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Privacy and Cookie Policy

pebble believes in protecting your data, and being transparent about how we use it. We're complying with GDPR regulations, but we'd also like you to know that...

• We are not currently collecting or storing any personally identifiable data about you.

• We gather information about traffic to the website via Google Analytics. We only use this data to improve content and functionality of the website. You can prevent your browser from giving us this information (see section 12 in the legal bit below).

• We use a Facebook pixel on our website. If you are a Facebook user, this tracks that you have visited this website and helps us share content with you again via Facebook. For more information about opting out, visit Facebook's help page https://www.facebook.com/help/...

• Website visitor statistics aside, we don't share any data with third-party individuals or organisations. In the event this changes, we would clearly notify all users of any change and we will never share your information with for any reason whatsoever without your express and clear consent.

• We will only ever work with individuals or organisations that can prove they share the same commitment to respecting your privacy.

If you have any questions, you're welcome to drop us an email to [email protected]

As is required by GDPR legislation, we also have all the serious legal notices below if you want more detail about how we use and safeguard data below...

1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4    In this policy, "we", "us" and "our" refer to Otter Media Limited. For more information about us, see Section 13.

2. Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com).

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, 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. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, via a double-opt in subscription confirmation.

3.4  We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.5  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.

3.6  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, or in order to protect your vital interests or the vital interests of another natural person.

3.7  Please do not supply any other person's personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

We do not share your personal data with any third-parties beyond that which may legally be required of us.

4.1    We may disclose your personal data where such disclosure 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 natural person. 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.

5. International transfers of your personal data

5.1    There are currently no circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    The hosting facilities for our website are situated in the United Kingdom.

5.3    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.  Retaining and deleting personal data

6.1    This Section 6 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.

6.2    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.

6.3    We will retain your personal data as follows:

(a)    Usage data, correspondence data and notification data will be retained for a minimum period of 2 years following the date of provision, and for a maximum period of 5 years following date of provision.

6.4    Notwithstanding the other provisions of this Section 6, 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 natural person.

7.  Amendments

7.1    We may update this policy from time to time by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

8. Your rights

8.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the payment of a fee (currently fixed at GBP 10); and

(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2    We may withhold personal information that you request to the extent permitted by law.

8.3    You may instruct us at any time not to process your personal information for marketing purposes.

8.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9.  About cookies

9.1    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.

9.2    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3    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.

10. Cookies that we use

10.1  We use cookies for the following purposes:

(a)    authentication - we use cookies to identify you when you visit our website and as you navigate our website. Cookies used for this purpose are: "CraftSessionId" (essential for browsing the website and relates to the content management system in use. It is used to store any session specific settings that need to be remembered between one page and the next.)

(b)    analysis - we use cookies to help us to analyse the use and performance of our website and services. Ccookies used for this purpose are: 

_ga." (used to distinguish users), "_gid." (used to distinguish users), "_gat."(used to distinguish users));

(c)    advertising - we use cookies to help us to display advertisements that will be relevant to you on Facebook. Cookies used for this purpose are: "Facebook Pixel" (used to measure, optimise and build audiences for advertising campaigns served on Facebook. It enables pebble to see how our users move between devices when accessing theweb site and Facebook, and to ensure that pebble's Facebook advertising is seen by our users most likely to be interested in such advertising by analysing which content a user has viewed and interacted with on the pebble web site. For further information about the Facebook Pixel please see: https://en-gb.facebook.com/business/help/651294705016616)

11.  Cookies used by our service providers

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are:  "_ga." (used to distinguish users), "_gid." (used to distinguish users),"_gat." (used to throttle request rate).

11.3 We use a Facebook Pixel to help us control advertising served to a user of the pebble guide web site on Facebook. This service uses cookies for the recognition of such users and the devices used by the user to access Facebook and the pebble guide web site. You can view the privacy policy of this service provider at https://www.facebook.com/busin... . The relevant cookies are: "Facebook Pixel"

12.  Managing cookies

12.1  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 these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2  Blocking all cookies will have a negative impact upon the usability of many websites.

12.3  If you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1  This website is owned and operated by Otter Media Limited.

13.2  We are registered in England and Wales under registration number 10935206, and our registered office is at 6 Oyster Court, Crampton Street, London, United Kingdom, SE17 3BW.

13.3  Our principal place of business is at 6 Oyster Court, Crampton Street, London, United Kingdom, SE17 3BW.

13.4  You can contact us:

(a)    by post, to the postal address given above;

(b)    by email, using the email address published on our website from time to time.

14.    Data protection officer

14.1  Our data protection officer's contact details are: Alex Traska, c/o Makermet Creative Limited, 7 Malin Hill, Nottingham, NG1 1JQ.

Mediavine Programmatic Advertising

The Website uses Mediavine to manage all third-party advertising on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. The cookie may collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from a third-party site, the URL of the linking page.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at www.allaboutcookies.org/manage-cookies/.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site.

