PRIVACY NOTICE
Last updated June 23, 2024
1. INTRODUCTION
This Privacy Notice is provided by Pepster Limited (trading as Pepster App), a company registered in England and Wales under company number 13921118 with registered office 2nd Floor College House, 17 King Edwards Road, Ruislip, London, United Kingdom, HA4 7AE (‘we’, ‘our’ or ‘us’) for use of our website, being https://www.trypepster.com/ and Pepster mobile app (collectively referred to as the ‘Website’).
We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
2. WHAT THIS POLICY APPLIES TO
This privacy notice relates to your use of the Website and accessing the services provided through the Website.
The Website may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with the services through the Website. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3. PERSONAL DATA WE COLLECT ABOUT YOU
The personal data we collect about you depends on the particular activities carried out through the Website. We will collect and use the following personal data about you:
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Category of data |
In more detail |
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Identify and account data you input into the Website |
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Data collected when you use specific functions in the Website |
Data you store online with us using the Website including your usage history (while such data may not always be personal data as defined at law in all cases, we will assume it is and treat it in accordance with this policy as if it were) |
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Other data the Website collects automatically when you use it |
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Data collected when you make an enquiry with us |
Your name and email address |
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ usage data (including information about how users interact with and use the Website and products and services offered through the Website) to calculate the percentage of users accessing a specific feature of the Website in order to analyse general trends in how users are interacting with the Website to help improve the Website and our offerings.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4. SENSITIVE DATA
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Website (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.
5. LOCATION SERVICES/DATA
The Website will request your consent to use location services to precisely identify your location each session (i.e. each time the Website is opened or has been placed in the background for more than 30 seconds).
If you do not provide your consent, you may use the Website but that will mean the “maps” feature on the Website will not be available and you will not be able to use the Website properly and for the purpose. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.
The location services in the Website will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Notice, as this is the map service we integrate to our app.
We exert no control over Google’s Privacy Notice and we therefore recommend that you consult their privacy notice for further information on how Google protect personal data please visit their site – https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.
6. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
(i) Your interaction with us: We collect personal data from you directly when you sign up to the Website, sign up to the mobile app, subscribe to our communications, contact us directly or reach out to us via social media, make submissions via the Website when a forum element is available, or indirectly, such as your activity while using the Website, participate in any feedback or survey.
(ii) Automated technologies or interactions: As you interact with the Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie police available at https://www.trypepster.com/cookie-policy/ for further details.
7. HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
(ii) to comply with our legal and regulatory obligations
(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or
(iv) for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
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What we use your personal data for |
Our reasons |
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Create and manage your account with us |
To enable you give access to other users in a 25 mile radius of your location as also to perform our contract with you or to take steps at your request before entering into a contract. To authenticate and verify your identity by sending you SMS and text message subject to your consent. |
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Providing services and/or the functionalities of the Website to you |
Depending on the circumstances:
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To enforce legal rights or defend or undertake legal proceedings |
Depending on the circumstances:
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Carry out market research through your voluntary participation in surveys |
Necessary for our legitimate interests to study how customers use the products, use our Website and to help us improve and develop our Website and products and services offered through the Website. |
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Communications with you not related to marketing, including about changes to our terms or policies or updates concerning the order placed by you through the Website or changes to the Website or service or other important notices |
Depending on the circumstances:
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Protect the security of systems and data |
To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
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Operational reasons, such as improving efficiency, training, and quality control or to provide support to you |
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you |
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Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app |
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Updating and enhancing user records
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Depending on the circumstances:
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To comply with our legal and regulatory obligations |
Depending on the circumstances:
where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website |
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To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances:
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See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
8. MARKETING
We do not intend to send you SMS, messages or emails for promotional or marketing purposes.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations or other third parties for marketing, advertising or promotional purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
9. WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with service providers we use to help us run our business, help us with fulfilment of the orders placed through the Website such as authentication or verification services such as Vonage, payment aggregators, apple store or google play store, or provide the services or functionalities in the Website, including developers, cloud storage providers etc.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
- external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
10. HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal data for as long as you have an active account with us and for a period of up to 2 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
11. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy notice’ below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely an appropriate safeguard under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
12. YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
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Access to a copy of your personal data |
The right to be provided with a copy of your personal data. |
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Correction (also known as rectification) |
The right to require us to correct any mistakes in your personal data. |
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Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data—in certain situations. |
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Restriction of use |
The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data. |
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Data portability |
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. |
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To object to use |
The right to object:
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Not to be subject to decisions without human involvement |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
13. KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
14. HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
15. CHANGES TO THIS PRIVACY NOTICE
We may change this privacy notice from time to time. When we make significant changes we will take steps to inform you, for example via the Website or by other means, such as email.
16. HOW TO CONTACT US
You can contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
- 2nd Floor College House, 17 King Edwards Road, Ruislip, London, United Kingdom, HA4 7AE
- +44 20 3286 2749