Privacy Policy (US and Rest of the World)

This Privacy Policy was last updated on 12 July 2023.
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Key points covered in this Privacy Policy. 1. Introduction.
2. Definitions.
3. What Personal Data PepTalk might collect on you.
4. How long might PepTalk hold on to your Personal Data.
5. How PepTalk might collect your Personal Data.
6. The grounds on which PepTalk may store and use your Personal Data.
7. The way(s) in which PepTalk might use your Personal Data.
8. The measures that PepTalk has in place to protect your Personal Data.
9. Your rights.
10. Third Party Websites.
11. How PepTalk will communicate changes to this Privacy Policy.
12. Cookies.
13. International Transfers.
14. California privacy rights.
15. Children's data.
16. Google User Data.
17. How you can contact PepTalk.

1. Introduction
1.1 Thank you for visiting the Site and/or using the Services. In order to operate the Site and
provide the Services, and to improve the Site’s offering, Peptalk collects information from you.
Even if you are just browsing the Site, PepTalk may receive certain information from you, for
example the device you access the Site from and your IP address.
1.2 Please read this Privacy Policy carefully as it contains important information on who we are
and how and why we collect, store, use and share your personal information. It also explains
your rights in relation to your personal information and how to contact us in the event you
have a complaint. Please rest assured that we take your privacy very seriously.
1.3 THIS PRIVACY POLICY APPLIES TO ALL SITE USERS EXCLUDING THOSE VISITING FROM THE UK
AND EUROPEAN UNION. IF YOU ARE VISITING FROM THE UK OR EUROPEAN UNION, THE UK +
EU SPECIFIC PRIVACY POLICY WILL APPLY TO YOU.
1.4 This Policy sets out the obligations of PepTalk in respect of the collection, retention,
safeguarding of and access to your Personal Data.
1.5 Please read this Policy in full, as by continuing to use the Site you are deemed to be bound by
its contents. Please also read the Website Terms and Conditions of Use, accessible via the
Site, and any other terms applicable to your participation in the Services (together the “Key
Terms”). IF YOU DO NOT AGREE TO ANY OF THE KEY TERMS, PLEASE STOP USING THE SITE
IMMEDIATELY.
2. Definitions
2.1 In this Privacy Policy:
(i) “PepTalk” means: The Peptalk Co, with offices at 188 Grand Street, Unit 241, New York,
NY 10013;
(ii) “Personal Data” means: any information relating to an individual that specifically
identifies that individual;
(iii) “Services” means: the group video coaching sessions offered via the Site, and such other
services as PepTalk may provide via the Site or via third party sites from time to time;
(iv) “Site” means: www.getapeptalk.com/us and/or www.getapeptalk.com/uk, and all
associated web pages.
3. What Personal Data PepTalk might collect on you.
3.1 PepTalk might collect some or all the following Personal Data from and/or about you if
provided by you or someone acting on your behalf:
(i) Your name, age, date of birth and profession;
(ii) Your photograph and biography, if provided during the sign-up process;
(iii) Your contact details, including: postal address, telephone numbers and e-mail address;
(iv) Your credit card or other payment information;
(v) Details of services provided and/or orders made by you;
(vi) Details of PepTalk events attended by you (if applicable);
(vii) Your competition or other contest entries;
(viii) Your communication and marketing preferences;
(ix) Your interests, preferences, feedback and survey responses;
(x) Your correspondence and communications with PepTalk;
(xi) Other publicly available Personal Data, including any which you have shared via a public
platform (such as a Twitter feed, public Facebook page or a company website);
3.2 In addition, PepTalk may collect some or all of the following:
(i) information about your visit to the Site, including the full Uniform Resource Locators
(URL), clickstream to, through and from the Site (including date and time), pages you
viewed or searched for, page response times, download errors, length of visits to certain
pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods
used to browse away from the page;
(ii) Technical information, including the Internet protocol (IP) address used to connect your
computer to the Internet, your login information, browser type and version, browser plugin
types and versions, and operating system and platform; and
(iii) Information collected from the Site and elsewhere across the internet through cookies,
web beacons, pixel tags, device identifiers and other technologies including information
about your shopping habits and preferences.
