Privacy Notice

Welcome to the Peblo Privacy Notice
1. This is the Privacy Notice that applies to the Peblo business and services, operated by Chamberlain Media Limited, (a subsidiary of Wayflyer Limited and a member of the Wayflyer Group, being all companies which are controlled by, or under common control with Wayflyer Limited). Peblo respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
2. Please use the Glossary to understand the meaning of some of the terms used in this Privacy Notice
3. The General Data Protection Regulation (EU Regulation 2016/679) and implementing regulation (”GDPR”) defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular 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, mental, economic, cultural, or social identity of that natural person. The GDPR defines “special categories of personal data” as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, the processing of genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
4. This Privacy Notice aims to give you information on how we collect and process your personal data through your use of Peblo’s websites and mobile application (the “Platform”) including any data you may provide as part of our online application process, by signing up for our services, our newsletter or other marketing material, by submitting a query, by using other online services or applying for a role at Peblo.
  1. This Privacy Notice should be read in conjunction with related policies and procedures which Peblo maintains regarding its compliance with the GDPR.
  2. Peblo is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data and on respecting the legal rights, privacy, and trust of all individuals with whom it deals.
  3. It is important that you read this Privacy Notice 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 Notice supplements the other notices and is not intended to override them.
Our Role as Data Controller
1. This Privacy Notice is issued on behalf of Chamberlain Media Limited, trading as “Peblo”, having its registered office at Grand Canal Dock, Dublin 2, Ireland. Our company registration number is 675567. Peblo is the controller for the purposes of this Privacy Notice and for the processing of personal data collected.
2. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact info@getpeblo.com
3. You have the right to make a complaint to a supervisory authority under the GDPR at any time. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.
4. 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. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.
What personal data do we collect?
1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include business data, or data where the identity has been removed (anonymous data). In order to provide the services, and to communicate with our customers we will need information about employees, directors and other officers of those companies. We also process data of individuals who interact with Peblo, whether through direct contact with us, through Peblo websites or on social media.
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3. Identity Data includes first name, last name, username or similar identifier, title, and date of birth.
4. Contact Data includes billing address, email address, and telephone numbers.
5. Financial Data includes bank account and payment card details.
6. Access Data includes username, login, and password details for your bank account, card processor account and other third-party services (including, but not limited to, Adwords, Facebook, Google Analytics, Shopify, Stripe, and such other accounts as may be required from time to time), provided by you to us as part of the onboarding process.
7. Transaction Data includes details about payments to and from you and other details of our transaction history.
8. 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 Peblo Platform.
9. Profile Data includes your username and password, service purchases or orders made by you, your interests, preferences, feedback, and survey responses.
10. Usage Data includes information about how you use the Peblo Platform.
11. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
12. Recruitment Data where you are being considered for a role at Peblo, CV/resume data will be processed.
13. Records of discussions with our customer support teams, including call recordings, when you share comments and opinions with us, ask us questions or make a complaint, including when you phone us, we will keep a record of this. This includes when you send us emails, letters, phone our support team or contact us through social media.
Purposes and Legal Bases of Data Processingo register you as a new customer
1. To register you as a new customer, we may collect and process data relating to the following: a) identity; b) contact; c) profile; and d) marketing and communications. The legal basis of such processing is the performance of a contract with you.
2. To undertake the onboarding process, in particular obtaining onboarding information and communicating with you, we may collect and process data relating to the following: a) identity; b) contact; c) financial; d) access; e) transaction; f) profile; and g) records of discussions. The legal basis of such processing is the performance of a contract with you.
