Privacy Policy
Gold Pebble Ltd, whose registered office is at 140 Elphinstone Road, Hastings, East Sussex, TN34 2BN. Registered in England and Wales company number 13573524, VAT no. 388 6891 17
1. Our Data Promise to you
Gold Pebble Ltd is absolutely committed to respecting and protecting your data whilst it is in our care. We collect your personal information because it helps us to understand your needs and guides the way in which we interact and communicate with you about our products and services now and in the future. We have strict policies and procedures in place to protect your data when you send it to us; when we process it in order to provide you with the services you have requested; or, where you have given us your permission to do so, to send you information that we think you’ll find interesting, and thereafter when we store your data on our secure servers.
We are registered with the Information Commissioner’s Office, the regulator of General Data Protection Regulations (GDPR) and other relevant legislation and abide by its requirements.
2. The lawful bases Gold Pebble Ltd process personal data
Gold Pebble Ltd rely upon four of these lawful ways to collect, use, store and process personal data: Consent, Contractual; Legitimate Interests and Legal Obligations
To perform our contractual obligations to you.
We and our external companies process your information to perform our contractual obligations to you when we use your information to provide you with the Services. For example, when you purchase a product from us, we process your payment and contact information as necessary to confirm the set up and subscription and we process your contact information and other details to provide you with support services in regard to your subscription.
To pursue our legitimate interests.
We process your information to meet our legitimate interests when we use your information to provide you with the Services to communicate with you and for our demos, advertising, events and marketing purposes. In such cases we have balanced our interests with your interests and believe that these activities will not have a negative impact on your privacy rights. You can withdraw your consent at any time, by using the unsubscribe link or emailing [email protected].
To comply with our legal obligations.
We process and share your information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights. For example, we are required to collect certain information from you when processing your subscription payment for tax or financial reporting reasons.
With your consent.
We obtain your consent to process your information when we are required to do so by law. In relation to Cookies and Similar Technologies, we obtain your consent as described in our Cookie Policy. If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time, by using the unsubscribe link or emailing [email protected].
3. What Personal Data do we collect?
Gold Pebble Ltd collects Personal Data in a number of ways, such as, when you subscribe to one of our products, enter a competition, provide details at an event or when you interact with us via a website, mobile app or other digital services (“Services”). This Personal Data could include:
- Contact information, your name; postal address; email address; phone number.
- Comments, photos, videos and other content that you choose to publish or share with us.
- Payment information for product subscriptions or purchases made through our websites, mobile application or other digital services.
- Information you provide when participating in a competition; survey; event or apply for a job.
- Location information, when you permit the digital service to access device location. To prevent this access, please refer to instructions provided by your mobile service provider.
Information we obtain from other sources, such as our business partners, and social media platforms - You may give us information about other people, such as the name and email of a contact if you are attending an event or the name and address of a gift subscription recipient. Please ensure that you are authorised or have the person’s permission to do so.
4. How do we keep it secure?
We hold your personal data on our secure systems, mainly based within the UK and the European Economic Area (EEA). Our staff are trained in data security, and our staff policies and procedures help our staff to understand what is required of them under their obligations to us, and also their responsibilities under GDPR and other privacy legislation.
When we ask another organisation to provide a service for us, we ensure that they have appropriate security measures in place. If we or our service providers transfer any information out of the European Economic Area (EEA), it will only be transferred with the correct protection in place. This includes the use of Model Contractual Arrangements as approved by the European Commission and the EU-US Privacy Shield
5. How do we collect Personal Data?
We collect your details when you register on one of our websites; subscribe to one of our products; search for a product; correspond with us by phone, e-mail or otherwise; participate in discussion boards or other social media functions on our website; enter a competition or promotion; apply for a job.
With regard to each of your visits to our websites we may automatically collect the following information:
- technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We will always be transparent about how we plan to use your data so that you have the choice whether or not to give it to us. We respect your preferences and will do our best to make sure that we keep our promises.
If you give us your consent to send you further marketing messages we may contact you from time-to-time with carefully selected offers and promotions from our network of carefully selected partners, from which you may always opt-out or unsubscribe. It is not our practice to contact you if you have made it clear that you do not wish to hear from us about our products and services.
We may need to authenticate your identity to provide you with access to subscriber-only services. We might also send you surveys or invite you to enter a competition or receive a newsletter, for instance. If you do not wish to participate you may simply decline our invitations.
To understand how our “apps” are used we may use the service Google Analytics to provide us with anonymous statistical information about your use of our app(s).
