PRIVACY POLICY

We are committed to protecting your privacy, and we take our responsibilities
regarding the security of user and customer information very seriously. This
policy explains how we use user and customer information and how we protect
your privacy.
Please read this policy carefully, as we will ask you to give your express
agreement to the terms of it (for example, by ticking the appropriate box on our
website, or when installing a browser extension, or on our mobile or desktop
application or otherwise).

1. Introduction
1.1 In this policy, "we", "us" and "our" refer to JOIN PEEKABOO LTD (UK
Company number 14485051), whose registered office is at Hazelbank
Sandy Lane, Antrobus, Northwich, England, CW9 6NU.
1.2 You can contact us by using the contact details available on our website.
2. Amendments
2.1 We may update this policy from time to time by publishing a new version
on our website.
2.2 You should check this page occasionally to ensure you are happy with
any changes to this policy.
2.3 We may notify you of any significant changes to this policy by email or
using any other contact details we hold for you.
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services ("usage
data"). The usage data may include your IP address, geographical
location, browser type and version, operating system, referral source, the
retailer who you make a purchase with, length of visit, page views and

website navigation paths, as well as information about the timing,
frequency and pattern of your service use. The source of the usage data
is our analytics tracking system. This usage data may be processed for
the purposes of analysing the use of the website and services.
3.3 We may process your account data ("account data"). The account data
may include your name, telephone number, email address, address, and
any other information you provide to us when setting up an account. The
account data may be processed for the purposes of operating our website,
providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you.
3.4 We may process your personal data that are provided in the course of you
using our services ("personal data"). The personal data may include any
data provided as part of setting up your account. The personal data may
be processed for the purposes of operating our website, providing our
services, marketing, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you.
3.5 We may process information contained in any enquiry you submit to us
regarding our services ("enquiry data"). The enquiry data may be
processed for the purposes of offering, marketing and selling our services
to you, or those of any affiliate or other retailer.
3.6 We may process information relating to transactions, including any bank
details you provide to us if you wish to claim payments for purchasing
products through our affiliates ("transaction data"). The transaction data
may be processed for the purpose of making payments and keeping
proper records of those transactions.
3.7 We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court
procedure. The legal basis for this processing is our legitimate interests,
namely the protection and assertion of our legal rights, your legal rights
and the legal rights of others.
3.8 We may process any of your personal data identified in this policy, for the
following reasons, which provide the legal basis for the processing:
(a) where necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, or obtaining professional
advice - the legal basis for this processing is our legitimate
interests, namely the proper protection of our business against
risks;

(b) the proper administration of our website and business, and/or the
performance of a contract between you and us or a third party
and/or taking steps, at your request, to enter into such a contract.
3.9 In addition to the specific purposes for which we may process your
personal data set out in this Section 3, we may also process any of your
personal data where such processing is necessary for compliance with a
legal obligation to which we are subject.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company
and all its subsidiaries) insofar as reasonably necessary for the purposes,
and on the legal bases, set out in this policy. We may also disclose any of
your data to any of our affiliates.
4.2 We may disclose your personal data to our insurers insofar as reasonably
necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, obtaining professional advice, or the
establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
4.3 Financial transactions relating to our website and services may be
handled and held securely by third party payment services providers. We
may share transaction data with our payment services providers to the
extent necessary for the purposes of them processing your payments,
refunding such payments and dealing with complaints and queries relating
to such payments and refunds.
4.4 In addition to the specific disclosures of personal data set out in this
Section 4, we may disclose your personal data where such disclosure is
necessary for compliance with a legal obligation to which we are subject.
We may also disclose your personal data where such disclosure is
necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court
procedure.
4.5 The personal data we collect from you may be transferred to, or stored at,
a destination outside of the UK or the EEA. By submitting your personal
information to us, you agree to such transfer, storing or processing.
4.6 Your data may be transferred to and stored on third party servers.
5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which
are designed to help ensure that we comply with our legal obligations in
relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be
kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data for as long as we need to, to meet any
possible legal requirements and your contact details indefinitely for the
purposes of marketing.
5.4 In some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will
determine the period of retention based on how long we consider it is
reasonable to retain such data for the purposes specified in Section 3.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your
personal data where such retention is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another person.
6. Your rights
6.1 In this Section 6, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details
have been included. Please seek legal advice or read the information at
https://ico.org.uk/ (the ‘ICO Website’), should you wish to know more.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

6.3 You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together
with certain additional information. Providing the rights and freedoms of
others are not affected, we will supply to you a copy of your personal data.
The first copy will be provided free of charge, but additional copies may be
subject to a reasonable fee. More details can be found on the ICO
Website.
6.4 You have the right to have any inaccurate personal data about you
rectified and, taking into account the purposes of the processing, to have
any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal
data without undue delay. However, there are exclusions of the right to
erasure. More details can be found on the ICO Website.
6.6 In some circumstances you have the right to restrict the processing of
your personal data. Where processing has been restricted on this basis,
we may continue to store your personal data. However, we will only
otherwise process it: with your consent, or for other legal reasons. More
details can be found on the ICO Website.
6.7 You have the right to object to our processing of your personal data for
direct marketing purposes (including profiling for direct marketing
purposes). If you make such an objection, we will cease to process your
personal data for this purpose.
6.8 To the extent that the legal basis for our processing of your personal data
is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to
which you are party or in order to take steps at your request prior to
entering into a contract,
and such processing is carried out by automated means, you have the
right to receive your personal data from us in a structured, commonly used
and machine-readable format. However, this right does not apply where it
would adversely affect the rights and freedoms of others.
6.9 If you consider that our processing of your personal information infringes
data protection laws, you have a legal right to lodge a complaint with a
supervisory authority responsible for data protection.
6.10 To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any

time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.
6.11 You may exercise any of your rights in relation to your personal data by
contacting us at the address on our website.
7. About cookies
7.1 A cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the
browser. The identifier is then sent back to the server each time the
browser requests a page from the server.
7.2 Cookies do not typically contain any information that personally identifies
a user, but personal information that we store about you may be linked to
the information stored in and obtained from cookies.
8. Cookies that we use
8.1 We may use cookies for the following purposes:
(a) authentication - to identify you when you visit our website and as you
navigate our website;
(b) personalisation - to store information about your preferences and to
personalise the website for you;
(c) security - as an element of the security measures used to protect
user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally;
(d) advertising - to help us to display advertisements that will be
relevant to you;
(e) analysis - to help us to analyse the use and performance of our
website and services; and
(f) cookie consent - to store your preferences in relation to the use of
cookies more generally.

9. Cookies used by our service providers
9.1 Our service providers use cookies and those cookies may be stored on
your computer when you visit our website – such as Google Analytics and
Google AdSense advertisements.
10. Managing cookies

10.1 Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and
from version to version. You can however obtain up-to-date information
about blocking and deleting cookies via searching about your specific
browser using an internet search engine.
10.2 Blocking all or some cookies may have a negative impact upon the
usability of many websites and you may not be able to use all the features
on our website.
11. How to contact the appropriate authority
11.1 Should you wish to report a complaint or if you feel that we have not
addressed your concern in a satisfactory manner, you may contact the
Information Commissioner’s Office who enforces data protection laws –
contact details on the ICO Website.