The Website may collect IP addresses and location information to serve personalized ads and pass it to Mediavine. If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit https://www.networkadvertising.org/managing/opt_out.asp. You may also visit https://optout.aboutads.info/#/ and https://optout.networkadvertising.org/# to learn more information about interest-based advertising. You may download the AppChoices app at https://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

Mediavine partners with the following data processors:

  1. Pubmatic. You may find Pubmatic’s privacy policy through this link. The data collected on the Website may be transferred to Pubmatic and its demand partners for interest-based advertising. Statistical information and other non-cookie technologies (such as eTags and web or browser cache) may be used by third parties on this Website. Browser settings that block cookies may have no effect on these technologies, but you may clear your cache to delete such trackers. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected.
  2. Criteo. You may find Criteo’s privacy policy through this link. The data collected on the Website may be transferred to Criteo and its demand partners for interest-based advertising. Criteo may collect, access, and use non-identifying data to improve the Criteo Technology and other Criteo products, programs, and/or services. This non-identifying data may include on-site user behavior and user/page content data, URLs, statistics, or internal search queries. The non-identifying data are collected through the ad call and stored with a Criteo cookie for a maximum period of 13 months.
  3. Pulsepoint. You may find Pulsepoint’s privacy policy through this link.
  4. LiveRamp. You may find LiveRamp’s privacy policy through this link. When you use the Website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating system, with LiveRamp Inc, and its group companies (‘LiveRamp’). LiveRamp may use a cookie on your browser and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email, in-app, etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. To opt out of LiveRamp’s targeted advertising, please go here: https://liveramp.com/opt_out/
  5. RhythmOne. You may view RhythmOne’s privacy policy through this link. RhythmOne uses cookies and similar tracking technologies (such as mobile device identifiers and digital fingerprinting) to provide its services. RhythmOne may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit the following webpage: https://www.networkadvertising.org/managing/opt_out.asp.
  6. District M. You may find District M’s privacy policy through this link.
  7. YieldMo. You may find YieldMo’s privacy policy through this link. If you want to opt out of receiving interest based ads from Yieldmo or exercise your right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of your personal information, you may do so through this link.
  8. The Rubicon Project. You may find Rubicon’s privacy policy through this link. If you want to opt out of receiving interest based ads from Rubicon or exercise your right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of your personal information, you may do so through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page.
  9. Amazon Publisher Services. You may find Amazon Publisher Services’ privacy policy through this link.
  10. AppNexus. You may find the AppNexus privacy policy through this link.
  11. OpenX. You may find OpenX’s privacy policy through this link.
  12. Verizon Media formerly known as Oath. You may find Verizon Media’s privacy policy through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising.
  13. TripleLift. You may find TripleLift’s privacy policy through this link. To opt out of receiving interest-based advertising (including retargeting) from TripleLift’s services through the use of cookies in your current browser and for more information on what it means to opt-out, please go to www.triplelift.com/consumer-opt-out.
  14. Index Exchange. You may find Index Exchange’s privacy policy through this link. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising.
  15. Sovrn. You may find Sovrn’s privacy policy through this link.
  16. GumGum. You may find GumGum’s privacy policy through this link. GumGum may (i) use place and use cookies on end users’ browsers or use web beacons to collect information about end users who visit such Publisher Websites and (ii) link such collected end user information to other end user information provided by third parties in order to deliver targeted Advertisements to such end users.
  17. Digital Remedy. You may find Digital Remedy’s privacy policy through this link.
  18. MediaGrid. You may find MediaGrid’s privacy policy through this link. MediaGrid may collect and store information about end-user interactions with this website through cookies, advertising IDS, pixels and server-to-server connections. MediaGrid was receive the following information: the page an End-User has requested and the referring/exit pages; Timestamp information (i.e., the date and time the End-User has visited the page); IP address; mobile device identifier; device model; device operating system; browser type; carrier; gender; age; geolocation (including GPS coordinates); clickstream data; cookie information; first-party identifiers'; and hashed email addresses; demographic and inferred interest information; and post-conversion data (from both online and offline behaviour). Some of this data is gathered from this website and others is gathered from advertisers. MediaGrid uses this data to provide its services. You may also utilize the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or the European Interactive Digital Advertising Alliance’s opt-out page to opt-out of the use of cookies for interest-based advertising or review their privacy policy for more information.
  19. RevContent - You may find RevContent’s privacy policy through this link. RevContent may collect information about your browser or device, including browser type, IP Address, device type, user agent string, and operating system. RevContent also collects information about the websites you visit through their services, such as date and time of access and specific pages accessed and the content and ads you click on. You may opt-out of any personalization track by opting-out of RevContent’s data collection.
  20. Centro, Inc. - You may find Centro’s privacy policy through this link. You may find opt-out information for Centro’s services through the privacy policy link.
  21. 33Across, Inc. - You may find 33Across’s privacy policy through this link. To opt-out of personalized advertising, please visit https://optout.networkadvertising.org/?c=1.
  22. Conversant. LLC - You may find Conversant’s privacy policy through this link. Conversant uses information that does not directly identify you, such as information about your browser type, time and date of visit, your browsing or transaction activity, the subject of advertisements clicked or scrolled over, and a unique identifier (such as a cookie string, or a unique advertising identifier provided by your mobile device) during your visits to this and other websites and apps in order to provide advertisements about goods and services likely to be of greater interest to you. Conversant may use technologies such as cookies and other tracking technologies to collect this information. To learn more about interest-based advertising, or to opt-out, you can visit www.youronlinechoices.eu or https://www.networkadvertising.org/.