3. To complete and manage the relevant customer agreement following successful completion of the onboarding process, in particular obtaining any further onboarding information and communicating with you, we may collect and process data relating to the following: a) identity; b) contact; c) financial; d) access; e) transaction; and f) profile. The legal basis of such processing is the performance of a contract with you.
4. To manage our relationship with you, which will include: a) notifying you about changes to our terms or Privacy Notice, and b) asking you to participate in or complete a survey, we may collect and process data relating to the following: a) identity; b) contact; c) profile; d) marketing and communications; and e) records of discussion. The legal bases of such processing are a) the performance of a contract with you; b) it is necessary to comply with legal obligations; and c) it is necessary for our legitimate interests (to keep our records updated and to study how customers use our services to develop our offerings).
5. To administer and protect our business and our websites (including recruitment, debt collection, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), we may collect and process data relating to the following: a) identity; b) content; c) access; d) technical; e) profile; f) usage; g) recruitment; and h) financial. The legal bases of such processing are a) it is necessary to comply with legal obligations, and b) it is 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).
6. For the purposes of internal and statutory audits and complying with obligations imposed by regulators, we may collect and process the data outlined in section 4.5 above. The legal basis of such processing is compliance with legal obligations.
7. For the purposes of compliance with anti-money laundering, and detection of fraud, corruption and bribery requirements, we may collect and process data relating to the following: a) identity; b) contact; c) transaction; d) technical; and e) profile. The legal basis of such processing is compliance with legal obligations.
8. To deliver relevant website content and advertisements to you on our website, third party websites and social media channels, and measure or understand the effectiveness of the advertising we serve to you, we may collect and process data relating to the following: a) identity; b) contact; c) transaction; d) technical; e) profile; f) usage; and g) marketing and communications. The legal basis of such processing is that it is necessary for our legitimate interests (to study how customers use services, to develop them, to grow our business and to inform our marketing strategy).
9. In order to use data analytics to improve our website, offers, marketing, customer relationships and experiences, we may collect and process data relating to the following: a) technical, and b) usage. The legal basis of such processing is that it is necessary for our legitimate interests (to define types of customer for our various offerings, to keep our website update and relevant, to develop our business and to inform our marketing strategy).
10. In order to make suggestions and recommendations to you about offers that may be of interest to you, we may collect and process personal data relating to the following: a) identity; b) contact; c) technical; d) profile; e) usage; f) marketing and communications; and g) records of discussions. The legal basis of such processing is that it is necessary for our legitimate interests (to develop our products and services and grow our business).
11. We also 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 Usage Data to calculate the percentage of users accessing a specific website or Service 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 Notice.
12. 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).
13. We may as part of our legal obligations under anti-money laundering legislation, require information in respect of any criminal records, sanctions or embargoes.
14. 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 not be able to perform the contract we have or are trying to enter into with you (for example, insufficient onboarding information). In such a case, we might have to cancel an Online Application Process but we will notify you if that happens.
How is your personal data collected?
1. We use different methods to colelct data from and about you including through:
2. Direct interactions. You may give us your Identity, Contact and Financial Data filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
  1. create an account;
  2. engage in the onboarding process;
  3. subscribe to our publications;
  4. request marketing material to be sent to you;
  5. enter a promotion or survey;
  6. apply for a job in Peblo;
  7. give us some feedback; or
  8. submit a query through the Contact Us form.
3. Automated technologies or interactions. As you interact with the Platform, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies (in accordance with our Cookie Notice), server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
4. Third parties or publicly available sources. We may receive Contact, Financial and Transaction Data from providers of technical, payment, and delivery services such as Realex or Stripe, other analytics providers, public registries or public social media sites such as LinkedIn.
How we use your personal data
1. Lawful basis -
  
