Privacy policy

JDC Newco Ltd (trading as One Tribe) Privacy Policy

JDC Newco Ltd. (trading as One Tribe)  (“us”, “we”, or “our”) operates the website and the One Tribe mobile application (collectively, the “Services”). This page informs you of our policies and practices regarding the collection, use and disclosure of information which personally identifies you (“Personal Information”) when you use our Services. We will not use or share your information with anyone except as described in this privacy policy (the “Privacy Policy”). We use your Personal Information for providing and improving the Services. By using the Services, you agree to the collection and use of your Personal Information in accordance with this Privacy Policy.

Information Collection and Use; Personal Information

We may ask you to provide us, or third parties may provide us with certain Personal Information that can be used to contact or identify you. Personal Information may include, but is not limited to, your name, postal address, email address, and employer. We collect Personal Information for the purpose of providing the Services, identifying and communicating with you about the Services, responding to your requests/inquiries, servicing your purchase orders, improving our Services, and communicating with you about our Services, discounts, and promotions.

How Long We Keep Your Personal Information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account Information

We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, it will be anonymized and used to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.

Marketing Information

If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. Every marketing email we send will provide you with the option to opt out of receiving future emails.

Accessing and Correcting Your Personal Information

We acknowledge individuals’ rights to access their personal information. You may access, update, correct or have removed from our systems and records the Personal Information you provided to us by emailing a request to info@onetribe.com  or contacting us by telephone or postal mail as further specified in the How to Contact Us clause of this Privacy Policy. To protect your privacy and security, we will also take reasonable steps to verify your identity before updating or removing your information.

Information Collected Directly from You

We collect information about you when you provide it to us and automatically when you use the Services.

Log Data

We collect information that your browser sends whenever you visit our website or use our Services (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we use third party services such as Google Analytics that collect, monitor and analyse this type of information in order to increase our Services’ functionality. These third-party service providers have their own privacy policies addressing how they use such information. When you access the Services by or through a mobile device, we collect certain information automatically, including the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, and your general location information as described further below.

Location Information

We use and store information about your general location. We use this information to provide features of our Services and to improve and customise our Services.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device. We use cookies to collect information in order to improve our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The “Help” feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Services and we recommend that you leave them turned on.

Information Collected from Other Sources

We will enrich your Personal Information with additional Personal Information received from publicly accessible sources. We may also receive your information from services you integrate with One Tribe, from other users of One Tribe, or from our partners.

Integrations

You may enhance the Services by enabling One Tribe integrations with third-party products. If you provide third-party account credentials to us, you understand some content and/or information in those accounts (“Third Party Account Information”) will be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy.

Partners

We work with partners who may market, sell, or support our Services. These partners may provide us your Personal Information so that we can contact you. We also may receive your Personal Information from advertising, market research, or data enrichment partners with whom we engage to identify prospective customers.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. We currently have not appointed any additional data processors, however should this be the case their details and contact information will appear below.

Service Providers who may Receive Your Personal Information

We may employ third-party companies and individuals (our “agents”) to facilitate our Services, to provide the Services on our behalf, to perform complimentary services and/or to assist us in analysing how our Services are used. Examples may include storing data, delivering messages, processing credit card payments, analysing data, providing marketing assistance, managing our agreements with you, supplementing the information you provide us in order to provide you with better service, and providing customer service. We do not transfer data to non-agent third parties. These third parties have access to your Personal Information only to perform specific tasks on our behalf and are under a written obligation not to disclose or use your Personal Information for any purpose other than those disclosed in this Privacy Policy.

Notwithstanding such legal and contractual obligations between us and such service providers, we remain potentially liable for any misuse of your Personal Information. We will only disclose Personal Information when we are required to do so in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Communications; Your Options

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by emailing info@onetribe.com

Security of Personal Information

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorised access, destruction, use, modification, or disclosure. However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

International Transfer of Personal Information

Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

Links To Other Sites

Our Services may contain links to other websites or online locations that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site or location you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Notice

When we collect your Personal Information, we’ll give you timely and appropriate notice describing what Personal Information we’re collecting, how we’ll use it, and the types of third parties with whom we may share it. This Privacy Policy serves as such notice, and any changes to our collection, use or disclosure of your Personal Information will be reflected in revisions to the Privacy Policy posted on our website.

Choice

As established and described in this Privacy Policy, we’ll give you choices about the ways we use and share your Personal Information, and we’ll respect the choices you make.

Accountability for Onward Transfer

If we transfer your Personal Information to another country, we may remain liable and will take appropriate measures to protect your privacy and the Personal Information we transfer.

