The purpose of this statement is to explain to you what personal information we collect and how we may use it.
1. About Us
This website (https://ethical-collective.com/ is owned and operated by Tembo Ltd, a company registered in England, companies registration no. 08902148 having its registered offices at 133 China Works, Black Prince Street, Vauxhall, London, SE1 7JS.
Tembo Ltd is committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the requirements of the data protection legislation in the UK, including the General Data Protection Regulation 2016 and the Data Protection Act 2018 and we are registered on the Data Protection Public Register number.
Unless the context otherwise requires, in this Agreement the following expressions shall have the meanings set out below: –
“Affiliate” means organisations which we partner, work or associate with.
“Group Companies” or “Group Company” means any and all entities controlling or controlled by or under common control with Us. This includes but is not limited to: The Ethical Collective, Ethical Fashion, Ethical Beauty, Ethical Home, Ethical Travel and future brands created under The Ethical Collective umbrella.
“Control” means ownership, directly or indirectly, of at least fifty percent (50%) of the voting rights in such entity, and ‘controlling’ and ‘controlled’ shall have the corresponding meaning.
For the purposes of Section 13 a subscriber is defined as an “Active Subscriber” and will remain so if they open an email from Tembo Ltd., or any The Ethical Collective group of brands or enter a competition.
3. The Data Protection Officer (DPO)
Due to the type of data we collect and the nature of our business we currently have no legal requirement to have a DPO Tembo Ltd. However, our Founder & CEO, will be happy to deal with any queries or requests regarding the data we hold about you. They can be contacted by email at email@example.com or by post to Kate Disley, Founder & CEO, Tembo Ltd, 133 China Works, Black Prince Street, Vauxhall, London, SE1 7JS.
4. Information we collect about You and How we use it
When you register on any of our websites we may collect your name, address, email address, contact number and other contact details and content preference information. This allows us to process your registration.
We do not collect sensitive information (also known as special categories of information) about you except when you specifically knowingly provide it and have consented to this. Examples are allergies in a situation where food maybe provided or a disability so we can ensure a venue can facilitate access.
We do collect some information from cookies and similar software which allows us to understand how you arrive on our websites and use and navigate round them so we can improve the sites. We obtain some information from google analytics social media platforms.
The information provided by social media analytics is limited and only that which you have previously agreed with that they can share.
5. What we do with your Information
We will use your personal information for a number of purposes including
- To process your orders and provide our services, events or online content, to provide you with information about them and to deal with your requests and queries and, where applicable, to grant you access to the specific areas of our websites.
- For administration purposes which means we may contact you for reasons related to events or services ordered or online content you have signed up for, to let you know that a service or online site has been suspended for maintenance, if your subscription is about to expire to ask if you wish to renew it or if an online account has become dormant to ask if you wish to retain the account before we close it.
- To provide personalised communications.
- Where we provide personalised services, we may analyse the information you supply, as well as your activity on our (and other) services, so we can offer a more relevant, tailored service. For example, if you view the news page first thing each day, we can present this information when you first log in. If you have selected personalisation through your account you will receive a personalised service, where it is applicable for us to be able to provide this.
- A certain amount of advertising is tailored to the individual based on viewing and/or purchase habits. This is a common practice known as online behavioural advertising.
- We may show you relevant advertising on third party sites. See section 7 (on marketing)
- To contact you about a submission you have made including any content you provide.
- We use IP addresses and device identifiers to identify the location of users, to establish the number of visits from different countries, to limit/cap adverts of a certain type, personalise content and emails, and allow access to paywall protected content.
- For analysis and research to improve our services and events offered.
- We may use and disclose information in aggregate (so no individuals are identified) for marketing and strategic development purposes.
6. What if I don’t provide some or all of the information requested?
The impact of this will depend on what information you withhold but the main impacts may be:
- We may not be able to process or fully process your order.
- We may not be able to contact you to let you know of problems regarding our events/services provided.
- We may not be able to respond fully to requests and queries you may have.
- We cannot personalise the service you receive. So, if you are online you will have to search more for the content type you normally view or for similar/related products.
- We won’t be able to limit online adverts to products or services you have shown interest in and so you may receive adverts that mean nothing to you and are not related to your interests.
- Withholding marketing consent. You are free to do this at any time. It will only stop you receiving marketing. It will not impact any other service/events we provide you with.
7. Will You be contacted for Marketing Purposes?
We use your personal information to update you about new products/services by post and email. We will only contact you with your consent. You will provide this either when you fill in a form to provide your data, by signing up for a newsletter, selecting your preferences in your online account or when you call us.