  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:
  1. We need to perform the contract we are about to enter into or have entered into with you;
  2. It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  3. 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 certain marketing communications to you via email or text message. You have the right to withdraw consent to markerting at any time by contacting us at info@getpeblo.com
2. Marketing communications from us
  
  We may use your Identity, Contact, Technical, Profile, and Usage 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.
3. Opting out
  
  We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can ask us or previously authorised third parties to stop sending you marketing messages at any time by contacting us at info@getpeblo.com.
4. Cookies
  
  You can set your browser or your cookie preferences centre to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Notice.
5. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@getpeblo.com.
  
  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.
Disclosures of your personal data
1. We may have to share your personal data with the parties set out below:
  1. Internal third parties as set out in the Glossary
  2. External third parties as set out in the Glossary
2. Third parties in the course of an acquisition, merger, equity investment, or similar corporate transaction; and
3. Third parties to whom we sell, transfer, or merge parts of our business or our assets; alternatively, we may seek to acquire other businesses or merge with them; if a change happens to our business, then the new owners or newly acquired businesses may use your personal data in the same way as set out in this Privacy Notice.
  
  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.
International Data Transfers
1. Whenever we transfer your personal data out of the European Economic Area (’EEA’), we ensure a similar degree of protection is afforded to it by using specific contracts approved by the European Commission which give personal data the same protection it has in the European Union (known as the Standard Contractual Clauses).
Data Security
1. 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.
2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority or other regulators of a breach where we are legally required to do so.
Data Retention
1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
2. 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.
3. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax and other legal purposes.
4. In some circumstances you can ask us to delete your data: see below for further information.
5. In some circumstances we may 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.
Your Legal Rights
1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. Specifically, you may:
  1. 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.
  2. 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.
  3. 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 to continue 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.
  4. 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 your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have a compelling legitimate ground to process your information which overrides your rights and freedoms.
  5. 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: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) 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; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. 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.
  7. 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 offerings to you. We will advise you if this is the case at the time you withdraw your consent.
2. If you wish to exercise any of the rights set out above, please contact us at info@getpeblo.com.
3. 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.
4. 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.
5. We try to respond to all legitimate requests within one month. 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.
Glossary
1. Lawful basis
  1. ‘Legitimate interest’ means the interest of our business in conducting and managing our business to enable us to give you the best offering and the best and most secure experience; we make sure we consider and balance any potential impact on you (both positive and negative) 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); you can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at info@getpeblo.com.
  2. ‘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.
  3. ‘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.
2. Third Parties
  1. Internal Third parties; other companies in the Wayflyer Group which provide IT and system administration services and marketing services to the Wayflyer Group.
  2. External Third parties;
    1. service providers, business partners and agencies engaged to provide the services set out in this Privacy Notice, always within the terms of an appropriate agreement between us;
    2. professional advisers acting as processors or controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services; and
    3. the Revenue Commissioners in Ireland, regulators, and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances.
California Privacy Notice and Rights
1. If you are consumer who is a resident of California and a user of the Peblo Platform or services, the following clauses apply to you. Under the California Consumer Privacy Act of 2018, as amended (“CCPA”), California consumers are afforded specific rights regarding their Personal Information. These rights have been described in this Privacy Notice and are further highlighted in this section. If you need to access this notice in an alternative format, please contact us at info@getpeblo.com.
2. For the purposes of this section the following definitions apply:
  
  “Personal Information” is anything that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household; and
  
  “Records” may include any Personal Information we collect from you or other individuals in order to provide our Services to you.
  1. Peblo does not, and will not, sell (as defined under the CCPA) your Personal Information and have not sold your Personal Information in the past 12 months.
  2. California consumers have the right to request the following:
  3. Deletion of Personal Information we have about them and for us to direct the same of any third-party service providers processing their information on our behalf;
  4. Additional information about whether and how we have collected, used, disclosed, and sold Personal Information about them;
  5. Specific pieces of Personal Information we have about them;
  6. Opt-out of the sale of their Personal Information, if the Personal Information is being sold by the business, and not be contacted to request the resumption of those activities for at least 12-months; and
  7. That any information held be returned by mail or electronically, and if electronically held, be returned in a format permitting its transfer to another service.
  8. California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above. You cannot be charged a fee for these requests, penalized in any way, denied benefits, products, or services or charged differently for benefits, products, or services for doing so.
  9. California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer.
  10. California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer.
Nevada Privacy Rights
1. Nevada residents have the right to submit a verified request directing us not to sell their Personal Information. As noted above, we do not sell Personal Information. If you are a Nevada resident and have questions, please contact us at info@getpeblo.com or the contact information listed above.
Changes to the Privacy Notice

We reserve the right to change our Privacy Notice at any time. If we make changes, we will post them and will indicate on this page the Privacy Notice’s new effective date. Please check this page from time to time to take notice of any changes we make, as they are binding on you.

01 September 2022