1. About Our Privacy Policy

This Privacy Policy applies to the Personal Information talkdeal collects from you or about you when you visit our Platform or use our Services. We explain below why and how We process your Personal Information.
Responsible for data processing within the scope of this website within the meaning of the General Data Protection Regulation (GDPR):

Pepper Deals Ltd
63/66 Hatton Garden
Fifth Floor, Suite 23
London
EC1N 8LE

This Privacy Policy is effective from 03.12.2020.

We may change this Privacy Policy at any time and We will notify you thereof, either by email or by any means of electronic notice, within a reasonable time period prior to any later version coming into force.

2. Definitions

"Services"mean all the online services we offer you when you access or use our Platform.

"Platform"means our mobile application or our website which you can access at the following address: www.talkdeal.com.
"We" , "Our", "Us" and "talkdeal" mean our company Pepper Deals Ltd., a private company limited by shares, registered in England and Wales in accordance with the laws and regulations (9729292), having its address at Pepper Deals Ltd, 63/66 Hatton Garden Fifth Floor, Suite 23, London, EC1N 8LE

Personal Informationmeans any information relating to you, and on the basis of which you can be identified, directly or indirectly.

3. How can you contact us?

You can contact us in several ways:

• By mail: Pepper Deals Ltd, 63/66 Hatton Garden, Fifth Floor, Suite 23, London, EC1N 8LE
• We have also appointed a data protection officer that you can reach under: privacy@talkdeal.com

4. What kind of Personal Information do We process concerning you?

We process different kinds of Personal Information:

Personal Information that you must provide: Depending on your use of our Services, We will need you to provide us with some categories of Personal Information.	Account Information (email address, username, password)
Personal Information that you may provide: When you are using our Services, you may provide additional categories of Personal Information.	Additional Information (first name, last name, avatar, your description) Your Activity (your deals, your discussions, your comments, your saved threads, your likes, your keyword alerts, your active filters, your searches, your private messages) Your responses to our surveys (email address and behavioral data)
Personal Information that We collect automatically: We will also collect certain categories of Personal Information when you visit our Platform and use our Services.	Your Trends (likes received, followers, statistics about your deals) Behavioral Data (pages viewed, clicks, duration of data, your likes, your active filters, your keyword alerts, your searches) Log Data and Device Information (time, date, IP address)
Personal Information that We collect from a business partner (with your consent): When you consent to it (for instance, when you accept third-parties'cookies on our Platform or on third parties'website), We'l also collect certain categories of Personal Information from business partners (marketers, advertisers, resellers).	Account Information (email address, username) Your Telephone Number Order Data Your responses to our surveys (email address and behavioral data) Behavioral Data (page viewed, time on the Platform, clicks, interactions with the Platform...) og Data and Device Information (time, date, anonymized IP address, geo-localization, browser information, screen size, operating-system, device ID, advertising ID)

5. Why is the provision of some of your Personal Information necessarily required?

We sometimes require you to provide us with some of your Personal Information. We request this when it is necessary for the provision of our Services or required by law. For instance, we need to collect your email address when you sign up to our newsletter or when you create an account on our Platform).

Failure to provide us with mandatory information may have consequences: We will not be able to create your account; We will not be able to provide our Services to you, etc.

6. Why and for what do We use your Personal Information?

We need to use your Personal Information for several purposes because we have a lawful basis to do it, which can be either:

• the necessity to enter into or perform Our Term of Use with you (Contractual necessity),
• our necessity to comply with legal obligations (Compliance with law),
• a legitimate interest We have in processing your Personal Information (Our Legitimate Interest),
• you have consented to such processing (Your Consent).

PLEASE NOTE THAT YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT OR TO OBJECT TO THE PROCESSING BASED ON OUR LEGITIMATE INTEREST FOR ANY PROCESSING OF THE OPERATIONS LISTED ABOVE AT ANY TIME, BY CONTACTING US OR BY WITHDRAWING YOURSELF AND YOUR PERSONAL INFORMATION FROM THE PLATFORM, WHERE POSSIBLE.

We collect, process and use your above shown Personal Information for the following purposes:

PURPOSES	LEGAL BASIS	(CATEGORIES OF) PERSONAL INFORMATION CONCERNED
To sign up and log in on our Platform	Contractual necessity	Account Information
To provide our services	Contractual necessity	Account Information, Additional Information, Your Activity, Your Trends
To enable you to personalize your user profile	Consent	Account Information
To send you our weekly or daily newsletter, to send you push and / or e-mail notifications	Consent	Account Information
To send you support messages, updates, security alerts, and account notifications.	Contractual necessity	Account Information
To notify you about changes to our services	Contractual necessity Compliance with law	Account Information
To prevent and detect fraud, to improve the security of our services	Legitimate interest Compliance with law	Log Data and Device Information, Your Activity
To keep a log of actions and pages visited on our website	Legitimate interest	Log Data and Device Information, Account Information
To administer our Platform and for internal operations, including running surveys, troubleshooting and testing for bugs, data analysis, research, analytics for product development.	Legitimate interest	Account Information, Additional Information, Your Activity, Your Trends, Log Data and Device Information
To improve our Platform, services, experiences, customer relationships to provide answers to your questions.	Legitimate Interest	Account Information, Additional Information, Your Activity, Your Trends, Log Data and Device Information
To measure the performance of our ads and marketing campaigns	Legitimate Interest Consent	Log Data and Device Information, Behavioral Data

7. How long do We retain your Personal Information for?

We retain your Personal Information for as long as is necessary for the purpose for which we obtained them, notably as long as you continue to use our Services and for a 3 (three) year period after our last contact with you or the last use of such Services in case you would have created an account on our Platform.

At the end of the above mentioned period, We will be able to contact you to find out whether you wish to continue using our Services. In the absence of a positive and explicit response from You, your Personal Data will be deleted or archived in accordance with the provisions in force.

Please note that even if your account and Personal Information are deleted:

• Your contributions, topics, deals and comments will be kept and anonymized,
• Your private messages will always remain available to their recipients.

In the event that your account is blocked, we will keep part of your Personal Information for a period of between 1 and 3 years in order to prevent you from circumventing the rules applying to our Platform.

We retain cookies data for a 30 days period from when they were collected, in the event where you’re not logged in on our Platform, and for up to 13 months in other instances.

8. What kinds of profiling or automated-decision processes do We use?

We may use profiling methods based on your visits on the Platform, and other interactions and content you submit to the Platform, in order to personalize features and content and make suggestions for you (such as groups or deals you may be interested in).

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

To manage your personalisation preferences, visit ourCookies Policy.

9. Who are the recipients of your Personal Information?

We do not sell personal data to third parties
We share your Personal Information with our parent / sister companies for legitimate interest:

Pepper Media Holding GmbH
Torstr. 164, 10115 Berlin, Germany

6Minutes Media GmbH
Torstr. 164, 10115 Berlin, Germany

Pepper Deals Ltd, 63/66 Hatton Garden, Fifth Floor, Suite 23
London, EC1N 8LE

Pepper France SAS
18 Rue Félix Mangini, 69009 Lyon, France

Tipping Canoe Ltd
200 - 171 McDermot Avenue, R3B 0S1 Winnipeg, Canada

PMH Solutions GmbH
Torstr. 164, 10115 Berlin, Germany

We are also working closely with third parties which are the recipients of your Personal Data such as:

• Our business partners who are social media platforms or technology companies: Facebook Login (Privacy policy), Google Sign-in (Privacy policy), Sign in with Apple (Privacy policy) and that may provide you with connecting services, such as the connection of the information of your profile from their platforms to our Platform;
• Our sub-contractors in technical or analytics providers. For example, they may help us: analyze our traffic, analyze the behaviour of users visiting the Platform in order to distinguish humans from automated programs, deliver personalised push notifications to our mobile app, measure the performance of our ads and marketing campaigns, perform product development, maintenance and debugging, and provide customer service. These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy. You can find out more about these providers in our Cookies Policy.