As part of our Google Analytics tracking we have implemented the following features: Remarketing, Google Analytics Demographics and Interest Reporting. Visitors can opt-out of Google Analytics for Display Advertising by visiting here https://tools.google.com/dlpage/gaoptout/
We use this information for reporting purposes and to advertise online. Third-party vendors, including Google, may show our ads on sites across the Internet. We may use the cookies relating to Google Analytics together with third party cookies to inform, optimise and serve ads based on a user’s part visits to our websites. For more information please see our Cookie Policy.
6. How do we use your Personal Data?
Fulfilment of a service
We will use your personal data when fulfilling a product or service that you have requested. For example, when you subscribe to our e-news; register to access online content; register to test one of our demos; enter a prize draw/competition or apply for a job.
Marketing
We will only send you direct marketing when you have either provided consent for example by ticking a box or where we believe we can demonstrate a legitimate interest and have balanced this with your interests and privacy. You can opt out of receiving direct marketing at any time by clicking on the unsubscribe link on our emails or emailing [email protected].
Events
If you register for one of our demos at one of our events or in general, such as a specific meme generator or other products, we may share your details such as your name, job title and company name, with the events sponsors and social media platforms such as Facebook and Twitter .
Please note that at some events photographs and video footage may be taken and used for post event publicity. If you have any objection please email [email protected].
7. Do we share that data with any other companies?
Except as otherwise stated in this Privacy Policy or in the data collection statements that will always be visible when we collect your information and where we give you the opportunity to select your preferences, we may release your data to external companies that we use to process your orders, to supply you with a prize in the event you win a competition, or charge your credit card, for instance. Every supplier we use has to go through a rigorous up-front process to ensure that their processes are at least as good as our own, and they are required to sign a contract that defines what their responsibilities and liabilities are. We make site visits regularly whether our suppliers are in the UK, the EEA or outside the EEA, where we require an EU approved model contract to be signed.
If you send in a comment, we may post it on our site or use it as a testimonial without mentioning your full name or publishing any information that would identify you. Furthermore, in some circumstances we may display some of your information such as your username and age. Others may be able to see your personal data if you post any information on bulletin boards or forums and may be used to send you unsolicited communications over which we have no control.
We may share some of your information with advertisers, ad servers and ad networks to deliver targeted advertising both on our websites and on selected partner websites but this will not include any information which directly identifies you. However, by interacting with or viewing an advert, you should be aware that the third party may make the assumption that you meet the targeting criteria used to display the advert.
These activities may involve the use of cookies and other similar technologies. To learn more or to see how you can opt out of targeted advertising, for more information please read our Cookie Policy.
Please take care when using social networking sites to which we may invite you to join that you do not disclose anything that you might later wish to retract.
There are certain times when we may have a legal obligation to disclose your data in good faith where it is required by law or to respond to subpoenas or warrants served on us, or where we have a requirement to protect or defend the rights of Gold Pebble Ltd or any users of our servers. We will always ensure that those requesting the information have the legal right to do so.
If another company should acquire any of our companies or our assets, including our database, that company will have the right of possession to the Personal Data collected by us and will assume the rights and obligations formerly attributable to us and will use the data in line with the terms under which you submitted it or as described in this Privacy Policy.
8. The information we may collect from you about others
Sometimes we may offer you the chance to invite a family member or a friend to enjoy a particular service. In such circumstances, we will collect both your personal details and those of your friend or family member. We will ask your consent to mention your name when we contact the person or persons you have recommended and we will only use this information once and not save it in our database, unless they have entered a competition, for example, when the information will be stored purely for that purpose. If they decide to take up any of our invitations then their data will be treated exactly the same as your own, using the terms under which the data was collected and the information as described in this Privacy Policy, which they will be made aware of at the time of our invitation.
9. Leaving our website and moving on to third party websites
When you click on social media or external platform links on any of our sites, you will leave that site and go to a third-party site, which is outside of our control. When we place an advertisement on one of our sites, it does not signify that we are endorsing that advertiser’s product or service. We do not accept responsibility for content, which we have no control over, and our Privacy Policy does not apply to these companies, sites or content; and if such third-party sites collect Personal Data, we cannot control how this data is processed, stored or used. We advise that you read their data collection statements, which accompany any registration and their Privacy Policies, before you submit your personal information.
10. Cookies and how we use them
“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. Gold Pebble Ltd uses cookies for a number of reasons:
- To provide you with a more personal and interactive experience on our sites.
For statistical purposes to track how many users we have and how often they visit our websites. - We use organisation to collect anonymous user information so they can analyse how the website is being used and the number of visitors.
- We and our advertisers may use statistical cookies to track who has seen an advert and clicked on it.