3.3 This above lists are not exhaustive and, in specific instances, PepTalk may need to collect
additional data for the purposes set out in this Policy. PepTalk may also collect Personal Data
and other information about you from third parties who have your consent to pass your details
to PepTalk, or from publicly available sources.
4. How long might PepTalk hold on to your Personal Data.
4.1 PepTalk will not retain your Personal Data for longer than necessary for the purposes set out
in this Policy. Different retention periods apply for different types of data.
4.2 Should you request a deletion of any Personal Data that PepTalk holds on you, PepTalk will
take all commercially reasonable steps to remove your Personal Data from its database,
provided that nothing in this Policy shall prevent PepTalk from retaining information strictly
necessary for and in compliance with its business practices (for example, for the purposes of
dispute resolution, enforcement and to comply with legal agreements).
5. How PepTalk might collect your Personal Data.
5.1 PepTalk may collect your Personal Data in the following:
(i) When you opt-in to receive marketing or other communications from PepTalk;
(ii) When you place an order for Services via the Site;
(iii) When you sign-up to provide Services via the Site;
(iv) When your employer signs-up to receive Services via the Site or a third-party site, and
shares your details with PepTalk when doing so;
(v) When you enter one of PepTalk’s competitions or other contests;
(vi) When you correspond with PepTalk (by phone, email or otherwise);
(vii) Information that PepTalk may collect automatically when you use the Site, for example
with regard to each of your visits to the Site it may, independently or through third-party
data analytics tools or services such as Google Analytics, automatically collect information
as you use PepTalk’s services and/or the Site;
(viii) Information gathered through cookies and other similar technology to distinguish you
from other users of the Site, to assist PepTalk in providing you with a good experience
when you browse the Site and also allows PepTalk to improve the Site.
6. The grounds on which PepTalk may store and use your Personal Data.
6.1 PepTalk might store and use your Personal Data on the following legal grounds:
(i) Consent:
- for example, if you have opted in to receive marketing communications and/or news from PepTalk.
(ii) Fulfilment of a Contractual Obligation/Performance of Services:
- for example, if you have purchased Services via the Site, PepTalk will store and process your Personal
Data insofar as it is necessary to fulfil such order. Further, if you have signed up to provide Services,
PepTalk will store and process your Personal Data insofar as it is necessary to aid, manage and
remunerate you for the provision of Services.
(iii) Legitimate Interest:
- for example, (i) to provide you with technical support if requested; and (ii) if you have previously
provided PepTalk with your contact details in the course of business (for example, you have signed up
to receive and or provide Services via the Site), PepTalk may send you electronic communications
relating to similar goods/services that it may provide from time to time. You will always be given the
opportunity to opt-out of the latter form of communication via an ‘unsubscribe’ link. If relying on
legitimate interest as a lawful ground for processing your Personal Data, PepTalk will always take into
account your rights and interests prior to sending any such communications.
(iv) Legal and Compliance Purpose(s):
- for example, to assist PepTalk in keeping the Site safe and secure; to use profiling tools to identify
behaviour which breaches the terms upon which you are using the Site and/or Services; and to protect
PepTalk’s rights or property.
7. The way(s) in which PepTalk might use your Personal Data.
7.1 General:
PepTalk (and necessary trusted partners acting on PepTalk’s behalf under contract) might use your
Personal Data:
(i) to provide the platform for the Services to you;
(ii) to make a tailored website available to you;
(iii) to manage any registered account(s) that you may hold and other administrative matters;
(iv) to verify your identity;
(v) for crime and fraud prevention, detection and related purposes, including if PepTalk
believes you are using the Site and/or the Services in contravention of any Key Terms;
(vi) to contact you electronically about news/events and/or products/services which PepTalk
thinks may interest you;
(vii) for market research purposes and to better understand your needs;
(viii) where PepTalk has a legal right or duty to use or disclose your information (for example
in relation to an investigation by a public authority or in a legal dispute or for other law
enforcement matters);
(ix) to progress or respond to an employment application made by you or to defend against
employment claims.
