Your information is in safe hands
When you submit your information to The Thought Box, our primary concern is storing it securely. From time to time, we may let you know about our own products and promotional offers we believe are relevant to you. Please be assured – we never sell data to third parties. Your trust is important to us and we value your right to privacy.
- Sets out the types of personal data that we collect
- Explains how we use your data
- Explains how we ensure your privacy is maintained
- Explains the rights and choices you have when it comes to your personal data
This policy also applies to information we collect about people who use our services and our website.
Under the General Data Protection Legislation (‘GDPR’), The Thought Box is classed as ‘the Data Controller’ and the individual whose data we have collected is known as the data ‘subject’.
If you require any further information you can contact the Data Protection Officer directly at firstname.lastname@example.org or post to Data Protection Officer, The Thought Box, 274 High Road, London, NW10 2EY.
What types of data does The Thought Box collect?
When you register with us, use or enquire about our Services, you may provide us with the following pieces of personal data:
- Name and job title
- Company name and address
- Contact information including email address
- Financial details for invoicing and payment processing purposes
- Names and phone numbers of contacts you hold
- Information you believe is relevant and necessary to deliver services e.g. payment preferences, preferred contact times
Whilst delivering our services we may also collect the phone number the call originated from.
In instances where we, The Thought Box, collect personal data we are known as the data ‘controller’ in instances where our clients supply the personal data we are known as the data ‘processor’. When acting as a data processor we will manage on your behalf the personal information you require from your clients.
What The Thought Box does with the information we gather
The Thought Box wants to provide the best service experience; we therefore gather this data to understand your needs and personalise our service, thus providing you with a better service experience. In particular, the information will be used for:
- Providing a tailored and personalised service to clients and customers with products and services most likely to interest you
- Internal audit purposes
- Providing anonymous usage reports to our clients
- Improving our services
- Processing payments
- Periodically send promotional or market research communications which we think you may find interesting using the contact details which you have provided. The Thought Box may contact you by email, phone, SMS or mail. The lawful basis on which we process data for this purpose includes:
- If you’re a customer – a customer/contractual consent
- If you’ve enquired about our services – either consent (where we’re obliged to obtain), or legitimate interest will apply
How long do we keep your data?
The Thought Box will keep your information for as long as we are providing you a service or are likely to provide a service due to an enquiry we have received.
We will retain records after our business relationship has ended in accordance with our Data Retention Policy which can be accessed on our website. After this time your data will be securely deleted.
Where data is processed solely for marketing purposes, any information we use for this purpose will be kept until you notify us that you no longer wish to receive this information, or until the data is deleted in accordance with our Data Retention Policy, whichever is earliest. As part of ensuring we are providing the right services to you we may use your data to pursue our legitimate interests in a way which would reasonably be expected as part of running our business and supplying services, this will be done in a way that does not materially impact your rights, freedom or interests.
For example, we may use the services and products supplied historically to you to support or make available personalised offers.
We may also use your address details to post out direct marketing materials telling you about products and services that we think may be of interest to you.
You may choose to opt out of any marketing communications at any time by emailing us at email@example.com or post to Data Protection Officer, The Thought Box, 274 High Road, London, NW10 2EY.
Sensitive Personal Data
It may benefit you to notify us of any health condition or disability you have so that we are aware of these conditions and how they affect you. This will allow us to take any reasonable steps to accommodate specific needs or requirements you have when providing our services to you. This type of information is known under the law as ‘special category information’ (or ‘sensitive personal data’) and we require your explicit consent to process this information.
This data will only be kept as long as it is required for this purpose, or until such time as you notify us you no longer consent to its processing.
Sharing your personal data
The Thought Box works with carefully selected Service Providers that carry out certain functions on our behalf to support the services provided to you. These include, for example, companies that help us with technology services, storing and combining data, processing payments. We only share personal data that enable our Service Providers to provide their services and it will always be shared in a secure and appropriate manner.
We may share personal data with other organisations in the following circumstances:
- If the law or a public authority says we must share the personal data;
- If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk);
- To an organisation we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us; or
- To any other successors in title to our business
How we protect personal data
We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.
- We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe. We only authorise access to employees who need it to carry out their job responsibilities.
- We protect the security of your information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).
- We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We may occasionally ask for proof of identity before we share your personal data with you.
However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.
All data, when no longer required will be treated in accordance with our Data Retention Policy
Your rights and choices relating to your personal data
Under data protection legislation, you have several rights regarding the use of your personal data, as follows:
The Right of Confirmation and Access
As a data subject you have the right to obtain confirmation from the data controller as to whether or not personal data concerning you is being processed. You also have the right to obtain from us free information about your personal data stored at any time, and a copy of this information. Furthermore, you have the right to obtain information as to whether personal data is transferred to a third country or to an international organisation. Where this is the case, you also have the right to be informed of the appropriate safeguards relating to the transfer.
Right to Rectification and Erasure (Right to be Forgotten)
You have the right to ask us to rectify inaccurate data or to complete any incomplete personal data that we hold.
You have the right to ask us to erase your personal data without delay where one of the statutory grounds applies, so long as the processing is not necessary. If you request us to erase your personal data, then this means that our business relationship will end as we cannot provide our service without processing your data.
Right of Restriction of Processing/Right to Object
You have the right to restrict the processing of your personal data under certain circumstances, including if you have contested its accuracy and while this is being verified by us, or if you have objected to its processing and while we are considering whether we have legitimate grounds to continue to do so. You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you.
Right of Data Portability
You also have the right for certain data you have given us to be provided to you in a structured and commonly used electronic format (for example, a Microsoft Excel file), so that you can move, copy or transfer this data easily to another data controller. You may also request that we transmit this data directly to another organisation where it is practical for us to do so.
Automated individual decision-making, including profiling
You have the right not to be subjected to a decision based solely on automated processing, including profiling. The Thought Box do not process any personal data in this way.
Data protection for Employment and Recruitment Procedures
Details of how we process data for recruitment or employment procedures are covered separately and will be provided to applicants/employees as part of the HR process.
How to exercise your Rights
If you wish to contact us in respect of any of the Rights described above, please get in touch with our Data Protection Officer via email at firstname.lastname@example.org. We will respond to your request free of charge and usually within one month.
How to complain about the use of your data
If you wish to raise a complaint about how we have handled your personal data, including in relation to any of the rights outlined above, you can contact us on the details below at the start of this notice and we will investigate the matter for you.
If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Supervisory Authority – Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. You can find further information about the ICO and their complaints procedure here: https://ico.org.uk/concerns/
This notice was last updated on 05/05/2020. We may change this notice by updating this page to reflect changes in the law or our privacy practices. However, we will not use your Personal Data in any new ways without your consent.