Privacy Policy
1. About Our Privacy Policy
This Privacy Policy applies to the Personal Information PepperBonus collects from you or about you when you visit our Platform or use our Services. In the section below, we set out how and why we process personal data gathered from the site.
Responsible for processing data within the scope of this website in compliance with the General Data Protection Regulation (GDPR): PMH Solutions GmbH, Torstr. 164, 10115 Berlin, Germany
This Privacy Policy is effective from the 11th of November 2019.
We may change this Privacy Policy at any time and we will notify you thereof, either by email or by any means of electronic notice, within a reasonable time period prior to any later version coming into force.
2. Definitions
“Services” mean all the online services we offer you when you access or use our Platform.
“Platform” means our website which you can access at the following address: https://pepperbonus.com/.
“we”, “our”, “us” and “PepperBonus” mean our company PMH Solutions GmbH, “Gesellschaft mit beschränkter Haftung”, registered in accordance with the laws and regulations of Germany (HR Amtsgericht Charlottenburg 200420 B), having its address at Torstr. 164 10115 Berlin, Germany.
Personal Information means any information relating to you, and on the basis of which you can be identified, directly or indirectly.
3. How can you contact us?
You can contact us in several ways:
- By mail: PMH Solutions GmbH, Torstr. 164, 10115 Berlin, Germany
- We have also appointed a data protection officer that you can reach through: support@pepperbonus-de.zendesk.com
4. What kinds of Personal Information do we process concerning you?
We process different kinds of Personal Information:
Personal Information that you must provide. Depending on your use of our services, you will be required to provide us with some categories of Personal Information.
- Account Information (email address, first name, last name, password)
Personal Information that you may choose to provide. When you are using our Services, you may provide additional categories of Personal Information.
- Additional Information (full address, information about promotional offer participations, and purchases made at our business partners)
- Your responses to our surveys (email address, and behavioural data)
Personal Information that we collect automatically. We will also collect certain categories of Personal Information when you visit our Platform and use our Services.
- Behavioural Data (pages viewed, clicks, how long you stayed on our site, your searches)
- Log Data and Device Information (time, date, IP address)
Personal Information that we collect from business partners (with your consent). With your consent (for instance, when you accept third-parties’ cookies on our Platform or on third parties’ website), we’ll also collect certain categories of Personal Information from business partners (marketers, advertisers, resellers).
- Account Information (email address, first name, last name)
- Your Telephone Number
- Order Data
- Your responses to our surveys (email address and behavioural data)
- Behavioural Data (pages viewed, time spent on the Platform, clicks, interactions with the Platform)
- Log Data and Device Information (time, date, anonymised IP address, geo-localisation, browser information, screen size, operating-system, device ID)
5. Why are you required to provide your Personal Information?
We sometimes require you to provide us with some of your Personal Information. We request this when it is necessary for the provision of our Services or required by law. For instance, we need to collect your email address when you sign up to our newsletter or when you create an account on our Platform.
Failure to provide us with mandatory information may have consequences. For instance, we will not be able to create your account; we will not be able to provide our Services to you, etc.
6. Why and what do we use your Personal Information for?
We need to use your Personal Information for several purposes, as we have a lawful basis to do so, which can be any of the following:
- the necessity to enter into or perform General Terms and Conditions with you (Contractual Obligation)
- the necessity to comply with legal obligations (Compliance with the Law)
- a legitimate interest We have in processing your Personal Information (Our Legitimate Interest)
- you have consented to such processing (Your Consent).
PLEASE NOTE THAT YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT OR TO OBJECT TO THE PROCESSING OF PERSONAL DATA BASED ON OUR LEGITIMATE INTEREST FOR ANY OF THE OPERATIONS LISTED ABOVE AT ANY TIME, BY CONTACTING US OR BY WITHDRAWING YOURSELF AND YOUR PERSONAL INFORMATION FROM THE PLATFORM, WHERE POSSIBLE.
