Previous Privacy Policy – April 2020
Privacy policy
Welcome to Peppy. This website is brought to you by Peppy Health Ltd. We take the privacy of our users very seriously. We ask that you read this Privacy Policy (‘the Policy’) carefully as it contains important information about how we will use your personal data. By submitting your personal information to us, you consent to the use of that information as set out in this policy.
For the purposes of data protection legislation, Peppy Health (‘we’ or ‘us’) is the ‘data controller’ of the information described in this Privacy Policy (i.e. the company who is responsible for, and controls the processing of, your personal data).
Personal data we may collect about you
We will obtain personal data about you such as your name, address, phone number and email address when you register. We will also collect data from you if you choose to interact with one of our practitioners.
Additionally, we will obtain your personal data when you send us feedback or contact us for any reason. We may also obtain sensitive personal data about you if you volunteer it during the completion of a form on the website/ App. If you volunteer such information, you will be consenting to our processing it for the purpose of our providing the service.
We may monitor your use of this website and our App through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on our use of cookies, please see our Cookie Policy.
How we use your personal data
We will use your personal data for the following purposes:
– research, statistical analysis and behavioural analysis;
– customer service improvements and quality management;
– customer profiling and analysing your purchasing preferences;
– marketing — see ‘Marketing and opting out’, below;
– fraud prevention and detection;
– customising this website and its content to your particular preferences;
– to display on the Peppy website and social media accounts any testimonial you may provide to us;
– to notify you of any changes to this website or to our services that may affect you; and
– improving our services.
Marketing and opting out
If you have given permission, we may contact you by SMS or email about products we think may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. For more details see ‘Your rights’, below.
Disclosure of your personal data
Keeping your data secure
We will use technical and organisational measures to safeguard your personal data, for example: we store your personal data on secure servers.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. It remains your responsibility to ensure nobody else will use our website and/or App while you are logged into your account (we advise our users to take extra care when using public computers/devices and to NOT leave themselves logged in; it is your responsibility to ensure this does not happen).
We may monitor and record communications with you (such as telephone conversations, emails and chat) for the purpose of quality assurance, training, fraud prevention and compliance.
Transfers of your information out of the EEA
We may need to transfer your personal data outside the European Economic Area (EEA), for example, if one of our suppliers or employees is located outside the EEA. We will ensure that any transfer of your data will be subject to appropriate safeguards, such as a European Commission approved contract (if appropriate) that will ensure you have appropriate remedies in the unlikely event of a security breach.
Information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
– give consent on his/her behalf to the processing of his/her personal data;
– receive on his/her behalf any data protection notices;
– give consent to the transfer of his/her personal data abroad; and
– give consent to the processing of his/her health data.
Links to Other Sites
Our website does and may contain links to other websites. This privacy policy applies only to our website (www.peppy.health and any website URL starting with www.peppy.health/) so when you visit other websites please read their privacy policies, as we cannot accept any responsibility for breaches or issues you may have in relation to privacy once you leave our website.
Your rights
You have the right to request access to personal data that we may process about you.
You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:
– email us at hello@peppy.health;
– provide us with enough information to identify you (e.g., account number, username, registration details); and
– specify the information that is incorrect and what it should be replaced with.
You can access, correct, update or request deletion of your personal information at any time, either through your online account or by contacting us. Deletion of data will be carried out on the understanding that removal of some information (e.g., addresses) during an active membership term may negatively affect your ability to use the site/ App.
You can request that we restrict processing of your personal information, object to processing of your information or request portability of your personal information. For these requests please email us at hello@peppy.health. We will comply with your request where your rights have been exercised in accordance with applicable laws.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you should:
– Email us at hello@peppy.health with subject title ‘Unsubscribe’;
– provide us with enough information to identify you (e.g., account number, username, registration details); and
– if your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g., email or telephone), please specify the channel you are objecting to.
Our contact details
We welcome your feedback and questions. If you wish to contact us, please send an email to hello@peppy.health.
Changes to privacy policy
We keep our privacy policy under regular review. If we change our privacy policy we will post the changes on this page, so that you may be aware of the information we collect and how we use it at all times.
Complaints to the ICO
If you make a complaint to us and think we have not dealt with it to your satisfaction, you may send your complaint to the Information Commissioner for investigation. For more information on the Information Commissioner, and how to make a complaint, please visit their website at www.ico.org.uk.
Latest version: 3 April 2020