Tropicalwarehouse.co.uk collects some Personal Data from its Users.
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Data Protection Manager, Blue Bay Travel Ltd., Unit A4 Bellringer Road, Trentham Business Quarter, Stoke-on-Trent, England (UK), ST4 8GB
Owner contact email: gdpr@bluebaytravel.co.uk
Among the types of Personal Data that tropicalwarehouse.co.uk collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; phone number; Data communicated while using the service; city; ZIP/Postal code; state; province; country; county; latitude (of city); longitude (of city); metro area; geography/region; IP address; device information; app information; device logs; operating systems; browser information; language; launches; number of sessions; session duration; scroll-to-page interactions; mouse movements; scroll position; keypress events; motion sensor events; touch events; video views; clicks; browsing history; search history; session statistics; page views; interaction events; page events; custom events; Application opens; number of Users; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using tropicalwarehouse.co.uk.
Unless specified otherwise, all Data requested by tropicalwarehouse.co.uk is mandatory and failure to provide this Data may make it impossible for tropicalwarehouse.co.uk to provide its services. In cases where tropicalwarehouse.co.uk specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by tropicalwarehouse.co.uk or by the owners of third-party services used by tropicalwarehouse.co.uk serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through tropicalwarehouse.co.uk.
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of tropicalwarehouse.co.uk (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Infrastructure monitoring, Traffic optimization and distribution, Hosting and backend infrastructure, Remarketing and behavioral targeting, Analytics, Advertising, Heat mapping and session recording, Contacting the User, Managing contacts and sending messages, Displaying content from external platforms, Tag Management, Content performance and features testing (A/B testing), Interaction with live chat platforms, Interaction with support and feedback platforms, Managing data collection and online surveys, Spam and bots protection, Registration and authentication provided directly by tropicalwarehouse.co.uk, Content commenting, Interaction with external social networks and platforms, Managing support and contact requests and Platform services and hosting.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Personal Data is collected for the following purposes and using the following services:
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on tropicalwarehouse.co.uk, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on tropicalwarehouse.co.uk.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Google AdSense is an advertising service provided by Google LLC. This service uses the “DoubleClick” Cookie, which tracks use of tropicalwarehouse.co.uk and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
In order to understand Google's use of data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta Audience Network with actions performed on tropicalwarehouse.co.uk. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Microsoft Advertising Universal Event Tracking is an analytics service provided by Microsoft Corporation that connects data from the Microsoft Advertising network with actions performed on tropicalwarehouse.co.uk.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Microsoft Advertising is an advertising service provided by Microsoft Corporation.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of tropicalwarehouse.co.uk, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of tropicalwarehouse.co.uk, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Quantcast Measure is an analytics service provided by Quantcast Corporation.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Cloudflare Web Analytics is an anonymized analytics service provided by Cloudflare, Inc. that gives the Owner insight into the use of tropicalwarehouse.co.uk by Users without needing to identify them. Further information may be found here and within the service's privacy policy.
Personal Data processed: device information; language; Usage Data.
Place of processing: United States – Privacy Policy.
Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of tropicalwarehouse.co.uk, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics on tropicalwarehouse.co.uk has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for tropicalwarehouse.co.uk (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics on tropicalwarehouse.co.uk has granular data collection activated which collects location and device data on a per-region basis. It allows the Owner to create and analyze User reports that rely on those metrics.
Personal Data processed: browser information; city; device information; number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning tropicalwarehouse.co.uk. Your email address might also be added to this list as a result of signing up to tropicalwarehouse.co.uk or after making a purchase.
Personal Data processed: email address; first name; last name; Usage Data.
Users that provided their phone number might be contacted for commercial or promotional purposes related to tropicalwarehouse.co.uk, as well as for fulfilling support requests.
Personal Data processed: phone number.
Content commenting services allow Users to make and publish their comments on the contents of tropicalwarehouse.co.uk.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Facebook Comments is a content commenting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of tropicalwarehouse.co.uk.
Google Optimize is an A/B testing service provided by Google LLC ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
This type of service allows you to view content hosted on external platforms directly from the pages of tropicalwarehouse.co.uk and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Adobe Fonts is a typeface visualization service provided by Adobe Systems Incorporated that allows tropicalwarehouse.co.uk to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows tropicalwarehouse.co.uk to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
This type of service has the purpose of hosting Data and files that enable tropicalwarehouse.co.uk to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of tropicalwarehouse.co.uk. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Cloudinary is a hosting service provided by Cloudinary Ltd.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Israel – Privacy Policy.
DigitalOcean is a hosting service provided by DigitalOcean Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United Kingdom – Privacy Policy.
Google BigQuery is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google App Engine is a hosting service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United Kingdom – Privacy Policy.
Algolia is a hosting and backend service provided by Algolia SAS.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: France – Privacy Policy.
This type of service allows tropicalwarehouse.co.uk to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of tropicalwarehouse.co.uk.
Bugsnag is a monitoring service provided by Bugsnag Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Turkey – Privacy Policy.
This type of service allows interaction with social networks or other external platforms directly from the pages of tropicalwarehouse.co.uk.
The interaction and information obtained through tropicalwarehouse.co.uk are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on tropicalwarehouse.co.uk isn’t being connected back to the User’s profile.
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing,
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
The X Post button and social widgets are services allowing interaction with the X social network provided by X Corp.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
This type of service allows Users to interact with third-party live chat platforms directly from the pages of tropicalwarehouse.co.uk, for contacting and being contacted by tropicalwarehouse.co.uk support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
The Crisp Widget is a service for interacting with the Crisp live chat platform provided by Crisp IM SARL.
Personal Data processed: Cookies; Data communicated while using the service; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: France – Privacy Policy.
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of tropicalwarehouse.co.uk.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
https://uk.legal.trustpilot.com/for-reviewers/end-user-privacy-terms
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When you write a review on Trustpilot or otherwise use our Website, we collect and process personal data about you. This document helps you understand what personal data we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.
When we talk about “Trustpilot,” “we,” “us” or “our,” we mean Trustpilot A/S and our affiliates. We also use “Policy” to refer to this Privacy Policy and “Website” to refer to our applications and all of Trustpilot’s websites, like uk.trustpilot.com, dk.trustpilot.com, de.trustpilot.com etc.
Trustpilot A/S is the entity responsible for processing your personal data.
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1. Personal data - what we collect and what we use it for
1.1 Master data
When you create a profile or write your first review on the Website, we will automatically generate a personal account for you on Trustpilot (“Account”) and collect the following personal data about you (the “Master Data”):
Your username (this will be public),
Your securely encrypted password,
Your email address, and
Your location and country.