7.2 Communications:
(i) PepTalk might use your Personal Data for electronic marketing purposes (with your
consent) and may send you postal mail to update you on various news, event and/or
products/services.
(ii) PepTalk aims to update you about items which are of interest and relevance to you as an
individual.
(iii) You have the right to opt-out of receiving marketing communications at any time, by:
a) making use of the simple “unsubscribe” link in emails; or
b) contacting PepTalk via www.getapeptalk.com/us/contact.
7.3 Sharing data with necessary trusted third parties:
(i) PepTalk’s service providers and suppliers:
In order to make certain services available to you, PepTalk may need to share your Personal Data with
some of its necessary trusted service providers/partners (“Trusted Partners”). These could include IT,
payment, customer services and marketing service providers.
PepTalk only allows its Trusted Partners to handle your Personal Data when PepTalk has confirmed
that they apply appropriate data protection and security controls. PepTalk may also impose
contractual obligations on its Trusted Partners relating to data protection and security, which mean
they can only use your Personal Data to provide services to PepTalk and to you, and to improve the
services it provides.
PEPTALK DOES NOT SHARE YOUR PERSONAL DATA WITH ANY TRUSTED PARTNER FOR IT TO USE FOR
ITS OWN MARKETING PURPOSES WITHOUT YOUR CONSENT.
7.4 Other third parties:
Aside from to its necessary trusted service providers and partners, PepTalk will not disclose your
Personal Data to any other third party, except as set out below.
PepTalk may share your data with:
(i) credit reference agencies where necessary for card payments;
(ii) governmental bodies, regulators, law enforcement agencies, courts/tribunals and
insurers where PepTalk is required to do so: -
a. to comply with PepTalk’s legal obligations;
b. to exercise PepTalk’s legal rights (for example in court cases);
c. for the prevention, detection, investigation of crime or prosecution of
offenders; and
d. for the protection of PepTalk’s employees and customers.
PEPTALK WILL NOT SELL OR RENT YOUR PERSONAL DATA TO OTHER ORGANISATIONS FOR
MARKETING PURPOSES WITHOUT YOUR PRIOR WRITTEN CONSENT.
8. The measures PepTalk has in place to protect your Personal Data.
8.1 PepTalk strives to maintain the highest standards of data privacy and security to protect your
personal details and other information about you, however no method of transmission over
the Internet or method of electronic storage is 100% secure, therefore you use the Site and
transmit information at your own risk.
8.2 PepTalk has in place the following safeguards to protect your Personal Data:
(i) PepTalk shall ensure that Personal Data is stored securely using modern software that
is kept-up-to-date.;
(ii) Access to Personal Data within PepTalk’s organisation shall be limited to personnel
who need access and appropriate security should be in place to avoid unauthorised
sharing of information;
(iii) When Personal Data is deleted this should be done safely such that the data is
irrecoverable;
(iv) Appropriate back-up and disaster recovery solutions shall be in place; and
(v) PepTalk regularly reviews its processes and procedures to protect your information
from unauthorised access and use, accidental loss and/or destruction.
