Your privacy is important to TRIBE.MCR, so to:
let you know about your privacy rights;
how the law protects you, and
enable you to understand how TRIBE.MCR looks after your personal data
1. IMPORTANT INFORMATION ABOUT TRIBE.MCR
2. THE DATA TRIBE.MCR COLLECTS ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW AND WHY TRIBE.MCR USES YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. Important information about TRIBE.MCR
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
TRIBE.MCR would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us at firstname.lastname@example.org in the first instance.
This version came into effect on 26 October 2018.
It is important that the personal data TRIBE.MCR holds about you is accurate and current. Please keep TRIBE.MCR informed if your personal data changes during your relationship with us.
2. The data TRIBE.MCR collects about you
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).
TRIBE.MCR may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, or similar identifier.
Contact Data includes email address and telephone numbers.
Technical Data includes details of visits to the TRIBE.MCR Website site, internet protocol (IP) address, 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 this website as well as your country (but not your exact geographic location).
Usage Data includes information about how you use the TRIBE.MCR Website and services.
Marketing and Communications Data includes your preferences in receiving marketing from TRIBE.MCR and your communication preferences.
TRIBE.MCR does 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, medical history and/or any genetic and biometric data). Nor does TRIBE.MCR collect any information about criminal convictions and offences. Please do not provide us with any Special Category of Personal Data through the TRIBE.MCR Website (see “Unwanted Submissions” in the main Website Terms and ConditionS Where Special Categories of Personal Data are provided offline through the Physical Activity Readiness Questionnaire (PAR-Q) form, to enable TRIBE.MCR to assess your suitability for personal or group training, this is provided with your consent and the minimum amount of information necessary will be taken and will be stored securely and deleted as soon possible once an assessment has been made.
In order to lawfully process Special Category Personal Data, the General Data Protection Regulation (GDPR) requires TRIBE.MCR to identify a lawful basis under Article 6 and a separate condition under Article 9. The basis for processing Special Category Personal Data is that you have given your clear and explicit consent for TRIBE.MCR to process your Special Category Personal Data for TRIBE.MCR to assess your suitability for exercise and participation in personal, or group training services. Please note that you can withdraw this consent at any time.
If you fail to provide personal data
Where TRIBE.MCR needs to collect personal data by law, or under the terms of a contract it has with you and you fail to provide that data when requested, TRIBE.MCR may not be able to perform the contract TRIBE.MCR has or is trying to enter into with you (for example, to provide you with services). In this case, TRIBE.MCR may have to cancel a service you have requested from us but TRIBE.MCR will notify you if this is the case at the time.
3. How is your personal data collected?
TRIBE.MCR uses different methods to collect data from and about you including through:
Direct correspondence. You may give TRIBE.MCR your Identity and Contact Data by filling in forms or by corresponding with TRIBE.MCR by phone, email or otherwise. This includes personal data you provide when you:
apply for our services;
subscribe to our newsletter;
request marketing to be sent to you;
subscribe to a promotion or survey; or
give us some feedback.
4.How and why TRIBE.MCR uses your personal data
TRIBE.MCR will only use your personal data when the law allows us to. Most commonly, TRIBE.MCR will use your personal data in the following circumstances:
Where TRIBE.MCR needs to perform the contract, it is about to enter into, or has entered into with you.
Where it is necessary for TRIBE.MCR’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where TRIBE.MCR needs to comply with a legal or regulatory obligation.
Generally, TRIBE.MCR does not rely on consent as a legal basis for processing your personal data other than in relation to collecting personal data offline (please see the section on Special Category Personal Data, above). You have the right to withdraw consent to marketing at any time by contacting TRIBE.MCR.
The INFORMATION below sets out how TRIBE.MCR uses your data and the lawful basis for doing so.
To contact you regarding the provision of TRIBE.MCR services
dATA: Identity, Contact
WHY: Performance of a contract with you
dATa: Identity, Contact, Profile, Marketing and Communications
wHy: Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for TRIBE.MCR’s legitimate interests (to keep TRIBE.MCR’s records updated and to study how customers use TRIBE.MCR ‘s services)
To enable you to complete a survey
DATA: Identity, Contact, Profile, Usage, Marketing and CommunicationS
wHY: Necessary for TRIBE.MCR’s legitimate interests (to study how customers use TRIBE.MCR’s services, to develop them and grow TRIBE.MCR’s business)
To administer and protect TRIBE.MCR’s business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
dATA: Identity, Contact, Technical
WHY: Necessary for TRIBE.MCR’s legitimate interests (for running TRIBE.MCR’s business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), 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 TRIBE.MCR serves to you
DATA: Identity, Contact, Profile, Usage, Marketing and Communications, Technical
WHY: Necessary for TRIBE.MCR’s legitimate interests (to study how customers use TRIBE.MCR’s services, to develop them, to grow TRIBE.MCR’s business and to inform TRIBE.MCR’s marketing strategy)
To use data analytics to improve the TRIBE.MCR Website, services, marketing, customer relationships and experiences
DATA: Technical, Usage
WHY: Necessary for TRIBE.MCR’s legitimate interests (to define types of customers for TRIBE.MCR’s services, to keep the TRIBE.MCR Website updated and relevant, to develop TRIBE.MCR’s business and to inform TRIBE.MCR’s marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you on the basis of previous services to you via electronic means (telephone, email, SMS or App push notifications)
DATA: Identity, Contact, Technical, Usage, Profile
WHY: Necessary for TRIBE.MCR’s legitimate interests (to develop TRIBE.MCR’s services and grow TRIBE.MCR’s business)
Note that TRIBE.MCR may process your personal data for more than one lawful ground depending on the specific purpose for which it is using your data. Please contact TRIBE.MCR if you need details about the specific legal ground it is relying on to process your personal data where more than one ground has been set out in the table above.
