Cookie Policy — Pepper (pepperhq.com)

1. Who We Are

This Cookie Policy applies to Pepper HQ Ltd ("Pepper", "we", "us", "our"), the company behind PepperOS — the loyalty, ordering, payments, and marketing platform for UK hospitality operators.

Our website is pepperhq.com.

Our registered address is: 45 Gresham Street, London, England, EC2V 7BG

If you have any questions about this policy or how we use cookies, contact us at: privacy@pepperhq.com

2. What This Policy Covers

This policy explains:

• What cookies and similar tracking technologies are
• Which cookies we use on pepperhq.com
• Why we use them and what legal basis applies to each
• How to manage or withdraw your consent at any time
• How to submit a data protection complaint

This policy covers pepperhq.com only. It does not cover cookies set by Pepper's client-facing apps or platforms — those are governed by the relevant operator's own privacy and cookie policies.

3. The Legal Framework

We comply with the following legislation when using cookies and similar technologies:

• The Privacy and Electronic Communications Regulations 2003 (PECR), as amended
• The UK General Data Protection Regulation (UK GDPR)
• The Data Protection Act 2018 (DPA 2018)
• The Data (Use and Access) Act 2025 (DUAA), fully in force as of 19 June 2026

The DUAA amended PECR so that, alongside the existing consent and "strictly necessary" grounds, a limited set of lower-risk purposes can be used without consent where strict conditions are met. PECR now sets out five consent exceptions in total: (1) communication; (2) strictly necessary; (3) statistical/analytics; (4) appearance/functionality; and (5) emergency assistance. This policy reflects those changes. The ICO is the supervisory authority responsible for enforcing these rules in the UK. ico.org.uk

4. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They are used to make websites work correctly, remember your preferences, measure how the site is used, and — where you have consented — show you relevant advertising.

This policy also covers similar tracking technologies, including:

• Pixels and web beacons — tiny images embedded in pages or emails that register when they are loaded
• Local storage — browser-based storage used by some scripts and tools
• Session tokens — temporary identifiers used during a single browsing session
• Device fingerprinting — a technique that identifies devices based on browser and hardware characteristics, covered by PECR in the same way as cookies

5. Cookie Categories and
Legal Basis

We group the cookies used on pepperhq.com into five categories. The legal basis and consent requirement for each is set out below.

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6. How to Manage Your
Cookie Preferences

Using Our Consent Banner

When you first visit pepperhq.com, a cookie consent banner will appear. You can:

• Click "Accept all cookies" to allow all categories
• Click "Reject all" to switch off advertising and social networking cookies. We also use a limited set of analytics and functionality cookies to measure and improve the site; the law lets us set these without consent, but you can object to them at any time via [Cookie Preferences].
• Click "Manage preferences" to make individual choices by category

The "Reject all" and "Manage preferences" options are displayed as prominently as "Accept all" in our banner. We do not use design techniques that make it harder to reject cookies than to accept them.

Changing Your Preferences

You can update your consent choices at any time by clicking the "Cookie Settings" link in the footer of any page on pepperhq.com.

Your preferences are saved locally and will be honoured on your next visit. If you clear your browser cookies, you will be asked for your preferences again.

Browser-Level Controls

You can also manage cookies through your browser settings. The following links explain how to do this for the most common browsers:

• Google Chrome: support.google.com
• Mozilla Firefox: support.mozilla.org
• Safari: support.apple.com
• Microsoft Edge: support.microsoft.com

Note that disabling all cookies through your browser may affect the functionality of pepperhq.com and other websites.

Opting Out of Third-Party Advertising

You can opt out of interest-based advertising from our third-party advertising partners directly:

• Google: adssettings.google.com
• LinkedIn: linkedin.com
• Meta: facebook.com

7. Data Transfers Outside the UK

Some of the third-party tools listed in this policy (including Google, Meta, LinkedIn, and HubSpot) process data on servers located outside the UK, including in the United States. Where this occurs, Pepper ensures appropriate safeguards are in place, including UK International Data Transfer Agreements (IDTAs) or the UK Addendum to the EU Standard Contractual Clauses, in accordance with UK GDPR Chapter V.

8. How Long We Retain Cookie Data

The retention period for each cookie is set out in the tables in Section 5 above. Where a third-party provider sets the retention period (for example, Google, LinkedIn, or Meta), we have listed the duration as documented by that provider. You can find more detail in each provider's own privacy policy:

• Google: policies.google.com
• LinkedIn: linkedin.com
• Meta: facebook.com
• HubSpot: legal.hubspot.com

9. Data Protection Complaints

Under the Data (Use and Access) Act 2025, you have the right to submit a data protection complaint to us electronically. We are required to acknowledge your complaint within 30 days.

To submit a data protection complaint:

Please complete the form below or email us at privacy@pepperhq.com with the subject line "Data Protection Complaint."

Your complaint should include:

• Your full name
• Your email address
• A description of your concern
• The date the issue occurred (if known)

We aim to respond substantively within 30 days of acknowledgement. If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Phone: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

10. Changes to This Policy

We review this policy whenever our cookie practices change or when there is a relevant change in UK data protection law. The "Last updated" date at the top of this page will always reflect the most recent version.

Where changes are material — for example, if we add a new marketing cookie or change our consent management platform — we will display a notice on pepperhq.com and, where appropriate, re-request your consent.

11. Contact Us

Data Controller: Pepper HQ Ltd Website: pepperhq.com Email: privacy@pepperhq.com Address: 45 Gresham Street, London, England, EC2V 7BG

If you have a question about this policy that is not a formal complaint, you can also contact us via the live chat on pepperhq.com.

This policy was prepared in accordance with the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (as amended), and the Data (Use and Access) Act 2025, fully in force as of 19 June 2026.

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Cookies

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What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, PepperHQ) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

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Why do we use cookies?

PepperHQ utilises first and third party cookies for many reasons. Most cookies are required for technical reasons in order for our website to operate, and these are essential or strictly necessary cookies. Other cookies enable us to track and target the interests of our users to enhance the experience on our website. Third parties serve cookies through our website for advertising, analytics and other purposes. This is described in more detail below.

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Disabling cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser's 'Help' for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.

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Required 'first party cookies'

• Served by pepperhq.com and webflow.io

How to refuse:
Because these cookies are strictly necessary to deliver our website to you, you cannot refuse them. You may block or delete them by changing your browser settings.

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Additional Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

• PepperHQ uses Google Analytics, which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, click here.
• PepperHQ also uses Geotargetly to ensure you are redirected to and shown the best content for your region. For more information on Geotargetly's cookies, click here.
• From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
• As we sell products it's important for us to understand statistics about how many of the visitors to our site actually make a purchase and as such this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price.

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More Information

If you are still looking for more information then you can contact us via email at info@pepperhq.com