01Our Role
In client projects - campaign platforms, loyalty programmes, referral systems and websites - the client decides why and how participants' data is used. Under the UU PDP the client is the data controller and PAGII is the data processor.
We process that data only on the client's documented instructions and under the project agreement. Participants should read the privacy policy of the campaign or brand they take part in.
02Collect Only What Is Needed
We work with the client to collect only the data a campaign actually needs, set a clear purpose for each field, and avoid sensitive data unless the client has a lawful basis and it is truly required.
03How We Protect It
- Encrypted connections (HTTPS/TLS) for all data in transit.
- Access limited to the people working on the project, with individual accounts.
- Separate environments for development and live data; real participant data is not used for testing.
- Passwords stored as secure hashes, never in plain text.
- Regular updates to the software and libraries we use.
04Service Providers
We host projects with established cloud and hosting providers, chosen with the client. Where other service providers are involved - such as email, messaging or payment services - we agree on them with the client beforehand, and they are bound by confidentiality and data protection obligations.
05Retention and Deletion
Data is kept only as long as the agreement with the client requires. When a campaign or contract ends, we return the data to the client, delete it, or both - as agreed - including copies in backups once they expire.
06If Something Goes Wrong
If we become aware of a breach involving client data, we inform the client without delay, help contain it, and provide the information the client needs to meet its own obligations - including the UU PDP requirement to notify the people affected and the authority within 3 x 24 hours.
07Requests from Participants
If a participant asks us directly to access, correct or delete their data, we pass the request to the client and help the client respond.
08Contact
Questions about how we handle data in a project: hello@pagii.id.