Cookie and Privacy Policy

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Welcome to Tribal Surveys and our website at www.tribalsurveys.com. This Cookie Policy will provide more information about the cookies and similar technologies we, Two Elephants Ltd of Grass And Holm Thornbury Cottage, Chalk Hill, Coleshill, Amersham, Bucks, England, HP7 0LY, UK (“Tribal Surveys”, “we”, “us”, or “our”), use, as well as information on how to refuse and disable/delete cookies.

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If you have any questions about this policy or our data protection practices, please email us at chris@wearetribal.com, or write to us at the above address.

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Why do we have a Cookie Policy?

 

This Cookie Policy sits in line with the UK's Privacy and Electronic Communications Regulations (“PECR”) and the EU's Privacy and Electronic Communications Directive (“PECD”). In accordance with them, we need to inform you about the cookies we use and obtain your consent when using certain types of cookies namely Functional, Performance, Analytical and Advertising Cookies.

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What are cookies?

Cookies are small files with configuration information that are stored on your device. Cookies can be divided into the following five categories: 

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Essential cookies 
These cookies are essential to allow you to browse our website and use its features, such as accessing secure areas of the website, providing requested services, and storing a user's cookie settings. 

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Functional cookies     

These cookies are used to store preferences set by users such as account name, language, and location.

Performance cookies 

These cookies collect information about how you use a website, such as which pages you have visited, and which links you have clicked on. None of this information can be used to identify you. All data is aggregated and therefore anonymised. Their sole purpose is to improve our website's functionality. 

 

Analytical cookies 

We, as well as third-party vendors acting on our behalf, may use first-party cookies, third-party cookies, or other third-party identifiers to collect anonymous analytics and statistics about our website and how our visitors use them in order to help us improve our website. Our web servers' storage logs may collect domain names, Internet Protocol addresses, web browser types, and certain data from visitors to the Sites. 

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Advertising Cookies

 

Advertising Cookies are used to deliver customised advertising to the user. This can be very convenient, but also very irritating.

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Within the described categories, different types of cookies are used and these can be subdivided into:

 

Session cookies

 

While you are active on a website, a session cookie is temporarily stored in your computer's memory, which stores a session identifier, for example, to prevent you from having to log in again each time you change pages. Session cookies are deleted when you log out or lose their validity once their session has automatically expired.

Permanent or persistent cookies

A persistent or protocol cookie stores a file on your computer for the period of time specified in the expiration date. These cookies allow websites to remember your information and settings the next time you visit. This results in faster and more convenient access, as you do not have to set your language preferences for our portal again, for example. When the expiration date passes, the cookie is automatically deleted when you visit the website that generated it.

 

Third-party cookies

 

Third-party cookies come from providers other than the website operator. For example, they may be used to collect information for advertising, custom content, and web statistics.

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Cookie Consent

 

When you first visit our website, you will be asked to give your consent to cookies being stored on your device. You can accept all cookies or adjust your cookie settings to store only some of the above categories of cookies on your device. You can also refuse all cookies, except for essential cookies, which are cookies that are required for the proper functioning of the website.

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You should be aware that if you disable/reject certain cookies, we will not be able to provide you with the best possible user experience on our website, as there may be services and features that you will not be able to use if cookies are required for us to remember the choices you have made.

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You can revoke your consent or change your cookie settings at any time.

 

How can I delete or block cookies?

Since cookies are not stored on our system, but locally on your computer/phone/tablet, we cannot retrieve or delete cookies. However, you can delete existing cookies and disable the use of cookies in general using the following instructions Google Chrome, Mozilla Firefox, Microsoft Edge, Opera, Safari.

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Links to other websites

 

Please note that when you use a link from our website to a third-party website, such third-party websites may also set new cookies that are not subject to this policy. In such cases, we recommend that you refer to the cookie policy on the relevant third-party website itself.

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Changes, Contact and Effective Date

 

We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above. The effective date of this policy is Tuesday, 1st August, 2023.

 

Privacy Policy

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General Information 

What law applies?

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In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the UK`s Data Protection Act (“DPA”) and the EU counterpart the General Data Protection Regulation (“GDPR”).

Who is responsible for data processing?

The responsible party within the meaning of the DPA and the GDPR is Two Elephants Ltd of Grass And Holm Thornbury Cottage, Chalk Hill, Coleshill, Amersham, Bucks, England, HP7 0LY, UK (“Tribal Surveys”, “we”, “us”, or “our”). If you have any questions about this policy or our data protection practices, please email us at chris@wearetribal.com, or write to us at the above address.