This information is mandatory, which means that it will not be possible to write a review on the Website without it.
You can choose to add further personal data to your profile. The additional data you can add is your name, a profile description, photo, gender, city, and language. This additional information will be part of your public profile and will also be part of the Master Data.
Trustpilot is an open review platform and when we display your review we will connect it to your profile so that people can see who wrote the review. Therefore, please be aware that depending on the information you add to your profile and the username you choose, you may or may not be anonymous.
1.2 Information in reviews and ratings
When you write a review about a company, we collect the information you put in your review. This includes:
Which company you review
The type of buying or service experience your review concerns (see the definition of “Service Experience” and “Product” in our User Guidelines
The headline and content of your review
The location of your Service Experience
Your rating of your Service Experience with the company (1-5 stars)
Your rating of the Product (1-5 stars)
The date of your review and, if you update your review, the date on which it is edited
A reference number or order ID (if you or the company provides one)
If we ask you to provide information or documentation verifying your Service Experience and you send us such documentation, we will collect and process the documentation for the purpose(s) stated in the request.
Please don’t share any sensitive personal documents or information with us, either concerning yourself or others.
1.3 Information about views, likes and how useful your review is for others
When you write a review on our Website, people can show that they find your review useful, for example by “liking it”, and we collect this information. We also collect information about how many people read your review. We don’t track the identities of people who aren’t logged in and read the reviews, but we do collect data on the number of consumers who read your review. If you “like” another person’s review we will also collect that information.
1.4 Notifications
If you notify us about a review that you believe violates our User Guidelines, then we collect the information you provide in your notification to us. This can include which review you notified us about, the reason for your notification, the date of your notification, etc.
1.5 Information from other services, including social networks like Facebook
You can connect your Trustpilot profile with your profile on social networks, e.g. Facebook, and Google+ (“Social Network(s)”). When you use this option we automatically collect selected information about you from your Social Networks. The information we collect depends on what information you have made available on those Social Networks and your privacy settings for sharing such information on the Social Networks. Depending on your settings and selection, we will collect the following information:
Name and/or username
Email address
Profile photo
Who your social connections are
When you make a request to connect your Trustpilot profile with a Social Network profile, you will be informed about which information we will collect from the Social Network in question. You will receive this information before your request is carried out.
You can choose to disconnect your Social Network profile from your Trustpilot profile via your Account. At this point, Trustpilot will remove your Social Network unique ID, and disconnect/revoke Trustpilot from your Social Network. Your profile picture from your Social Network profile will remain on your Trustpilot profile.
1.6 Cookies
Our Website uses cookies. Cookies identify your computer or device rather than you as an individual user, and are used for different purposes.
Read more about which cookies the Website uses and for which purposes below (in 8).
1.7 Your IP address, browser settings and location
When you visit the Website, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the Website. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the Website. We also use the IP address to approximate your location (at city level) and so that we know which sets of our Terms & Conditions apply to your use of our Website.
1.8 Newsletters and digest emails
We collect the information you provide us with when you subscribe to receive our newsletters, digest emails or similar (we collect your name, email address and newsletter preferences). If you no longer wish to receive our newsletters, digest emails or similar, you can unsubscribe by logging into your Account and changing your email settings or you can contact us at privacy@trustpilot.com.
1.9 For what purposes do we use your personal data?
We will use the information you provide to us to:
Provide our services to you, including displaying your reviews, and providing you with access to your profile and our Website
Identify you as a registered user when you log in to the Website and re-visit the Website
Verify the legitimacy of your reviews
Improve the Website and our services
Invite you to leave more reviews
Respond to your questions and provide related customer service
Pass on a message from the company you reviewed or the company that has invited you to review a Product via the Website
Contact you if your review is flagged by other users or companies and, if necessary, ask you to provide documentation to verify your review or experience
Send you our newsletters
Inform you when other users find your review helpful or otherwise provide feedback concerning your review
Facilitate the social sharing function, including giving you the option to connect with members of your network who are both users of Trustpilot and users of one or more Social Networks
Display which members of your Social Networks are users of Trustpilot in order to increase confidence in reviews and to create a better user experience on our Website
Engage in various internal business purposes, i.e data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying the Website, or our services including our TrustBoxes, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities
Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies
Enforce our Terms & Conditions
Protect our operations or those of any of our affiliates
Protect our rights, privacy, safety or property and/or that of our affiliates, you or others
Allow us to pursue available remedies or limit any damages that we sustain
We will also use the information in other ways for which we provide specific notice at the time of collection.
1.10 On what legal basis do we process your personal data?
We need to process your personal data in order to:
Perform our contract with you (see Article 6.1.b of the GDPR)
Comply with our legal obligations (see Article 6.1.c of the GDPR) and operate an online review platform in compliance with, for example, the Unfair Commercial Practices Directive, ICPEN’s guidelines on online reviews and endorsements, The Consumer Protection from Unfair Trading Regulations 2008, The Competition and Markets Authority’s guidance on online reviews and endorsements, the Danish Consumer Ombudsman’s Guidelines on publication of user reviews, the Danish Marketing Practices Act etc.
Pursue legitimate business interests of our own related to operating the Website and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).
For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)
Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal data.
In those limited circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), for example, when subscribing to our newsletters, you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.
You have the right to object to how we process your personal data, or ask us to restrict the processing. Please see below, at 13, for more details.
If you would like more information about our legal basis for processing your personal data, please contact our Data Protection Officer (DPO) - see 14, below.
2. Disclosure of personal data
2.1 Disclosure of personal data on the Website
We are an open review platform and we share your review on our Website so that others can read about your experience with a specific company. When you write a review, we will disclose your review, your username, your location and country and other information you have chosen to connect with your public profile. Remember that if you have selected to use your name as your username, this can reveal your identity in full or in part - unless you use a pseudonym.
We recommend that you exercise care in deciding which information to make available for disclosing on the Website and be aware that depending on the level of information provided, you may or may not be anonymous.
Master Data and other information
When you write a review on our Website and create an Account, your username, review, photo, location and the number of reviews you have written will be visible on the Website. The companies you review can also receive information about your review.
Geo-location
When you write a review on the Website, we use your computer’s IP address (see 1.7 of this Policy, above) to approximate your location to the nearest city. This information is made available to other users of the Website.
Reviews you found useful
When you find other reviews useful (by “liking” them), other users of our Website can see the review(s) you “liked”.
Social Networks
If you connect to a Social Network, information such as your profile photo, your name, birth year and approximate location will be collected from your Social Network profile and used to identify you on the Website. Subject to your privacy settings and the level of information available from the Social Network, users of the Website can use this information to identify which reviews you have written.
