Privacy Policy

Introduction

Empire Group appreciates the interest you have shown in our company, products and services by visiting our websites (www.tanzanitemalls.com) or related communication channels, including, but not limited to, our social media pages and/or channels and blogs (together “Empire Group Pages”). This Privacy Notice applies to the Personal Data that we collect or process when you interact with Empire Group Pages. You can interact with Empire Group through Empire Group Pages, through the purchase and use of our products/services, through marketing communications, as well as through our customer support. These interactions can be made by visitors, customers, business customers, suppliers and/or business partners.

Your privacy is of sincere importance to us. You have shown your trust in us by interacting with our Empire Group Pages and we value that trust. This means that we are committed to protecting your privacy at all times.

What personal data do we collect and for which purpose?

When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.

Empire Group Account Data

You can chose to create an online Empire Group Account to benefit from our services and online shopping experience.

When you create a Empire Group Account we collect the following Personal Data:

Name;
Date of birth or age;
Salutation;
Email address;
Password;
Country and language preference determined by the extended url from the Empire page you create your account;
If you decided to create a Empire Group Account with your social media account, we may receive the social media profile details you choose to share with us;
Furthermore, we may need the following information when you interact with Empire Group as a Professional (i.e. business customer, supplier and/or business partner):

○ Company name

○ Company address

○ Company phone number

○ Organization Type

○ Job title/specialty

○ Customer Account number

We use this Personal Data in order to create and maintain your Empire Group Account. You can use your Empire Group Account for various services. ‘When using your Empire Group Account for a service, we may add additional Personal Data to your Empire Group Account. The following paragraphs inform you of the services you may use and what Personal Data we will add to your Empire Group Account when you do.

Your Empire Group Account creation only happens at your request. Therefore, we consider the processing of your Account Data to be necessary for the performance of the contract to which you are party and lawful.

Purchase & Registration Data

When you purchase products/services, and when your register your product, we collect the following Personal Data:

Shipment and invoice address;
Phone number;
Invoice history, which includes an overview of Empire Group products/services purchased;
Details of conversations that you may have with the Customer Care departments around your purchase questions or online experience questions;
Details of your registered Product/service, such as the name of the product/service, the product category it belongs to, the product model number, date of purchase, proof of purchase.

Purchase and registration of products only happens at your request. We consider the processing of your Purchase and Registration Data to be necessary for the performance of the contract to which you are party and lawful

Promotional Communications Data

You can choose to sign up for marketing and promotional communications.

When you sign up for marketing and promotional communications, we will use the following Personal Data:

Email address;
Your Empire Group Account Data;
Date of birth or age;
Your interactions with Empire Group Pages, Empire Group mobile apps, the emails you clicked and opened and attendance of events.

We use this Personal Data to send you promotional communications – based on your preferences and behavior – about Empire Group products, services, events and promotions.

Empire Group group companies may contact you with promotional communications via email, SMS and other digital channels, such as mobile apps and social media. To be able to tailor the communications to your preferences and behavior and provide you with the best, personalized experience, we may analyze and combine all information associated with your Account Data and data about your interactions with Empire Group. We also use this information to create segments of our audience showing which of our products and/or services users are interested in and track success of our marketing efforts.

Empire Group will give you the opportunity to withdraw your consent for receiving promotional communications at any time via the unsubscribe link at the bottom of each promotional communications email you may receive from us.

We may also send Empire Group press releases by email (Press email data). When Empire Group sends press releases, Empire Group will process your name, contact details (e.g. email) and company information.

The processing of Personal Data for Promotional Communications are based on your consent, i.e. provided on a voluntary basis; such basis is lawful. Where Empire Group processes your Personal Data based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before withdrawing your consent

Competition Data

You may choose to participate in contest games or other competitions (Competition) via our Empire Group Pages.

