TRIBE COMMUNICATIONS PRIVACY POLICY

WHO WE ARE AND HOW TO CONTACT US

We are Tribe Communications Ltd. We control and process your personal data for our legitimate business interest, and that of our fee-paying clients, in the following ways:

• Sourcing participants to take part in market research studies.
• Conducting market research studies.
• Sourcing recipients to receive marketing information that is of legitimate interest.
• Conducting marketing, advertising and public relations campaigns on behalf of our fee-paying clients.
• Providing subscription-based services through our website

We control and process your personal data in accordance with UK and EU Data Protection laws and have in place suitable physical, electronic and managerial procedures to safeguard your data.This policy outlines how we collect, control, process and protect your personal data and your rights with regards to your data.

You can contact Tribe Communications Ltd. in the following ways:
By phone – 0845 4379340
By email – hello@tribecomms.com, or to the managing director, gareth@tribecomms.com
By post – 24 Nicholas Street, Chester, CH1 2AU

Via our website – www.tribecomms.com
Via social media – www.facebook.com/tribecomms or www.twitter.com/tribecomms

Tribe Communications Ltd is a registered Data Controller with the Information Commissioner’s Office (ICO). Our registration number is Z3117575 and lists the following:

Reasons/purposes for processing information
We process personal information to enable us to:
• provide marketing, advertising and public relation services to our clients
• maintain our accounts and records
• promote our services
• undertake research
• support and manage our employees

The ICO regulates data protection and privacy matters in the UK. Their website www.ico.org.uk/for-the-public/ has information for consumers.

Tribe Communications Ltd is a member of the Market Research Society (MRS) and works strictly in accordance with their Code of Conduct. The MRS website is www.mrs.org.uk

HOW WE COLLECT PERSONAL DATA

Tribe Communications Ltd collects personal data using the following methods:
• Via our websites www.tribecomms.com and www.tribemums.com when you register with us
• Via online surveys which you complete for us
• Through emails and text messages you send to us, or that we send to you
• During our conversations with you, whether in person or on the phone
• Via messages you send to us directly through social media
• Via our clients’ own customer, member, prospect or audience lists that are provided to us for the express and sole purpose of conducting a research, marketing, advertising or public relations project on their behalf
• Using Google Analytics, we also collect information automatically from devices you use to access the website, to allow us to analyse website traffic.

WHAT PERSONAL DATA IS COLLECTED

We may collect the following personal data:
• Personal data when you register through our website e.g. your name, postcode, occupation, age and gender. This helps us to send you details about market research projects we feel are relevant to you
• ‘Sensitive’ personal data. Due to the nature of some market research projects we may need to process ‘sensitive’ personal data about you. By this we mean personal data such as your racial or ethnic origin, religious beliefs or beliefs of a similar nature, your physical or mental health, or sexual life. We would always tell you the reason for asking these questions before we asked them. Your participation is always optional;
• Other personal data that we require to fulfil the quotas for some market research projects e.g. whether you have children;
• The time, date, location and topic of any market research you carry out.
• Personal data, which may include ‘sensitive personal data’, that is provided to us via our clients’ own customer, member, prospect or audience lists that are provided to us for the express and sole purpose of conducting a research, marketing, advertising or public relations project on their behalf

HOW WE USE YOUR PERSONAL DATA

We use the personal data we collect about you for our legitimate interests, which include some or all of the following:
• To send you links to invite you to carry out market research for third parties if you have signed up through tribecomms.com, tribemums.com or our TribeComms or TribeMums Facebook page
• To put you forward to participate in market research that you have consented to take part in that is conducted by third parties;
• To make sure you get the incentives you’re promised
• To reply to and deal with any questions, suggestions, issues, complaints or disputes you or our clients have contacted us about. We may share your data, including our recorded telephone conversations, with our clients to respond to a dispute or complaint that you or they raise about how we carried out the market research on their behalf;
• To respond to any social media posts or other public comments you might make, whether they are direct to us or about us, our websites, services or other activities;
• To tell you about any changes to our services. For example, if we change our terms and conditions or this privacy policy;
• To help us maintain administrative and statutory records about our business so we can better understand who we’ve recruited and pay our taxes.
• To enable us to deliver paid-for services on behalf of our clients, which include research, marketing, advertising and public relations projects.