Security

We’ll take appropriate physical, technical, and organisational measures to protect your Personal Information from loss, misuse, unauthorised access or disclosure, alteration, and destruction.

Data Integrity and Purpose Limitation

We’ll collect only as much Personal Information as we need for specific, identified purposes, and we won’t use it for other purposes without obtaining your consent. We’ll take appropriate steps to make sure the Personal Information in our records is accurate.

Access

If you wish to confirm the accuracy of your Personal Information or have it removed from our systems and records, you may contact us at the email address, telephone number or postal address provided in the How to Contact Us clause of this Privacy Policy.

Contact Information for the Data Controller

Controller of your Personal Information:

JDC Newco Ltd (“One Tribe”) (company number 16808458) whose registered office is at Marlow Place, Station Road, Marlow, England, SL7 1NB.

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Legal Bases for Processing Personal Information

We only process your information when we have the legal basis to do so. That is, we will only process your Personal Information when:

• We need it to provide you the Services;
• You give us consent for a specific purpose; or
• It satisfies JDC Newco Ltd’s legitimate interests (which are not overridden by your data protection interests), such as for improving, marketing, and promoting the Services and protecting our legal rights;
• We need to process your data to comply with our legal obligations.

Transfer of EU Users’ Personal Information Outside the EU

We may transfer your Personal Information to JDC Newco Ltd affiliated entities in third parties in the United Kingdom or other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we transfer Personal Information of customers in the European Economic Area or Switzerland to any such country, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules, or other appropriate legal mechanisms to safeguard the transfer. Please refer to the Section “EU-US and Swiss-US Privacy Shield” below.

EU Users’ Rights to Control Personal Information

You have control over your Personal Information. Below are the rights you have and the steps you can take to exercise them. Please note that your rights may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your employer are permitted by law or have compelling legitimate interests to keep, and it may take time for us to investigate your request. If you believe that we are not respecting your rights with regard to your Personal Information, you may lodge a complaint with your local supervisory authority.

Right to Access

You have a right to request a copy of the Personal Information that JDC Newco Ltd holds. To request this information, please email us at privacy@onetribe.com

Right to Rectification

If you believe that any Personal Information that JDC Newco Ltd holds is incorrect, you have the right to correct that information. You can change your One Tribe account information on the “Settings” page, and if you have any further concerns regarding the accuracy of your information, please email us at info@onetribe.com. Right to Erasure, Restriction, or Objection to Processing If you believe we do not have the right to process your information or you object to our processing for a particular purpose, or if you want us to erase your Personal Information altogether, please email us at info@onetribe.com 

Right to Withdraw Consent

If you gave us consent to process your Personal Information for a particular purpose, you have the right to withdraw that consent by emailing us at info@onetribe.com Your withdrawal of consent does not affect the lawfulness of our processing of your Personal Information prior to the withdrawal.

Data Portability

You have the right to obtain the Personal Information that you have directly submitted to JDC Newco Ltd in a format you can transfer to another service provider. If you want to exercise this right, please email us at info@onetribe.com 

Changes to This Privacy Policy

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Services after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

How to Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us by writing to us at:  

JDC Newco Ltd. (trading as One Tribe) Marlow Place, Station Road, Marlow, England, SL7 1NB

Email: info@onetribe.com 

Acceptable Use Policy

This Acceptable Use Policy (this “Policy”) describes prohibited uses of the products and/or services offered by JDC Newco Ltd. (the “Services”) and the website (the “One Tribe Site”). The examples described in this Policy are not exhaustive. We may modify this Policy at any time by posting a revised version on the One Tribe Site. By using the Services or accessing the TR[I]BE Site, you agree to the latest version of this Policy. If you violate the Policy or authorise or help others to do so, we may suspend or terminate your use of the Services. NO ILLEGAL, HARMFUL OR OFFENSIVE USE OF CONTENT

You may not use, or encourage, promote, facilitate or instruct others to use, the Services or One Tribe Site for any illegal, harmful, fraudulent, infringing or offensive use, or to transmit, store, display, distribute or otherwise make available content that is illegal, harmful, fraudulent, infringing or offensive. Prohibited activities or content include, but are not limited to:

• Illegal, Harmful or Fraudulent Activities. Any activities that are illegal, that violate the rights of others, or that may be harmful to others, our operations or reputation, including disseminating, promoting or facilitating child pornography, offering or disseminating fraudulent goods, services, schemes, or promotions, make-money-fast schemes, or ponzi and pyramid schemes.
• Infringing Content. Content that infringes or misappropriates the intellectual property or proprietary rights of others.
• Offensive Content. Content that is defamatory, obscene, abusive, invasive of privacy, or otherwise objectionable, including content that is pornographic in nature or discriminatory against any race, religion, or creed.
• Harmful Content. Content or other computer technology that may damage, interfere with, surreptitiously intercept, or expropriate any system, program, or data, including viruses, Trojan horses, worms, time bombs, or cancelbots.