If you have chosen to preserve anonymity by using a pseudonym for your Trustpilot username, be aware that information from Social Network(s) can reveal your identity in part or in full and make it possible to identify which reviews you have written.
If your contacts or friends (referred to as “Connections”) on the Social Network have also connected with Trustpilot, we display on the Website how you are connected to these Connections through the Social Network. This is only visible to you. Other people on Trustpilot cannot see your Connections from Social Networks.
2.2 Disclosure on services to which you connect your profile
If you choose to connect your Trustpilot profile with your profile on a Social Network, information and reviews provided by you on the Website or data compiled by us about your use of the service on the Website (e.g. the number of reviews you have written) will be shared with and displayed in connection with your profile on the Social Network and will be subject to the privacy policy of the Social Network.
2.3 Disclosure to other services, websites and companies
One of Trustpilot's main goals is to increase the exposure and availability of reviews on the Website. We therefore permit other services to show reviews created on the Website. This increases the potential audience for your reviews.
The categories of third party services and companies who can show your review(s) together with your public user profile are:
Search engines, including Google and Bing
Companies reviewed on Trustpilot
Companies that have invited you to review a Product
Consumer portals and business portals, including price comparison websites, shopping guides, etc.
Application partners and platforms, such as Prestashop, Magento, Shopify, WooCommerce
Other similar websites where, in Trustpilot’s assessment, it will be relevant for users to search for reviews.
Facebook “If your review has been shared on the Social Network”
Once you submit your review, it is published on the Website. This means that the following information is disclosed:
Your review(s), (see 1.2, above)
Your username and the additional data you choose to add to your profile, such as your name, a profile description, photo, gender, city, location, country, and language.
If you write a review on Trustpilot in response to an invitation sent by a company via our review invitation services, the company who sent you the invite will be able to link your review with the invitation.
If we need to verify your review, we will contact you and ask for documentation that shows that you have had a buying or service experience with the company you reviewed. We therefore recommend that you keep such documentation for 12 months from the date of your review. We explain the type of documentation you should send us here.
We do not share the documentation you send to us with the reviewed company. However, if you have a reference number or order ID, we may pass that on to the company, unless you ask us not to.
2.4 Other disclosures
In addition to the above, we disclose your personal data to the following parties and in the following circumstances:
To allow third party vendors, consultants and other service providers to perform services on our behalf
To Trustpilot subsidiaries and other companies within the Trustpilot group of companies
To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities
To cooperate with regulatory bodies and government authorities, including but not limited to Trading Standards, the Competition and Markets Authority, relevant data protection authorities and the Danish Consumer Ombudsman, in connection with investigations or case referrals
To third parties in connection with enforcement of our Terms & Conditions and Guidelines
To third parties in order for us to protect our operations or those of our affiliates
To third parties in order for us to pursue available remedies, or limit damages that we may sustain
To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our Website
To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).
3. Data controller
3.1 Information for which we are the data controller
We are the data controller of the Master Data you enter to create and maintain your profile, which includes but is not limited to your name, password, email address and location, as well as the registration of your IP address.
We are also the data controller of the information which is disclosed to other services (see 2.3). Denmark’s data protection laws govern our collection of your data.
3.2 Information for which you are the data controller
You are the data controller for the content you choose to disclose on the Website, and for the personal data disclosed when you connect your Social Network profile(s) with your profile on the Website.
4. Links to websites
Our Website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third party websites, and assume no responsibility for the third party or their policies or practices.
We encourage you to review the privacy policies for these third party websites because their procedures for collecting, handling and processing personal data will be different from ours.
5. Data processors and transfer of personal data outside the EU
We use external companies to maintain the technical operation of the Website and our services. These companies are data processors for the personal data for which we are the data controller. By accepting this Policy, you agree that we may also allow the data for which you are the data controller to be processed by these data processors.
We have data processing agreements in place with the data processors and it follows from these agreements that they must act solely in accordance with our instructions. By accepting this Policy, you authorize us to instruct the data processors to process data in accordance with the Policy and for the purposes of using the Website.
The data processors have taken reasonable technical and organizational measures to protect against the information being accidentally or illegally destroyed, becoming lost or deteriorating, and to protect against the information being disclosed to unauthorized persons, being misused, or in other ways being processed in violation of data protection laws.
On your request – and possibly in return for remuneration at the data processors' applicable hourly rates at any time for such work – the data processors must supply you with sufficient information to demonstrate that the above-mentioned technical and organizational safety measures have been taken.
Some of these data processors and third party services are located outside of the European Union, such as in the US. You consent to us using data processors in unsecure third countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework.
6. Data retention
We keep the Master Data and other personal data you provide, including your reviews, for as long as you have an Account or as needed to provide you with our services. If you choose to delete your Account please note that all your reviews will also be deleted. We will delete this information upon your request and we will only save a log with the following information: your name, email address and the date of the deletion of your Account. We will keep the log for 3 years. All other information will be deleted.
If you only use our Website for searching for reviewed companies, we will retain your information and keep your Account open until you decide to close your Account. In some cases, even if you close your account, we then choose to retain certain information (e.g. visits to our Website) in an anonymized or aggregated form.
7. Security measures
We use reasonable organizational, technical and administrative measures to protect your personal data within our organization and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via the Website may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.
To learn more about our current practices and policies regarding security and other information, please see our security practices. We are always working to improve our security practices and we will update this information as these practices evolve over time.
8. Cookies
The Website uses cookies and similar technologies (“Cookies”). By using our Website, you accept that we use Cookies as described below.
8.1 What types of Cookies do we use?
Cookies are small pieces of information that the Website places on your computer's hard disk, on your tablet or on your smartphone. Note that HTML5 introduced Web Storage that has a similar nature to Cookies, and that we therefore consider that as a Cookie in the following.
Cookies contain information that the Website uses to make the communication between you and your web browser more efficient. Cookies identify your computer or device rather than you as an individual user.
We use session cookies, persistent cookies, HTML5 sessionStorage and HTML5 localStorage session cookies and HTML5 sessionStorage objects are temporary in nature and are deleted when you exit your web browser. Persistent cookies are permanent in nature and are stored and remain on your computer until they are deleted. Persistent cookies expire or auto delete after a certain period of time, which is set per cookie, but are renewed each time you visit the Website. HTML5 localStorage objects are permanent in nature and remain on your computer until they are deleted.
8.2 What do we use Cookies for?
We use Cookies for:
Generating statistics
Measuring Website traffic such as the number of visits to the Website, which domains the visitors come from, which pages they visit on the Website and in which overall geographical areas the visitors are located.