 

What is Personal Data?

 

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website. 

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What is processing?

 

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

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What are the legal bases of processing?

 

In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:

• you have given your consent,

• the data is necessary for the fulfilment of a contract / pre-contractual measures,

• the data is necessary for the fulfilment of a legal obligation, or

• the data is necessary to protect our legitimate interests, provided that your interests are not overridden. 

 

Data we collect automatically

Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

 

Hosting 
The hosting services used by us for the purpose of operating our website is Wix.com LTD. In doing so, Wix processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website, on the basis of our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of contractual services and the conclusion of the contract for our services, including but not limited to our services).

 

Content Management System
We use the Content Management System (CMS) of Wix to publish and maintain the created and edited content and texts on my website. This means that all content and texts submitted to our website are transferred to Wix . The legal basis for this processing is our legitimate interest.

 

Content Delivery Network 
We also use the Content Delivery Network (CDN) of Wix, to distribute our online content. Our CDN is a network of regionally distributed servers operated by our technical service providers that are interconnected via the Internet. When you visit our website, your device's browser transmits information to these service providers, which is collected in corresponding server log files. The server log files are usually anonymized and then transmitted without personal reference. The server log files include in particular i) information on the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, and v) the date, time of all page views including the amount of data transferred. The legal basis for the processing is our legitimate interest.

 

Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies). 

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As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

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Cookie consent 
Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.

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Links to other websites
Please note that if you use a link from our website to a third-party website, that third-party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy on the third-party website itself.

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Data we collect directly

Contacting us
In addition to your name, company name (if any), and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.

For the Chat, we use Ascend by Wix. We have no influence on the processing of data by Wix and no possibility to influence it.The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.

 

Booking a Demo
For booking a Demo Meeting you can send us a request and we process your Name, Job Title, Company Name and Email Address, if provided. Your data from the form will be transferred to us and  will be kept until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. The legal basis is your consent as well as our legitimate interest.

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Registration and Profile
As part of the registration process, users provide their Company Name, Full Name, Address and Email address and Password. The data provided will be used for the purposes of creating and using the account and providing and/or using our services. In the context of the use of our registration and the use of your account, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as consent.

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Payment Data
To make a purchase, you may need to provide a valid payment method (e.g., credit card). Your payment information will be collected and processed by our authorised payment vendor Stripe Inc. We do not directly collect or store credit or debit card numbers ourselves in the ordinary course of processing transactions. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

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When using our services
When using our services, you become the data controller and we become the data processor in accordance with Part 3 Chapter 4 of the DPA and Chapter 4 of the GDPR. Where we process your Personal Data as data processor or in other words on behalf of you, we will process the Personal Data involved in your use of our services in accordance with your instructions and shall use it only for the purposes agreed between you and us. 

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We process the Personal Data involved in your use of our services in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

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All data collected through our services is generally transferred to our server provided by Amazon (AWS) in our MongoDB Database. We also use PureSpectrum to provide access to our worldwide panel. The legal basis for the data processing is the provision of our contractual obligations and our legitimate interest. We ensure that processing is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection. For further information please refer to our Data Processing Agreement.

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Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest. 

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Data management and customer support
For optimal data management and customer support, we may store the data related to your use of our services with us in our proprietary customer relationship management system. This data processing is based on our legitimate interest in providing our customer service.

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Marketing 
If you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

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Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. The legal basis for processing is the initiation of a contract, our legitimate interest and your consent.

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Economic analyses and market research
For business reasons, we analyse the data we have on business transactions, contracts, enquiries,browsing behaviour etc., whereby the group of persons concerned may include contractual partners, interested parties, and users of our services.

The analyses are carried out for the purpose of business evaluations and market research. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarised data).

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Principles of processing Personal Data

Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

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Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website. 

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Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

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Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

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Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

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Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

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Do Not Sell

We do not sell your Personal Data.

 

Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services and, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.

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International Transfer
We may transfer your Personal Data to other companies and/or staff members as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

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Your Rights and Privileges 

 

Privacy rights 

 

Under the DPA and GDPR, you can exercise the following rights:

• Right to information

• Right to rectification

• Right to object to processing

• Right to deletion

• Right to data portability

• Right of objection

• Right to withdraw consent

• Right to complain to a supervisory authority

• Right not to be subject to a decision based solely on automated processing.

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If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

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Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. 

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Withdrawing your consent 
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

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Access Request 
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

 

Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner's Office (ICO) located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk

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Validity and questions
We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above.

 

The effective date of this policy is Tuesday, 1st August, 2023.