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.
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.
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.
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
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
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.
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.
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 firstname.lastname@example.org 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.
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