Website privacy policy

Policy date: August 2021

www.thinkincircles.com (our website) is provided by THINKINCIRCLES LTD (‘we’, ‘our’ or ‘us’) via website host www.thinkincircles.com. We are the controller of personal data obtained via our website, meaning we are the organisation that is legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint. 

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals in the European Economic Area (EEA).

Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years of age. If you are aware that any personal data of anyone under 13 years of age has been shared with our website please let us know so that we can delete that data.

This version of our privacy policy is primarily written for adults, including parents and guardians of child users. 

This privacy policy is divided into the following sections:

  • What this policy applies to
  • Personal data we collect about you
  • How your personal data is collected
  • How and why we use your personal data
  • Marketing
  • Who we share your personal data with
  • How long your personal data will be kept
  • Transferring your personal data out of the UK and EEA
  • Cookies and other tracking technologies
  • Your rights
  • Keeping your personal data secure
  • How to complain
  • Changes to this privacy policy
  • How to contact us
  • Do you need extra help?

What this policy applies to

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by third parties. Those other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

  • your name, address and contact information, including email address and telephone number and company details
  • location data
  • details of any information, feedback or other matters you give us by phone, email, post or via social media
  • your activities on, and use of, our website
  • information about how you use our website and technology systems

If you do not provide personal data we ask for where it is required, it may prevent or delay our services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you: 

  • directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback or purchase services via our website, and 
  • indirectly, such as your browsing activity while on our website; we will collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract, or
  • for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Create and manage your account with us

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Providing services to you

To perform our contract with you or to take steps at your request before entering into a contract

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us

To comply with our legal and regulatory obligations; and

For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

To comply with our legal and regulatory obligations

In other cases, for our legitimate interests or those of a third party, ie to protect our business, interests and rights or those of others

Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website

Depending on the circumstances:

Your consent as gathered via cookies on our Website, see ‘Cookies’ below

Where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended

Depending on the circumstances:

Your consent as gathered via cookies on our website—see ‘Cookies’ below

Where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Communications with you not related to marketing, including about changes to our terms or policies or changes to the products services or other important notices 

Depending on the circumstances:

To comply with our legal and regulatory obligations

In other cases, for our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Protecting the security of systems and data

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Updating and enhancing customer records

Depending on the circumstances:

To perform our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

Where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant 

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers 

For our legitimate interests or those of a third party, ie to promote our business to existing and former customers

See ‘Marketing’ below for further information

External audits and quality checks, eg for the audit of our accounts

For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards

We may need to share your personal data with members of our group in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

To comply with our legal and regulatory obligations

In other cases, for our legitimate interests or those of a third party, ie to protect, realise or grow the value in our business and assets

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Services feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not store any Financial Data (this includes bank account and payment card details) or 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). 

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us at info@thinkincircles.com or
  • using the ‘unsubscribe’ link in emails 

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the group for marketing purposes.

For more information on your rights to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We may occasionally also need to share personal data with:

  • external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
  • professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
  • other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

Transferring your personal data out of the UK and EEA

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. 

It is sometimes necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will also ensure all protections required by applicable UK and EEA laws are in place before transferring personal data to any organisation or body (or its subordinate bodies) governed by public international law or set up by, or on the basis of, an agreement between two or more countries (international organisations). 

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

  • in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. 
  • in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. 
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
  • a specific exception applies under relevant data protection law

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where such is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data

The right to be provided with a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:

—at any time to your personal data being used for direct marketing (including profiling)

—in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests.

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our website.

For further information on each of those rights, including the circumstances in which they apply and circumstances in which they do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (eg your full name and address) and any additional identity information we may reasonably request from you, and
  • let us know what right you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK. The UK Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

How to contact us

Individuals in the UK

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

[Our Data Protection Officer’s contact details]

C/O Partners In Enterprise, 5 Bartholomews, Brighton, East Sussex, England, BN1 1HG info@thinkincircles.com

C/O Partners In Enterprise, 5 Bartholomews, Brighton, East Sussex, England, BN1 1HG info@thinkincircles.com

Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).