PRIVACY POLICY
Policy version: 14 August 2026
1 INTRODUCTION
This Privacy Policy is provided by The Tangerine Collective, a company registered in England and Wales under company number 17343250 with registered office at Unit 20 Gas House Road, Rochester, England, ME1 1PB ('we', 'our' or 'us') for use of our products and services (Services).
We take your privacy seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
2 WHAT THIS POLICY APPLIES TO
This privacy policy relates to your use of the Services only.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3 PERSONAL DATA WE COLLECT ABOUT YOU
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
Category of dataIn more detailData collected when you use specific functions in the ServicesData you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)Other data the Services collects automatically when you use itYour activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use.Data collected when you make an enquiry with usName, contact details, date of birth, email address, details of minors (including their names and date of birth)
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4 PERSONAL INFORMATION OF MINORS
If we collect personal data from individuals under the age of 18 directly, we will assess their capacity to consent on a case-by-case basis. As a general principle, an individual under the age of 18 may have the capacity to consent if they demonstrate sufficient maturity to understand the nature and consequences of what is being proposed. Where it is determined that the individual does not have such capacity, we will seek verifiable consent from a parent or guardian.
If it is not practicable to assess capacity on a case-by-case basis, we will generally assume that individuals aged 13 and above have the capacity to provide consent, unless there are reasonable grounds to believe otherwise. Parents or guardians may contact us using the details set out below to review, manage, or request deletion of their personal information. Where we collect personal data from children under 13, we will seek verifiable consent from a parent or guardian before collecting that data.
5 SPECIAL CATEGORY PERSONAL DATA OR SENSITIVE DATA
Certain Personal Data we collect is treated as a ‘special category’ to which additional protections apply under data protection law. This is also known as ‘Sensitive Data’. Where we process such Sensitive Data, we will also ensure we are permitted to do so under data protection laws, and any such data will be collected on the basis of your consent.
Sensitive personal data means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
We may also collect sensitive personal data or information Personal data pertaining to children and their family members, including but not limited to: identity documents, educational records, financial information, and safeguarding information. We process this information on the basis of Processing is necessary for significant public interest as stipulated by applicable laws.
We collect and use this Personal Data for the purposes described in the section ‘How and why we use your Personal Data’ below.
6 HOW YOUR PERSONAL DATA IS COLLECTED
We may collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this changes, you would be notified of this change, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant Cookies Policy.
7 HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
(i) where you have given consent
(ii) to comply with our legal and regulatory obligations
(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or
(iv) 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 information, 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 forOur reasonsCreate and manage your account with usTo perform our contract with you or to take steps at your request before entering into a contractProviding services and/or the functionalities of the Services to youDepending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)To enforce legal rights or defend or undertake legal proceedingsDepending on the circumstances:• to comply with our legal and regulatory obligations• in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of othersCommunications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important noticesDepending on the circumstances:• to comply with our legal and regulatory obligations• in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to youProtect the security of systems and dataTo 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 or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or usOperational reasons, such as improving efficiency, training, and quality control or to provide support to youFor our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to youStatistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measuresFor our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our appUpdating and enhancing user recordsDepending on the circumstances:• to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)• to comply with our legal and regulatory obligations• where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our servicesTo comply with our legal and regulatory obligationsDepending on the circumstances:• to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)• to comply with our legal and regulatory obligationswhere neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our servicesTo share your personal data with members of our group and third parties 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.In such cases information will be anonymised where possible and only shared where necessaryDepending on the circumstances:• to comply with our legal and regulatory obligations• in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
8 WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
other parties 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, however, the recipient of the information 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).
9 HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
10 DE-IDENTIFIED INFORMATION
The personal data we collect may have analytical, educational, or commercial value to us. Where we have de-identified the information we have collected, we reserve the right to process and distribute such information.
11 AUTOMATED DECISION-MAKING
We may use automated systems to make decisions that significantly affect you. These processes may involve the use of personal data to evaluate you. You may request human review of any automated decision by contacting us using the details below.
12 TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data would be indicated in this section and notified to you in accordance with the section on 'Changes to this privacy policy' below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; 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.
Accordingly, if we were to start transferring your personal data from the UK to:
The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements.
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
13 YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
Access to a copy of your personal dataThe 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 useThe 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 portabilityThe 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 useThe 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 you personal data for our legitimate interests.Not to be subject to decisions without human involvementThe 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 youWe do not make any such decisions based on data collected by the Services.
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 complete a request form available on our website at zestme@thetangerinecollective.com or email, call or write to us using the contact details below. When contacting us please:
provide enough information to identify yourself (e.g, your full name and username) 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
14 KEEPING YOUR PERSONAL DATA SECURE
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 business 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 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.
15 HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (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.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
16 CHANGES TO THIS PRIVACY POLICY
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.
17 HOW TO CONTACT US
For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:
Name: Nicola Elener
Email: zestme@thetangerinecollective.com