This document has two parts. The Privacy Policy explains how Pebbles collects, uses and protects personal information about visitors to this website and the people we deal with in business. The Terms and Conditions set out the terms on which you may use this website and its content.
This website is intended for business users. It is not directed at children.
"Pebbles", "we", "us" and "our" means the two companies below, both registered in England and Wales at International House, 36-38 Cornhill, London EC3V 3NG:
Each company is a separate controller of the personal information it holds. Where both companies use the same information, for example a shared list of client contacts, they do so as separate controllers under an internal data sharing arrangement. "You" and "your" means any user of this website or any individual whose personal information we hold.
Pebbles Financial Solutions Ltd is registered with the Information Commissioner's Office (ICO) under registration number ZB660204. Pebbles Data Solutions Ltd is registered with the ICO under registration number ZC275632.
If you have any questions about this Privacy Policy, or want to exercise any of your rights, please contact our Data Protection Lead:
We have not appointed a statutory Data Protection Officer because we are not required to. Our Data Protection Lead is responsible for data protection across both companies.
Pebbles does not access, request or hold personal information about our clients' customers, policyholders or claimants. Our data products are designed and checked before each release so that they contain no personal data and cannot reasonably be used to identify individuals. They are built mainly from official statistics and other aggregated sources, and from information about vehicle models.
To develop the market ratings in our data products, Pebbles Data Solutions Ltd uses motor insurance quote data supplied by a price comparison partner under a data sharing agreement. The data is pseudonymised before we receive it: names and contact details are removed and replaced with a reference number, and we cannot identify the individuals. We use it only to build statistical models, and only aggregated rating bands reach our products.
If you are a customer of one of our clients and want to know how your personal information is used, please contact that insurer, MGA or broker directly.
| Who | What we collect | How we get it |
|---|---|---|
| Website visitors | Information about your device and how you use the website, such as pages visited, approximate location (country or city), browser type and referring website. This is collected by Google Analytics using cookies (see section 11). | Automatically, when you visit the website |
| People who contact us | Name, business email address, job title, telephone number and the content of your message. | From you, through the contact form on this website, by email or by telephone |
| Client, supplier and partner contacts | Name, job title, employer, business email address and telephone number, correspondence, meeting notes, and contract and invoicing details. | From you, from your employer, or from publicly available sources such as your company's website, LinkedIn or Companies House |
| Prospects and event contacts | Name, job title, employer, business contact details and your marketing preferences. | From you (for example at an event or when you sign up to hear from us), or from publicly available business sources |
| Directors and owners of suppliers | Name, nationality, month and year of birth and role, as shown on Companies House. | From Companies House, when we carry out sanctions and identity checks on new suppliers |
We do not ask for, and ask you not to send us, sensitive information such as information about your health, ethnicity, religion or criminal record.
We only use your personal information where the law allows us to. The table below explains what we use it for and the lawful basis we rely on.
| Purpose | Lawful basis |
|---|---|
| To reply to your enquiry and follow it up | Our legitimate interests in responding to people who contact us |
| To manage our relationship with clients, suppliers and partners, including contracts, invoices and payments | Performance of a contract, or our legitimate interests where the contract is with your employer |
| To send business news, insights and event invitations to business contacts | Our legitimate interests in promoting our services, and consent where the law requires it (see section 7) |
| To understand how our website is used and improve it | Our legitimate interests in running and improving our website (see section 11 for cookies) |
| To carry out sanctions, identity and other due diligence checks on suppliers and clients | Legal obligation, and our legitimate interests in preventing financial crime |
| To keep records, deal with complaints and disputes, and protect our legal rights | Legal obligation and our legitimate interests |
| To comply with the law and respond to requests from regulators, the police or other authorities | Legal obligation |
Where we rely on legitimate interests, we have balanced our interests against your rights, and you have the right to object (see section 12). We do not make decisions about you using solely automated processing, including profiling, that have legal or similarly significant effects on you.
We send business news and event invitations to people at the companies we work with or think may be interested in our services. We send marketing emails to business email addresses, and every message includes a simple way to unsubscribe. We will not send marketing to a personal email address unless you have given your consent.
You can opt out at any time by using the unsubscribe link or by emailing pfsadmin@pebblesfs.com. We keep a record of people who have opted out so that we do not contact them again.
We will never sell or rent your personal information. We share it only where necessary, with:
Some of our service providers, such as Webflow and Google, are based in, or process information in, the United States. Where personal information is transferred outside the UK, we make sure it is protected by one of the safeguards allowed under UK law. These are UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework for certified organisations), or the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for more information about these safeguards.
| Information | How long we keep it |
|---|---|
| Website enquiries that do not lead to a business relationship | Up to 24 months after our last contact |
| Client, supplier and partner contact details, correspondence and contract records | For the length of the relationship and then 6 years after it ends |
| Financial and accounting records | 6 years from the end of the financial year |
| Marketing contacts | Until you unsubscribe, or 24 months after you last engaged with us. We keep a minimal record of opt-outs so that we do not contact you again. |
| Supplier sanctions and due diligence records | 6 years after the relationship ends |
| Website analytics data | Up to 14 months |
We may keep information for longer if the law requires it, or if it is needed for a complaint, dispute or legal claim. When information is no longer needed, we delete it securely.
Cookies are small text files that a website places on your device. Some are needed for the website to work. Others help us understand how the website is used.
| Cookie | Provider | Purpose | How long it lasts |
|---|---|---|---|
| _ga | Google Analytics | Distinguishes unique visitors so we can count visits | 2 years |
| _ga_<ID> | Google Analytics | Keeps track of your session on the website | 2 years |
We use Google Analytics only to produce statistics about how our website is used, so that we can improve it. We do not use Google Analytics data to identify you, and we do not use advertising or tracking cookies.
UK law allows websites to use cookies for this purpose without asking for consent first, as long as visitors are told about them and can easily object. You can object at any time by choosing "Reject analytics" in the cookie settings link at the bottom of every page. You can also block or delete cookies in your browser settings, or install Google's Analytics opt-out browser add-on. The website will still work if you do.
You have the following rights over your personal information:
Some of these rights only apply in certain circumstances. To exercise any of them, please contact us using the details in section 3. We may ask you to confirm your identity. There is no charge.
We will respond without undue delay and within one month. If your request is complex, we may extend this by up to two further months, and we will tell you within the first month if we need to. If we need more information to find what you have asked for, the time limit is paused until you provide it. Our searches will be reasonable and proportionate.
We hold personal information only in our business systems, mainly Microsoft 365, which are protected by encryption and multi-factor authentication. Access is limited to the people who need it, and our staff are trained in data protection and information security. If there is a personal data breach that is likely to put you at risk, we will tell you and the ICO as the law requires.
If you are unhappy with how we have handled your personal information, please contact us first using the details in section 3. We will acknowledge your complaint within 30 days, look into it, and tell you the outcome without undue delay.
You also have the right to complain to the Information Commissioner's Office:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Website: www.ico.org.uk · Telephone: 0303 123 1113
Our website contains links to other websites, such as LinkedIn. We are not responsible for their content or their privacy practices. Please read their privacy policies.
We review this Privacy Policy at least once a year and update it when the way we use personal information changes. The version number and date at the top show when it was last updated.
By using this website, you agree to these terms. If you do not agree, please do not use the website.
We use Google Analytics cookies to see how our website is used, so we can improve it. We don't use advertising cookies. You can reject analytics now or at any time. Read our privacy policy.