For the purpose of the Act the data controller is Pepco Group Limited, Unit B, 120 Weston Street, London, United Kingdom, SE1 4GS, United Kingdom.
1. Information we may collect from you
We may collect and process the following data about you:
Information that you give us
You may give us information about you by filling in forms on our website, (“Our Website”), or by corresponding with us by telephone, email or otherwise. This includes information you provide when you register to use Our Website, post material or request further services/ information. We may also ask you for information when you report a problem with Our Website.
If you contact us in writing, we may keep a record of that correspondence. If you are providing us with your personal information for us to help you with a complaint/enquiry then it is in Pepco Group’s legitimate interest to store and use that data for those purposes.
2. Information we collect about you
With regard to each of your visits to Our Website 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 Website (including date and time); terms you searched for using the search function Our Website, the resources on Our Website you accessed, 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.
We use and share data for evaluation purposes. This includes assessing its suitability for a particular purpose and, for example, deciding whether or not it would be useful to us as part of a product or service. Sometimes it may be necessary to share data with a third party in order for them to be able to match it to data that they hold and return additional data to us.
3. What our legal grounds for handling personal data are
This section explains the legal basis on which we process personal data.
The UK’s data protection law allows the use of personal data where necessary for legitimate purposes provided that this isn’t outweighed by the impact it has on the relevant individuals. The law calls this the “legitimate interests” condition for processing personal data.
Most of our processing activities are based on the legitimate interests condition. When the use of your personal data is based on our “legitimate interests”, these are:
to support our customers’ needs, including helping with enquiries;
to understand our customers including their patterns, behaviours as well as their likes and dislikes;
to protect and support our business, our staff, customers, suppliers and visitors;
to prevent and detect anti-social behaviour, fraud and other crime;
to test and develop new products and services as well as improve existing ones.
We sometimes rely on consent from the relevant individuals in order to process their personal data, but this is relatively rare. It is used as the basis for sending marketing materials to consumers by email, telephone, SMS or similar methods, for example.
4. Information we receive from other sources
We work closely with third parties (including, for example, but not limited to, business partners, sub-contractors in technical, payment, delivery and customer services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
5. How we will use your information
We use information held about you in the following ways:
Information you give us
We will use this information:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us and your complaints and enquiries;
to notify you about changes to our service;
to analyse market trends and use of Our Website.
Information we collect about you
We will use this information:
to administer Our Website and for internal operations, including trouble shooting, data analysis, testing, research, statistical and survey purposes;
to improve Our Website to ensure that content is presented in the most effective manner for you and your computer/device;
as part of our efforts to keep Our Website safe and secure;
Information we receive from other sources
We may combine this information with information you give us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
6. Where we store your personal data
All information you provide to us is stored securely and is only used for the purposes for which it was collected.
7. Who we share the personal data with
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may provide personal data to third parties who help us use it for the purposes described in section 2. For example:
Our databases of personal data may be hosted by third parties on our behalf.
Some of our products and services rely on us sending personal data to third parties who then analyse or enhance it and return the results to us.
We use third party email broadcasting services in order to send emails or SMS messages.
We sometimes use market research companies to help us better understand our customers.
These service providers are generally not allowed to use information for their own purposes or on behalf of other organisations.
If we sell our business to a third party, or go through a corporate reorganisation, we will transfer personal data to the company that acquires the business.
We may sometimes need to pass personal data to a regulator such as the Information Commissioner’s Office or the Financial Conduct Authority.
8. Where the personal data is stored and sent
We are based in the United Kingdom, and will access and use personal data from here.
We also send information elsewhere in the world. For example, where we use cloud-based technology or a data centre or backup facility overseas. People in other countries may also need to access that database for purposes such as technical support or system development and testing.
While countries within the European Union all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection in relation to personal data. As a result, when we do send personal data overseas, we will make sure that suitable safeguards are in place to protect the information. For example, these safeguards might include:
Putting in place a contract with the recipient containing terms which have been approved by the authorities as providing a suitable level of protection.