When you sign up for a Competition, we will use the following Personal Data:

Your Account Data in case you participate after logging in to your Empire account;
Your social media profile data in case you participate via your social media account;
Name;
Email address;
Telephone number;
Physical address;
Date of birth or age,;
Material or content generated and provided by you that allows you to participate in the sweepstake, contest, game or other competition.

We use this Personal Data to allow you to participate, to identify you, to prevent/detect fraud and to fulfill the prize to you (if you win).

We consider the processing of your Competition Data in the above context to be necessary for the performance of the contract to which you are party and lawful

Online Feedback Data

You can choose to give your feedback, comments, questions, ratings and reviews in online evaluations (Online Feedback).

Where you make use of this opportunity, we will process the following Personal Data:

Your cookie ID;
Your feedback/comments/questions/your rating review;
Your contact details in case you provide them to us (name, email, telephone number).

We use this Personal Data to provide Empire Group with valuable insights to improve our Empire Group Pages or products/services range.

We consider the processing of your Online Feedback Data to be based on legitimate interest of Empire Group to improve our Empire Group pages and our range of products and services and to be lawful.

Events Data

Empire Group may collect data for events, webinars or fairs (“Events”) that you may wish to attend and register for via the Empire Group Pages. You may either register for the Event via Empire Group Pages or via the other organizing company.

When you register for an event, we will process the following information:

Account Data;
Name;
Email;
Country;
Salutation;
Product/service interest.

By registering to an event, you are agreeing to receive communications from Empire Group directly related to the event, such as what location the event will be hosted, what time the event takes place.

We consider the processing of Events Data to be necessary for the performance of the contract to which you are party and lawful.

Social listening Data

When you interact or communicate on social media channels/pages/promotions and blogs (e.g. when you click on ‘like’ or ‘share’, when you post and share comments and when you submit ratings and reviews) your Personal Data is processed by a third party that provides social listening services to Empire Group. This means that the third party that provides social listening services will retain a copy of your online publicly available interactions to which the third party has provided us access.

The Personal Data we collect includes publically available data provided in the social media context by you from the relevant social media provider via a third party that provides social listening services such as: name, gender, birthday or age, homepage, profile photo, time zone, mail address, country, interests, and comments and content you have posted/shared.

We use this Personal Data to gain a general view of the opinion of people about us and our brands and to get an idea of relevant online influencers and to resolve issues and/or improve Empire Group products and services and/or start a promotional conversation with you (based on questions/requests that you addressed to us or our competitors).

We consider the processing of Social Listening Data in the above context to be based on a legitimate interest of Empire Group to be lawful.

Consumer or Customer Care Data

You may interact with our Consumer or Customer Care centers.

When you contact Customer Support, or when you communicate with one of our Empire Group Customer Care representatives by email, phone or in writing (e.g. reply card) we will use the following Personal Data:

Your Account data;
Your call recording and history, purchase history, the content of your questions, or requests that you addressed.

We use this Personal Data to provide you with consumer and customer support (which may be product- or service related), respond to your inquiries, fulfil your requests and provide you with related customer service, such as repair or redeem products/services. We also use this Personal Data to improve, fix and customize our products and services, to meet compliance standards and to educate our Customer Care employees during training.

If we provide this service on the basis of an agreement with you, we consider the processing of your Personal Data to be necessary for the performance of the contract to which you are party and lawful.

In other cases, we consider the processing of your Personal Data in the above context to be based on a legitimate interest of Empire Group to be lawful.

Improve our products and service (Improvement Data)

Where we use Personal Data we have collected from you while you have been using Empire Group Products/Services and/or our Empire Group Pages for analytical purposes, we do this in order to improve our Products/Services and to enhance your user experience. We also do this in order to have a general overview of the category of audiences that are interested in which of our Products and/or Services.

We consider the processing of your Personal Data in the above context to be based on legitimate interest of Empire Group to improve our Empire Group pages and our range of products and services and to be lawful.

