Privacy Policy

This is the privacy policy for the website www.thetulip.com (our website), owned by Bury Street Properties (Luxembourg) S.a.r.l. (The Tulip, we, us and our).

We explain who we are, why and how we collect, store, share and use (together, “process”) your personal information (also referred to as personal data), your rights and how to contact us. Please read this policy carefully to understand our views and practices regarding your personal information and how we will treat it.

By engaging with our website or contacting us, you acknowledge you have read and understood this privacy policy.

Our contact details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).

This policy sets out:

Information we collect about you
How we use your information
Our promotional updates and communications
Who we give your information to
Where we store your information
How we protect your information
How long we keep your information
Your rights
Changes to this policy
Contact us
Cookies and other technologies

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

CHANGES TO THIS POLICY

Any changes we make to our privacy policy as we update our website will be posted at www.thetulip.com/privacy and, substantive changes will be notified to you by e-mail where required.
This policy was last updated on 07 October 2020.

INFORMATION WE COLLECT ABOUT YOU

We may process personal information about you if:
You engage with our website.
You contact us via email or phone, or otherwise engage with the Tulip brand.
You or the company you work for are a prospect, customer or a supplier of ours.
You are someone (or you work for someone) to whom we want to advertise or market our goods (where permitted under applicable law).

YOU PROVIDE US WITH:

When you engage with us by phone, by e-mail, via our website, or otherwise (for example, to ask for information or report an issue), we may collect the following types of personal information where you share it with us:

Contact details: including first and last name, phone number(s) and e-mail address, and any further personal information you choose to provide.

WE AUTOMATICALLY COLLECT:

Technical information and information about your visit (see also the Cookies section below for more detail).
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Platform (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.

See Cookies and other technologies for more information on the use of cookies and device identifiers on the Platform.

OTHER PARTIES MAY PROVIDE US WITH:

CONSUMERS & WEBSITE USERS
If you are a consumer, [we do not receive personal data about website visitors from any third parties.]

BUSINESS PARTNERS & COMMERCIAL USERS
If you are or work for one of our business partners (our commercial customers, suppliers, and other partners), or we are interacting with you in your professional (not personal) capacity (Business Contact), we may collect the following from you or from your employer in connection with your job and how it relates to us:

Contact details: including first and last name, who you work for, and your job function or department, phone number(s) and e-mail address, address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for).
Information relating to transactions with us involving you or the company you work for if you are a customer or supplier of ours (for example, details of goods or services that we have supplied to, or obtained from, you or the person you work for).
Other information relating to you which it is necessary for us to process in order to enter into or perform a contract with you or the company you work for (for example, right to work information if you engage with us about employment opportunities).
Information about our events to which you or your colleagues are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events.

HOW WE USE YOUR INFORMATION

We’ve set out how we use each category of personal information, and what legal basis (or bases) allow us to undertake the processing. We explain more about what each legal basis means below.
We may process your personal data based one or more than one legal basis, depending on the specific purpose(s) for which we are using your personal information. Please contact us if you would like further details about the specific legal basis we are relying on to process your personal data.

INFORMATION YOU PROVIDE US WITH:

We will use this information to:

Provide you with information about The Tulip which you have requested from us.

If you are a business, please refer to the ‘Business Partner & Commercial User Information’ .

Our legal bases for processing:

Consent (where applicable)
Legitimate interests

AUTOMATICALLY COLLECTED INFORMATION:

We will use this information:

To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
To keep our site safe and secure.
For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
To improve our site to ensure that content is presented in the most effective manner for you and for your computer.

See Cookies and other technologies.

Our legal bases for processing:

Legitimate interests
Consent (where applicable)

BUSINESS PARTNER & COMMERCIAL USER INFORMATION:

If you are a Business Contact, we may use this information to:

Provide you or the company you work for with the information you request from us or otherwise respond to your queries (except where any communications with us relate to entering into or performing a contract with your employer).
Take steps in order to enter into any contract (which may include communications with you) or carry out our obligations arising from any contract entered into between you or the company you work for and us including administering your/your company’s account with us and notifying you about changes to our service.
Send you or the company you work for promotional communications (where you have not objected to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications). See ‘Our promotional updates and communications’.

Our legal bases for processing:

Consent (where applicable)
Contract
Legitimate interests

OUR PROMOTIONAL UPDATES AND COMMUNICATIONS

Where you have contacted us to request it, we will use your personal information to respond to your request.

If you are a consumer, we will not send you any marketing or promotional updates without your prior consent.

If you are a Business Contact, we may send you marketing or promotional updates in our legitimate interests in promoting and marketing The Tulip (and any products or services in relation to The Tulip). You can also request that we send marketing material to a non-personal email address instead of one which identifies you as an individual.

If you would prefer not to hear from us again, you can always ask to opt-out from any marketing campaigns we may run at any time by sending an email to media@thetulip.com.

LEGAL BASES EXPLAINED

CONSENT:
You have provided us with your clear consent to us processing your information for a specific purpose – for example, where you email us to ask for information, or you sign-up for any updates or newsletter.

We will only receive your personal information where you have provided it to us. We will not share your individual personal data without your authorisation.

If you are a consumer, we will only process your personal information for promotional or marketing purposes where you have given us your express consent for us to do this, where required by law. For more information, please refer to Our Promotional Updates and Communication section.

You can opt out from further marketing at any time by sending an email to e.g. media@thetulip.com.

CONTRACT:
We collect, store and process your personal information where it is necessary for performing a contract you have with us or where you have asked us to take specific steps before entering into that contract.

LEGAL OBLIGATION:
We may need to process our personal information to comply with our legal obligations, including under applicable local and EU law, and any court orders.

