TRIBECA PRIVACY NOTICE

This privacy policy explains how Tribeca collects and processes your personal data through your use of this website, attendance at our events, subscription to our newsletter or mailing list, or purchase of a product or service.This privacy policy tells you about your privacy rights and how the law protects you.

Table of Contents

The data we collect about you

Personal data 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). We may collect different kinds of personal data about you such as the types listed in the table below.


Identity Data Includes company, first name, last name, username or similar identifier, position, title, date of birth and gender.
Contact Data Includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account, fund details and payment information.
Technical Data Includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data Includes usernames and passwords, personal life data (in the form of security questions and answers), 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.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data will not directly or indirectly reveal your identity and so it is not ‘personal data’.


We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) or any information about criminal convictions and offences.Our website is not intended for children and we do not knowingly collect data relating to children.

When is your personal data collected and why?

We may collect data from and about you in the following circumstances:
  1. Direct interactions.
This includes personal data you provide when you:
  • Request our products or services: we may collect your Identity, Contact, Financial, Profile, or Marketing and Communications Data when you fill in forms or correspond with us by post, phone, email or otherwise. We may use this personal data in order to:
    • arrange a purchase with you;
    • carry out due diligence;
    • set up a client;
    • deliver our products/ services (including reporting on any managed service);
    • provide updates on services;
    • manage payments or recover fees owed to us; or
    • provide updates on changes to our T&Cs and policies.
Where you request services requiring operations on your IT infrastructure we may have access to personal data held by your organisation on your IT infrastructure;
  • Submit an enquiry on our website: we need to collect your Identity, Contact and Profile Data in order to assess your enquiry and respond and to track your history of queries;
  • Subscribe to our service, publications or request marketing communications: we may collect your Identity, Contact, Profile, Marketing and Communications Data in order to keep you updated on the services we provide, new products/ services, and to provide learning resources or offers;
  • Complete a survey or give us feedback: we may collect your identity, Contact, Profile, Marketing and Communications Data in order to improve the products and services we offer;
  • Contact us or request callbacks: if you need to contact us about our services, services you may deliver to us, job opportunities, for legal reasons or for any other purpose we may collect Identity, Contact, Profile, Marketing and Communications data;
  • Register for events or webinars: we may collect your identity, Contact, Profile, Marketing and Communications Data when you register for events or webinars or if we wish to provide materials in order to arrange your attendance, provide the event and improve these events.
  1. Automated technologies or interactions.
As you interact with our website or connect with us via email, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy here for further details. Data we collect may include:
  • Repeat site visits and interactions: we do this to assess and improve our products and services and to provide a better customer experience;
  • The devices you use to interact with us: knowing the device helps us improve your experience and our contact with you, including via advertisements across different devices;
  • Information about your browser or operating system: may be captured, including automatic capture such as your IP address and date and time of visit in order to optimise our service and your experience;
  • Storage of data locally on your device: helps us to improve your experience and interactions with us by recognising you as a user of the site and also helps us to provide relevant content and advertising including marketing communications from us and third parties.
  1. 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 analytics providers such as Google Analytics, advertising networks and search information providers.
  • Identity and Contact Data from publicly available sources such as Companies House, the FCA Register or the Electoral Register based inside the EU.
If you fail to provide personal data which we need to collect by law, or under the terms of a contract we have with you, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Lawful basis for using your personal data

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:
  1. Perform a Contract: where we need to perform the contract we are about to enter into or have entered into with you;
  2. Legal Obligation: where we need to comply with a legal obligation;
  3. Legitimate Interests: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. ‘Legitimate interest’ means the interest of our business to operate effectively to enable us to give you the best service/product and the best and most secure experience. Some examples of our legitimate interests under which we may use your personal data include:
  • to study how prospective clients use our website and keep our records updated;
  • to study how clients use our products/services and to keep our records updated;
  • to recover debts due to us;
  • 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;
  • to develop and improve our products/services, to grow our business and to inform our marketing strategy
  • to tailor your experience and manage our products and services in a way which meets your expectations as a customer
  • to provide more relevant content and market new products and services when we believe you may be interested in these (with the option to unsubscribe).
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  1. Consent: Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by unsubscribing or contacting us at dpo@tribeca-it.com.
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. We will also 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 further details about the ground we are relying on or 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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising, as detailed below.

