Pragmattic Ltd Privacy Policy

Data Controller

Pragmattic Ltd
Pragmattic Ltd, 19a South Street, Worthing, BN11 3AW (referred to as the 'Controller')

Owner contact email: hello@pictocard.app
Data Protection Officer: hello@pictocard.app

This Policy applies to data processed by the Controller's website and related services. It applies to all situations where the Controller acts as the data controller, including when Users engage with our services, upload photos, and create personalised gift cards.

Types of Data Collected

Personal Data collected by Pragmattic Ltd, directly or through third parties, includes:

• First Name, Last Name, Email Address, Postal Address (for physical card deliveries), Payment Details, Uploaded Images, Cookies, and Usage Data.

When Users register or purchase services, we collect their First Name, Last Name, Email Address, Postal Address (for delivery), and Payment Information (processed securely through Stripe). Uploaded images provided by Users for generating personalised gift cards are stored securely and processed solely for the purpose of providing our services.

We also collect usage data, including IP addresses, browser types, device details, referral sources, session durations, page interactions, and other technical details for analytics and security purposes.

Legal Basis of Processing

Pragmattic Ltd processes Personal Data under the following legal bases:

• Consent: Users provide explicit consent for specific purposes, such as non-essential cookies, marketing communications, and image uploads for gift card creation. Consent may be withdrawn anytime by emailing hello@pictocard.app.
• Contractual Obligations: Processing necessary to perform our service agreement, including delivering digital and printed gift cards.
• Legitimate Interests: Processing necessary for security, analytics, improving services, and defending or pursuing legal claims.
• Legal Compliance: Processing necessary for compliance with applicable UK and EU legal obligations.

Data Transfers

Data may be transferred outside the UK and EU/EEA to service providers and fulfillment partners. Such transfers rely on appropriate safeguards, including EU-US Data Privacy Framework, UK adequacy decisions, standard contractual clauses, or other measures compliant with UK and EU GDPR.

Retention of Data

Personal Data is retained as follows:

• Contract-related Data: Retained until services are fully delivered, plus a reasonable period for customer support.
• Uploaded Images: Stored securely until order completion, with temporary backups held securely for up to 60 days post-delivery.
• Financial transaction details: Retained securely for seven (7) years for legal accounting and tax purposes.
• Consent-based Data: Retained until consent is withdrawn.
• Legitimate interests: Data retained as necessary for security, analytics, and claims purposes, typically up to six (6) years.

Purpose of Data Processing

Data is collected to enable Pragmattic Ltd to:

• Provide personalised gift cards (digital and print).
• Process payments and manage orders.
• Improve user experience via analytics and user feedback tools.
• Enhance website security and fraud prevention.
• Communicate with Users regarding orders, marketing (with consent), and customer support.

Detailed Information on Data Sharing

Personal Data may be shared with:

• Secure payment providers (Stripe).
• Printing and fulfillment partners (e.g., Prodigi).
• Analytics and feedback services (Google Analytics for usage analytics, heatmaps, session recordings, performance analytics).
• Security and fraud prevention services.
• Customer support and email marketing tools.

User Rights Under GDPR

Users can exercise the following rights by emailing hello@pictocard.app:

• Withdraw Consent: Withdraw consent previously granted.
• Object to Processing: Object to Data processing for marketing or profiling purposes.
• Access: Obtain details of processed Personal Data and copies thereof.
• Rectification: Correct inaccurate or incomplete Personal Data.
• Restriction: Restrict processing under specific conditions.
• Deletion: Request erasure of Personal Data in certain cases.
• Portability: Receive Data in a machine-readable format and request its transfer to another provider.
• Complaint: Lodge a complaint with the UK's Information Commissioner's Office (ICO) via ico.org.uk.

Exercising Your Rights

Requests can be made to hello@pictocard.app and will be handled promptly, typically within one month and at no charge.

Changes to This Policy

Pragmattic Ltd reserves the right to update this Privacy Policy periodically. Users will be informed via email or notification on our website. Users are advised to regularly review this policy for any changes.

Contact Us

If you have any questions about this Privacy Policy, the Service, or your personal data, you may contact us at: