Version: February 2023

www.tropisbox.com and tropisbox.co.uk (our website) is provided and wholly owned by TropisBox Ltd trading as TropisBox (we, our or us). We are the controller of personal data obtained via our website and responsible for deciding how and for what purposes your personal data is used.

Protecting your private information is our priority and we take it very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

For the purposes of this privacy policy, the term “personal data” means any information which identifies you or which allows you to be identified when combined with other information.

We collect, use and are responsible for certain personal data about you. When we do so, we are subject to the UK General Data Protection Regulation (“UK GDPR”) and any other relevant legislation.

Given the nature of our website, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website, please let us know so that we can delete that data.

This privacy policy is divided into the following sections:

1. What this policy applies to
2. Personal data we collect about you
3. How your personal data is collected
4. How and why we use your personal data
5. Marketing
6. Who we share your personal data with
7. How long your personal data will be kept
8. Transferring your personal data out of the UK
9. Cookies and other tracking technologies
10. Your rights
11. Keeping your personal data secure
12. How to complain
13. Changes to this privacy policy
14. How to contact us

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.

The personal data we collect about you depends on the activities carried out through our website. We will collect and use the following personal data about you:

• your name, address and contact information, including email address and telephone/mobile number
• any delivery addresses specified for your order
• information to check and verify your identity, e.g. date of birth
• your billing information, transaction and payment card or other payment method information
• bank account and payment details
• details of any information, feedback, or other matters you give to us by phone, email, post or via social media
• your account details, such as username and login details
• your activities on, and use of, our website
• information about the products and services we provide to you
• your contact history, purchase history and saved items
• information about how you use our website and technology systems
• your responses to surveys, competitions, and promotions.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purposes. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 genetics and biometric data). Nor do we collect any information about criminal convictions and offences.

If you do not provide personal data where it is required, it may delay or prevent us from providing products or services to you and we will notify you of this at the time.

We collect personal data from you:

• directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products via our website, sign up to our subscription service, post material to our website, request marketing to be sent to you and complete customer surveys or participate in competitions via our website, and
• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below

Informing us of changes – it is important that the personal data we hold about you is accurate and current for the purposes of our subscription services. Please keep us informed if your personal data changes during your relationship with us.

We only use your personal data when the law allows us. We use your personal data in the following circumstances:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing products and subscription services to you	To perform our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us	To comply with our legal and regulatory obligations; and For our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us.
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e. to protect our business, interests and rights
Customise our website and its content to your particular preference based on a record of your selected preferences or on your use of our website	Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website —see ‘Cookies and other tracking technologies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent, you may withdraw it at any time by contacting us (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended	Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website —see ‘Cookies and other tracking technologies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent, you may withdraw it at any time by contacting us (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Protecting the security of systems and data used to provide the services	To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us understand our customer base	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records	Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant	To comply with our legal and regulatory obligations
Marketing our services to existing and former customers	For our legitimate interests, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information

You will receive marketing information from us via email, text message, telephone, or post if you have purchased our products or subscribed to our services or if you provided us with your details when you registered with us, or if you consented to it and, in each case, you have not opted out of receiving that marketing.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us at [email protected]
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts, or
• updating your marketing preferences at www.tropisbox.com/ user-preference

We may ask you to confirm or update your marketing preferences if you ask us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and do not share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

We may routinely share personal data with:

• Our third-party service providers who perform functions on our behalf in connection with the operations of TropisBox such as payment service providers, product vendors, warehouses and delivery companies, IT service providers and system administrators; and
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers.

We only allow those organisations to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

• our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations.
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.
• law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations.
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
  • If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not keep your personal data for longer than we need it for the purpose for which it is used.

If you stop using your account, we will delete or anonymise your account data. We will keep customer personal data for seven years after their final interaction with us. By law we keep some basic information about our customers for six years after they cease being customers for tax purposes, and we keep some past and prospective contract details on file for our legitimate interest of maintaining our business network, until you ask us to delete it or for a maximum of 7 years.

Some of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of data outside the UK,

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:

• in the case of transfers subject to UK data protection law, we will only transfer your personal data to countries that the UK government has decided to be on the Adequate List such as countries in the EEA, partial findings for Japan and Canada (covers private sector). These countries ensure an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. Any changes to the Adequacy List by the UK Government in the future to add priority countries like Brazil, Colombia, India, Indonesia, Kenya, Singapore, and the United States of America will be effective within this policy.
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you or
• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) a legally approved standard data protection clauses such as the International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum (Addendum) recognised or issued further to Article 46(2) of the UK GDPR.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies and web beacons, action tags, single-pixel gifs on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies and web beacons, action tags, single-pixel gifs, our use of cookies’ and/or to relevant similar technologies, when we will request your consent before placing them and how to disable them, please see our [insert link to Cookie Policy].

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party in certain situations.
To object to use	The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims,
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.
The right to withdraw consents	If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting us. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

 

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email us—see below: ‘How to contact us”. When contacting us please:

• • provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates.

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from “Get Safe Online” on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK.

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

We may change this privacy policy from time to time—when we make significant changes, we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

Individuals in the UK

You can contact us by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details
950 Great West Road Profile West Suite 2, Floor 1 TW8 9ES, Brentford England   [email protected] +44 20 3103 9843