9. Your Rights.
9.1 You have the following rights in respect of the Personal Data that PepTalk holds:
(i) the right to ask for a copy of Personal Data that PepTalk holds about you (the right of
access);
(ii) the right (in certain circumstances) to request that PepTalk deletes Personal Data held on
you where PepTalk no longer has any legal reason to retain it (the right of erasure or to
be forgotten);
(iii) the right to ask PepTalk to update and correct any out-of-date or incorrect Personal Data
that PepTalk holds about you (the right of rectification);
(iv) the right to opt out of any marketing communications that PepTalk may send you and to
object to PepTalk using / holding your Personal Data if PepTalk has no legitimate reasons
to do so (the right to object);
(v) the right (in certain circumstances) to ask PepTalk to ‘restrict processing of data’; which
means that PepTalk would need to secure and retain the data for your benefit but not
otherwise use it (the right to restrict processing); and
(vi) the right (in certain circumstances) to ask PepTalk to supply you with some of the Personal
Data that it holds about you in a structured machine-readable format and/or to provide a
copy of the data in such a format to another organisation (the right to data portability).
10. Third Party Websites.
10.1 The Site may from time to time, contain links to and from the websites of its partners,
advertisers and affiliates, or to any other third party. If you follow a link to any of these
websites, please note that these websites have their own terms of use and privacy policies
and that PepTalk does not accept any responsibility or liability for these policies. Please check
these policies before you submit any Personal Data to these websites.
11. How PepTalk will communicate changes to this Privacy Policy.
11.1 PepTalk may update this Policy to reflect changes in how it collects, stores and/or uses your
Personal Data. The most recent version of the Policy will always be available via the Site.
Where appropriate, PepTalk will provide you with notice of any significant changes to how it
uses your information.
12. Cookies.
12.1 The Site uses tracking and other technologies, which may include cookies, local storage, web
beacons, embedded scripts and location data to collect information about you and distinguish
you from other users of the Site. Some of these technologies may place a cookie on your
device, transfer a unique identifier for your device to a browser or otherwise use means to
track or access your interactions and access.
12.2 PepTalk’s Cookie Policy can be accessed via the Site.
13. International Transfers
13.1 Your information will be collected, process and stored directly on or transferred to servers in
the United States. In addition, it may be transferred to other countries where PepTalk has
business operations. No matter where your Personal Data is collected, processed or stored,
PepTalk will put appropriate safeguards in place to protect your Personal Data and safeguard
your rights in accordance with this Policy.
14. Children’s data.
14.1 The Children’s Online Privacy Protection Act 1998 (US) requires that online service providers
obtain parental consent before they knowingly collect personally identifiable information
online from children who are under thirteen (13). PepTalk does not knowingly collect or
solicit personally identifiable information from children under thirteen (13). If you are a child
under thirteen (13), please do not attempt to register with or otherwise use the Site or send
PepTalk any personal information. If PepTalk learns that is has collected personal
information from a child under thirteen (13), it will promptly delete that information. If you
believe that a child under thirteen (13) may have provided PepTalk with personal
information, please contact:
15. California specific privacy rights.
15.1 As detailed herein, PepTalk does not share your Personal Data with any third party for their
own marketing purposes without your express consent.
15.2 Should you request a copy of your Personal Data held by PepTalk, please contact
www.getapeptalk.com/us/contact.
16. Google User Data.
16.1 Notwithstanding anything else contained in this Privacy Policy, if you provide PepTalk with
access to any of your Google data (including calendar data), PepTalk’s use of that data will be
subject to these additional restrictions:
(i) PepTalk will only use access to read, write, modify or control Gmail message bodies
(including attachments), metadata, headers, and settings to provide a web email client
that allows users to compose, send, read, and process emails and will not transfer this
Gmail data to others unless doing so is necessary to provide and improve these features,
comply with applicable law, or as part of a merger, acquisition, or sale of assets;
(ii) PepTalk will not use this Gmail data for serving advertisements;
(iii) PepTalk will not allow humans to read this data unless we have your affirmative
agreement for specific messages, doing so is necessary for security purposes such as
investigating abuse, to comply with applicable law, or for PepTalk's internal operations
and even then only when the data have been aggregated and anonymized.
17. How you can contact PepTalk.
17.1 If you have any questions/comments on the contents of this Policy please contact:
contact@peptalk.cc or write to PepTalk at the address shown in paragraph 1.


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