PURPOSE OF THIS POLICY: This Policy aims to give you information on how Tremor collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our website or purchase products or services from us.
It is important that you read this Policy together with any other policy or notice we may provide so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
CONTACT DETAILS: Our full details are:
CONTROLLER: Tremor is made up of different legal entities. This Policy is issued on behalf of the Tremor Group so when we mention “Tremor”, “we”, “us” or “our” in this Policy, we are referring to the relevant company in the Tremor Group responsible for processing your data.
If you have any concerns about how we are handling your data you have the right to make a complaint to your data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.
CHANGES TO THE POLICY AND YOUR DUTY TO INFORM US OF CHANGES: This version was last updated on May, 2018. 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.
THIRD-PARTY LINKS: This website may include links to third-party websites, plug-ins and applications. We do not control these third-party websites. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Please note this website is not intended for children and we do not knowingly collect data relating to children.
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. We have categorised these as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. This data does not directly or indirectly reveal your identity. 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 notice.
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 do not provide that data, we may not be able to perform the contract (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.
We collect data from and about you as follows:
We only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than when we send third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
Purposes for which we will use your personal data
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||Identity; Contact||Performance of a contract with you|
|To process and deliver your order including managing payments, fees and charges and collecting and recovering money owed to us||Identity; Contact; Financial; Transaction; Marketing and Communications||Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated)
|To administer and protect our business and this website (including troubleshooting, data analysis, system maintenance, support, reporting and hosting of data)||Identity; Contact; Technical||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
Necessary to comply with a legal obligation
|To deliver relevant website content||Identity; Contact; Usage; Marketing and Communications; 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, products/services, marketing, customer relationships and experiences||Technical; Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
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.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit our service providers to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Tremor Group. This will involve transferring your data outside the European Economic Area (EEA). In addition many of our external third parties are based outside the EEA so their processing of your personal data will 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:
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine 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 requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We may use this information indefinitely without further notice to you.
You have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
No fee usually required. 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 may refuse to comply with your request in these circumstances.
What we may need from you. 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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may 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.