Menu
Menu
Pureprofile is founded on the principle of making your everyday online activities more valuable. We know that you care about how your personal information is used and shared, and we take your privacy seriously.
By visiting and using Pureprofile, you are accepting the practices outlined in this policy.
Pureprofile UK is a data and insights business, underpinned by technology. We help brands and media owners identify, connect and engage with more of the people that matter, as part of a mutually beneficial relationship.
By capturing your data, we build profiles which will enable businesses to gain the ability to segment, target and engage with their audiences for the purpose of research, marketing and advertising. In exchange, you receive value for your data, both as an immediate reward and through the delivery of preferred, more relevant content and personalised experiences.
Pureprofile UK understands the importance of data and is committed to protecting personal data collected in the course of our work.
This privacy policy explains what personal data we collect and how we use it, along with your privacy rights and how the law protects you. This policy applies to you only if you are located in the United Kingdom, a member state of the European Union or the European Economic Area (EEA).
This privacy policy is based on the following principles:
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here. Please note that sections 1 and 4 -9 inclusive apply to all types of personal data covered by this privacy policy.
Purpose of this privacy policy
This privacy policy aims to give you information on how Pureprofile UK collects and processes your personal data. You should read this privacy policy alongside any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.
Controller
Pureprofile UK Limited is a limited company incorporated and registered in England and Wales with company number 4077299. We are referred to as “Pureprofile UK“, “we“, “us” or “our” in this privacy policy. We are registered with the Information Commissioner’s Office under registration number Z8017946.
Data protection officer
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO by email to dataprotectionofficer@pureprofile.com.
European representative
We have appointed a European representative to act on our behalf regarding our compliance with the EU General Data Protection Regulation. If you are based in the EEA, you may contact our European representative regarding data protection matters relevant to you. Details for our European representative are as follows:
Our EU GDPR Representative is Rickert Rechtsanwaltsgesellschaft mbH, – Pureprofile -, Colmantstraße 15, 53115 Bonn, Germany, art-27-rep-pureprofile@rickert.law
Our UK-GDPR Representative is: Rickert Services Ltd UK, – Pureprofile -, PO Box 1487, Peterborough, PE1 9XX, United Kingdom, art-27-rep-pureprofile@rickert-services.uk
Your right to make a complaint
If you are based in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).
If you are based in the EEA, you have the right to make a complaint at any time to a supervisory authority, in particular in the country in which you live or work. You can locate a supervisory authority on the European Data Protection Board website (https://edpb.europa.eu/about-edpb/about-edpb/members_en).
In either case, we would, however, appreciate the chance to deal with your concerns before you approach the ICO or the relevant supervisory authority so please contact us, or, if applicable, our European representative, in the first instance.
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.
Third-party links
Our website at https://www.pureprofile.com/ (the “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/policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
We may collect, use, store, analyse and transfer personal data we obtain from you through our Website such as 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 Website (“Website Visitor Data”). The Website is not intended for children and we do not knowingly collect data relating to children.
We may create, collect, use and share Aggregated data such as statistical or demographic data using Website Visitor Data. Aggregated data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity. 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 policy.
How we use your personal data
We use Website Visitor Data in order to support the operation of our Website. We may on occasion also use it to detect or prevent fraud or crime. We have a legitimate interest in using Website Visitor Data for this purpose where your interests and fundamental rights do not override those interests. We may also use Website Visitor Data in order to comply with a legal obligation to which we are subject.
The term “legitimate interest” means our interest in conducting and managing our business to enable us to give our clients the best service/product 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). If you would like further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities, please contact our DPO by emailing dataprotectionofficer@pureprofile.com.
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.
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. 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.
Our two roles: first, as a controller
We act as a controller in relation to the information that we hold and process when you register to become a member of the Pureprofile community and if you subsequently participate in a Pureprofile activity, where we determine the information collected and the manner in which it is used. We may also control data that we gather as part of studies that our clients commission.
Our two roles: second, as a processor
We act as a processor when we process data on behalf of a controller (for example, one of our clients). The controller alone determines the purpose of and manner in which the data is collected and used, such as when we collect, analyse or process data in accordance with the instructions of a client.
Our clients may ask you to provide your name, email address and other contact information during a Pureprofile activity. You should know that:
– you are providing this information to the client and not Pureprofile UK, though we may process it;
– your information will be dealt with in accordance with the relevant client’s privacy policy and not this privacy policy; and
– you are always free to decline providing contact details or any other personal data to a client.
Where we act as a processor, or where you provide personal data to a client, if you wish to correct, amend, or delete inaccurate personal data, or if you wish to exercise any other of your legal rights in respect to your personal data, you should direct your request to the relevant client as it is the controller. If you struggle to contact our client you can request us to contact them on your behalf by emailing us at dataprotectionofficer@pureprofile.com.
Personal data that is collected from you may, subject to adequate confidentiality undertakings, and for the sole purpose of providing our clients with the services they have contracted from us, be accessed by our personnel and to or by third party companies and subcontractors that help us provide our services.
We will retain the personal data which our clients have instructed us to process for them for as long as needed to provide the services to them in accordance with the contractual terms we have agreed with them. Our clients can at any time instruct for such personal data to be deleted. We will retain any personal data as necessary to comply with our legal obligations, resolve disputes, and in accordance with our client agreements.
If you want to know if we are acting as a controller of or processing your personal data on behalf of a client, please email our DPO by dataprotectionofficer@pureprofile.com. When you do so, please make sure you provide details of the relevant Pureprofile activity. If we are a processor, we will provide you with contact details of the client/controller.
The remainder of this section 3 relates to our role as a controller.