- To show you adverts that you may be interested in and to control the number of time you see them and measures the effectiveness of the ad campaign.
- We may use ‘Flash’ cookies to store your preference for your media player. If we do not use them, it may not be possible for you to watch some video content.
You have the ability to accept or decline cookies, when you use the website for the first time via “see all options” link on the “pop up” banner, but please be aware that for some parts of our sites to work, you will need to accept cookies.
For more information about third party cookies generated by advertisers, please visit www.allaboutcookies.org and/or www.youronlinechoices.com
For more information on how Gold Pebble Ltd use cookies please read our Cookie Policy.
11. Logging in using social networking
If you login to our sites using a Facebook login or a Google login, you are granting permission to Facebook and/or Google to share your user details with Gold Pebble Ltd. This will include your name, email address, date of birth and location which will then be used to form a Gold Pebble Ltd identity. This will also allow Gold Pebble Ltd and Facebook and/or Google to share your networks, user ID and any other information you choose to share according to your Facebook and/or Google account settings. If you remove the Gold Pebble Ltd from your Facebook and/or Google settings, we will no longer have access to this information.
12. Opting out on Receipt of Email Marketing Communications Email
If you receive a marketing email from us, you will have the option to “opt-out” by clicking on the unsubscribe link provided at the bottom of each and every message we send you. If you wish to unsubscribe from all brand lists please contact [email protected]. Please be aware that this will not unsubscribe you from our service based messages, such as subscription rewards and subscription reminders. If you wish to be opted out of reward emails, please contact [email protected]
SMS
If you receive a marketing SMS text, please text “STOP” to any message received.
Phone
If you receive a marketing call from Gold Pebble Ltd, please let the call operator know you do not wish to receive any further calls.
If you wish to stop all marketing communications from Gold Pebble Ltd, please email [email protected]
13. Telephone and Mailing Preference Services
The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS) and the Mailing Preference Service (MPS) allow you to choose to opt out of unsolicited marketing. However, if you are registered on any of the preference services, which are general opt-out registers, you may still receive marketing communications from us if you have given us your consent previously or if you subsequently give us that consent or if we are contacting you under legitimate interests.
14. Marketing to Children
We do not knowingly collect personal information from children under the age of 16 for marketing purposes.
15. Using our websites from outside the UK
Our servers are situated in the EEA and when you submit your details and in whichever country you are situated you agree to the data being transferred to the EEA and processed under the terms of GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 which stem from European Directives 95/46/EC and 2002/58/EC respectively. If you are not in agreement please do not add your personal details on the website.
16. How you can gain access to the personal data we collect about you
Under GDPR, you have the right to see what information we hold about you and the purposes for which we are using it. This is known as a Subject Access Request. In responding to such a request, we may ask for proof of your identity, to ensure that we do not send you personal data to another person. We will respond to any requests as soon as possible, but at least within 30 days.
Please click here to make a Subject Access Request
You may ask us to make any changes that you consider necessary to make the information accurate. If you want to apply to see the data we hold about you, please write to or email:
Data Protection Officer, 140 Elphinstone Road, Hastings, East Sussex, TN34 2BN
We will require that you satisfactorily identify yourself to demonstrate your entitlement to view this data.
If you wish for your personal data to be deleted we will review any request on a case-by-case basis. We will respond to you as soon as possible, at least within 30 days of receiving your request.
17. How long do we keep your personal data?
We hold personal data for different purposes and the length of time we keep your information will vary depending on the services or products we are providing. We will only keep your data for a reasonable period of time, which is based on the purpose for which we are using your data. Once that purpose has been fulfilled, we will securely delete that data or anonymise your information (so that we, or anyone else, can no longer tell that data relates to you) unless we are required to retain the data longer for legal, tax or accounting reasons.
We have a detailed retention policy for ensuring that we do not hold personal data for any longer than we justifiably need to. For further information on our retention policy contact [email protected].
18. Questions regarding this Privacy Policy
If you have comments or questions related to this Privacy Policy please email [email protected] and we will respond as promptly and as fully as we can.
Complaints will be dealt with within 30 days. If you are not satisfied with the response you should refer your complaint to the ICO ico.org.uk/concerns/
19. Changes to this Privacy Policy
This Privacy Policy will be amended from time-to-time if we make any important changes in the way that we collect, store and use personal data. We may notify you by sending an email to your last known email address or writing to your last known postal address to direct you to the Privacy Policy if the changes are material. Our dispatch of a communication to you will, in any event, constitute notification.
Any changes will be effective immediately.
This Privacy Policy was last revised in May 2022