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Privacy & Cookie Policy

ThinkinCircles honours the rights of its clients, employees and other users’ including website visitors’ right to privacy and data protection. ThinkinCircles is fully committed to complying with the provisions of all applicable Data Protection legislation and regulations such as Data Protection Act and EU GDPR. ThinkinCircles honours the rights of its clients, employees and other users to privacy and data protection. This Privacy Policy (“Policy”) describes how we collect, use, share, and retain personally identifiable information provided by users of this website. The Policy is effective as of 15th May 2018. The policy will be continuously assessed against new technologies, business practices, regulatory changes and the evolving needs of ThinkinCircles. We are registered with the Information Commissioners Office, the UK’s Data Protection Authority.

Data Controller

The data controller for all personal data collected via this website is ThinkinCircles with its registered office at The Vestry, 38 Watling Street East, Towcester, NN12 6AF. This means that we are responsible for deciding what data we collect and how we hold and use your personal data. We will implement appropriate data security measures for protecting the data from unauthorised access and loss, as laid out in the Security section of this Policy.

Data Collection

ThinkinCircles collects and maintains a variety of personally identifiable information, including names, email addresses and phone numbers. ThinkinCircles collects information directly from individuals. The information could be collected through e-mails, phone calls, online forms and face to face meetings. ThinkinCircles does not collect personal data about individuals except when there is a legitimate business requirement or when such information is provided on a voluntary basis.

Users should also be aware that non-personal information and data may be automatically collected through the standard operation of ThinkinCircles’s web servers, and by the use of cookies technology and/or Internet Protocol (“IP”) address tracking. Non-personal identification information might include the browser used by you, the type of computer, the operating systems, the Internet service providers, and other similar information. ThinkinCircles’s web server also automatically gathers information about the top viewed and visited pages and links on our website, top entry and exit points, number of form completions, time spent on pages, top downloads, top keywords used offsite to lead customers to our website, your internet protocol (IP) address, information collected via cookies, the areas you visit on the website, the links you may select from within the website to other external websites and device event information such as system activity, crashes, hardware settings, browser type etc. Most browsers are set to accept cookies. You can set your browser to refuse cookies, or to alert you when cookies are being sent; however, if you disable cookies, the full functionality of ThinkinCircles’s website may not be available to you. The information thus collected enables us to develop and customise our services better to meet your needs and preferences, and to bring to your attention our services.

Purpose of Processing

The personal data collected is used by ThinkinCircles to give you information in relation to our services, industry news, prospecting new clients, to process and respond to queries received from the public or other relevant stakeholders and to send marketing communications on ThinkinCircles’s behalf or on behalf of ThinkinCircles’s partners. ThinkinCircles may perform statistical analyses of user behaviour and characteristics to measure interest in and the use of various sections of the website. The personal data held by ThinkinCircles may also be used on an aggregate basis without any personal identifiers to provide third parties with information, such as to help us develop our services and offerings, improve the features and content of the website or other marketing material, and to provide others with aggregate information about our website users and their usage patterns in relation to services and/or the website.

If you or your parent company are a current client of ThinkinCircles, opting out of marketing emails will not stop all communication from us. As a client of ThinkinCircles, your firm is signing you up to receive certain information related to the organisation. It is a constitutional requirement for us to send this information to you.

If you are no longer or have never been a client of ThinkinCircles, you can choose to opt in or out of further contact with us. We also receive data through networking (e.g. business cards) and add these details, if relevant, onto our data management system. We may on occasion purchase ‘opt-in’ data (lists from reputable providers) for promotional campaigns.

Data retention

The personal data collected is stored in the ThinkinCircless CMS and other appropriate data management systems, both paper based and electronic. Personally identifiable information will not be disclosed to any third party except if permission has first been obtained from the users. The data will not be transferred to any agency located outside the EU. At regular intervals, we will:

  • Review the length of time we keep your personal data for
  • Consider the purpose or purposes for which we hold your personal data for in deciding whether (and for how long) to retain it
  • Securely delete information that is no longer needed for that purpose or those purposes
  • Update, archive or securely delete information if it goes out of date

Security

ThinkinCircles uses reasonable measures to safeguard personally identifiable information. The implemented measures will be appropriate to the type of information maintained and compliance with all relevant legislation governing protection of personal information. Measures are implemented to preserve the confidentiality, integrity and availability of the personal information. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those employees, contractors or agents who have a legitimate business need to have access to that data. The employees, contractors or agents will process your personal data in accordance with our instructions. They will be subject to a duty of confidentiality and due care with respect to handling the personal data. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. ThinkinCircles’s employees are trained on data security and information protection. Relevant areas of ThinkinCircles’s website will employ Secure Socket Layer (“SSL”) or Transport Layer Security (“TLS”) encryption technology to enhance data privacy and help prevent loss, misuse, or alteration of the information collected and retained by ThinkinCircles.