When processing your personal information in order to manage our relationship with you, and to comply with any rights requests we receive, we ensure that we comply with the General Data Protection Regulation 2016/679 (GDPR) and the Directive on Privacy and Electronic Communications 2002/58/EC, and applicable local laws which implements these rules.

LEGITIMATE INTERESTS:
Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests.

Our legitimate interests are:

gaining insights on how you use our website
delivering, developing and improving our website
enabling us to enhance, customise or modify our website, service and communications
understanding and responding to feedback and queries
growing our business and informing our marketing strategy
improving our website and data security
entering into or performing a contract with our business partners (in relation their personnel data)
where you are a Business Contact, providing you with our promotional updates and communications (you are free to object to this at any time) – see our Promotional Updates and Communication section.

In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests. If you would like further information about how we assess our legitimate interests, please contact us at media@thetulip.com.

We also use different types of cookies (including automatically collected information) on our Platform with your consent – we explain this in the Cookies section.

WHO WE GIVE YOUR INFORMATION TO

We may share your personal data with:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent where required.

Appropriate third parties including:

if you are a Business Contact, our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
our auditors, legal advisors and other professional advisors or service providers;

In relation to information obtained via our website:

our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others during your browsing experience on other third party sites. See Cookies and other technologies for further information.
analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

OTHER DISCLOSURES WE MAY MAKE

We will disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
If The Tulip or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the company you work for; or to protect the rights, property, or safety of The Tulip, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

WHERE DO WE STORE YOUR INFORMATION ?

The data that we process in relation to you may be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”) that may not be subject to equivalent data protection law. It may also be processed by personnel situated outside the UK or the EEA who work for us or for one of our suppliers.

We may transfer your personal information outside the EEA:

In order to store it.
In order to enable us to respond to your requests, provide goods or services to and fulfil our contract with you or the company your work for. This includes order fulfilment, processing of payment details, and the provision of support services.
Where we are legally required to do so.
In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
Where the third parties with which we engage to deliver the website to you are based outside the EEA.

Where your information is transferred outside the EEA, we will take steps reasonably necessary to put in place appropriate safeguards, such as relying on a recognised legal adequacy mechanism, for example, approved standard contractual clauses, and that it is treated securely and in accordance with this privacy policy.

We transfer your information our partners abroad, including to the organisations listed below. For a full, current list of who we share your personal data with internationally, please contact us at media@thetulip.com.

Recipient

Country

Transfer Safeguard

Google LLC

USA

Standard Contractual Clauses (SCCs)

HOW WE PROTECT YOUR INFORMATION

All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our website and this privacy and cookies policy may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

HOW LONG WE KEEP YOUR INFORMATION

If you contact us, we may retain records relating to this for a reasonable and proportionate period from the date we were last in touch with you (e.g. 6-12 months). Depending on the nature of the query, we may need to keep this for a longer period of time.

If you are a Business Contact, we typically retain personal data relating to any agreement (including any agreement with the company you work with or for) with us (including any contact with us, e.g. emails) for the duration of that agreement in order to meet our contractual obligations, and for six years after that to identify any issues and resolve any legal proceedings.

We may also retain personal data where otherwise permitted or required by applicable law.

YOUR RIGHTS

You have the right under certain circumstances:

to be provided with a copy of your personal data held by us;
to request the rectification or erasure of your personal data held by us;
to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
to object to the further processing of your personal data, including the right to object to marketing (as mentioned in ‘Our promotional updates and communications’ section;
to request that your provided personal data be moved to a third party.

Your right to withdraw consent:

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.

You can also change your marketing preferences at any time as described in Our promotional updates and communications.

How to exercise your rights:

You can also exercise the rights listed above at any time by contacting us at media@thetulip.com.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).

The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

CONTACTING US

Please submit any questions you have about this Privacy Policy by email to media@thetulip.com, or write to us at:

or write to us at:

FAO: The Tulip
Bury Street Properties (Luxembourg) S.a.r.l
17-21 boulevard Joseph II,
L-1840 Luxembourg,
Grand Duchy of Luxembourg

COOKIES AND OTHER TECHNOLOGIES

Like most websites and apps, we use cookies to distinguish you (or your device) from other users of our website. Cookies help us provide you with a better browsing experience and help us improve our website.

WHAT ARE COOKIES?

Cookies are small amounts of information that are stored on your browser or the hard drive of your device to enable our server to collect certain information from your web browser. Our Platform uses cookies and to collect and store certain information. Cookies in themselves do not identify the individual, but do collect information about your computer, browser, online session, the websites you visit and other information.

Except for essential cookies, all cookies used on our site will expire after 2 years.

WE MAY USE THE FOLLOWING TYPES OF COOKIES

You can find more information about the individual cookies we use and the purposes for which we use them here:

Strictly necessary cookies. These are cookies that are required for the operation of our Services and under our terms with you (in our legitimate interests). They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us, subject to your choices and preferences, to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us, subject to your choices and preferences, to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting/Advertising cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information, subject to your choices and preferences, to make our site/app more relevant to your interests. We may also share this information with third parties for this purpose.

We may also work with advertising networks that gather information about the content on our site you visit and on information on other websites and services you visit. This may result in you seeing our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit www.youronlinechoices.co.uk.

We use the following cookies:

_ga – Google Analytics

Used to distinguish users
2 years expiration time

_gat – Google Analytics

Used to throttle request rate
1 minute expiration time

_gid – Google Analytics

Used to distinguish users
24 hours expiration time

DISABLING COOKIES

The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.

If you want to disable cookies on our website, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use; please use your browser’s settings and help functions to change this.