers.

There are different durations of cookie. These are:

Temporary (session) cookies: Session cookies last for the duration of your visit and are deleted upon closure of your browser. They facilitate tasks such as allowing a website to identify a user of a particular device is navigating from page to page, supporting website security or basic functionality.

Persistent cookies: Persistent cookies last after you have closed your browser and allow a website to remember your actions and preferences. Sometimes persistent cookies are used by websites to provide targeted advertising based on the browsing history of the device.

Cookies can come from different sources:

First and third party cookies: Cookies from us (1st party) or cookies from someone else (3rd party). We use both first party and third party cookies.

And they are usually one of the following types:

Strictly necessary cookies: These enable you to move around the website, use its features and ensure your online security. Without these cookies, some functions can’t be provided. These don’t gather information about you for marketing purposes.

Performance cookies: These collect information about how visitors use a website like most visited pages and web page error messages. These cookies may collect the IP address of the device used to access the site. The information these cookies collect is used to improve how a website works, the user experience and to optimise our advertising.

Functionality cookies: These allow the website to remember choices you make (such as your user name). They are also used to identify what type of customer you are based on your behaviour. Using this information we may set your default homepage to that which is most appropriate for your customer type for the next time you visit us. They may also be used to provide services you request, such as watching a video. The information these cookies collect don’t track your browsing activity across other websites.

Targeting cookies: These cookies collect several pieces of information about your browsing habits. They are usually placed by advertising networks. They remember that you have visited a website and this information is shared with other organisations such as media publishers.

These organisations do this in order to provide you with targeted adverts more relevant to you and your interests. This type of advertising is called online behavioural advertising and place an icon in the top right hand corner of an advert. This icon when clicked, will take you through to the website Your Online Choices where there is more help and guidance for you to Opt-out of this type of advertising.

Cookies we use:

Cookie name Description
G-Analytics The G-A cookie is part of Google analytics, and is primarily used to track visits to any site which uses Google analytics. G-A stores the number of visits made from your device, the time of the first visit, the previous visit, and the current visit. This cookie doesn’t contain any Personal Data other than the IP address of your device. This is a third party cookie
   

 

Contacting us, exercising your information rights and complaints

Under certain circumstances, by law you have the right to:

You will not have to pay a fee to exercise any of these rights however we may charge a reasonable fee if your request for Personal Data access is clearly unfounded or excessive or alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to invoke any of your Personal Data rights. This is another appropriate security measure to ensure that Personal Data is not disclosed incorrectly.

If you have any questions about this Privacy Policy, wish to exercise your information rights in connection with the Personal Data you have shared with us or wish to make a complaint, please contact us via our contact details listed earlier in this Privacy Policy.

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