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PRIVACY PLOICY
1. Introduction
Pear Flow is a trading name of Pear Digital Marketing Limited (“Company”, “we”, “us”, “our”).
We are committed to protecting your privacy and handling personal data transparently and lawfully.
This Privacy Policy explains how we collect, use, process and protect personal data when you:
Visit our website
Apply to work with us
Enquire about our services
Engage us as a client
Communicate with us
For the purposes of UK and EU data protection law, Pear Digital Marketing Limited acts as a Data Controller in relation to data collected directly through our website and business operations.
2. Data We Collect
We may collect and process the following categories of personal data:
Information You Provide Directly
Full name
Business name
Job title
Email address
Phone number
Website URL
Business information submitted via application forms
Communications you send to us
Automatically Collected Information
When you visit our website, we may collect:
IP address
Browser type
Device information
Pages visited
Time spent on pages
Referral sources
This data is collected via cookies and analytics tools.
3. How We Use Your Data
We process personal data for the following purposes:
To respond to enquiries
To assess suitability for our services
To provide agreed services
To manage contracts and billing
To communicate with clients
To improve our website and services
To comply with legal obligations
We do not sell personal data to third parties.
4. Lawful Basis for Processing (UK & EU GDPR)
We rely on one or more of the following lawful bases:
Contractual necessity – where processing is required to provide services
Legitimate interests – for responding to business enquiries and improving services
Legal obligation – to comply with regulatory requirements
Consent – where legally required
Our legitimate interest is conducting lawful B2B marketing and business development activities.
5. Outbound Email and B2B Communications
Pear Flow provides outbound infrastructure services to clients.
In the context of client campaigns:
Clients act as Data Controllers
Pear Flow may act as a Data Processor
Clients are responsible for ensuring lawful data sourcing and compliance with applicable regulations including UK GDPR, EU GDPR and CAN-SPAM
Pear Flow does not independently collect prospect data for resale.
We provide infrastructure and strategy services only.
6. Data Sharing
We may share data with:
Professional advisers (legal, accounting)
Service providers necessary for delivering our services
IT and hosting providers
Regulatory authorities where required
All third parties are required to maintain confidentiality and appropriate data protection safeguards.
7. International Data Transfers
Where data is transferred outside the UK or European Economic Area, we ensure appropriate safeguards are in place, including:
Standard Contractual Clauses
Adequacy decisions
Secure hosting environments
We take reasonable steps to ensure international data protection standards are met.
8. Data Retention
We retain personal data only for as long as necessary to:
Provide services
Fulfil contractual obligations
Meet legal requirements
Enquiry data may be retained for up to 24 months unless deletion is requested.
Client data is retained in accordance with contractual and regulatory obligations.
9. Data Security
We implement appropriate technical and organisational measures to protect personal data, including:
Secure access controls
Encrypted systems where appropriate
Restricted staff access
Secure hosting environments
No internet-based transmission can be guaranteed as fully secure, but we take commercially reasonable steps to protect data.
10. Your Rights (UK & EU)
Under UK and EU data protection laws, you may have the right to:
Access your personal data
Rectify inaccurate data
Request erasure
Restrict processing
Object to processing
Request data portability
To exercise your rights, contact us using the details below.
We may require identity verification before responding.
11. US Residents
If you are based in the United States, you may have rights under applicable state privacy laws, including rights relating to:
Access to personal data
Deletion requests
Transparency regarding data use
We do not sell personal information as defined under US privacy laws.
12. Cookies and Analytics
Our website may use cookies and tracking technologies to:
Analyse traffic
Improve user experience
Understand visitor behaviour
You may adjust your browser settings to refuse cookies. Disabling cookies may affect website functionality.
13. Third-Party Links
Our website may contain links to third-party websites.
We are not responsible for the privacy practices of external sites.
14. Changes to This Policy
We may update this Privacy Policy periodically.
The latest version will always be available on our website with an updated effective date.
15. Contact Information
For privacy-related enquiries, please contact:
Pear Digital Marketing Limited Trading as Pear Flow Company Number: 08833123 Email: [email protected] Registered in England and Wales
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) in the UK or your local data protection authority.
Final Positioning Statement
Pear Flow operates within lawful B2B marketing frameworks. We prioritise compliance, transparency and responsible data handling.