We collect, process, and use your above shown Personal Information for the following purposes:
To sign up and log in on our Platform
- Legal basis: Contractual Obligation
- Categories of Personal Information concerned: Account Information
To provide our services
- Legal basis: Contractual Obligation
- Categories of Personal Information concerned: Account Information, Additional Information
To enable you to personalise your user profile
- Legal basis: Consent
- Categories of Personal Information concerned: Account Information
To send you our newsletter, to send you push and / or email notifications
- Legal basis: Consent
- Categories of Personal Information concerned: Account Information
To send you support messages, updates, security alerts, and account notifications
- Legal basis: Contractual Obligation
- Categories of Personal Information concerned: Account Information
To notify you about changes to our services
- Legal basis: Contractual Obligation, Compliance with the Law
- Categories of Personal Information concerned: Account Information
To prevent and detect fraud, to improve the security of our services
- Legal basis: Legitimate Interest, Compliance with the Law
- Categories of Personal Information concerned: Log Data and Device Information
To keep a log of actions and pages visited on our website
- Legal basis: Legitimate Interest
- Categories of Personal Information concerned: Log Data and Device Information, Account Information
To administer our Platform and for internal operations, including running surveys, troubleshooting and testing for bugs, data analysis, testing, research, analytics for product development.
- Legal basis: Legitimate Interest
- Categories of Personal Information concerned: Account Information, Additional Information, Log Data and Device Information
To improve our Platform, services, marketing, customer relationships and experiences, to provide answers to your questions.
- Legal basis: Legitimate Interest
- Categories of Personal Information concerned: Account Information, Additional Information, Log Data and Device Information
7. How long do we retain your Personal Information for?
We retain your Personal Information for as long as is necessary for the purpose for which we obtained them, notably as long as you continue to use our Services and for a 3 (three) year period after our last contact with you, or the last use of such Services in case you would have created an account on our Platform.
At the end of the above mentioned period, we will be able to contact you to find out whether you wish to continue using our Services. In the absence of a positive and explicit response from You, your Personal Data will be deleted or archived in accordance with the provisions in force.
Please note that even if your account and Personal Information are deleted Your contributions (e.g. reviews of promotional offer participations) will be kept and anonymised. In the event that your user account is blocked, we will keep part of your Personal Information for a period of 1 to 3 years in order to prevent violations of the General Terms and Conditions applicable to the platform.
We retain cookies data for a 13 months period from when they were collected, in the event where you’re not logged in on our Platform, and for up to 13 months in other instances.
8. What kinds of profiling or automated-decisions processes do we use?
We may use profiling methods based on your visits on the Platform and other interactions with our Platform, in order to personalise features and content, and make suggestions for you (such as promotional offers that might be of interest to you).
Profiling means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a physical person, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
9. Who are the recipients of your Personal Information?
We do not sell personal data to third parties.
We share your Personal Information with our parent / sister companies for legitimate interest:
- Pepper Media Holding GmbH, Torstr. 164, 10115 Berlin, Germany
- 6Minutes Media GmbH, Torstr. 164, 10115 Berlin, Germany
- Pepper Deals Ltd, Unit 2, 1-6 Bateman's Row, EC2A3HH London, United Kingdom
- Pepper France SAS, 18 Rue Félix Mangini, 69009 Lyon, France
- Tipping Canoe Ltd, 200-171 McDermot Avenue, R3B 0S1 Winnipeg, Canada
We are also working closely with third parties which are the recipients of your Personal Data such as:
- our business partners who are social media platforms: Facebook Like Button and Facebook Login (Privacy Policy), Twitter Tweet Button (Privacy Policy), Google Sign-In (Privacy Policy) and which may provide you with connecting services, such as the connection of the information of your profile, from their social media platforms to our Platform.
- our sub-contractors in technical or analytics providers. For example, they may help us: analyze our traffic, perform product development, maintenance and debugging, provide customer service. These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.
10. Do we transfer your Personal Information outside the European Union?
We prefer as much as possible to store your Personal Information within the European Union. For example, we host our servers in the European Union.
We only decide to transfer some of your Personal Information where our recipients (for instance our IT providers) have provided adequate safeguards in accordance with GDPR.
Such adequate safeguards may be notably provided for by:
- Standard data protection clauses adopted or approved by the European Commission
- Compliance with an approved code of conduct
- Certification under an approved certification mechanism as provided for in the GDPR
- Contractual clauses agreed authorized by the competent supervisory
By sending a request to support@pepperbonus-de.zendesk.com we can provide you with the details regarding such recipients and their appropriate safeguards.
11. How do we use cookies?
A cookie is a small piece of data (text file) that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as your language preference or login information.
We use cookies for different purposes:
Strictly Necessary Cookies: These are cookies that are necessary for the Platform to function. These are used to let you login and to ensure site security. Without this type of technology, our Services won't work properly or won't be able to provide certain features and functionalities.
Functionality Cookies: These are cookies that are necessary for the performance of our Services (i.e. to store some information such as your language preferences, to remember you, etc.).
Analytics Cookies: These are cookies that are used for collecting information about how you use our Services and visit our Platform (i.e. duration of your navigation on our Platform, pages visited, link clicked, referrer page, etc).
Targeting or advertising cookies: These are cookies that are used to personalise our content or ads based on your interests and preferences. You have the option to change your choices relating to cookies utilized to deliver behaviourally targeted advertising at the Ad Choices page (Digital Advertising Alliance) or Your Online Choices page (European Interactive Digital Advertising Alliance).
Affiliate Cookies: These are cookies that are used by affiliate networks to track a transaction you may make after participating in a promotional offer on our Platform.
Social Media Cookies: These cookies are used by social media services to enable you to share our content with your friends and networks. These cookies may track your browser across other sites and build a profile of your interests, which may impact the content and messages you see on other websites you visit. You can also use Facebook Login and Google Sign-in to allow you to access your account on our Platform using your Facebook or Google account. To protect your privacy, Google and Facebook use authentication cookies to keep your credentials (in encrypted form).
12. How can you control cookies?
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
More information about cookie settings can be found on the website of the browser provider: Internet Explorer, Microsoft Edge, Chrome, Mozilla Firefox, Safari, Opera
Please note: Due to a lack of standardisation, a browser-side activated "Do-not-track" setting is not taken into account on our platform.
13. What are your rights?
You have several rights to your Personal Information under GDPR:
Right of access: You have the right to access your Personal Information by making a request in writing to us. It means you have the right to obtain a copy of your Personal Information.
Right to rectification: You have the right to rectify or to complete your Personal Information if it is inaccurate or incomplete.
Right to erasure: You have the right to request the erasure of your Personal Information. Please note that this right is not absolute and only applies in certain circumstances (for instance only if the Personal Information is no longer necessary for the purpose which we originally collected or processed for it, etc.).
Right to restrict processing: You have the right to request the restriction of your Personal Information where you have a particular reason for wanting the restriction.
Right to data portability: You have the right to ask the portability of your Personal Information. It means you have the right to receive Personal Information you have provided to Us, in a structured, commonly used and machine readable format.
Right to object: You have the right to object to the processing of your Personal Information. This allows you to ask us to stop processing your Personal Information.
Right related to automated decision making including profile: You have the right not to be subject to a decision based solely on automated means, if the decision produces legal effects concerning you or significantly affects you in a similar way.
Right to lodge a complaint: You have the right to lodge a complaint before the data protection supervisory authority: Information Commissioner’s Office - ICO Wycliffe House, Water Lane, Wilmslow SK9 5AF, Cheshire. Helpline number: 0303 123 1113. Website: https://ico.org.uk/
14. How to exercise your rights?
Right to rectification: You can exercise this right by going into the settings of your account where you’re able to update your personal information.
To exercise your other rights, please contact us by using the contact information at the beginning of this Privacy Policy. We may need to ask you for proof of identity to be certain that it is you. We will do our best to answer you within a month.
Sometimes we will not be able to accept your request because your Data Protection Rights may only apply in certain circumstances or depends on the legal basis of processing: we will then inform you.