Sharing your Personal Data with others

Affiliates and service providers

We may disclose your Personal Data:

To our affiliates or subsidiaries for the purposes described in this Privacy Notice;
To our third party service providers who provide services such as website hosting, data analysis, payment/billing processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, CRM, identity management, event management, marketing intelligence, auditing, fraud detection and other services;
To third parties, to permit them to send you marketing communications, consistent with your choices if you have opted into such sharing;
To third-party sponsors of sweepstakes, contests and similar promotions;
To your connections associated with your social media account, to other website users and to your social media account provider, in connection with your social sharing activity. By connecting your Empire Group account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share is governed by the social media provider’s privacy policy;
When you interact with Empire Group as a business customer, supplier or business partner, Empire Group may disclose Personal Data available in reports and other materials provided by you and/or your company pursuant to an engagement with another business partner and/or a supplier.

Other uses and disclosures

We may also use and disclose your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.

In addition, we may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Third-party services

This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Empire Group Pages link. The inclusion of a link on the Empire Group Pages does not imply endorsement of the linked site or service by us or by our affiliates or subsidiaries.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or in connection with the Empire Group Pages. These other organizations may have their own privacy notices, statements or policies. We strongly suggest that you review them to understand how your Personal Data may be processed by those other organizations.

By connecting your Empire Group account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media provider’s privacy policy. Your Personal Data may be shared with your friends associated with your social media account, to other website users and to your social media account provider, in connection with your social sharing activity. Empire Group is bound by the privacy practices or policies of these third parties as well as our own.

Third-party cookies or other tracking technologies

We use cookies or similar technologies when you interact with and use the Empire Group Pages – when you visit our websites, use our social media pages, receive our emails, use our mobile apps and/or connected devices. In most cases we will not be able to identify you directly from the information we collect using these technologies.

The data collected is used to:

Ensure that the digital channel functions properly;
Analyze digital channel usage so we can measure and improve performance of our digital channels;
Connect to your social media networks and read reviews;
Help better tailor advertising to your interests, both within and beyond Empire digital channels;

You can delete cookies if you wish; while certain cookies are necessary for viewing and navigating on our website or app, most of the features will be still accessible without cookies. For further information about the use of cookies or other similar technologies used and your choices regarding cookies, please read our Cookie Notice.

How we protect your Personal Data

How do we secure your Personal Data?

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How can you contact us?” section below.

How long will the Personal Data be kept?

We will retain your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you to participate in the Empire pages; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Jurisdiction and cross-border transfer

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Empire Group Pages you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

Rights and choices available to you

Your rights and choices available to you

If you would like to submit a request to access, rectify, erase, restrict or object to the processing of Personal Data that you have previously provided to us, or if you would like to submit a request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us via our contact form. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Data. For your protection, we may only implement requests with respect to the Personal Data associated with your account, your email address or other account information, that you use to send us your request, and we may need to verify your identity before implementing your request.

You may also opt-out from receiving electronic communications from Empire Group. If you no longer want to receive marketing-related emails on a going-forward basis, you may opt-out by clicking the unsubscribe button at the bottom of each promotional email you receive from us.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g. when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completing of such a purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

If you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, certain Empire Group Services.

Special information for parents

The Empire Group Pages are not directed to children, as defined under applicable law, and we do not knowingly collect Personal Data from children. It is, however, Empire Group policy to comply with the law when it requires parent or guardian permission before collecting, using or disclosing Personal Data of children. We are committed to protecting the privacy needs of children and we strongly encourage parents and guardians to take an active role in their children’s online activities and interests.

If a parent or guardian becomes aware that his or her child has provided us with his or her Personal Data without their consent, please contact us via our contact form. If we become aware that a child has provided us with Personal Data, we will delete his/her data from our files.

How can you contact us?

If you have any questions about this Privacy Notice or about the way Empire Group uses your Personal Data, please contact our marketing via our contact form.