User Data

What we collect

We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal data about you:

This may include:

1. Personal Identification
   1. Name;
   2. Email;
   3. Your  employer or business partner and place of work;
2. Any information you make available, or transmit to us, via social media accounts
3. We may record telephone conversations for training and security purposes. You will be notified if recording is taking place at the commencement of any call.

 We do not collect, store or use sensitive personal data.

How is data collected

In the course of our business, we may collect personal data directly from an individual:

1. when you submit an enquiry about our services; and
2. when you sign up to our mailing list.

We may also collect personal data about individuals from other sources such as:

• clients to whom we provide services and who ask us to process personal data on their behalf
• to confirm any bought-in marketing lists, information provided to us by marketing agencies and information provided to us by referrers.

We will only collect personal data to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it and we will keep it only as long as is necessary.

How we will use personal data 

We will only use personal data when the law allows us to do so and relying on a relevant basis for lawful processing in each instance.  We will use your personal data in the following circumstances, relying on the basis of processing indicated:

Basis of processing: Where we need to perform a contract we are about to enter into or have entered into with you.

• To provide you with information or services that you request from us (contact details).
• To carry out our obligations arising from any contracts entered into between you and us (contact details, payment information and any information relating to personalisation status).

Basis of processing:  Where it is necessary for our legitimate interests (or those of a third party, such as a client using our services, and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.

• To perform our obligations under any contract with our clients (name, contact details, online identifiers and other related information that our clients may provide).
• To ensure that content from our site is presented in the most effective manner for you and for your device (online identifiers and other technical information).
• To provide you with information or services that we feel may interest you (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details and any information relating to personalisation preferences).
• To allow you to participate in interactive features of our service, when you choose to do so (online identifiers and other technical information).
• To notify you about changes to our service (contact details).
• To maintain a basic amount of information about you and your use history, in order to provide you with a service tailored to your preferences (contact details, payment history and any information relating to personalisation status).

Basis of processing: Where we need to comply with a legal or regulatory obligation.

Basis of processing: Where you have consented to the processing.

• To use non-essential cookies on our site (see “Cookies” section below for further information) (online identifiers, location data and other technical information).  You have the right to withdraw consent to such use at any time by contacting us but please note that some or all parts of our site may no longer be accessible to you.
• To send you direct marketing communications via email, text message, post or telephone call (contact details).  You have the right to withdraw consent to any such use at any time by contacting us.

Other issues about how we use personal data:

1. Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.  Please contact info@peak.ai if you need details about the specific legal basis we are relying on to process your personal data.  
2. We will only use your personal data for the purposes for which we collected it (or were asked to process it on behalf of one of our clients), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  Please contact us if you would like further details of any additional purposes of processing.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
3. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).  If this happens, we may have to cancel, or be unable to provide, any services you have requested. 
4. Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
5. We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered “personal data” in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your website 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.
6. If you provide us with any personal data relating to colleagues or other individuals it is your duty to make such persons aware that their personal data may be shared with us and to provide them with appropriate information about how their personal data may be processed by us.   

Direct marketing 

As indicated above, we may use your personal data to provide you with information about goods and services which may be of interest to you and we may contact you about these by email, text message, post or telephone call. This is known as direct marketing.

Examples of direct marketing may include:

• sending promotional emails about new products, special offers, customer events or other information which we think you may find useful or interesting using the email address which you have provided; 
• contacting you for market research purposes (by email, text message, post or telephone call).

We will only process personal data for the above purposes as permitted by law, which usually means with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.

We may also disclose your information to third parties (including our subsidiaries, our ultimate holding company and its subsidiaries and any marketing agencies) for the purpose of direct marketing.  Again, we will only do this with your explicit consent and you have the right to withdraw this consent at any time.  

Consent

In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:

• is specific consent for one or more specified purposes; and

• is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the relevant processing of personal data.

Automated decision-making  

Automated decision-making takes place when an electronic system uses personal data to make a decision relevant to you without human intervention. We may process automated decision-making in the following circumstances:

1. Where we have notified an individual of the decision and given that individual 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with an individual and appropriate measures are in place to safeguard that individual’s rights.
3. In limited circumstances, with an individual’s explicit and informed consent and where appropriate measures are in place to safeguard that individual’s rights.

We will not make any decision that would significantly affect an individual based solely on processing by automated means, unless we have taken measures to protect the legitimate interests of that individual. If decisions are made by automated means, the individual has the right to know the logic involved in that decision-making.

Third parties we use to process data

We may share personal data we hold with: (i) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries; and/or (ii) in the event that we sell or buy any business or assets, or sell Peak, we will disclose your personal data to the prospective seller or buyer of such business or assets.  We may also disclose personal data we hold to third parties if we are under a duty to disclose or share an individual’s personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements; or to protect our rights, property, or safety of our employees, customers or others.  This includes exchanging personal data with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We utilise Amazon Web Services (AWS) for hosting and infrastructure services. AWS has no access to your data, all access control is managed by Peak. 

We may share personal data with other members in the group as part of our regular reporting activities on company performance.  When appropriate, we will anonymise personal data when used for performance reviewing and reporting activities. 

We may also share personal data we hold with selected third parties for the purposes set out below.  We do not allow our third-party service providers to use your personal data for their own purposes; we only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we hold your data

Transfer of personal data outside of the EEA: We may transfer certain personal data that we hold on individuals living to a country outside the UK or European Economic Area (“EEA“), provided that one of the following conditions applies:

• the country to which the personal data is transferred ensures an adequate level of protection for that individual’s rights and freedoms; 
• an individual has given their explicit and informed consent having had the risks explained to them;
• the transfer is covered by one of the derogations set out in the GDPR, including the performance of a contract between us and that individual, or to protect the vital interests of individuals;
• the transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
• the transfer is authorised by the relevant data protection authority where we have checked adequate safeguards exist with respect to the protection of the individual’s privacy, their fundamental rights and freedoms, and the exercise of their rights.

Subject to the requirements set out above, the personal data we hold may also be processed by individuals operating outside the UK or EEA who work for us or for one of our suppliers. Those individuals may be engaged in, among other things, the fulfilment of contracts with the relevant individual, the processing of payment details and the provision of support services.

Safeguards: If we use a third party data processor to process personal data on our behalf, we will obtain contractual commitments to safeguard the security of the personal data to ensure that the third party only acts on our instructions when using that personal data and that the third party has in place appropriate technical and organisational security measures to safeguard the personal data.  Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it, for example: 

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO or, where applicable, the European Commission.
• Where we use service providers, we may use specific contracts approved by the ICO or, where applicable, the European Commission which give personal data the same protection it has in Europe. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside the UK or EEA. 

How long we hold your data

We will only hold your data for as long as we need it for the purpose that we are using it for.

In certain circumstances, you can ask us to stop using your data earlier. You can find more information about your rights below, alternatively, you can contact us at any time using the contact details at the top of this page.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required (or, where we are processing on behalf of another data controller, return their information to them).

We may sometimes 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.