The Company known as SF Software Limited trading as Pebble is hereafter referred to as the Company.
We are SF Software Limited trading as Pebble. In this privacy notice we explain how we will process your personal information obtained through your use of our website, www.mypebble.co.uk, and through other interactions with you, for example, when you interact with us professionally or purchase our products as the account holder.
We also provide cloud based software solutions, Tali, Trac and Till systems, for schools and other organisations (our Customers). This involves processing personal data of individuals (pupils, parents, guardians and employees of our Customers) on behalf of our Customers. Our processing of personal data obtained in connection with the provision of our systems to our Customers is not covered in this privacy notice. If you wish to learn about it, please read our Data Protection Statement.
It is important that you read this privacy notice, together with any other privacy notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data, and what data protection rights you have.
What does this notice cover?
Data Protection Legislation
We are committed to protecting your privacy and safeguarding your personal data. Our use of your personal data is subject to the data protection laws applicable in the United Kingdom, which on the date of the publication of this notice includes the EU General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 and other relevant UK and EU legislation concerning personal data (together Data Protection Legislation).
Who we are and how to contact us
When we say we, us, our or software in this privacy notice, we mean SF Software Limited, a company incorporated and registered in England and Wales with company number 05580540 and whose registered office is: Spaceworks, Benton Park Road, Newcastle Upon Tyne, England, NE7 7LX
For the purposes of the Data Protection Legislation, we are the controller of your personal data. This means that we are responsible for deciding how we hold and use personal information about you.
If you have any questions about this privacy notice, (including any requests to exercise your legal rights) please contact us either by:
Personal data we collect
Personal data means information which relates to an identified or an identifiable individual. Types of personal data we may collect including examples
We may also collect, use and share anonymised, aggregated data such as statistical or demographic data for any purpose. Anonymised data may be derived from your personal data but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate information on how you use our website to calculate the percentage of users accessing a specific website feature.
How we collect personal data
We collect most of this information from you direct. However, we may also collect information from other sources.
How and why we use personal data
Under the Data Protection Legislation, we can only use your personal data if we have a proper reason for doing so.
1.) Consent. Generally, we do not rely on consent as a legal basis for processing your personal data other than to:
Where your permission is required, we will ask you for such consent separately and clearly.
You have the right to withdraw consent or object to marketing at any time by emailing us at email@example.com or using the ‘unsubscribe’ link in our marketing emails. Even if we are not required to obtain your consent for marketing purposes, you can still opt-out of receiving marketing communications at any time, so you are still in control.
2.) Contract. We will use your personal data if we need to do it to perform our obligations under a contract with you, or if it is necessary for a contract which we are about to enter with you. For example, if we need to:
3. ) Legitimate interests. We may process your personal data when we (or third party) have a legitimate reason to use it, so long as this is not overridden by your own rights and interests. For example:
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or structure of our business.
4.) Legal obligation. We may process your personal data to comply with our legal obligation. For example, to:
Who we share personal data with
We may share your information with third parties for the purposes set out in this notice.
We may share your data with service providers, which we use to operate our business. For example:
We have contracts in place with the above providers to ensure that your personal data is protected. Please note that we may from time to time engage new providers or stop using providers included in the list above.
Transfers of data outside the European Economic Area (EEA) are subject to special rules under the Data Protection Legislation. Those of our providers, who are based in the USA, subscribe to the EU-US Privacy Shield framework. Transfers of personal data under the Privacy Shield framework are deemed by the European Commission to provide an appropriate level of protection.
Some of our providers may transfer your data outside the EEA but only to countries that have been identified by the European Commission as providing adequate protection (such as New Zealand), or a third party using an appropriate safeguard mechanism (for example, by entering into the European Commission’s standard contractual clauses, or, for transfers to US-based third parties, by ensuring that the entity subscribes to the EU-US Privacy Shield).
We may also:
The recipients of the information will be bound by confidentiality obligations.
How long we keep personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. For example:
In some circumstances we may 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.
You have a number of rights in relation to your personal data, which allow you to access and control your information in certain circumstances. You can exercise these rights free of charge, unless your request is manifestly unfounded or excessive (in which case we may charge a reasonable administrative fee or refuse to respond to such request).
Keeping personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We hope that we can resolve any query or concern you may raise about our use of your information. You may contact us by using the contact methods set out in the How we are and how to contact us section of this policy.
The Data Protection Legislation also gives you a right to lodge a complaint with a supervisory authority, in particular in the European Union (or the European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws has occurred. The supervisory authority in the UK is the Information Commissioner, who may be contacted at https://ico.org.uk/concerns, telephone on 0303 123 1113, or by post to: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance.
We may change this privacy notice from time to time. When we do, we will publish the new version of the policy on our website. We may also inform you via email or post.
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