Privacy Policy
Effective date: 01/09/2025
Last updated: 22/01/2026
- Who we are
This Privacy Policy (Policy) explains how HAPPY PAWS OF THE VALE LTD (company number 14856878) of Dept 6211a 126 East Ferry Road, Canary Wharf, London, United Kingdom, E14 9FP (Company, we, us, our) collects and processes personal data when you use pebblewish.com (Site) and related services.
Contact: info@pebblewish.com.
For the purposes of applicable data protection law, the Company is the controller of your personal data.
- Scope of this Policy
This Policy applies to personal data we collect from you or that you provide to us when you browse the Site, create an account, use the Site features, make payments, communicate with us, or otherwise interact with the Site.
This Policy should be read together with any cookie notice and any other privacy-related notices displayed on the Site from time to time.
- Data protection laws we follow
We process personal data in accordance with the UK GDPR and the Data Protection Act 2018. Where and to the extent EU/EEA data protection laws apply to our processing, we will also comply with those requirements.
- Personal data we collect
We may collect and process the following categories of personal data (depending on how you use the Site):
(a) Account data: name (if provided), email address, account identifiers, login and authentication information (we do not store your password in plain text).
(b) Child-related inputs you provide: a child’s first name, age and general interests (in broad terms). We do not require photos and we do not intend to collect special category data (such as health data, religious beliefs, biometric data) about a child or any other person.
(c) Purchase and Wallet data: records of your purchases, Wallet top-ups, Wallet balance movements, transaction timestamps, amounts, currency, payment status, and related operational logs.
(d) Communications: messages you send to us (for example, emails to support), and our responses.
(e) Technical and usage data: IP address, device and browser type, operating system, approximate location derived from IP, pages viewed, clicks, referral source, and other analytics and log data.
(f) Cookies and similar technologies: we may use cookies and similar technologies to operate the Site, remember preferences, enable features and help us understand Site usage. Details are provided via our cookie notice (where applicable).
- How we use personal data and our lawful bases
We process personal data only where we have a lawful basis to do so. Depending on the context, the lawful bases we rely on include performance of a contract, legitimate interests, consent, and legal obligations. We may use personal data for the following purposes:
(a) Providing the services: to create and administer accounts, provide access to Site features, generate and supply digital products, maintain Wallet functionality, and provide customer support. Lawful basis: performance of a contract; legitimate interests.
(b) Payments and fraud prevention: to process payments, manage chargebacks and disputes, prevent fraud and abuse, and maintain financial records. Lawful basis: performance of a contract; legitimate interests; legal obligations.
(c) Communications: to send service-related messages (for example, confirmations, security notices, important account updates) and to respond to your enquiries. Lawful basis: performance of a contract; legitimate interests.
(d) Improving and securing the Site: to monitor performance, debug, maintain, protect and improve the Site and its features, including analysing usage patterns and ensuring network and information security. Lawful basis: legitimate interests.
(e) Legal and compliance: to comply with applicable laws, respond to lawful requests, enforce our terms and policies, and establish, exercise or defend legal claims. Lawful basis: legal obligations; legitimate interests.
(f) Marketing (if applicable): to send marketing communications where permitted by law and where required, subject to your choices. Lawful basis: consent and/or legitimate interests (depending on the circumstances and applicable law). You can opt out at any time using the instructions provided in the message or by contacting us.
- Children’s data
The Site is intended to be used by adults. If you provide a child’s first name, age and general interests to personalise content, you confirm that you have the right to provide that information and that doing so is lawful. Please do not provide photos or sensitive information about any child or any other person.
- Sharing personal data (recipients)
We do not sell your personal data. We may share personal data with the following categories of recipients, where necessary for the purposes described in this Policy:
(a) Service providers (processors): suppliers that help us operate the Site (for example, hosting, infrastructure, security, analytics, customer support tools) and process data on our instructions.
(b) Payment providers: payment processors and related providers used to take payments and handle chargebacks and fraud screening. We do not typically store full payment card details; payment providers process those details in accordance with their own privacy documentation.
(c) Professional advisers: legal, accounting, auditing, and other advisers where necessary.
(d) Authorities and others for legal reasons: law enforcement, regulators, courts, or other parties where disclosure is required by law, necessary to protect rights, or necessary to prevent fraud or security issues.
Where we use processors, we require them to process personal data only on documented instructions and to apply appropriate security measures.
- International transfers
We aim to process personal data within the UK and/or the EEA. If we transfer personal data outside the UK or EEA, we will take steps required by applicable law to ensure an adequate level of protection (for example, using recognised transfer mechanisms such as adequacy regulations or standard contractual clauses, as appropriate).
- Security
We use technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. No system is completely secure, and we cannot guarantee absolute security, but we maintain safeguards appropriate to the nature of the data and the risks involved.
- Retention
We keep personal data only for as long as necessary for the purposes described in this Policy, including to provide the services, comply with legal obligations, resolve disputes and enforce agreements. Retention periods may vary depending on the type of data, how it is used, and applicable legal requirements. Where data is no longer needed, we will delete it or anonymise it.
- Your rights
Subject to applicable law, you may have the right to:
(a) access your personal data;
(b) rectify inaccurate or incomplete personal data;
(c) request erasure of personal data;
(d) restrict processing;
(e) object to processing (including, where applicable, processing based on legitimate interests);
(f) data portability (in certain circumstances);
(g) withdraw consent at any time where processing is based on consent (withdrawal does not affect the lawfulness of processing before withdrawal);
(h) lodge a complaint with the UK Information Commissioner’s Office (ICO) or another competent supervisory authority.
You can exercise your rights by contacting us at info@pebblewish.com. We may need to verify your identity before responding.
- Automated processing and AI-generated text
The Site may use automated systems (including artificial intelligence) to generate story text based on the information you provide. This is used to provide the service you request. We do not intend to use automated decision-making that produces legal effects concerning you or similarly significantly affects you.
- Third-party links and services
The Site may reference or link to third-party websites or services. Their privacy practices are governed by their own policies. We are not responsible for third-party privacy practices.
- Changes to this Policy
We may update this Policy from time to time by posting an updated version on the Site. The version in force is the one available on the Site at the time you use it.
- Governing law
This Policy and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter shall be governed by and construed in accordance with the laws of England and Wales, and the courts of England and Wales shall have exclusive jurisdiction.
