Privacy policy
Last updated July 2023
Introduction
Welcome to Pinnacle Pet Group Limited’s privacy policy.
Pinnacle Pet Group Limited 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 Pinnacle Pet Group Limited collects and processes your personal data through your use of this website.
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
This privacy policy is issued by Pinnacle Pet Group Limited so when we mention "we", "us" or "our" in this privacy policy, we are referring to Pinnacle Pet Group Limited who is the controller and responsible for this website. Pinnacle Pet Group Limited is the parent company to a number of subsidiary companies, details of which can be found here:
Pinnacle Pet Group Limited
Pinnacle Insurance plc (trading as helpucover and everypaw)
Pinnacle Insurance Management Services plc
The above companies are part of the Pinnacle Pet Group (all "Group companies")
Registered Address
Pinnacle House
A1 Barnet Way
Borehamwood
Hertfordshire
WD6 2XX
Together all of the companies are referred to as “Pinnacle Pet Group”. Should you visit the website or otherwise interact with one of these subsidiary companies, that company will be the controller for your data in relation to that visit and/or interaction and their privacy policy will apply.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Pinnacle Pet Group Limited
Postal address: Pinnacle House, A1 Barnet Way, Borehamwood, Hertfordshire WD6 2XX
Email: dataprotection@pinnaclepetgroup.com
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.
Links to other websites
This website includes links to websites of other companies within the Pinnacle Pet group of companies. When you leave our website, we encourage you to read the privacy policy of every website you visit.
This website may also 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 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:
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Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
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Usage Data includes information about how you use our website.
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 (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
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Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
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We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
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Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical Data from analytics providers such as Google based outside the UK;
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:
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To comply with our legal and regulatory obligations
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To fulfil our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Purposes for which we will use your personal data
We have set out below, a 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. Please use the Glossary at the end of this policy to understand the meaning of some of the terms used in this section.
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 1: To administer this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
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Identity
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Contact
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Technical
Lawful basis for processing including basis of legitimate interest
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Necessary for our legitimate interests (for provision of administration and IT services, network security, to prevent fraud)
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Necessary to comply with a legal obligation
Purpose/Activity 2: To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you
Type of data
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Identity
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Contact
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Profile
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Usage
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Marketing and Communications
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Technical
Lawful basis for processing including basis of legitimate interest
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Necessary for our legitimate interests (to study how visitors use our website, to develop them, to grow our business and to inform our marketing strategy)
Purpose/Activity 3: To use data analytics to improve our website, marketing, relationships and experiences
Type of data
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Technical
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Usage
Lawful basis for processing including basis of legitimate interest
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Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy
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 “Purposes for which we will use your personal data” above.
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Sharing of information within our Group: We share your personal data within our Group for commercial reasons to understand our visitor base to our website.
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Sharing of information outside our Group: IT service providers that perform services on our behalf related to the website strictly where necessary.
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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.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
In cases of international data transfers originating from the UK or the European Economic Area (EEA) to a non-EEA country, the transfer of your personal data may take place. Where the Information Commissioner's Office or the European Commission has recognised that non-EEA country as providing an adequate level of data protection, your personal data may be transferred on this basis without your specific authorisation.
In cases of international data transfers originating from the UK to non-EEA countries where the level of protection has not been recognised as adequate by the Information Commissioner's Office or the European Commission, we will either rely on an exemption from a rule or law that is applicable to the specific situation (e.g. if the transfer is necessary to perform our contract with you) or use one of the following safeguards to ensure the protection of your personal data:
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Standard contractual clauses approved by the Information Commissioner's Office; or
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Binding corporate rules (for inter-group transfers), where applicable.
To obtain a copy of these safeguards or details on where they are available, you can send us a written request as set out in Section 9.
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. Retention of your personal data
We retain your personal data for a minimum period from the date of the data collection or the date of our last contact with you so that we can comply with applicable laws and regulations and our operational requirements
9. What are your rights and how can you exercise them?
In accordance with applicable regulations and where applicable, you have the following rights:
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to access: you can obtain information relating to the processing of your personal data and a copy of the personal data held.
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to rectify: where you consider that your personal data are inaccurate or incomplete, you can request that such personal data is updated.
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to erase: you can require the deletion of your personal data, to the extent permitted by law.
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to restrict: you can request the restriction of the processing of your personal data.
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to object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
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to withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
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to data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically possible, transferred to a third party.
If you wish to exercise the rights listed above, please contact us using the details listed above.
You may be required to verify your identity in certain cases when you exercise your rights.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.