Links to Third-Party Sites

Where appropriate and only for the legitimate business needs of ThinkinCircles, we may provide links to third-party web sites, or advertisements which contain links to third-party sites. These links are provided as a service to website users. The linked third-party websites are operated by independent entities that have their own privacy policies. This Privacy Policy does not apply to such other websites or to the use that those entities make of your information. ThinkinCircles has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information. ThinkinCircles’s website may also serve third party advertisements, or other content that contains their own cookies or tracking technologies. ThinkinCircles does not control the use of those technologies.

Opt-Out

ThinkinCircles, for legitimate business interests, maintain contact information on its clients and the wider business community to communicate information on our services and updates. ThinkinCircles also sends promotional material promoting its services, new clients, industry news and other relevant offerings. From time to time, ThinkinCircles collaborates with other relevant organisations and companies to promote other programs that may be of interest to clients and the wider business community. In such cases, ThinkinCircles does not provide these organisations with any personally identifiable information but may distribute the organisation’s information on their behalf to those who may legitimately be benefited from receiving such information or have elected to receive such information. If you do not wish to receive marketing material, you may opt out. Every marketing e-mail will include an ‘unsubscribe’ link at the bottom. You may also notify ThinkinCircles in writing as set out below. If your parent company has nominated you as a relevant contact required to receive information on its behalf, you cannot opt out of important information ThinkinCircles is required to provide you as per ThinkinCircles’s contractual obligations to its clients.

Social media

We may use third party provided tools such as Hootsuite to manage our social media interactions. If you send us a private or direct message via social media the message may be stored by Hootsuite. Like other personal data, these direct messages will not be shared with any other organisations.

Access, Review and Correction

The General Data Protection Regulations gives you the right to access your personal data held by us (“subject access request”). If you have an established business relationship with ThinkinCircles, you may request from us a list of the categories of personal information held about you. Subject access requests must be made in writing to the details below. We will endeavour to respond to the request within a reasonable period and in any event within one month as required by the relevant provisions in the GDPR.

It is important that the personal data we hold about you is accurate and current. We will take all reasonable measures to ensure that the personal data we hold about you is accurate. When you make a request to access or review the personal data we hold about you, we will request you to verify your identity before the request can be fulfilled.

Privacy Rights

In addition to the rights of access, review and correction, you have the right to object to your personal data being processed for any particular purpose, or to request that we stop using your information. If you wish to exercise these rights, please e-mail dataprotection@firstinternet.co.uk or send a letter marked “Data Protection” to ThinkinCircless offices at The Vestry, 38 Watling Street East, Towcester, NN12 6AF. If you have further concerns about how we use your personal data, you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the data protection authority for the UK. Please visit https://ico.org.uk/ for more details on your data protection rights and how to contact them.

Cookies

Harmless cookies that are designed to enhance your user experience of this website are stored on your device. These consist of small data files relating to you and this website.

Information stored in cookies created by ThinkinCircles Ltd. are not shared with any third party unless required to do so by law.

By continuing to browse this website you are consenting to the storage of its first party cookies on your device.

Should you disagree to the storage of first party cookies from this website on your device please here to remove them and discontinue browsing this website.

The first party cookies used by this website include (but may not be limited to):

  • __utma: Google Analytics cookie that refers to the number of times you have visited our website and the first and the last visit times.
  • __utmb and __utmc: Google Analytics cookies that contain timestamps of time you enter and leave our website.
  • __utmz: Google Analytics cookie that tracks which search engine you have used to come to this website, which keyword(s) you used to find the website, which link(s) you have clicked on within the website and where you were located when you clicked that link.
  • The third party cookies that have been set as a result of browsing this website include (but may not be limited to):
  • datr: A Facebook cookie that monitors your Facebook account for suspicious behaviour such as failed login attempts or attempts to create spam accounts.
  • lu: A Facebook cookie that is used to identify public computers where users are logging into Facebook using the same browser. This identification helps to provide more secure login features to Facebook users using public computers.
  • locale: A Facebook cookie that identifies user’s language and country.
  • SID: A Google cookie that is used as your unique identification for services provided by Google.
  • HSID: A Google cookie that works in a similar way to SID cookie with the only difference that it is not accessible from JavaScript.
  • PREF: A Google cookie that is used to protect you from malware and phishing attacks and maintain language preferences on Google websites.
  • NID: A Google cookie that stores preferences referring to a particular website.
  • Please note that third party cookies may not be controlled by us and are part of your agreement with the third party, e.g. if you are logged in to Facebook or Google. However, most Internet browsers give you the facility to delete cookies that you do not want stored on your device. You can usually visit your browser’s website for instructions on how to do this.

This privacy and cookie policy was last updated on 15th May, 2018.