Sending the information to an organisation which is a member of a scheme which has been approved by the authorities as providing a suitable level of protection. One example is the “Privacy Shield” scheme that has been agreed between the European and US authorities.
9. How long the personal data is kept for
We keep personal data only for as long as is necessary for the purposes for which it is held. You will need to contact us or refer to the privacy notices for our specific activities in order to find out exactly how long the data is kept for.
10. Whether the personal data is used to make automated decisions or to profile people
We perform various profiling activities using personal data. When we refer to profiling, we mean using personal data to make predictions about people, or to categorise them into particular groups.
12. Links to other websites
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Website; any transmission is at your own risk. However, once we have received your information, we will take appropriate security measures to try to prevent unauthorised access. For more information on the Data Protection Act 2018, please visit the website maintained by the Office of the Information Commissioner.
14. Your rights in respect of the personal data that we hold about you
You have several different rights in relation to the personal data that we hold about you. These are briefly described below. To enquire about exercising these rights, please use the contact details set out in section 1.
Access: You have a right to find out what personal data we hold about you, and certain other information such as how we are using it.
Withdrawal of consent: When we rely on your consent to use your data (see section 3 above), you have the right to withdraw that consent at any time.
With effect from 25 May 2018 you also have the following rights:
Rectification: If the information that we hold about you is inaccurate or out of date, you have a right to ask us to correct it.
Objection to legitimate interests: If you disagree with us relying on the legitimate interests grounds for using your personal data (see section 3 above), you can object to us doing so. We will then reassess the extent to which we can continue to use the data in light of your particular circumstances.
Erasure: In certain circumstances you can ask us to delete your personal data from our systems. However, this usually won’t apply to all of your data because we might have good reason for needing to keep some of it.
Restriction: In some circumstances you can ask us to restrict the ways in which we use your personal data.
Portability: You have the right to receive some limited kinds of information in a portable format.
15. Who you can complain to if you are unhappy about the use of your personal data
We try to ensure that we deliver the best levels of customer service but if you are not happy you should make contact so that we can investigate your concerns. Please contact us using these details:
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body that regulates the handling of personal data in the United Kingdom. You can do this online through the ICO’s website at www.ico.org.uk, by telephone on 0303 123 1113, or by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
This Policy explains how we collect and use information about you using web cookies, and how this affects your privacy.
What is a cookie?
A cookie is a small file of letters and numbers that we store on your computer/ mobile device if you agree.
We use the following cookies:
Strictly necessary cookies - These are cookies that are required for the operation of Our Website. They include, for example, cookies that enable you to log into secure areas of Our Website.
Analytical/performance cookies - These allow us to recognise and count the number of visitors and to see how visitors move around Our Website when they are using it. This helps us improve the way Our Website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies - These are used to recognise you when you return to Our Website. This enables us to personalise our content for you, greet you by name and remember your preferences.
Targeting cookies - These cookies record your visit to Our Website, the pages you have visited and the links you have followed. We will use this information to make Our Website and the advertising displayed on it more relevant to your interests.
Third Party Cookies - Our Website uses “Google Analytics”, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses persistent cookies (which remain in the cookie file of your browser after you have left Our Website) to help Google analyse how you use Our Website. These cookies collect information in an anonymous form.
The information generated by the cookie about your use of Our Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google and/or its subsidiaries may use this information for the purpose of evaluating your use of Our Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where:
required to do so by law;
it has a good faith belief that such disclosure is reasonably necessary to protect the rights, property or safety of Google, its users or the public; or
such third parties process the information on Google’s behalf.
Google will not associate your IP address with any other data it holds. If you would like to read more about Google Analytics or how Google might use your information, please click here: https://www.google.com/analytics/learn/privacy.html
Can I opt out of cookies?
You may block cookies by activating the setting on your browser or from the site which allows you to refuse some or all cookies. Please note that if you do this to block all cookies (including essential cookies), you may not be able to use the full functionality of Our Website.