Privacy Policy

Introduction

Welcome to the Privacy Policy of Pepper Global Servicing Management Limited (“Pepper Advantage”).

Pepper Advantage respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Pepper Advantage collects and processes your personal data through your use of this website, including any data you may provide through this website when you subscribe to our communications service or make general and/or specific enquiries to Pepper Advantage.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may 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 Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Controller

Pepper Global Servicing Management Limited is part of a group of different legal entities (collectively the “Pepper Advantage Group”). This Privacy Policy is issued on behalf of the Pepper Advantage Group so when we mention, "we", "us" or "our" in this Privacy Policy, we are also referring to the relevant company in the Pepper Advantage Group responsible for processing your data. Note that this website may take you to the website of another entity within the Pepper Advantage Group, in which case the Privacy Policy of that Pepper Advantage Group company shall apply.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights please contact: sokosi@peppergroup.co.uk . You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. This version was last updated in June 2022. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not always control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data	includes first and second name, company or employer name, username or similar identifier;
Contact Data	includes email address and / or telephone numbers;
Location Data	includes location or country of employment;
Technical Data	includes IP address, browser type and version, device specific information, operating system, device, and other technology on the devices you use to access this website;
Usage Data	includes information about how you use our website and services;
Marketing and Communications Data	includes your preferences in receiving marketing and communications from us and our third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (such as race, ethnicity, religion, health or sexual orientation) nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the communications service). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

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

Direct interactions. You may give us your Identity, Location or Contact Data by filling in forms or by corresponding with us through our website. This includes personal data you provide when you apply for or subscribe to our communications or marketing services or give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we may automatically collect Location or Technical Data about you, your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will request your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to such marketing communications at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a more detailed description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including legitimate interest
To review and respond to any queries you may submit to us, including queries relating to the website, recruitment or job vacancies	(a) Identity (b) Contact (c) Technical (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to consider potential applicants for employment and direct them to the appropriate contact)
To manage our relationship with you which will include notifying you about business updates relating to the Pepper Group	(a) Identity (b) Contact (c) Technical (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our employees, customers and users informed)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to improve our marketing strategy)
To make suggestions and recommendations to you about services or job vacancies that may be of interest to you	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)
To enable you to receive our mailing and marketing services	(a) Identity (b) Contact (c) Marketing and Communications	Consent

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing communications at any time by contacting us. Please note that this opt-out will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table at Section 4 above:

Internal Third Parties: Other companies in the Pepper Advantage Group who are based in the UK, EEA and outside of the EEA.
External Third Parties: Service providers acting as processors based inside and outside of the UK and EEA who provide website services, including Hubspot.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We may also need to disclose your data to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

6. International transfers

We share your personal data within the Pepper Advantage Group. This will involve transferring your data outside the UK. Some of our external third parties are also based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details on what is an adequate level of protection, see the ICO website.
We will only transfer your personal data to countries that have not been granted an adequacy decision by the ICO where a binding agreement is in place with that third party which requires the third party to give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will keep your data for fourteen (14) months from the end of the month on which you visited our website or inputted your details in respect of a general enquiry.

If you have subscribed to our marketing and communication services, we will keep your data for fourteen (14) months from the end of the month on which you unsubscribed to such service.

In some circumstances you can ask us to delete your data: see Section 9 below for further information. Further, in some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

In relation to your personal data we hold, you have the right to:
Request access	This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction	This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure	This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
Object to processing	Where we are relying on a legitimate interest (or those of a third party), you may object to the processing on this ground if there is something particular about your situation which you feel impacts on your fundamental rights and freedoms. You 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.
Request restriction of processing	of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer	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.
Withdraw consent	Please note, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at: sokosi@peppergroup.co.uk

No fee usually required

You will not have to pay a fee to access your personal data or to exercise any of the other rights mentioned above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.