We may personalise the message content based on information you provide us with, purchases you make and your use of Tembo Ltd websites, as well as The Ethical Collective, Ethical Fashion, Ethical Beauty, Ethical Home, Ethical Travel and future brands created under The Ethical Collective umbrella.
We may use information which we hold about you to show you relevant advertising on third party sites (e.g., Facebook, Google, Instagram, LinkedIn, YouTube Tik-tok and Twitter). This could involve showing you an advertising message where we know you have a Tembo Ltd account and/or have used our products and services under the Tembo or The Ethical Collective Umbrella. If you don’t want to be shown targeted advertising messages from us, some third-party sites allow you to request not to see messages from specific advertisers on that site in future. If you want to stop personalised services from Tembo Ltd or The Ethical Collective, including targeted advertising messages on third party sites you can do so by amending your preferences by emailing firstname.lastname@example.org.
You are entitled to withhold this consent and opt out from receiving such communications at any time by not giving your consent on the form (paper or web) that collects your details or telling the operator when you call. You can also update these options by logging into your account (if you have one) and adjusting your preferences, contacting us by email at email@example.com or by post to Kate Disley, Founder & CEO, Tembo Ltd, 133 China Works, Black Prince Street, Vauxhall, London, SE1 7JS.
We will always provide you with a way of opting out of receiving future marketing messages from us, each time we send them to you.
8. What grounds (legal basis) are we processing the data under?
There are a number of grounds we process your data under. These are
- Contractual – we need the information to perform the contract for events or services you have requested/ordered including payment, delivery etc.
- Legal – should we be legally required to contact you concerning a product e.g. a product recall.
- Legitimate interest – this means the processing is in Tembo Ltd.’s interest. It allows us to manage the customer relationship effectively and efficiently and improve the events and/or services we provide by better understanding how our online provisions are used and which events are popular with which groups of individuals.
- Consent – where you have given us consent to market to you.
9. Sharing your Information with Third Parties
We may from time to time provide your personal information to third parties for the purposes of providing you with our events and services. These third-party providers include payment processors, providers of card validation services, credit referencing providers, third party sales processor (includes fulfilment services) and service providers who assist us with hosting our marketing/advertising campaigns. They do not decide what is done with your data and only process it on our behalf.
These third parties may be located outside the European Economic Area; however, we only use providers that provide adequate protection for your information at all times.
When transferring any personal information out with the EEA we only do so under one of the legally recognised transfer mechanisms for ensuring the data is safeguarded. These are:
- The country in question has been deemed safe for data transfer by the European Commission. Also known as an adequacy finding.
- The contract for data processing contains the standard contractual clauses laid down by the European Commission to safeguard the transfer of personal data.
- Binding corporate rules – this is where a large company’s own internal processes for international data transfer have been signed-off and agreed by the European Commission as safeguarding the data.
- If the data is going to the USA it can be safely transferred to a company that is certified under the EU-US Privacy Shield.
- Appropriate certification schemes.
We will not provide your data to other third parties for marketing purposes unless you have specifically consented to this when you first provided your data to us. You are entitled to withhold this consent and opt out from receiving such third-party communications at any time by not giving your consent on the form (paper or web) that collects your details or telling the operator when you call.
You can also update these options by contacting us by email at firstname.lastname@example.org by post to Kate Disley, Founder & CEO, Tembo Ltd, 133 China Works, Black Prince Street, Vauxhall, London, SE1 7JS.
10. Cookies [and web browser information]
11. What if I am aged under 16?
If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to Tembo Ltd as this website is not aimed at under 16’s.
12. How we Protect your Information
We follow strict security procedures in the storage, use and disclosure of information which you have given us, to prevent unauthorised access to, and loss, misuse or alteration of your personal information in accordance with the UK data protection legislation. These include access control, firewalls and virus checking procedures.
You are responsible for keeping any confidential passwords or other login or access details which you select or which we allocate to you secret. Whilst we take steps to ensure the security of your information, there is a risk that any information transmitted over the Internet and stored on a computer may be intercepted or accessed by an unauthorised party. If you think that someone has accessed your information held by us without your permission or gained unauthorised access to your login details, you must notify us at email@example.com.
We also recommend that if you use a shared computer or a computer in a public place such as a library that you close your browser when you have finished your session.
13. How long we hold your Data for
Some of the information you provide to us is necessary to carry out repeated tasks, such as verifying your identity when signing in to use an account or providing our events and services to you or you are using an online checkout. We will keep this information for as long as you remain a registered user of any of our sites and an Active Subscriber.
Some information may be required for longer periods such as financial information for HMRC purposes, usually a maximum of 7 years.
Tembo Ltd do not retain your payment card information. It is keyed directly into the payment processor’s system when you provide it.
