We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

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Personal information we collect about you

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We may collect and use the following personal information about you:

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• your name and contact information, including email address and telephone number and company details

• Information to enable us to check and verify your identity, e.g. your date of birth

• your gender information

• location data

• your billing information, transaction and payment card information

• your personal or professional interests

• your professional online presence, e.g. LinkedIn profile

• your contact history, purchase history and saved items

• information from accounts you link to us, e.g. Facebook

• information to enable us to undertake credit or other financial checks on you

• Information about how you use our website, IT, communication and other systems

• your responses to surveys, competitions and promotions

• information pertaining to your investment opportunity, such as pitch deck, executive summary, pitch video, financial model and other materials used in your pitch

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This personal information is required to provide services to you.

If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

 

How your personal information is collected

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We collect most of this personal information directly from you—in person, by telephone, text or email and via our website. However, we may also collect information from cookies on our website—for more information on our use of cookies, please see our cookies policy.

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How and why we use your personal information

 

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;

• for the performance of our contract with you or to take steps at your request before entering into a contract;

• for our legitimate interests or those of a third party; or

• where you have given consent.

 

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal information for and our reasons for doing so:

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The above table does not apply to special category personal information, which we will only process with your explicit consent.

 

 

Promotional communications

 

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

 

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.

 

You have the right to opt out of receiving promotional communications at any time by:

• contacting us (see ‘How to Contact Us’)

• using the ‘unsubscribe’ link in emails

 

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business

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Who we share your personal information with

 

We routinely share personal information with:

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• third parties we use to help deliver our services to you, e.g. payment service providers, warehouses and delivery companies;

• other third parties we use to help us run our business, e.g. marketing agencies or website hosts;

• third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;

• our bank/s;

 

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to the audit of our accounts.

 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

 

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

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Where your personal information is held

 

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

 

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

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How long your personal information will be kept

 

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

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• to respond to any questions, complaints or claims made by you or on your behalf;

• to show that we treated you fairly;

• to keep records required by law. We will not retain your personal information for longer than necessary for the purposes set out in this policy.

 

[Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

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Transferring your personal information out of the EEA

 

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

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• with your and our service providers located outside the EEA;

• if you are based outside the EEA;

• where there is an international dimension to the services we are providing to you.

 

These transfers are subject to special rules under European and UK data protection law.

 

Countries in the EEA which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information.

 

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you would like further information, please contact us (see ‘How to contact us’ below).

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For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

 

If you would like to exercise any of those rights, please:

• email, call or write to us -see below: ‘How to contact us’; and

• let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);

• 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); and

• let us know what right you want to exercise and the information to which your request relates.

 

Keeping your personal information secure

 

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

How to complain

 

We hope that we can resolve any query or concern you may raise about our use of your information.

 

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

 

Changes to this privacy policy

 

This privacy notice was published on the 17th of March 2023 and last updated on 17th of March 2023.

We may change this privacy notice from time to time—when we do we will inform you via our website.

 

How to contact us

 

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you. Our contact details are shown below:

 

Our contact details:

Tribe First Ltd

56 Carey Way, Olney Buckinghamshire, MK46 4DR

enquiries@tribefirst.co.uk

 

Do you need extra help?

 

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).