 

  1. 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 and you have not opted out of receiving that marketing.

 

  1. Third-party marketing

 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

  1. Opting out

 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at dpo@tribeca-it.com.

 

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 or service purchase or other transactions.

 

  1. Cookies

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy here.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in section 3 of this Privacy Notice.

  1. Other companies in the Tribeca Group

These companies may provide IT services, system administration services or may deliver the services as a subcontractor to Tribeca and may act as joint controllers or processors. The Tribeca Group means any one or more of the companies within the group of companies of which Tribeca is a part, such as Tribeca’s subsidiaries or parent companies. The Tribeca Group are currently based in the UK, Ireland, United States, and Hong Kong.

  1. External Third Parties

 

We do not share your personal information or disclose it to others for their own use, other than the Tribeca Group or as set out in this Privacy Notice or with your consent. External third parties which we may share personal data with include:

  • Service providers/ subcontractors which provide services to us so that we can provide the services to you;
  • Third-party service providers which carry out marketing activities or customer satisfaction assessments on our behalf;
  • Payment processing companies, credit check and anti-fraud screening companies;
  • Professional advisers including lawyers, bankers, auditors and insurers which may be based in the UK, EEA, the US and Hong Kong who provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities which may be based in the United Kingdom, EEA, the US and Hong Kong who require reporting of processing activities in certain circumstances; and
  • Regulatory or government authorities if necessary to comply with a legal obligation in any jurisdiction, including in relation to the general operation of our business (e.g. in regards to operating our business in that jurisdiction).
  1. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

We require all third parties to respect the security of your personal data 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.

 

Note that our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements and accordingly this paragraph (5) does not apply to such third parties. When you leave our website, we encourage you to read the privacy policy of every website you visit.

International transfers

We may share your personal data within the Tribeca Group. Where we do, this will involve transferring your data within the EEA and outside of the EEA to the US and Hong Kong, and to the UK once it leaves the European Union after 31 December 2020. The external third parties referred to in (5) above may also be based outside of the EEA so their processing of your personal data may involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where an adequate level of protection is not in place in the countries where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see the European Commission’s website for a copy of the model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

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

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

When considering 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, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

Your legal rights

In some jurisdictions under certain circumstances, you have rights under data protection laws in relation to your personal data. We have listed the rights applicable in the EEA below. These rights are subject to certain limitations under the applicable laws meaning that we may not always be able to comply with your request, however, we will comply with applicable law in relation to your rights. If you would like to exercise these rights contact us at dpo@tribeca-it.com:

  • Request access to your personal information;
  • Request that we correct any inaccurate information we hold about you;
  • Request that we delete your personal data where we do not have a good reason to continue processing it;
  • Object to processing of your personal information processed under a legitimate interest (or those of a third party)
  • Object to processing of your personal information where we are processing for direct marketing purposes;
  • Request the restriction of processing of your personal information; and
  • Request the transfer of your personal information to another party.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).

 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Privacy Policy

We keep our privacy policy under regular review and may update this privacy policy from time to time. This version was last updated in June 2020. We will notify you of any changes by posting the new policy on this page. You are advised to review our policies periodically for any changes. Changes are effective when they are posted on this page.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Information about Tribeca and Contact Details

This privacy policy is issued on behalf of Tribeca Technology Limited (referred to in this Privacy Policy as ‘Tribeca’). When we refer to“we”, “us” or “our” in this privacy policy, we are referring to Tribeca.

 

Tribeca is the controller and responsible for this website. Tribeca is registered with the Information Commissioners Office (ICO) in the UK under registration number ZA041707.  We will let you know which entity will be the controller for your data when you purchase a product or service with us.

 

Contact Details

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below.

  • Full name of legal entity: Tribeca Technology Limited
  • Email address: dpo@tribeca-it.com
  • Postal address: 16 Berkeley Street, London, W1J 8DZ
  • Telephone number: +44 (0)203 475 8733

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.

London:

+44 (0)203 475 8733

New York:

+1 347 690 1190

Hong Kong:

+852 5808 4824

Dublin:

+353 1901 4077