We may retain anonymised information for analytical purposes.
14. Your rights regarding your Personal Information
Under the Data Protection law, you have a number of rights with respect to your personal information which are:
- Correcting your Information. You are entitled to have your personal information updated to ensure it is up-to-date and accurate. This can be done by following the instructions below.
- Withdrawing Consent. You have the right to withdraw your consent to any processing that is currently being done under your consent e.g., marketing. Consent can be withdrawn for some processing by updating your preferences via the link in your email You can also follow the process below.
- Obtaining a copy of your Information. You are entitled to receive a copy of the personal information we hold about you.
- Deleting your information. You can request that we delete personal information in certain circumstances. These will be specific to each case.
- Data Portability. You are entitled to have us transfer to another controller the personal information that you have provided us with.
- Restricting Processing. You can request a restriction on the processing of your data in some limited circumstances. Examples are concerns over data accuracy or we no longer require to hold your data but you have requested its retention by us to aid you in a legal matter.
- Right to object to processing. You are entitled to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyse your information for targeted content etc. (also known as profiling).
You can action any of these rights by contacting your normal customer service department or by contacting us by email at firstname.lastname@example.org or by post to Kate Disley, Founder & CEO, Tembo Ltd, 133 China Works, Black Prince Street, Vauxhall, London, SE1 7JS.
15. Sale of the Business
Should all or part of the Tembo Ltd business be sold to or taken over by another organisation, your personal information may move to that other organisation as part of the sale or takeover agreement.
16. Right of complaint to the Regulator for Data Protection
The data protection laws in the UK are regulated and enforced by the Information Commissioner’s Office (ICO). Each individual has the right to raise a concern/complaint to the ICO if they have any concerns about how their personal information and/or privacy is treated. You can do this via:
The ICO’s website (https://ico.org.uk/concerns ), follow the links or have an online Live Chat
Call the ICO helpline on 0303 123 1113
Tembo Ltd ICO Number: CSN0753081
Postal address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
17. Links to Third Party Websites
18. Updates to this Policy
We may update this Policy at any time without notice. We will tell you that we have updated the policy by emailing you at the email address you have provided to us and/or by posting an announcement on the website. By continuing to use the website after we have emailed you or posted a notice informing you of an update, you accept the changes to this Policy.
19. Contacting Us
If you have any questions about privacy or wish to update your details or action any of your other data rights at any time, please contact us using email@example.com.
Privacy statement updated 12th March 2021.
COPYRIGHT © 2021 THE ETHICAL COLLECTIVE – ALL RIGHTS RESERVED.
Your use of our website indicates your consent to the cookies described in this policy.
What is a cookie?
Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Please be aware that restricting or blocking cookies may impact on the functionality of our website and it may not work properly.
Partners we work with also collect user information on our sites through cookies, tags and pixels. Tags and pixels, also known as web beacons, are similar to cookies but are collected through embedded images.
Using cookies and other technology allows other organisations to help us to analyse how our site is being used, measure the number of visitors to the site, and display advertising.
What are the reasons for using different types of cookies?
These are cookies which we need for the website to work properly. They cover areas such as ensuring the website functions and helping us monitor and maintain security of the website.
Information storage and access
The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.
The collection and processing of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, which inform future selection of content and/or advertising.
Ad selection, delivery, reporting
The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase. This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as websites or apps, over time.
Content selection, delivery, reporting
The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether you took any action related to the content, including for example clicking on content. This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, such as websites or apps, over time.
The collection of information about your use of the content, and combination with previously collected information, used to measure, understand, and report on your usage of the service. This does not include personalisation, the collection of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, i.e. on other service, such as websites or apps, over time.
How to manage advertising cookies
You can manage the use of advertising cookies, and disable the sharing of data with partners for advertising purposes by using our preferences tool which you can find here.
You can switch some cookies off through the Your Online Choices site. You may need to do this again each time you use a different IP address or device.
How to manage necessary cookies
For cookies which we have listed as being required we do not have a current mechanism that would allow you to opt out in an automated fashion.
These cookies are required to make the sites work in the correct fashion, offer enhanced security, provide additional insight or improve our marketing capabilities.
If you wish to stop all cookie’s you run the risk of our sites not working properly. If you wish to continue to do so Internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your Internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the ‘Help’ option in your Internet browser for more details.
For more detailed information on how to control cookies you may wish to visit www.allaboutcookies.org
If you would like to find out more about privacy, cookies and their use on the internet, you may find the following links useful:
If you would like to contact us about cookies please email firstname.lastname@example.org
Last Update – 17 March 2021
COPYRIGHT © 2021 THE ETHICAL COLLECTIVE – ALL RIGHTS RESERVED.