TRIBE.MCR strives to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We do not use consent as our lawful basis for marketing (we rely upon legitimate interest instead, in order to provide you with information about our services, that you have approach us for).
Promotional offers from TRIBE.MCR
TRIBE.MCR 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 TRIBE.MCR decides which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from TRIBE.MCR if you have requested information or services from us, or if you provided TRIBE.MCR with your details when you registered for a newsletter and, in each case, you have not opted out of receiving that marketing.
You can ask TRIBE.MCR or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to TRIBE.MCR as a result of a service. TRIBE.MCR will continue to communicate with you for reasons essential to the fulfilment of any orders.
Change of purpose
TRIBE.MCR will only use your personal data for the purposes for which it was collected, unless TRIBE.MCR reasonably considers that it is needed for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If TRIBE.MCR needs to use your personal data for an unrelated purpose, TRIBE.MCR will notify you and will explain the legal basis which allows TRIBE.MCR to do so.
Please note that TRIBE.MCR may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
TRIBE.MCR may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
TRIBE.MCR requires all third parties to respect the security of your personal data and to treat it in accordance with the law. TRIBE.MCR does not allow third-party service providers to use your personal data for their own purposes and only permits them to process your personal data for specified purposes and in accordance with TRIBE.MCR’s instructions.
6. International transfers
We transfer some of your personal data to the USA as part of our website hosting arrangements. The hosting service provider provides an adequate level of protection under the Privacy Shield arrangements.
7. Data security
TRIBE.MCR has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
TRIBE.MCR has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where it is legally required to do so.
8. Data retention
How long will you use my personal data for?
TRIBE.MCR will only retain your personal data for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, TRIBE.MCR 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 TRIBE.MCR processes your personal data and whether TRIBE.MCR can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask TRIBE.MCR to delete your data: see the section entitled “Request erasure” below for further information.
For Personal Data that is not required to be kept for legal purposes, TRIBE.MCR will delete this as soon as possible.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, these include:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact TRIBE.MCR at email@example.com.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data TRIBE.MCR holds about you and to check that TRIBE.MCR is lawfully processing it.
Request correction of the personal data that TRIBE.MCR holds about you. This enables you to have any incomplete or inaccurate data TRIBE.MCR holds about you corrected, though TRIBE.MCR may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask TRIBE.MCR to delete or remove personal data where there is no good reason for TRIBE.MCR continuing to process it. You also have the right to ask TRIBE.MCR to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where TRIBE.MCR may have processed your information unlawfully or where TRIBE.MCR is required to erase your personal data to comply with local law. Note, however, that TRIBE.MCR may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where TRIBE.MCR is 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where TRIBE.MCR is processing your personal data for direct marketing purposes. In some cases, TRIBE.MCR may demonstrate that it has compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask TRIBE.MCR to suspend the processing of your personal data in the following scenarios: (a) if you want TRIBE.MCR to establish the data's accuracy; (b) where TRIBE.MCR’s use of the data is unlawful but you do not want TRIBE.MCR to erase it; (c) where you need TRIBE.MCR to hold the data even if TRIBE.MCR no longer requires it, as you need it to establish, exercise or defend legal claims; or (d) you have objected to TRIBE.MCR’s use of your data but TRIBE.MCR needs to verify whether TRIBE.MCR has overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. TRIBE.MCR will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for TRIBE.MCR to use or where TRIBE.MCR used the information to perform a contract with you.
Withdraw consent at any time where TRIBE.MCR is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, TRIBE.MCR may not be able to provide certain products or services to you. TRIBE.MCR will advise you if this is the case at the time you withdraw your consent.
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, TRIBE.MCR may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, TRIBE.MCR may refuse to comply with your request in these circumstances.
What TRIBE.MCR may need from you
TRIBE.MCR may need to request specific information from you to help TRIBE.MCR 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. TRIBE.MCR may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
TRIBE.MCR will 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, TRIBE.MCR will notify you and keep you updated.
Legitimate Interest means the interest of TRIBE.MCR in conducting and managing its business to enable TRIBE.MCR to give you the best service and the best and most secure experience. TRIBE.MCR makes sure to consider and balance any potential impact on you (both positive and negative) and your rights before TRIBE.MCR processes your personal data for its legitimate interests. TRIBE.MCR does not use your personal data for activities where TRIBE.MCR’s interests are overridden by the impact on you (unless TRIBE.MCR has your consent or is otherwise required or permitted to by law). You can obtain further information about how TRIBE.MCR assess its legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that TRIBE.MCR is subject to.