TH_NK Privacy Notice

14/08/18

Introduction

TH_NK respects your privacy and is committed to protecting your personal data. This privacy notice will; inform you about how we use and look after your personal data when you visit our website and when we provide our services to you, regardless of where you visit from, and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how TH_NK collects and processes your personal data through all your engagements with us, when using our services, including use of this website, including any data you may provide when you sign up to our services or request information about other services from TH_NK.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data Controller

Think Limited is the Data Controller and responsible for your personal data (collectively referred to as " Think Limited","TH_NK", "us" or "our" in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing activities and questions in relation to this privacy notice and responding to specific queries about the processing of data held by us. If you have any questions about this privacy notice, including any requests to exercise your legal rights (including an opt-out mentioned in this privacy notice), please contact the DPO using the details set out below.

Contact details

Data Protection Officer

TH_NK Limited

Address: 8-14 Vine Hill, Clerkenwell, London, EC1R 5DX, UK

Email: Privacy@wearethink.com

Tel: +44 (0)207 504 6000

www.wearethink.com

You have the right to make a complaint at any time to the competent supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office (ICO). Contact details can be found at www.ico.org.

At TH_NK we would, however, appreciate the chance to understand and address your concerns before you approach the competent supervisory authority so please contact our Data Protection Officer in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 9th August 2018 and previous versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. aggregated or anonymous data.

For clients and users of our products and services, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

  • Identity Data includes - first name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes - billing address, correspondence address, email address and telephone numbers.
  • Financial Dataincludes - bank account details
  • Transaction Data includes - details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes - internet protocol (IP) address, your login data, browser type, language and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and our services.
  • Social Media Dataincludes :Facebook, Twitter, Instagram, LinkedIn, etc.
  • Usage Data includes - information about how you navigate and use our website and services.
  • Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Hiring Data – work history usually in the form of a CV, identity, contact details, financial details.

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 genetic and biometric data.

For prospective employees and contractors of TH_NK, we may collect, use, store and transfer different kinds of personal data about you when you apply for a job at TH_NK. This includes information within your CV or resume and any additional information we may request over the phone or via email to support our processing of your job application. This typically includes: See Hiring Data above.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
    • Apply for our services;
    • Apply for a job with us;
    • Enter into an agreement with us;
    • Subscribe to our service or publications;
    • Give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your computing equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  1. Analytics providers such as Google based outside the EU;
  2. Social media networks
  3. Identity and Contact Data from publicly availably sources such as credit bureaux based inside the EU, former employers, references, etc.

4. How we use your personal data

We will only use your personal data for the purposes we communicate to you and when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform specific actions in support of the contract we are about to enter into, or have entered into with our clients, partners and third parties.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • To inform you of relevant activities and services from TH_NK and our key partners.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at privacy@wearethink.com.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you on our key contacts database.

(a) Identity

(b) Contact

(c) Experience

(d) Preferences, interests, hobbies

Legitimate Interest – providing a service to new and existing clients as well as employees and job candidates.

To process your agreement including:

(a) Manage payments, fees and charges

(b) Collect and recover monies owed to TH_INK

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to keep our records updated (and pay monies owing or recover debts due to us).

To manage our relationship with you, which will include:

(a) Notifying you about changes to our terms or privacy policy.

(b) Informing you of relevant product and service updates.

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Necessary for our legitimate interests – providing products and services

(b) Necessary for our legitimate interests to keep our records updated as to areas of interest and to study how interested parties use our services.

To deliver relevant website content and potential available services to you and measure or understand the effectiveness of the details we share with you.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests to study how visitors to our website use our services, to develop them, to grow our business and to inform our marketing strategy.

To use data analytics to improve our website, services, marketing, client / potential client relationships and experiences.

(a) Technical

(b) Usage

Necessary for our legitimate interests to define types of interested parties for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

To make suggestions and recommendations to you about events, research opportunities, case studies and updates that may be of interest to you.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests to develop our services and grow our business).

