PRIVACY NOTICE

(Last updated September 2024)

INTRODUCTION

Who are we?

We are PrettyGreen Things Limited, a company incorporated and registered in England and Wales with registered address at 3rd Floor Paternoster House, 65 St Paul's Churchyard, London, EC4M 8AB and registered number 06594155 (“PrettyGreen”, “we”, “us” or “our”), and we are a creative communications and PR agency.

Where we decide the means or purpose of processing your personal data, we are the “controller."

What’s this notice about?

This notice relates to the “Picture of Health” campaign (“Promotion”), which comprises of:

Organising and running the “Picture of Health” competition to go live on 21^st May 2024 and close on 21^st June 2024 (excluding managing the fulfilment of this competition’s prizes) (“Competition”).
Curating, hosting and maintaining the online “Picture of Health” gallery (“Online Gallery”).

The Competition shall comprise of both an “Internal Competition”, which can only be entered into by Bupa employees, and an “External Competition”, which can be entered into by members of the general public (excluding Bupa employees).

This notice explains how we process personal data relating to:

Individuals who have entered into the Competition, or who have submitted a photograph to be included in the Online Gallery (“Participant”, “you” and “your”), via the following websites: www.bupapictureofhealth.com (“Websites”).
Individuals who feature in photographs submitted by Participants in relation to the Promotion (“Non-participants”).

We update this notice from time to time, so you should check back in on a regular basis. Where appropriate, we will send you an updated version of the notice using any contact information which you have shared with us.

Please note that other websites or services mentioned on the Websites are not operated by us, and you should refer to the privacy notices on those websites to understand how they process personal data.

What are your rights?

You have the following rights, although these rights may be limited in some circumstances:

Ask us to send a copy of your personal data to you or someone else
Ask us to restrict, stop processing, or delete your personal data
Object to our processing of your personal data
Object to use of your personal data for direct marketing purposes (although PrettyGreen does not currently intend to undertake any direct marketing in relation to the Promotion)
Ask us to correct inaccuracies in your personal data

If we rely on consent to process personal data, or send direct marketing, you can withdraw consent by email to: [email protected]

How do you contact us?

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: [email protected]. You can also contact us in order to exercise your rights by using the same details.

If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns
(or if you live in a European country other than the UK, you can submit a complaint to the supervisory authority in your country).

YOUR PERSONAL DATA AND HOW WE USE IT

PROMOTION

Purpose – We process certain information relating to Participants and Non-participants to enable us to organise and manage the Promotion.

Categories of personal data – We collect and process the following information when Participants enter into the Competition, or submit a photograph to be included in the Online Gallery:

A Participant’s name and email address, a photo of the Participant, the Participant’s photo caption, the language settings used by the Participant on the Websites and the Participant’s IP address.
If a Participant’s photo features another individual (i.e. a Non-participant), such photo will contain personal data relating to a Non-participant.
If we contact Participants in relation to the Promotion, we may also collect and process additional personal data relating to them where it is contained within correspondence exchanged between us and the Participant.
The Internal Competition is divided into sections, determined by where each “Bupa employee” Participant is geographically located, and therefore we will collect information on which section of the Internal Competition you have entered (“Market Unit”).

STORAGE, TRANSFERS AND DISCLOSURE

Storage & Transfers

We are based in the United Kingdom and may from time-to-time use subcontractors based in other countries. As a result, there may be occasions where we transfer personal data to a country which does not provide an adequate level of protection. Where this is the case, we use contracts which give personal data the same protection it has in the UK. For more information, please contact us at: [email protected]

Disclosure

We may share the following personal data with Bupa for the purposes set out below:

Names and email addresses of winners – in order to engage them for the Internal Competition’s fulfilment and their entry’s feature on media .
Names, email addresses, Market Unit, photos and photo captions – in order to judge short-listed entries for the Internal Competition.
Names, photos and photo captions and contact information – in order to enable Bupa to promote Bupa and liaise directly with participant
Names – in order to verify whether Participants entering into the Internal Competition have complied with the applicable terms and conditions.

When processing your personal data, Bupa will comply with the Competition’s applicable terms and conditions and in accordance with Bupa’s own Privacy Notice, which can be found at https://www.bupa.com/important-notices/privacy-notices. If you have any questions regarding how Bupa processes your personal data, you can contact them at: [email protected], citing “Picture of Health" in the subject line.

We may also disclose your personal data:

Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
With suppliers and subcontractors, as necessary for the purposes set out in this notice.
If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

Cookies, pixels and other technologies store and access data on devices to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get consent to use them unless they’re essential to the Websites.

Cookie/data	Duration	Purpose
NEXT_LOCALE	2 years	Save language preferences