We only transfer your Personal Data to third parties only if there is a legal basis.

10. Do We transfer your Personal Information outside the European Union?

We prefer as much as possible to store your Personal Information within the European Union. For example, we host our servers in the European Union.

We only decide to transfer some of your Personal Information where our recipients (for instance our IT providers) have provided adequate safeguards in accordance with GDPR.

Such adequate safeguards may be notably provided for by:

• Standard data protection clauses adopted or approved by the European Commission;
• Compliance with an approved code of conduct;
• Certification under an approved certification mechanism as provided for in the GDPR;
• Contractual clauses agreed authorized by the competent supervisory.

By sending a request to privacy@talkdeal.com we can provide you with the details regarding such recipients and their appropriate safeguards.

11. How do We use cookies?

A cookie is a small piece of data (text file) that a website - when visited by a user - asks your browser to store on your device in order to remember information about you, such as your language preference or login information.

We use cookies and similar technologies (such as Pixels), find out more and manage your preferences in our Cookies and Tracking Technologies Policy.

12. What are your rights?

You have several rights to your Personal Information under GDPR:

Right of access	You have the right to access your Personal Information by making a request in writing to Us. It means you have the right to obtain a copy of your Personal Information.
Right to rectification	You have the right to rectify or to complete your Personal Information if it is inaccurate or incomplete.
Right to erasure	You have the right to request the erasure of your Personal Information. Please note that this right is not absolute and only applies in certain circumstances (for instance only if the Personal Information is no longer necessary for the purpose which we originally collected or processed for it, etc.).
Right to restrict processing	You have the right to request the restriction of your Personal Information where you have a particular reason for wanting the restriction.
Right to data portability	You have the right to ask the portability of your Personal Information. It means you have the right to receive Personal Information you have provided to Us, in a structured, commonly used and machine readable format.
Right to object	You have the right to object to the processing of your Personal Information. This allows you to ask us to stop processing your Personal Information.
Right related to automated decision making including profile	You have the right not to be subject to a decision based solely on automated means, if the decision produces legal effects concerning you or significantly affects you in a similar way.
Right to lodge a complaint	You have the right to lodge a complaint before the data protection supervisory authority : Information Commissioner’s Office - ICO Wycliffe House, Water Lane, Wilmslow SK9 5AF, Cheshire. Helpline number: 0303 123 1113. Website: https://ico.org.uk/

13. How to exercise your rights?

Right to rectification	You can exercise this right by going into the settings of your account where you’re able to update your personal information.
Right to erasure	You can exercise this right by going into the settings of your account, in the "Profile" section, and by clicking on"Delete Account".We will retain your account and information for 30 days and then it will be permanently deleted. If you change your mind you can reactivate your account by logging back in (within 30 days). In the event where your account would be suspended or permanently banned, you remain able to access a restricted mode that will allow you to delete your account. Please note that some of your Personal Information may be kept, in accordance with the 7th Section of this Privacy Policy.
Right of access / to data portability	You can exercise this right by going into the settings of your account, in the "Profile" section, and by clicking on"Generate data". You will then receive an email once the data will be ready, and you will be able to download it from the settings of your account, in the "Profile" section. You're able to generate the essential data related to your account every two weeks. We invite you to contact us by using the contact information shown at the beginning of this Privacy Policy should you want to receive your full data. In the event where your account would be suspended or permanently banned, you remain able to access a restricted mode that will allow you to download your Personal Information.

To exercise your other rights, please contact Us by using the contact information at the beginning of this Privacy Policy. We may need to ask you for a proof of identity to be certain that it is you.

We will do our best to answer you within a month.

Sometimes we will not be able to accept your request because your Data Protection Rights may only apply in certain circumstances or depends of the legal basis of processing: we will then inform you.