Third-party marketing – We do not sell your personal details to third party partners for marketing purposes.

Opting out

You can ask us to stop sending you marketing communications emails at any time by following the opt-out links on any marketing or communication message sent to you or by contacting us at any time, see below:

Data Protection Officer

TH_NK Limited

Address: 8-14 Vine Hill, Clerkenwell, London, EC1R 5DX, UK

Email: Privacy@wearethink.com

Tel: +44 (0)207 504 6000

www.wearethink.com

Where you opt- out of receiving these messages, this will not apply to personal data provided to us as a result of any contractual or legal relationship or obligations we have with you.

Cookies

We employ cookie technology to help log visitors to our web site. Cookies are pieces of data that are often created when you visit a website, and which are stored in the cookie directory of your computer or mobile device. A number of cookies may be created when you visit the TH_NK website. The cookies do not contain any personal information about you, and they cannot be used to identify an individual user.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some of the enhanced features of this website may become inaccessible or not function properly.

Log files
When you visit this website we collect web statistics concerning your visit, which are stored in a log file. Log files allow us to record visitors’ use of the site. Log files are also used to detect potential harmful users, which may be reported by us to the relevant authorities.

5. Disclosures of your personal data

We may have to share your personal data with relevant third parties for the operation of your contract with TH_NK.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law(s) and our own strict requirements.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

As a Data Controller, we will not transfer your personal data outside the European Economic Area (EEA).

7. Data security

We treat the privacy and security of the personal data we hold very seriously.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, transferred, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to the same duty of confidentiality.

We have put in place procedures to deal with any suspected or confirmed personal data breach and will notify you on the details held for you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see [ Request erasure] below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this aggregated information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see these within the glossary below (link)

If you wish to exercise any of the rights set out below please contact us (link) or write to:

Data Protection Officer

TH_NK Limited

Address: 8-14 Vine Hill, Clerkenwell, London, EC1R 5DX, UK

Email: Privacy@wearethink.com

Tel: +44 (0)207 504 6000

www.wearethink.com

No fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we reserve the right to charge a reasonable fee if we believe that your request is clearly repetitive or excessive.

Where we believe that a request is excessive, e.g. significant amounts of data are requested, we will attempt to clarify in more detail exactly what you are looking for.

Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We endeavour to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In such cases we will respond within two months of the date we clarified your request or the fee to access the data was paid.

Your right to complain

You have the right to make a complaint at any time to the competent supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office (ICO). Contact details can be found at www.ico.org.

We would, however, appreciate the chance to understand and address your concerns before you approach the competent supervisory authority. So please contact our Data Protection Officer in the first instance.

Data Protection Officer

TH_NK Limited

Address: 8-14 Vine Hill, Clerkenwell, London, EC1R 5DX, UK

Email: Privacy@wearethink.com

Tel: +44 (0)207 504 6000

www.wearethink.com

10. Glossary

DATA SUBJECT

A living natural person, who has rights regarding their personal data and can be identified through personal identifiable information (PII).

DATA PROCESSING

The collection, storage, access, use, sharing, manipulation and deletion of personal data.

SUPERVISORY AUTHORITY

The national body that regulates the General Data Protection Regulations (GDPR) in an EU member state. In the UK, the Supervisory Authority is the Information Commissioner’s Office (ICO), details of which can be located at www.ico.org

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent, where required or are otherwise required or permitted to by applicable law).

You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (link)

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with other legal or regulatory obligation that we are subject to.

THIRD PARTIES

  • Service providers [acting as data processors] based within the EU who provide IT and system administration services
  • Professional advisers [acting as data processors or joint controllers] including lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom, who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

As a Data Subject, you have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy, in an agreed machine-readable format, of the personal data we hold about you and to check that it is complete, current and we are lawfully processing it.

In certain situations, we may seek further clarification of your data access request, e.g. where the request is complex or sizeable

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Also known as the right to rectification.

Request erasure of your personal data. Also commonly known as the “right to be forgotten”. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you advise us of your request to withdraw your consent.