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 aggregated data from which it is not reasonably possible to identify the individuals to whom it relates.
When you register to become a member of the Pureprofile community and participate in a Pureprofile activity we are conducting we may collect, use, store, analyse and transfer any personal data about you that you provide to us through registration or that activity, including any personal data we create by analysing your answers to activity questions. We will ask you to provide contact information such as your name, address, email address or phone number, or information about your age, gender, marital status or other demographic data. We may ask you to answer questions about your personality traits and decision-making habits, how you relate to others and the society you live in, and your exercise and consumption habits. You may also be asked to answer questions about your opinions of your health care system, global events, of mainstream media, as well as other outcomes which may be added later if we deem they become relevant. We will also ask you to provide bank account or Paypal account information so that we may transfer rewards you have chosen to redeem.
In this privacy policy we refer to the personal data we collect through Pureprofile UK registration and activities as “Pureprofile activity data”.
In most cases we will only share anonymised data or aggregated data with our clients and they will not be able to attribute any of the responses that you have provided to you, as an individual. In these cases we will not be passing your personal data to our clients.
In the event that a specific project requires us to share any personally identifiable responses with our clients, we will make it explicitly clear at the relevant part of an activity and obtain informed consent from you as a respondent to share that information with a named client. You will be able to withdraw from the study at any point if you do not want your data to be shared with our client or for any other reason.
Occasionally we or our clients will extrapolate/model out traits, using the data that we have collected, that can be applied across their wider customer base to improve their understanding of and ability to classify and communicate with their customers. In these situations your personal data will not be shared with the client unless we obtain your prior consent to do so.
Aggregated data
We also create, collect, use and share “Aggregated data” such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity.
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 policy.
Special category data
We may, on occasion, collect, use, analyse and process “special category data” from or about you through your answers to Pureprofile activity questions. This could include personal data which reveals your race or ethnicity, religious or philosophical beliefs, sex life, political opinions, and information about your health).
We do not collect any information about criminal convictions and offences.
While we use this data the same way we use profiling data, GDPR distinguishes it as ‘sensitive personal data,’ and so we treat it separately. Under GDPR, consent is the legal basis for processing this data.
The data is used for the purpose of selecting suitable respondents (or to exclude those who do not meet the defined target profile) for an invitation to participate in a survey.
When an account holder unsubscribes or is blacklisted the system will automatically delete all personal data for that user, in order to comply with GDPR and CCPA, while retaining anonymous activity history for a period of 12 months.
How we use Pureprofile activity data
We aggregate personal data provided to us through Pureprofile activities, then analyse it in order to predict trends in human behaviour. We do this on the basis of your express consent given to us when you sign up to participate in our activities.
We use the information you provide us to publish and deliver “Insights” and relevant activities to you through Pureprofile. This can include:
We do not share Pureprofile Activity Data for a given Pureprofile activity with the relevant client unless you have consented to us doing so or you have previously given consent to the client.
In most cases we will only share anonymised data or aggregated data with our clients and they will not be able to attribute any of the responses that you have provided to you, as an individual. In these cases we will not be passing your personal data to our clients.
In the event that a specific project requires us to share any personally identifiable responses with our clients, we will make it explicitly clear at the relevant part of the activity and obtain informed consent from you as a respondent to share that information with a named client. You will be able to withdraw from an activity at any point if you do not want your data to be shared with our client or for any other reason.
Occasionally we (or our clients) will extrapolate/model out traits, using the data that we have collected, that can be applied across their wider customer base to improve their understanding of and ability to classify and communicate with their customers. In these situations your personal data will not be shared with the client unless we obtain your prior consent to do so.
Legal basis for processing Pureprofile activity data
We process Pureprofile Activity Data relating to:
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. 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 Pureprofile activity data
With your consent, we may disclose Pureprofile Activity to the client for whom we have facilitated that Pureprofile activity.
Please see section 5 “Disclosures of Your Personal Data” below for more information about how we more generally share your personal data.
You may receive marketing communications from us if you have requested information from us, signed up for our newsletter, or purchased our services, or you have consented to receiving that marketing. In the course of communicating with you regarding marketing we may collect and process your preferences in receiving marketing from us and our third parties and your communication preferences.
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 at any time.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you by them.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of becoming a member of the Pureprofile community or participating in Pureprofile activities.
Browser Cookies
You can set your browser 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 cookies policy.
This section applies to all personal data covered by this privacy policy.
· We may share your personal data with the parties set out below for the purposes set out above – see “How we use your personal data” and “How we use Pureprofile activity data.”
– Service providers, such as Amazon Web Services (AWS), Sample Ninja, Alchemer, Confirmit, Decipher acting as processors based in the United Kingdom and Ireland who provide data storage services.
– Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in the UK and Australia who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
– Third parties to whom we may choose to 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 may use your personal data in the same way as set out in this privacy policy.
For further detail about how we disclose Pureprofile Activity Data, please see the Pureprofile activity data section 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.
This section applies to all personal data covered by this privacy policy.
Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
This section applies to all personal data covered by this privacy policy.
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 also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
This section applies to all personal data covered by this privacy policy.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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.
This section applies to all personal data covered by this privacy policy.
Under certain circumstances, you have rights under data protection laws in relation to your personal data as described below.
– If you want us to establish the data’s accuracy;
– Where our use of the data is unlawful but you do not want us to erase it;
– 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
– You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact our DPO by emailing dataprotectionofficer@pureprofile.com.
No fee usually required
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 could refuse to comply with your request in these circumstances.
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 (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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
PUREPROFILE UK LIMITED
Effective from 26th January 2023
Copyright @ 2024. Pureprofile Ltd. Patented and patent pending.