Monitoring Website performance and your use of our Website
Monitoring the performance of the Website, our applications and TrustBoxes and how you use our Website, applications and TrustBoxes.
Authentication and improving the functionality of our Website
Optimizing your experience with the Website, which includes remembering your username and password when you return to the Website and remembering information about your browser and preferences (e.g. which language you prefer).
Connecting you to Social Networks
We give you the option of connecting with Social Networks, such as Facebook.
Quality assurance
Ensuring the quality of reviews and to prevent misuse or irregularities in connection with writing reviews and using the Website.
Targeted advertisements
Displaying relevant advertisements on the Website, including interest-based advertisements, which we believe are of interest to you. We use third parties to provide these advertisements when you visit the Website and other websites. These third parties may use Cookies alone or in conjunction with web beacons or other tracking technologies to collect information about your use of our Website and other websites.
8.3 Third party Cookies
Third party Cookies are set by third party websites – not our Website. When you visit our Website, the following third party Cookies may be set:
Facebook cookies, set when you log in to our Website with Facebook
Google cookies, set when you log in to our Website with Google
Google AdSense cookies, set when displaying relevant targeted advertisements on our Website. Some cookies may be set as DoubleClick, which is part of Google
Hotjar localStorage, set for managing how and when surveys are displayed. Read more here.
8.4 Deletion of cookies
You can delete the cookies already on your device. You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu in the browser. In most browsers, the same menu can be reached through the Ctrl+Shift+Del keyboard shortcut or Command+Shift+Del if you're on a Mac.
If you do not accept Cookies from our Website, you may experience inconvenience in your use of the Website, and you may be prevented from accessing some of its features.
9. Access and insights into the personal data we have about you
If you have an Account on Trustpilot, you can log in to your Account and see what information we have about you, including your reviews, and why we have that information. You can read more about how to here.
If you don’t have an Account, you can email privacy@trustpilot.com and request information about your personal data. Upon receiving your request, we will let you know what personal data we have about you, how we collect the information, the purpose for which we process your personal data, and who we share your personal data with.
10. Download your personal data (data portability)
If you have a user profile on Trustpilot, you can download the personal data that you have provided to us, including your reviews. You can read more about how to download your personal data here.
11. Correction and deletion of your personal data
If any of the Master Data or other personal data that we have about you in our capacity as a data controller is incorrect or misleading, you can correct most of the information yourself via your Account. We recommend that you make any the correction(s) yourself. Otherwise, you are welcome to ask us to assist with correcting your information.
You may at any time correct or delete any content and personal data on the Website for which you are the data controller (see 3.2). If your personal data changes, or if you no longer wish to appear on the Website, you can update or delete the information by logging in to your Account.
If your Account is deleted, all the data associated with your Account will be deleted, including your Master Data and reviews on the Website.
We reserve the right to block access to your Account and/or delete it if the Account or the content associated with your Account or your review(s) on the Website is, in our assessment, discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or otherwise violates applicable laws, third party rights or our User Guidelines, or is inconsistent with the purpose of the Website. If we block access to or delete your Account, we will inform you of the reason for blocking or deleting your Account by sending an email to the address you provided when you created your Account.
12. Other rights
In addition to the rights set out above concerning your personal data, you also have the following rights:
You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
If our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us at privacy@trustpilot.com.
In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.
13. Children’s information
Our Website is not intended for children. If you become aware that a child under the age of 18 has provided us with their personal data, please contact us.
14. Our Data Protection Officer
We have a Data Protection Officer (DPO). If you have any questions about the data processing activities performed by us, you are welcome to contact our DPO by email at: privacy@trustpilot.com.
15. Changes to this Policy
We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our Website, or by other means, to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your Account. Your continued use of our Website after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.
16. Contact information and where to send questions or complaints
If you have questions or concerns about our Policy, how we process your personal data, or would like us to correct your personal data, feel free to contact us at: privacy@trustpilot.com.
You can also reach us by post.
If contacting us does not resolve your complaint, you have further options, for example you may always lodge a complaint with a data protection supervisory authority, e.g. The Danish Data Protection Agency. You can read more about it here.
Our contact details are:
Trustpilot A/S,
Pilestraede 58, 5th floor, 1112 Copenhagen, Denmark
CVR no.: 30276582
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
SparkPost is an email address management and message sending service provided by Message Systems, Inc.
Personal Data processed: email address; various types of Data as specified in the privacy policy of the service.
Place of processing: United Kingdom – Privacy Policy.
Emarsys Email Marketing is an email address management and message-sending service provided by SAP Emarsys eMarketing Systems GmbH or by Emarsys North America, Inc., depending on how the Owner manages the Data processing.
Personal Data processed: email address; first name; last name; Trackers; Usage Data.
Place of processing: Austria – Privacy Policy; United States – Privacy Policy.
This type of service allows tropicalwarehouse.co.uk to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Typeform is a form builder and data collection platform provided by TYPEFORM S.L.
Personal Data processed: email address; first name; last name; phone number.
Place of processing: Spain – Privacy Policy.
This type of service allows tropicalwarehouse.co.uk to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Freshdesk is a support and contact request management service provided by Freshworks, Inc.
Personal Data processed: Data communicated while using the service; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
These services have the purpose of hosting and running key components of tropicalwarehouse.co.uk, therefore allowing the provision of tropicalwarehouse.co.uk from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
WordPress.com is a platform provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing, that allows the Owner to build, run and host tropicalwarehouse.co.uk.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
By registering or authenticating, Users allow tropicalwarehouse.co.uk to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
The User registers by filling out the registration form and providing the Personal Data directly to tropicalwarehouse.co.uk.
Personal Data processed: email address.
This type of service allows tropicalwarehouse.co.uk and its partners to inform, optimize and serve advertising based on past use of tropicalwarehouse.co.uk by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of tropicalwarehouse.co.uk with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of tropicalwarehouse.co.uk with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Tropicalwarehouse.co.uk uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from tropicalwarehouse.co.uk with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors.
If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
This type of service analyzes the traffic of tropicalwarehouse.co.uk, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.
Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.
Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
This type of service helps the Owner to manage the tags or scripts needed on tropicalwarehouse.co.uk in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
This type of service allows tropicalwarehouse.co.uk to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between tropicalwarehouse.co.uk and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through tropicalwarehouse.co.uk, i.e., communication between tropicalwarehouse.co.uk and the User's browser, while also allowing analytical data from tropicalwarehouse.co.uk to be collected.
Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
jsDelivr CDN is a traffic optimization and distribution service provided by Prospect One Sp. z o.o. sp. k.
Personal Data processed: Usage Data.
Place of processing: Poland – Privacy Policy.
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
OUR PRIVACY POLICY
Infinity Tracking Limited (“Infinity”) is committed to protecting your personal data. This privacy policy will inform you how we look after your personal data we collect from you when you visit our website (regardless of where you visit it from), or that you provide to us and will tell you about your privacy rights and how the law protects you. By visiting our website, you are accepting and consenting to the practices described in this policy.
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, contact us, purchase a product or service or any other interaction etc.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any such other notices and is not intended to override them.
Infinity is the data controller of the personal information that we hold about you. Infinity complies with the requirements of the law and is registered with the Information Commissioner's Office.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Full name of legal entity: Infinity Tracking Limited
Name or title of person to contact: Data Protection Officer
Email address: legal@infinity.co
Telephone number: 0808 2502 999
Postal address: London Court, 39 London Road, Reigate, Surrey, RH2 9AQ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) (this includes information relating to your name, email address, or other identifiers relating to you such as cookies).
This policy explains how we collect, use and store the personal information you provide to us when you use our service or website. We will only use personal in accordance with the content of this policy, as amended from time to time.
WHAT WE COLLECT
We will collect and process the following data about you:
Information you give us:
This is information about you that you give us when you create an account, complete forms on our website or correspond with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our services and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial or credit card information etc.
Information we collect about you:
We automatically collect certain information when you use our website and services. In order to manage the service Infinity stores, maintains and processes information relating to your service and account, including:
Retaining information about your contract and other information relating to your account;
Call activity information including: call duration, inbound caller line identification (i.e. the phone number calling you), call forwarding information,
call data/time and duration, and other information required to generate calling reports for your records and our billing purposes;
Recording calls and retaining the call recording unless you request us to disable call recording; and,
We also record information when you use our website relating to:
Technical information: including the Internet protocol (IP) address used to connect your computer to the Internet, your login information and browser
type and version;
Information about your visit: including account activity, clickstream to, through and from our site (including date and time) and login information;
Identity Data includes first name, last name, username or similar identifier, title;
Contact Data includes billing address, email address and telephone numbers;
Financial Data includes bank account and payment card details;
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey
responses;
Usage Data includes information about how you use our website, products and services;
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication
preferences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Apply for our products or services;
Create an account on our website;
Subscribe to our service or publications;
Request marketing to be sent to you;
Enter a competition, promotion or survey; or o give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties: analytics providers such as Google based outside the EU; advertising networks; and search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
WHAT WE DO WITH THE INFORMATION WE GATHER
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Information you give to us - we will use this information:
Where we need to perform the contract we are about to enter into or have entered into with you and to provide you with the information and services that you request from us;
To respond to an inquiry or support matter initiated by you;
Depending on your marketing preferences, we may provide you with information about other services we offer that are similar to those
that you have already purchased or enquired about;
To notify you (in accordance with your marketing preferences) about notifications, updates or changes to your service or account; or o to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect. We will use this information:
To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey
purposes;
To improve our site to ensure that content is presented in the most effective manner for you and for your computer; o to allow you to participate in interactive features of our service, when you choose to do so; or
As part of our efforts to keep our site safe and secure.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity: To register you as a new customer
Type of data: (a) Identity (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
Purpose/Activity: To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
Purpose/Activity: To register you as a new customer
Type of data: (a) Identity (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
Purpose/Activity: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey
Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity (b) Contact (c) Technical
Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data: (a) Technical (b) Usage
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/Activity: TTo make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any company outside the Infinity group of companies for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
HOW WE USE COOKIES
Our website uses cookies to distinguish you from other users of our website and to improve your experience on the website. In this section of the policy you will find out what cookies are, how we use them and how you can switch them off.
However, for the best experience on our website, we would recommend that you enable cookies in your web browser as disabling our cookies may mean that not all the functions on the website can work properly.
What is a cookie?
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. By continuing to browse this site, you are agreeing to our use of cookies.
What cookies do we use?
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
How to control or delete cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, for the best experience on our website, we would recommend that you enable cookies in your web browser as disabling our cookies may mean that not all the functions on the website can work properly.
DISCLOSURE OF YOUR INFORMATION
We may have to share your personal data if one of these situations occur:
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to comply with our regulatory obligations. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Infinity or a substantial part of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We require all third parties to respect the security of your personal data
INTERNATIONAL TRANSFERS
We share your personal data within the Infinity group. This will involve transferring your data outside the European Economic Area (EEA).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
SECURITY
We are committed to ensuring that your information is secure. To prevent your personal data from being accidentally lost, used or accessed in unauthorised way, altered or disclosed, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We will also notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
CHANGES TO PRIVACY POLICY
This version was last updated on May 1st, 2018 and historic versions can be obtained by contacting us.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
YOUR LEGAL RIGHTS
Under certain circumstances, you will have rights under data protection laws in relation to your personal data.
For example, you have rights to:
Request access to your personal data;
Request correction of your personal data;
Request erasure of your personal data;
Object to processing of your personal data;
Request restriction of processing your personal data;
Request transfer of your personal data; and
Withdraw consent
If you wish to exercise any of the rights, please contact us at London Court, 39 London Road, Reigate, Surrey, RH2 9AQ, UK or legal@infinity.co
If you would like a copy of the information held please write to us at the above address.
If you also believe that any information we are holding is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
Response IQ Ltd Privacy Policy
Last updated: April 24, 2018
https://responseiq.com/ website (the “Website”) is operated by Response IQ Ltd, company registration number 09951115 and the registered office of which is at Response IQ LTD, 124 City Road, London, EC1V 2NX (“We”, “Us” or “ResponseIQ”).
We take your privacy very seriously and we ask that you read this Privacy Policy carefully as it contains important information on:
- the personal information we collect about you,
- what we do with your information, and
- who your information might be shared with.
Who we are
ResponseIQ are a “data controller” for the purposes of the General Data Protection Regulation EU 2016/679 (the “GDPR”), (i.e. we are responsible for, and control the processing of, your personal information).
What information we collect?
Personal information provided by you
We may collect personal information about you (such as your name, address, telephone number, payment card details etc.) when you use our Website, register with us or purchase services from us. We may also collect personal information when you contact us, send us feedback or post material to the Website.
We may also collect information that your browser sends us whenever you visit our Website. This data may include information such as your computer’s IP address, browser type, browser version, the pages of our Website that you visit and other statistics relating to your use of the Website. This information may be collected in conjunction with third party services such as Google Analytics.
Personal information provided by third parties
The nature of the Services we offer means that we may receive information about you from a third-party source, such as one of our clients. We will only accept that information if we have evidence that you have consented for the personal information to be passed to us or it is passed pursuant to another legal basis under the GDPR.
Personal information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his/her personal data;
- receive on his/her behalf any data protection notices; and
- give consent to the transfer of his/her personal data abroad.
Sensitive personal information
It is very unlikely that we will ask you to provide sensitive personal information. If we request such information, we will explain why we are requesting it and how we intend to use it.
Sensitive personal information includes information relating to your ethnic origin, your political opinions, your religious beliefs, whether you belong to a trade union, your physical or mental health or condition, your sexual life, and whether you have committed a criminal offence.
We will only collect your sensitive personal information with your explicit consent.
Monitoring and recording communications
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of performing the Services we offer to our clients, quality assurance, training, fraud prevention and regulatory compliance.
Sensitive personal information
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our Website. We use cookies on this Website to:
- keep track of any services you may wish to purchase;
- recognise you whenever you visit this Website (this speeds up your access to the Website as you do not have to log in each time);
- obtain information about your preferences, online movements and use of the internet;
- carry out research and statistical analysis to help improve our content and services and to help us better understand our visitor and customer requirements and interests;
- target our marketing and advertising campaigns more effectively by providing interest-based advertisements that are personalised to your interests; and
- make your online experience more efficient and enjoyable.
The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you—but only where you voluntarily provide it (e.g. by completing an online form) or where you purchase services from us.
In most cases we will need your consent in order to use cookies on this Website. The exception is where the cookie is essential in order for us to provide you with a service you have requested (e.g. to enable you to purchase services from us).
There is a notice on our home page which describes how we use cookies and which also provides a link to this Privacy Policy. If you use our Website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this Privacy Policy.
We may work with third party suppliers who may also set cookies on our Website. These third-party suppliers are responsible for the cookies they set on our Website. If you want further information, please go to the website of the relevant third party.
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this Website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.
How will we use the information about you?
We collect information about you so that we can:
- identify you and manage any accounts you hold with us;
- process your order or carry out obligations arising from any contract(s) entered into between you and us;
- conduct research, statistical analysis and behavioural analysis;
- carry out customer profiling and analyse your purchasing preferences;
- if you agree, let you know about other products or services that may be of interest to you—see ‘Marketing’ section below;
detect and prevent fraud;
- customise our Website and its content to your particular preferences;
- notify you of any changes to our Website or to our services that may affect you;
- carry out security vetting; and
- improve our services and notify you about changes to these services.
Marketing
Only where you have provided us with specific, informed and unambiguous consent shall we provide you with marketing materials by the mechanism(s) you have consented to (e.g. email). We will only provide you with marketing materials relating to features that you have explicitly consented to.
If you have consented to such receive marketing from us, you can opt out at any time. See ‘What rights do you have?’ below for further information.
Who your information might be shared with
We may disclose your personal data to:
- our clients as part of the service offered, but only with your explicit consent or pursuant to another legal basis under the GDPR;
- our service providers pursuant to strict data processing agreements that protect your personal data to the same or higher standards than we treat it;
- law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
a court of law or regulator where we are under a duty to disclose or share your personal data in order to comply with a legal or regulatory obligation.
Rest assured that we will never pass your information to a third party outside of the categories above without your explicit consent.
Keeping your data secure
We will use technical and organisational measures to safeguard your personal data, for example:
- access to your account is controlled by a password and username that are unique to you;
- we store your personal data on secure servers; and
- payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How can you contact us?’ below).
Our Website may contain links to other websites of our partners, suppliers, advertisers or other approved third parties. If you follow a link to any of these websites, please note that these websites have (or should have) their own privacy policies. We do not accept any responsibility or liability for these policies or the way in which your personal data may be treated by these third parties. We recommend you check the privacy policy of any third party before you submit any personal data to their website.
Transfers of your information out of the EEA
We may need to transfer your personal data to countries which are located outside the European Economic Area (“EEA”), for the purpose of providing the services to you. You may be located in a country outside of the EEA and therefore we may have no choice but to transfer your data outside of the EEA. Rest assured that any transfer of your personal data outside of the EEA will be subject to a GDPR-compliant guarantee (such as the EU-US Privacy Shield or a Model Contract Clause approved by the European Commission) that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
How long do we hold your data for?
We only keep your personal data as long as necessary for the purpose for which it was obtained. After that period, we either: (1) anonymise the data if we still wish to use it for analytical purposes, or (2) pseudonymise the data if believe in good faith that we may need to process the data in the future for a legitimate purpose, or in all other cases (3) delete it completely from our servers.
What rights do you have?
Right to request a copy of your information
You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or it, please:
- email, call or write to us (see ‘How can you contact us?’ below),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill will suffice), and
- let us know the information you want a copy of, including any account or reference numbers, if you have them.
We will acknowledge receipt of your request and will respond within thirty (30) days. We will not charge you for providing the information.
Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below),
- let us have enough information to identify you (e.g. account number, user name, registration details), and
- let us know the information that is incorrect and what it should be replaced with.
We will acknowledge receipt of your request and will respond within thirty (30) days.
Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
email, call or write to us (see ‘How can you contact us?’ below). You can also click on the ‘unsubscribe’ button at the bottom of marketing emails from us,
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill will suffice), and
let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
We will acknowledge receipt of your request and will respond within thirty (30) days.
Right to erasure
You can request that we delete all personal data relating to you free of charge. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below), and
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill will suffice), and
- provide us with the justification for the erasure request (e.g. you are withdrawing your consent, you no longer believe that we should be processing the personal data for the original purpose for which it was obtained, the personal data is being unlawfully processed, there is a legal reason for erasure etc.).
We will acknowledge receipt of your request and will respond within thirty (30) days.
Right to Restrict Processing
You can request that we restrict processing of some of your personal data. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below), and
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill will suffice), and
- provide us with details of what personal data you would like us to restrict the processing of (e.g. where you contest the accuracy of some personal data, we shall restrict the processing of it whilst its accuracy is verified).
We will acknowledge receipt of your request and will respond within thirty (30) days. If we agree to restrict the processing of the personal data before the thirty (30) day period, we will inform you as soon as we have put in place the restriction.
Right to Object
You can object to us processing any of your personal data. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below), and
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill will suffice), and
- provide us with details of what personal data you object to us processing.
We will acknowledge receipt of your request and will respond within thirty (30) days.
Right to Data Portability
You can request that be provide some or all of your personal data we hold to a third party free of charge. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill will suffice), and
- provide us with sufficient details of the third-party entity to which you would like your data transferred.
