The privacy of your personal information, or personal data, is a big deal to us. This policy explains what data we collect and why and how we handle your personal information.
It is your data and you can exercise your rights at any time – please see section 8 for your rights. We do not sell your personal data and we handle it in line with this policy and the current data protection laws.
This policy applies to TiliShop Ltd, its website tilitribe.com and related tili.me domain.
2. Who We Are
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:
- Our site address is https://tilitribe.com and related tili.me domains.
- Our company is TiliShop Ltd, registered in England with its registration number 11770116 and registered address at 382 Kenton Road, Harrow, Middlesex, HA3 8DP.
- Our Data Protection contact is Wout Fierens and he can be contacted at firstname.lastname@example.org.
3. What information we collect
We collect and process the following data about you:
- Identity data, including name, optional profile picture and similar identifiers.
- Contact data, including email address, postal address and telephone numbers.
- Financial data, including limited information such as last 4 digits of payment cards and bank accounts as a reference for future support from payment providers who collect all the necessary payment details directly.
- Transaction data, including details about payments to and from you and other details of products / services you have purchased from us or products / services we have purchased from you.
- Technical data, including IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology you use to access our site.
- Profile data, including your email address and password, your line of business preferences, feedback and survey responses.
- Usage data, including information on event logs generated from actions taken by the users on our system, how you use our website and products and services that you purchase from us.
- Marketing and communication data, including your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to calculate the percentage of users accessing a specific website feature.
We will not specifically 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). We do not collect any information about criminal convictions and offences.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- a) you have given consent to the processing of your personal data for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which we are subject;
- d) processing is necessary to protect the vital interests of you or of another natural person;
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
We use different methods to collect data from and about you, including:
- Direct interactions when you purchase our products or services or make enquires or we purchase your products or services, you create an account on our site, request marketing to be sent to you, enter a promotion or survey, or give us feedback or contact us.
- Third parties or publicly available sources, including a privacy-respecting open-source analytics provider Plausible.io. We may use advertising networks and search information providers and we may collect identity and contact data from publicly available sources such as Companies House.
5. How we use what we collect
We use information about you to:
- Present site content effectively to you.
- Provide information and products and services that you request, or (with soft opt-in following your purchase, your consent or if we have another lawful basis, such as legitimate interest) which we think may interest you.
- Carry out our contracts with you.
- Tell you our charges.
If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you and you will be given an opportunity to opt-out and unsubscribe from further communications.
Please note: We don’t identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience.
If you don’t want us to use your personal data for any of the reasons set out in this section 5, you can let us know at any time by contacting us at email@example.com or firstname.lastname@example.org, and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide our products and services to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.
|Type(s) of data subject||Categories of personal data||Purpose of processing||Lawful basis|
|Customers, their employees and contractors.||Contact information, including Name, address, telephone number and email address Communication data including email communication, text and other messaging services Financial data including some limited bank account and payment card details Transaction data including details about payments to and from customers.||Process orders, including invoices, payments and refunds Provision of services.||Necessary for the performance of a contract.|
|Customers, their employees and contractors.||Contact information, including name, address, telephone number and email address.||Marketing communications, including competitions.||Consent OR Soft opt-in in case of existing or previous users and those enquiring about our services.|
|Suppliers, partners, subcontractors and their employees.||Contact information, including name, address, telephone number and email address; bank details.||To enable compliance with obligations under relevant contracts, including processing order, refunds, logging and payment of invoices.||Necessary for the performance of a contract.|
|Business contacts.||Contact information, including name, company name, job position, address, telephone number and email address, including those available via business networking websites, such as LinkedIn.||Business networking.||
Legitimate interests of all parties.
1. The legitimate interests of both TiliShop Ltd and our business contacts is to network in the context of business.
2. It is necessary to exchange, keep and otherwise process contact information in order to network in the context of business.
3. There is normally a positive action taken by all parties to provide their contact details during networking with the expectation that such contact details, including personal data, may be used by the recipient for business networking.
6. Where we store your data
We will generally store your personal data within the European Economic Area (EEA) and we may transfer your collected data to storage or companies based outside of EEA. It may be processed outside the EEA as may be necessary to provide our products and services to you, to fulfil your order and deal with payment, or if we have your consent.
We will only transfer your data to countries that are deemed to have an adequate level of protection of personal data by the European commission; or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, such as Model Clauses; or we may transfer data to US based providers that are part of the Privacy Shield.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
You must keep any passwords confidential. Please don’t share it. We make sure that passwords are securely encrypted with the latest hashing algorithms and we use various other measures including passwords and encryption. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. Our general retention period for accounting and legal reasons is 7 years but your data may be kept for shorter or longer periods of time, in accordance with our data retention procedures. In any event, we will conduct regular reviews to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
7. Disclosing your information
We are allowed to disclose your information in the following cases:
- If we want to sell our business, we can disclose it to the potential buyer.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
- We can exchange information with others to protect against fraud or credit risks.
We may contract with third parties to supply our products or services to you on our behalf. These may include payment processing, search engine facilities, web hosting, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:
- Accounting companies, as may be required for our compliance with statutory obligations and financial calculations – identity, contact, financial and transactional data.
- IT and hosting services providers, as may be necessary for the provision of their services to us – identity data, contact data, financial data, transaction data, technical data, profile data, usage data and/or marketing and communications data.
- Payment processing companies, as may be necessary for the provision of their services – identity data, contact data, financial data and transaction data.
- Banks, as may be necessary for the provision of their services to us - identity data, contact data, financial data and transaction data.
- Debt collection agencies, as may be necessary for the provision of their services to us - identity data, contact data, financial data and transaction data.
- Marketing services and CRM providers, as may be necessary for the provision of their services to us - identity data, contact data and transaction data.
- Telecommunication services providers, as may be necessary for the provision of their services to us - identity data, contact data, financial data, transaction data, technical data, profile data and usage data.
- Parcel tracking services providers, as may be necessary for the provision of their services to us – identity data, contact data and transaction data.
- Other services providers, including law firms and documents services – identity data, contact data, financial data and/or transaction data as may be required for the provision of the relevant services.
- Governmental authorities, as may be necessary in order for us to comply with statutory requirements and official requests – identity data, contact data, financial data, transaction data, technical data, profile data, usage data, marketing and communication data.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
8. Your rights
You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, clicking the unsubscribe link contained in our marketing communications or by contacting us at any time at email@example.com.
Under the GDPR, you also have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another party (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling.
9. Links to other sites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
11. Automated Decision-Making and Profiling
We do not undertake any automated decision-making, including profiling.