Peak is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this policy. The main laws governing data protection in the UK are the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as “GDPR” and the Data Protection Act 2018.
Peak may change this policy from time to time by updating this page. 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.
You should check this page intermittently to ensure that you are happy with any changes or updates. This policy is effective from 16 December 2020.
We are the controller of all personal data used in our business for our own commercial purposes.
Who we are:
“We”, “us” and “our” in this policy refers to Peak AI Ltd. Our registered business address is: Floor 12, Neo Building, Charlotte Street, Manchester, England, United Kingdom, M1 4ET.
Our company number is: 09307701
We are registered with the Information Commissioner’s Office (ICO) and our registration number is: ZA186006.
Data protection principles
We are accountable for demonstrating compliance with GDPR’s six principles of processing personal data. These provide that personal data we deal with must be:
- processed fairly, lawfully and in a transparent manner;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- adequate, relevant and limited to what is necessary;
- accurate and, where necessary, kept up to date;
- not kept for longer than necessary; and
- processed securely, maintaining integrity and confidentiality.
Some basic definitions we use in this policy
Personal data: In this policy, when we use the term “personal data” we mean any information relating to an identified or identifiable human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).
Sensitive personal data: In this policy, when we use the term “sensitive personal data” we mean special categories of information which are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning someone’s sex life or sexual orientation.
- Using appropriate technical and organisational measures to protect your data;
- testing our security and conducting audits to ensure that it stays up to date; and
- putting contractual terms in place with third parties that process your data to ensure
that your data and your rights are secured.
Links to other websites
Our website may contain links to other applications or websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
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:
- Personal Identification
- Your employer or business partner and place of work;
- Any information you make available, or transmit to us, via social media accounts
- 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:
- when you submit an enquiry about our services; and
- 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:
- 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 email@example.com if you need details about the specific legal basis we are relying on to process your personal data.
- 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.
- 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.
- Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
- 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.
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.
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 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:
- Where we have notified an individual of the decision and given that individual 21 days to request a reconsideration.
- Where it is necessary to perform the contract with an individual and appropriate measures are in place to safeguard that individual’s rights.
- 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.
You have the right to be informed
We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal data and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, please contact us using the details at the top of this page.
You have the right to access your data
You have the right to ask us to confirm whether or not we hold any of your personal data. If we do, you have the right to have a copy of your information and to be informed of the following:
- why we are using your information;
- what categories of information we are using;
- how long we envisage holding your information.
In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.
You have the right to correct our records
Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case, you can contact us so that we can correct our records.
You have the right to be forgotten
There may be times where it is no longer necessary for us to hold personal data about you.
This could be if:
- the information is no longer needed for the original purpose that we collected it for;
- you withdraw your consent for us to use the information (and we have no other legal reason to keep using it);
- we have used your information unlawfully; or
- we are subject to a legal requirement to delete your information
In those situations, you have the right to have your personal data deleted. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
You have the right to data portability
You have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy, or transfer your personal data more easily from one IT system to another, in a safe and secure way. If you would like us to transfer a copy of your data to you or another organisation, we will provide a structured, commonly used, and machine-readable file (such as a .CSV file). 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.
You have the right to object to direct marketing
You can tell us at any time if you would prefer not to receive direct marketing from us. A link to this policy and an unsubscribe link OR instructions on how to unsubscribe are included in all our marketing communications.
You have the right to restrict how we use your information
You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:
- you have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this;
- you have objected to us using your information for our own legitimate interests and we are in the process of considering your objection;
- we have used your information in an unlawful way, but you do not want us to delete your data; and,
- we no longer need to use the information, but you need it for a legal claim.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org. We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may actually come from that other party as the relevant data controller). Occasionally it may 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.
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 may refuse to comply with your request in these circumstances.
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 for further information in relation to your request to speed up our response.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer or device. We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site 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 site. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our site.
Except for essential cookies, all cookies will expire after 365 days.
Raising a concern
If you have any concerns over how we use your data, please contact us in the first instance so that we can try to help. Our contact details are listed at the top of this page.
If you are not satisfied that we have addressed your concerns properly, you can lodge a complaint with the ICO. Their contact details are below:
Information Commissioner’s Office
Tel: +44 303 123 1113
We are registered with the Information Commissioner’s Office (ICO) and our registration number is: ZA186006.