Privacy Policy

Introduction

Tamarindo Group ("we", “us”, “our” and “ours”) recognise that the security of personal data is of the utmost importance to our clients, members and our employees. As such, we have put in place the following privacy policy. We use a combination of technical, organisational and physical security measures to protect your personal data in line with our obligations under Data Protection Legislation. Our employees receive training to help us comply with Data Protection Legislation and safeguard your personal data.

There may be separate privacy notices from us or third parties depending on the service that you are provided with, so you may need to review more than one privacy notice. Such privacy notices will usually be available on the relevant websites or linked to a section of a website. You should review privacy notices to advise you as to how your personal data might be obtained and processed, and your rights in relation to this.

This privacy policy is not contractual and we may update or amend it any time. Please refer to paragraph 11 below for further details in this regard. It is important that you read this privacy policy and together with any other policies and notices that we may provide from time to time.

We keep our privacy policy under regular review. This privacy policy was last updated on 27 April 2022.

1. Purpose of this privacy policy

This privacy notice describes how we collect and use personal data about you when you us our websites and services, in accordance with the Data Protection Act 2018 and any other laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

Our websites are not intended for children and we do not knowingly collect data relating to children.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. About us

A Word About Wind Ltd registered in England and Wales with company number 08597371 whose registered office is at 2nd Floor, 167-169 Great Portland Street, London, W1W 5PF, United Kingdom. Our contact details are:

Tamarindo Group
Tyndale House, 3rd Floor,
134 Cowley Road,
Oxford,
OX4 1JH,
United Kingdom

Telephone number: + 44 (0)20 7100 1616

Email address: membership@tamarindogroup.com

For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy policy.

Should you wish to contact us, you can do so using the contact details noted at paragraph [12] (Contact Us) below or the contact details above. Please mark any correspondence “Data Protection” so that it can be dealt with promptly.

We may also act as a ‘data processor’ in the performance of our services to our clients and members. Where applicable, our contracts impose on us the obligations required by the Data Protection Legislation when acting this capacity.

3. How may we collect personal data

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service(s) or publications;
  • request marketing to be sent to you;
  • enter promotion or survey; or
  • give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers such as Google based outside the UK; 
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from publicly available sources such as Companies House.

4. The kind of information that we hold  

Personal data, or personal information, 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, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
  • Contact Data includes [billing address, trading address, email address and telephone numbers].
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (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 on the devices you use to access our website(s). 
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, 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 also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, 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 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.

5. How we use personal data

We may process your personal data for purposes necessary for the performance of our contract with our clients and members and to comply with our legal obligations. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client. 

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Purpose / Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new member or client

(a) Identity

(b) Contact

Performance of a contract for services

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract for services

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or complete a survey, or participate in forums or discussion

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract for services

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how clients and members use our products/services)

To administer and protect our business and  website(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (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)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website(s), products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website(s) updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We may use personal data to send direct marketing communications about our products and services, or those offered by other group companies, that we feel you will be interested in.

Marketing communications may be sent by email, post, SMS, telephone and push notification. You may also see display advertising on websites, mobile applications, social media, television or in online search results.

You have control over our use of your personal data in relation to marketing communications. You can:

  • ‘Opt out’ of receiving direct marketing. When you register with us, express an interest in our services, or purchase service, you will be given the opportunity to opt out.
  • Change your marketing preferences at any time by e-mailing us or writing to us using the contact details at the end of this privacy policy.

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 services from us and you have not opted out of receiving that marketing.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration: 

  • the requirements of our business and the services provided;
  • any statutory or legal obligations;
  • the purposes for which we originally collected the personal data;
  • the lawful grounds on which we based our processing;
  • the types of personal data we have collected;
  • the amount and categories of your personal data; and
  • whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6. Data sharing

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or our clients and members or perform the contracts with our client and members, or where we have another legitimate interest in doing so.

We may share your personal data with the parties set out below for the purposes set out in the table, Purposes for which we will use your personal data, above.

  • Internal Third Parties, being other companies in the Tamarindo Group acting as joint controllers or processors and who are based UK and provide IT and system administration services and undertake leadership reporting.
  • External Third Parties as follows:

(a)   Service providers acting as processors based in the UK who provide IT and system administration services.

(b)   Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

(c)   HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

  • 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.

7. Transferring personal data outside of the UK

We will not transfer the personal data we collect about you outside of the UK without your prior consent. 

Whenever we transfer your personal data out of the UK, 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.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

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

8. Data security

We have put in place commercially reasonable and 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. Rights of access, correction, erasure and restriction

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to: 

  • Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal data that we hold about you. 
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes. 
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) that we hold. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

10. Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

11. Changes to this policy

We reserve the right to update this privacy policy at any time to ensure compliance with the laws and legislation of the UK and any other relevant associations or bodies of authority e.g. the Information Commissioners Office (ICO). 

Any changes we may make to our privacy policy in the future will be updated on our website.  

12. Contact us

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email at membership@tamarindogroup.com and mark your email “Data Protection”.

You may write also to us at using the contact details above.

You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are available on their website www.ico.org.uk .