No Security Violations

You may not violate the security or integrity of any network, computer or communications system, software application, or network or computing device (each, a “System”). Prohibited activities include, but are not limited to:

• Unauthorised Access. Accessing or using any System without permission, including attempting to probe, scan, or test the vulnerability of a System or to breach any security or authentication measures used by a System.
• Interception. Monitoring of data or traffic on a System without permission.
• Third Party Services. Developing any applications that interact with the Services or other users’ content or information without our written consent.

No Network Abuse

You may not make network connections to any users, hosts, or networks unless you have permission to communicate with them. Prohibited activities include, but are not limited to:

• User Solicitation. Soliciting login credentials from another user or using or attempting to use another user’s account, username, or password without their permission. Monitoring or Crawling. Monitoring or crawling of a System that impairs or disrupts the System being monitored or crawled.
• Intentional Interference. Interfering with the proper functioning of the Services, including any deliberate attempt to overload a network or System.
• Avoiding System Restrictions. Using manual or electronic means to avoid any use limitations placed on a System, such as access, message, seat, API, bot, or contact restrictions.

No Email or Other Message Abuse 

You will not distribute, publish, send, or facilitate the sending of unsolicited mass email or other messages, promotions, advertising, or solicitations (like “spam”), including commercial advertising and informational announcements. You will not alter or obscure mail headers or assume a sender’s identity without the sender’s explicit permission. You will not collect replies to messages sent from another internet service provider if those messages violate this Policy or the acceptable use policy of that provider.

Our Monitoring and Enforcement

We reserve the right, but do not assume the obligation, to investigate any violation of this Policy or misuse of the Services or JDC Newco Ltd. We may:

• investigate violations of this Policy or misuse of the Services or JDC Newco Ltdl; or
• remove, disable access to, or modify any content or resource that violates this Policy or any other agreement we have with you for use of the Services or the One Tribe Site.

We may report any activity that we suspect violates any law or regulation to appropriate law enforcement officials, regulators, or other appropriate third parties. Our reporting may include disclosing appropriate customer information. We also may cooperate with appropriate law enforcement agencies, regulators, or other appropriate third parties to help with the investigation and prosecution of illegal conduct by providing network and systems information related to alleged violations of this Policy.

Reporting of Violations of this Policy

If you become aware of any violation of this Policy, please contact us immediately and provide us with assistance, as requested, to stop or remedy the violation.

JDC Newco Ltd (trading as One Tribe) & GDPR

JDC Newco Ltd  has aligned our policies and practices with the General Data Protection Regulation (GDPR). This page provides a high-level summary. Please contact us at info@onetribe.com with any questions.

Overview

JDC Newco Ltd, as a Data Controller, collects and stores Personal Data only as instructed for the purposes of delivering the One Tribe Services.

This page will cover:

• The data we collect and store on behalf of our customers
• How we comply with GDPR with respect to obtaining consents, honouring Data Subject Requests, putting in place the appropriate contracts, and maintaining appropriate safeguards.
• Our sub-processors and what we do to ensure they keep customer data safe.

The Data We Collect and Store

Scope: JDC Newco Ltd collects, processes and stores Personal Data about people who use the One Tribel platform.

Categories of Data Subjects:

• Customer’s end-user customers or prospects
• Customer’s employees or other authorised users or administrators of JDC Newco Ltd

Categories of Personal Data:

• Name
• Contact information (company, business email address and phone number)
• IP Address*
• Cookie Data**

*JDC Newco Ltd will only use the IP address for data enrichment, i.e. to determine if it is associated with a business and then give you additional information re: that business such as industry and # of employees).

**JDC Newco Ltd will only use cookies to track the activities of your site visitors within your site, e.g. whether they visited a particular product page or the pricing page before engaging with the messaging widget. 

How we comply with GDPR

Appropriate Safeguards

Per Article 32 of the GDPR, we have in place appropriate technical and organisational measures to keep your data secure. All data is securely stored on Vercel, Postgres, and Blob.

Contracts

We have in place the appropriate Data Processing Agreements (DPAs) with all vendors and sub-processors that process data on our behalf. 

Honouring Data Subject Rights

We have processes in place to honour data subject requests. JDC Newco Ltd will export, correct, or delete Contact Data upon request by the Customer. If we receive a request directly from a Data Subject, we will work with the Customer to honour the request.