SHARING YOUR INFORMATION

We recruit individuals to participate in market research on behalf of third parties. We, therefore, can’t run our business or provide many of the services and incentives you receive from us without sharing your information with other people and organisations from time to time.
Your information may be shared with:
• Third party companies who have commissioned market research that you take part in. We may share your name, contact details and your responses to the market research;
• Any new business partners we may have over time, for example, in the event of a joint venture, reorganisation, business merger or sale that affects us;
• Our professional advisors including our lawyers and technology consultants when they need it to give us their professional advice;
• The police, local authorities, Her Majesty’s Revenue and Customs (HMRC), the courts and any other government authority if they ask us to do so (but only if it is lawful);
• Other people who make a ‘subject access request’, where we are allowed to provide your personal data by law.

INFORMATION SHARED WITH US

We undertake paid-for research, marketing, advertising and public relations projects on behalf of our clients. We, therefore, can’t run our business or provide many of our services to our clients without then sharing your information with us from time to time. In these instances, we act responsibly in:

• Confirming that the information the client has provided to us is in accordance with UK and EU Data Protection laws, for which they are solely responsible
• Confirming that the information the client has provided to us is legitimate in relation to the project we are to deliver on their behalf
• Controlling and processing the information the client has provided to us in accordance with our own data protection policies
• Securely protecting the information the client has provided to us with the use of password controlled access to folders and files that are restricted to the project team
• Securely storing or deleting the information the client has provided to us once the project is completed, in accordance with client instructions

SOCIAL MEDIA, BLOGS AND REVIEWS

Any social media posts or comments you send to us (on our Facebook page, for instance) will be shared under the terms of the relevant social media platform (e.g. Facebook) on which they’re written and could be made public. Other people, not us, control these platforms. We’re not responsible for this kind of sharing. So, before you make any such remarks or observations, you should review the terms and conditions and privacy policies of the social media platforms you use. That way you’ll understand how they will use your information, what information relating to you they will place in the public domain and how you can stop them from doing so if you’re unhappy about it.
It’s worth remembering too that any blog, review, or other posts or comments you make about us, our products and services on any of our blogs, reviews or user community services will be shared with all other members of that service and the public at large.
You should take extra care to ensure that any comments you make on these services are not offensive, insulting or defamatory. Ultimately, you are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.

INTERNATIONAL TRANSFER OF YOUR INFORMATION

Although we’re based in the UK we recruit participants and deliver marketing, advertising and public relations projects on behalf of clients around the world. If you take part in market research for a client who is not located within the EU we will ask your consent before any personal data is transferred.

HOW LONG DO WE KEEP YOUR INFORMATION

• If you register with TribeComms or TribeMums through our website or via a survey on our Facebook page we will keep the personal data you share until you tell us not to.
• When we collect any other personal data for specific market research projects, you will be told what the retention and deletion policy on personal data is for that project.
• When we control or process your data on behalf of a client, we securely store or delete it once the project is completed, in accordance with client instructions

YOUR RIGHTS

You have various rights about the processing of your personal data:
• The right to be informed. You have the right to be informed about the collection and use of your personal data. We do this through this privacy policy. If there is a requirement for any additional data protection information we will advise you of this when we speak to you
• The right of access. You have the right to access your data and any supplementary information. You can request details of the personal data we have about you by submitting a request in writing to hello@tribecomms.com Certain exemptions and conditions apply to this right
• The right to rectification. If you think that any data we hold about you is incorrect you can request either verbally or in writing for it to be rectified;
• The right to be forgotten. You have the right to have your personal data erased if the personal data is no longer necessary for the purpose which it was originally collected or processed for. If you originally gave consent for your data to be held you can withdraw consent. We reserve the right not to comply with any enquiries or requests we receive about the information we collect, where we may lawfully do so. For example, if we have reason to believe that a request is malicious, technically impossible, involves a disproportionate effort or could be harmful to others;
• The right to object. You have the right to object to the processing of your personal data;
• The right to restrict processing. You can request the restriction or suppression of your personal data under certain circumstances.
• The right to opt out. Any marketing communications you receive from us will always give you the opportunity to withdraw your consent at any time by opting out. We will keep our database accurate by reflecting any changes about which we are notified.
More information on your data protection rights can be found on the ICO website www.ico.org.uk/for-the-public/
If you have any worries or complaints about the way we use your information, please don’t hesitate to get in touch with us. We’ll do our very best to set your mind at rest or if anything is wrong to put things right. And if, for whatever reason, you feel we’re not meeting the exceptionally high standards we expect of ourselves, you’re within your rights to tell the UK Information Commissioner’s Office (ICO).

UPDATES TO THIS PRIVACY POLICY

We will need to update this policy from time to time as our business changes. Please look out for the flags on our websites and materials which indicate we have changed this policy. If you continue to provide us with information or use our services after we’ve changed our policy, we’ll take it that you accept the changes.
PRIVACY POLICY – REVISED MARCH 2019