We will acknowledge receipt of your request and will provide your personal to the third-party entity in a commonly used machine-readable format within thirty (30) days providing you have provided us with sufficient information to do so. We will not charge you for this service.
Rights relating to automated decision making and profiling
We use software that automatically processes personal data for us. We ensure that processing using this software is fair and we implement all appropriate technical and organisational measures to ensure inaccuracies are minimised. If you are concerned about the use of such software, you have the right to ask for more details about the processing and request that we stop using the software to process your data. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below),
- let us have enough information to identify you (e.g. account number, user name, registration details), and
- provide us with details of your concerns and the categories of personal data you believe are being processed by automated software.
We will acknowledge receipt of your request and will respond within thirty (30) days. Please note that if the automated processing is necessary for the performance of a contract between you and us, if you request that the software is no longer used to process your data, we may not be able to provide you with services anymore.
Right to complain to the supervisory authority
If you are unhappy with the way in which we have dealt with a request you have made or you feel that we are not complying with this Privacy Policy in any way, you have the right to complain to the supervisory authority in the country in which you live. The supervisory authority in England and Wales is the Information Commissioners Office and details of how to contact them are available on their website: www.ico.org.uk.
Time Extensions and Refusals
We reserve the right to extend the time period to respond to any of the requests listed above by up to sixty (60) days where a request is complex or a large number of requests are made. If we fail to respond to you by the deadline we set, you have a right to complain to the supervisory authority or seek a judicial remedy (see – ‘Right to complain to the supervisory authority’ above).
We may also refuse a request where there are legitimate reasons to do so. These include, but are not limited to:
- where a request is manifestly unfounded, excessive or repetitive; or
- where personal data is being processed:
• in order to comply with a legal obligation;
the public interest;
• in the exercise or defence of a legal claim;
• in the exercise of the right to freedom of expression and information.
How to contact us
Please contact us via help@responseiq.com or call +44 208 629 5280. Our Data Protection Officer is Scott Lee. If you have any questions about this Privacy Policy or the information we hold about you, we will be delighted to assist.
Changes to this Privacy Policy
We may change this Privacy Policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this Website.
1. Preamble
As part of a separate contract and/or on the basis of separate individual assignments (hereinafter collectively referred to as the “Main Contract”), Emarsys shall provide Tropical Warehouse with various marketing services, with particular emphasis on planning, implementing, and analysing email communication (hereinafter collectively referred to as “Services”). The Services are described in more detail in the Main Contract and in the descriptions of each respective Service.
2. Subject Matter
2.1. Processing of Personal Data
This agreement (“Contract”) shall provide regulations for processing personal data which Emarsys processes on behalf of Client whilst the Services are being delivered (“Data”). Personal data means any information relating to an identified or identifiable natural person. The Data particularly include the names, e-mail addresses, and areas of interest of the recipients of Tropical Warehouse’s e-mail newsletters.
3. Duties of Tropical Warehouse
3.1. Client as controller
Emarsys shall exclusively process the Data as part of, and for the purpose of, delivering Services for Tropical Warehouse and in accordance with Tropical Warehouse’s documented instructions. Emarsys shall process the personal data in no other way, and for no other purpose, unless required to do so by EU or EU Member State law to which Emarsys is subject; in such a case, Emarsys shall inform Tropical Warehouse of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest.
3.2. Obligation to notify
If in Tropical Warehouse’s area of accountability, Data which has been processed by Emarsys in accordance with this Contract becomes inadvertently known to unauthorized third parties, Tropical Warehouse shall inform Emarsys about this in due time to enable Emarsys to take necessary technical and organizational measures on its side.
3.3. Obligation to indemnify
If a third party (inclusive of public authorities) makes claim(s) against Emarsys and/or accuses Emarsys to be in breach of contract which is/are based on Tropical Warehouse’s breach of its duties, the following shall apply: Tropical Warehouse shall grant Emarsys indemnity against these claims, provide Emarsys with appropriate support for their legal defence, and indemnify Emarsys for the reasonable cost of the legal defence. The obligation to indemnify shall only be valid if Emarsys informs Tropical Warehouse of any asserted claims in writing and without undue delay, does not make a confession or any other similar statement to that effect, and allows Tropical Warehouse, at Tropical Warehouse’s own expense and as far as is procedurally possible, to conduct all legal and out of court proceedings regarding the claims.
4. Duties of Emarsys
4.1. Obligation to inform
Emarsys shall immediately inform Tropical Warehouse if, in its opinion, an instruction given by Tropical Warehouse violates applicable provisions in relation to data protection. Emarsys shall be entitled to suspend the performance of said instruction until it is confirmed or modified by Tropical Warehouse. Emarsys is not under any obligation to carry out a legal review of the instructions. Tropical Warehouse remains the sole controller regarding the Data, and is responsible for the legality of the Data processing and protecting the rights of the data subjects. Tropical Warehouse shall inform the data subjects or obtain their consent with regards to the processing of Data where required.
4.2. Obligation to Provide Support
Emarsys shall, upon Tropical Warehouse’s request, adequately assist Tropical Warehouse in the event that Tropical Warehouse is only able to fulfil its obligations towards the data subjects (particularly the obligation to provide a data subject with details regarding the processing of his/her personal data) with Emarsys’s assistance. Emarsys shall forward to Tropical Warehouse data subject requests directed to Emarsys. Emarsys shall also, upon Tropical Warehouse’s request, assist Tropical Warehouse in ensuring its compliance regarding the security of personal data (security of processing, notification of a personal data breach to the supervisory authority, communication of a personal data breach to the data subject) as well as a potentially necessary data protection impact assessment and prior consultations, in each case taking into account the nature of processing and the information available to Emarsys.
4.3. Rectifying, deleting, and blocking
Should personal data need to be rectified, deleted, or blocked, Tropical Warehouse shall undertake this themselves by using the corresponding functions available in the software provided. If this is not possible, Emarsys shall take on the tasks of rectifying, deleting, and blocking, following the instructions from Tropical Warehouse. Item 7.2 applies to the deletion of the Data at the end of the contract term.
4.4. Location of Data processing
The Data shall be processed solely in the European Union (EU) and/or in the member states which are included in the agreement covering the European Economic Area (EEA), provided that Tropical Warehouse has not permitted Emarsys to process the Data in a country outside of the EU and the EEA in this Contract or in any other manner.
4.5. Data protection officer
Emarsys shall have a designated data protection officer. Emarsys shall provide its data protection officer’s contact details to Tropical Warehouse upon request.
4.6. Confidentiality of the Data
Emarsys shall familiarize its employees who are assigned with the task of processing personal data with the regulatory provisions of data protection, and shall commit them in writing to maintaining confidentiality and data secrecy. This obligation of secrecy especially applies to persons assigned with the task of processing data, and for data relating to legal bodies or an association, and shall continue to apply for Emarsys even after the employment is terminated.
4.7. Obligation to notify
If Client Data becomes known to unauthorized third parties in an unlawful manner, i.e. in breach of applicable data protection laws, this Contract, or instructions given by Tropical Warehouse, Emarsys must immediately inform Tropical Warehouse of this.
4.8. Technical and organizational measures
Taking into account the state of the technology, the costs of implementation, and the nature, scope, context, and purposes of processing, as well as the risk of varying likelihood and severity for the rights and freedoms of persons, Emarsys shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. Furthermore, Emarsys shall take steps to ensure that any person acting under its authority who has access to the personal Data does not process it except on instructions from Tropical Warehouse, unless he or she is required to do so by EU or EU Member State law.
4.8.1. Pseudonymisation And Encryption Of Personal Data
Measures implemented my Emarsys which generally prevent unauthorized processing of personal data: data cannot be read, copied, altered, or removed without authorization during processing or utilization and after being saved (including encryption processes):
4.8.1. Personal data are encrypted when transmitted.
To the extent reasonably possible (without preventing the rendering of the agreed services) personal data are anonymized and/or pseudonymized by hashing or reference to a database whether personal data are stored.
4.9. Obligation to indemnify
If a third party (inclusive of public authorities) makes claim(s) against Tropical Warehouse and/or accuses Tropical Warehouse to be in breach of contract which is/are based on Emarsys’s breach of its duties, the following shall apply: Emarsys shall grant Tropical Warehouse indemnity against these claims, provide Tropical Warehouse with appropriate support for their legal defense, and indemnify Tropical Warehouse for the reasonable cost of the legal defence. The obligation to indemnify shall only be valid if Tropical Warehouse informs Emarsys of any asserted claims in writing and without undue delay, does not make a confession or any other similar statement to that effect, and allows Emarsys, at Emarsys’s own expense and as far as is procedurally possible, to conduct all legal and out of court proceedings regarding the claims.
5. Tropical Warehouse’s right to carry out audits
5.1. Certification
Emarsys must use an information security management system that is certified according to ISO 27001 during the term of this Contract, and shall provide proof of same upon request.
5.2. Audits
To the extent required, Tropical Warehouse is permitted to audit (or to have another auditor, mandated by Tropical Warehouse, audit) Emarsys’s compliance with: a) the legal regulations in relation to data protection, b) the contractual agreements made by the parties and c) Tropical Warehouse’s instructions. Emarsys shall contribute to such audits and make available to Tropical Warehouse all information necessary to demonstrate its compliance. Tropical Warehouse must give at least two weeks written notice prior to carrying out audits at Emarsys’s business
premises. The audits shall be carried out by Tropical Warehouse during the normal business hours, and without causing a significant disruption to business operations. Each party shall cover its own costs of, or in connection with, audits.
5.3. Legitimate interests of Emarsys
If by carrying out the audits Emarsys’s trade and business secrets may be revealed, or intellectual property belonging to Emarsys could be compromised, Tropical Warehouse must have the audits carried out by an independent specialist third party which is under the obligation to maintain confidentiality with respect to Emarsys.
6. Subcontracting
6.1. Engaging subcontractors
Emarsys shall be authorized to engage subcontractors to process the Data if Emarsys enters into a written or electronic contract with the subcontractor regarding the processing of the Data, and the level of protection provided by said contract is equal or greater than that of this Contract, and Tropical Warehouse gives its prior written or electronic consent to engage the subcontractor. Emarsys shall inform Tropical Warehouse in writing or electronic form of any intended changes concerning the addition or replacement of subcontractors, thereby giving Tropical Warehouse the opportunity to object to such changes. Tropical Warehouse’s consent shall be deemed given if Tropical Warehouse does not object in writing or electronic form within one month after receipt of this information.
6.2. Liability for subcontractors
Where a subcontractor fails to fulfil its data protection obligations, Emarsys shall remain fully liable to Tropical Warehouse for the performance of that subcontractor's obligations.
7. Terms of termination
7.1. Data at the point of contract termination
Emarsys shall delete Tropical Warehouse’s Data from its data storage media and destroy any relevant documentation it holds, 30 days after the Main Contract has ended, provided that Emarsys is not legally obliged to continue storing it. Tropical Warehouse shall be responsible for exporting the Data in a timely manner before the end of this period, and to save it for its own continued use. Tropical Warehouse shall separately commission and remunerate Emarsys for Data that is published or exported in such a way that is not covered by the services included in the standard functions (e.g. downloading files).
7.2. Backup copies
The above obligation to delete shall not apply to copies of the Data which are included in regularly created back-up copies of Emarsys’s comprehensive data sets, which would require Emarsys to invest significant resources to achieve an isolated deletion, and which will be automatically deleted or replaced after a maximum of 14 days as part of the back-up cycle that Emarsys applies. Until the automatic deletion or replacement occurs, any recovery or other use of such copies is prohibited after the termination of this Contract. Tropical Warehouse may request Emarsys delete such backup copies immediately if Tropical Warehouse reimburses Emarsys for the reasonable costs which are incurred by this; this also includes compensation for the incurred working hours of Emarsys’s personnel.
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by tropicalwarehouse.co.uk depends on the payment system used.
Tropicalwarehouse.co.uk uses Trackers. To learn more, Users may consult the Cookie Policy.
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of tropicalwarehouse.co.uk or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
In addition to the information contained in this privacy policy, tropicalwarehouse.co.uk may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
For operation and maintenance purposes, tropicalwarehouse.co.uk and any third-party services may collect files that record interaction with tropicalwarehouse.co.uk (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within tropicalwarehouse.co.uk and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through tropicalwarehouse.co.uk (or third-party services employed in tropicalwarehouse.co.uk), which can include: the IP addresses or domain names of the computers utilized by the Users who use tropicalwarehouse.co.uk, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using tropicalwarehouse.co.uk who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of tropicalwarehouse.co.uk. The Data Controller, unless otherwise specified, is the Owner of tropicalwarehouse.co.uk.
The means by which the Personal Data of the User is collected and processed.
The service provided by tropicalwarehouse.co.uk as described in the relative terms (if available) and on this site/application.
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
This privacy policy relates solely to tropicalwarehouse.co.uk, if not stated otherwise within this document.
Latest update: March 07, 2024
iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.
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