Powerchord respects your privacy and is committed to protecting personal data.
Scope of Policy
This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, through including but not limited to our mobile application software, such as the PEEX mobile application, (“App) and our
website(s) (“Services Site”), will be processed by us.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice 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 is not intended to override them.
Powerchord Group Limited is the controller and responsible for your personal data (collectively referred to as "Powerchord", "we", "us" or "our" in this privacy policy.
Information we collect from you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data rendered anonymous in such a manner that identification of a person is no longer
possible.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- IDENTITY DATA
includes first name, last name, username or similar identifier, marital status, title, and gender.
- CONTACT DATA
includes billing address, delivery address, email address and telephone numbers.
- FINANCIAL DATA
includes bank account and payment card details.
- TRANSACTION DATA
includes details about payments to and from you and other details of products and services you have purchased from us.
- TECHNICAL DATA
includes internet protocol (IP) address, your login data, 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 the App and Service Site. This will include unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of
operating system.
- PROFILE DATA
includes your username and password, purchases or orders made by you, your interests, preferences, and feedback.
- USAGE DATA
includes information about how you use our website, products and services.
- MARKETING AND COMMUNICATIONS DATA
includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 in its aggregated form not considered personal data in law when this data will not directly nor 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 (such as 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.
How do we collect your personal data?
We use different methods to collect and process your data including through:
- INFORMATION YOU GIVE US (SUBMITTED INFORMATION):
You may give us your Identity Data, Contact Data, Profile Data and Financial Data by completing forms or corresponding with us.
This includes personal data you provide when you:
- Subscribe to marketing on our Service Site;
- Complete a contact form on the Service Site;
- Register for a new user account;
- Place an order for our products or services.
- INFORMATION WE COLLECT FROM AUTOMATED TECHNOLOGIES OR INTERACTIONS
Each time you visit the Services Site or use our App and as you interact with both we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar
technologies. Please see our Cookie policy below for further details. We will also collect Profile Data stored on your device and Usage Data when you interact with our App and Services Sits.
- INFORMATION WE RECEIVE FROM OTHER SOURCES (THIRD PARTY OR PUBLICLY AVAILABLE INFORMATION)
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) from whom we will receive personal data about you including:
- Technical Data from the following parties: (a) analytics providers such as Google based outside the EU; and (b) mobile operating systems such as iOS and Android based outside the EU; and
- Identity Data, Contact Data, Financial Data, Profile Data and Transaction Data from e-commerce partners, based in the United Kingdom and/or inside the EU.
- Identity Data, Financial Data and Contact Data from publicly available sources, such as Companies House and the Electoral Register, based in the United Kingdom and/or inside the EU.
Cookie Policy
We use cookies to distinguish you from other users of the App, Appstore or the Service Site. This helps us to provide you with a good experience when you use the App or browse the Service Site and also allows us to improve the App and
Services Site.
You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions of our service.
Uses made of the information
We will only use your personal data when and in so far the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although where we do require consent we will ask for that separately and clearly, and you have the right to withdraw consent at any time by
contacting us.
Purposes for which we will use your personal data.
We have set out below, in a table format, 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.
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 |
Type of data |
Lawful basis for processing including basis of legitimate interest |
To register you as a new user |
(a) Identity Data (b) Contact Data (c) Profile Data |
Performance of a contract with you |
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data (e) Marketing and Communications Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) To provide customer support (c) Asking you to leave feedback |
(a) Identity Data (b) Contact Data (c) Profile Data (d) Marketing and Communications Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To administer and protect our business and our App or Service Site (including troubleshooting, data analysis, security, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity Data (b) Contact Data (c) Technical Data |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant content to you and measure or understand the effectiveness of that content |
(a) Identity Data (b) Contact Data (c) Profile Data (d) Usage Data (e) Marketing and Communications Data (f) Technical Data |
Necessary for our legitimate interests (to study how customers use our App and Service Site, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve and personalise our App and Service Site, marketing, customer relationships and experiences |
(a) Technical Data (b) Usage Data |
Necessary for our legitimate interests (to define types of customers for our App and Service Sites, to keep our App and Service Site updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about products or services that may be of interest to you. To facilitate product, software and applications development, conducting research, analysis, studies or surveys and
identifying usage trends. |
(a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Profile Data (f) Marketing and Communications Data |
|
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers
may be relevant for you (we call this
marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to our use of your personal data provided to us in order to complete a product/service purchase, warranty registration, product/service experience or other
transactions.
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 above.
- Service providers acting as processors based both inside and outside the EU who provide IT, e-commerce, payment and system administration services.
- Professional advisers acting as processors or controllers including lawyers, ac countants, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs (the United Kingdom’s tax, payments and customs authority), regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
Where We store your personal data
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services.
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see
European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
All information you provide to us is stored on secure servers using cloud infrastructure provided by Microsoft Azure. Any payment transactions carried out by our chosen third-party provider of payment processing services will be
encrypted using Secured Sockets Layer technology. Where We have given you (or where you have chosen) a password that enables you to access certain parts of the Services Site, you are responsible for keeping this password confidential. We
ask you not to share a password with anyone.
Unfortunately, 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 the Services Site; any
transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
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.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may
retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
Your Rights
- REQUEST ACCESS TO YOUR PERSONAL DATA
(commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- REQUEST CORRECTION OF THE PERSONAL DATA
that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- REQUEST ERASURE OF YOUR PERSONAL DATA
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- OBJECT TO PROCESSING OF YOUR PERSONAL DATA
where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- REQUEST RESTRICTION OF PROCESSING OF YOUR PERSONAL DATA
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- REQUEST THE TRANSFER OF YOUR PERSONAL DATA
to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- WITHDRAW CONSENT
at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to Privacy Policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you for instance by email or when you next start the App or log onto the Service Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@powerchord.co.uk or Powerchord Group Limited 1 Blythe Road, London, United Kingdom, W14 0HG.
You have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authority 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. This version was last updated on 3 December 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.