1 Important information and who we are
1.1 Purpose of this privacy notice
This privacy notice aims to give you information on how Black Pepper Software Limited (‘Black Pepper’) collects and processes your personal data, including any data you may provide when you ask us to provide services and when you use this website.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
Black Pepper is the controller and responsible for your personal data (referred to as “Black Pepper”, "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the data privacy manager using the details set out below.
1.3 Contact details
Data privacy manager: John Cooke
Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Please contact us in the first instance, as we would appreciate the chance to deal with your concerns before you approach the ICO.
1.4 Changes to the privacy notice and your duty to inform us of changes
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.
1.5 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
2 The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes name, username or similar identifier, title.
Contact Data includes postal address, email address and telephone numbers.
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 this website.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes 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.
2.1 If you fail to provide personal data
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 have to cancel the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we will notify you if this is the case at the time.
3 How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, corresponding with us by post, phone or email or engaging us to provide services. This includes personal data you provide when you:
- want to use our services
- subscribe to our newsletters
- request marketing to be sent to you
- give us some feedback
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google
- advertising networks such as LinkedIn
- search information providers such as Google
- Contact, Financial and Transaction Data from providers of technical and payment services
- Identity and Contact Data from publicly available sources such as Companies House
- Identity and Contact Data from marketing services providers such as Pearlfinders
4 How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we are entering into with you
- Where it is necessary for our legitimate interests
- Where we need to comply with a legal or regulatory obligation
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or social media. You have the right to withdraw consent to marketing at any time by contacting us.
4.1 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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client
Performance of a contract with you
To provide services to you, including:
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to prevent fraud)
Necessary to comply with a legal obligation
To deliver relevant website content and promotional material to you and measure or understand its effectiveness
Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, client relationships and experiences
Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our services and grow our business)
4.2 Marketing and Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to understand what may be of interest to you and which services may be relevant for you .
You may receive marketing communications from us if you have requested information from us or received services from us and you have not opted out of receiving marketing communications from us.
4.3 Third-party marketing
We do not share your personal data with any company outside of Black Pepper for marketing purposes. If we wanted to, we would first get your express opt-in consent.
4.4 Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.
4.6 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5 Disclosures of your personal data
We may have to share your personal data with the Third Parties (as set out in the Glossary) for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6 International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
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 the 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.
7 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.
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 required to do so.
8 Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
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 requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
9 Your legal rights
You have certain rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us
9.1 No fee
You will not usually have to pay a fee to access your personal data.
9.2 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.
10.1 LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best services and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
10.2 THIRD PARTIES
Service providers acting as processors based in the UK and the USA who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
10.3 YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data ("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. You may have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal data. You can ask us to delete or remove personal data where there is no good reason for us continuing to process it, or where you have successfully objected to processing (see below).
Object to processing of your personal data. Where we are relying on a legitimate interest and you feel it impacts on your fundamental rights and freedoms, you may object. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. You can ask us to suspend the processing of your personal data in certain circumstances, for example, if you want us to establish its accuracy.
Request the transfer of your personal data to you or to a third party. If you initially consented for us to use automated information, or we used the information to perform a contract with you, we will provide your personal data to you in a structured, machine-readable format.
Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain services to you. We will let you know if this is the case at the time you withdraw your consent.