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Privacy & Cookies Policy


INTRODUCTION

We, ThinkWhere Limited (Company Number SC315349) (“we”, “us”, “our”) are committed to protecting and respecting the privacy of everyone who visits our website, https://thinkwhere.com (the “website”).

This privacy policy (“Policy”) will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.

In this Policy, when we refer to “you”, we are referring to you, as the person or entity accessing, viewing and/or using the website.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.


1. GLOSSARY

2. WHO WE ARE AND HOW TO CONTACT US

3. WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU

4. HOW WE USE YOUR PERSONAL INFORMATION

5. OUR LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION

6. DO WE SHARE YOUR PERSONAL INFORMATION?

7. WHERE WE STORE YOUR PERSONAL INFORMATION

8. HOW WE PROTECT YOUR PERSONAL INFORMATION

9. THIRD PARTY LINKS

10. YOUR RIGHTS UNDER THE DATA PROTECTION LEGISLATION

11. ACCESS TO YOUR PERSONAL INFORMATION

12. RETENTION PERIODS

13. COOKIES

14. ABOUT COOKIES

15. COOKIES THAT WE USE

16. COOKIES USED BY OUR SERVICE PROVIDERS

17. MANAGING COOKIES

18. CHANGES TO OUR PRIVACY POLICY


1. GLOSSARY

When we refer to Data Protection Legislation we mean the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”); the Data Protection Act 2018; and all applicable laws and regulations relating to the processing of personal information and privacy.

Personal information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number, email address, etc., and also online identifiers and location data such as IP addresses and mobile device IDs.

Special category data means personal information revealing your racial or ethnic origin; political opinions; religious or philosophical beliefs; or trade union membership; genetic data; biometric data; data related to your health or data concerning your sex life or sexual orientation; and criminal convictions or involvement in criminal proceedings.

A controller is someone who decides why personal data is to be collected and how it will be used and treated.

2. WHO WE ARE AND HOW TO CONTACT US

Where we collect and process your personal data through the website we are the controller for the purposes of Data Protection Legislation.

If you need to contact us for any reason regarding this Policy, including the collection and / or use of your personal data, or as otherwise indicated in any section of this Policy, our contact details are:

If you are unhappy with how we handle your personal information you can:

  • submit a complaint in writing for the attention of the Chief Executive, thinkWhere Limited, 8-10 Corn Exchange Road, Stirling, FK8 2HU; and/or
  • notify the Information Commissioner’s Office (ICO) by calling their helpline on: 0303 123 1113.

3. WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU

Personal information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number or email address.

We may collect and process the following information about you when you contact us via the website, by email or telephone: Information which is given by you

We collect information you give us when you:

  • contact us by e-mail or otherwise. The information you give us may include your name, organisation, email address, and telephone number and any other information you choose to provide; and
  • apply for a job vacancy via email/post. The information you give to us (in your CV and cover letter) may include: your name and contact details (e.g. telephone numbers, postal address, email address, etc.), education history and qualifications, employment history and any other information you choose to provide us.

We ask that you do not provide any special category data to us or any personal information which is not relevant to your query.

Information we collect about you

  • Technical Data: With each of your visits to the website (regardless of whether you register or log in during your visit), we will automatically collect the following information: [your Internet Protocol (IP) address, log in information, browser type and version, time zone and setting, browser plug in types and version, operating system and platform;
  • Usage Data: information about your visit and how you use our website, including pages and products you viewed during your visit, any search terms entered on our website, length of time spent on each page, page response times, download errors;
  • If you contact us, we may keep a record of that correspondence or telephone call;

Marketing and Communication Data

When you sign up to receive our newsletter and/or details of our products and services that may interest you we will collect your name and email address. You may also choose to provide your telephone number and the name of your organisation.


4. OUR LEGAL GROUNDS FOR PROCESSING PERSONAL INFORMATION

Our legal grounds for processing your personal information are:

  • your consent, where you have agreed to us using your personal information;
  • the processing is necessary for compliance with a legal obligation to which we are subject;
  • the processing is necessary to take steps at your request prior to entering into a contract (including a contract of employment); or
  • the processing is necessary for the purpose of our legitimate interests or those of a third party, such as financial interests, operational and administrative interests, ensuring security, maintaining our relationship with you, marketing, optimising and understanding the use of our site, research and statistical analysis.

5. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information as the law allows us to. Most commonly we will use your personal data in the following circumstances:

  • if you contact us via the website (or using any of the email or postal addresses or phone numbers provided on the website) to submit a query or complaint, we will use the personal information you provide to respond to your query or complaint. We may keep a record of these communications to allow us to progress our communications or demonstrate how we dealt with your query/complaint (legal basis: legitimate interests, contractual obligations or legal obligations);
  • Where you have submitted a CV and cover letter/email to us we will process your personal data to assess your skills and experience to determine your suitability for working with us and to communicate with you about the recruitment or assessment decision process (legal basis: performance of our contract with you and legitimate interests);
  • if you contact us to request our goods or services we will process your personal data to allow us to enter into a contract with you (legal basis: necessary for the purpose of entering into a contract);
  • to send our existing customers information about products and services that we think may be of interest to you (legal basis: legitimate interests (for non-electronic communications) or consent (for electronic communications);
  • to provide you with our direct marketing materials by email (legal basis: consent);
  • Where we need to comply with a legal or regulatory obligation (legal basis: necessary for compliance with a legal obligation to which we are subject);
  • we use Technical Data and Usage Data to help us better understand how visitors use the website to enable us to create better content and provide a better service (legal basis: our legitimate interests).
  • Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at info@thinkwhere.com.

6. DO WE SHARE YOUR PERSONAL INFORMATION?

Except as provided below, we will not share personal information with any other third parties without informing you beforehand, unless required by, or in connection with, law and / or regulatory requirements.

We may share your personal data with the following parties, for the purposes noted below:

  • analytics and search engine providers that assist us in the improvement and optimisation of our site and our providers of web and hosting services;
  • we may share your details with our third party e-mail platform who provide and host our email service, currently Lithium Systems Limited;
  • the company who provides web design and hosting services to us, currently i23 Design Ltd;
  • when we believe it is appropriate to comply with the law, we may disclose information about you to law enforcement officials in the investigation of any alleged unlawful activities by you. We may also be required to disclose information to a court or regulatory body when required to do so by law.

We will not sell, trade or lease your personal information to others.


7. WHERE WE STORE YOUR PERSONAL INFORMATION

The information which we collect about you will usually be stored inside the UK or the European Economic Area (EEA). However, we may transfer data outside the UK or EEA where our service providers host, process or store data outside the UK or EEA. Where we do this, we will ensure that the transfer is to a country covered by the decision of the European Commission or is otherwise made in circumstances where we have put appropriate safeguards in place to protect your data in accordance with Data Protection Legislation.


8. HOW WE PROTECT YOUR INFORMATION

We implement a variety of security measures to maintain the safety of your personal information. Our security is reviewed and enhanced as necessary. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Unfortunately, the transmission of information via the internet is not completely secure and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk.


9. THIRD PARTY LINKS

The Website may, from time to time, contain links to and from other websites. Please note that this document applies solely to the personal information collected by us and does not apply to any third party websites. We are not responsible for the privacy policies, content or use of these websites and we advise you to read the privacy policy and terms of use of any third party websites before you submit any personal data to them.


10. YOUR RIGHTS UNDER THE DATA PROTECTION LEGISLATION

You have the following rights in respect of the information we process about you:

  • the right to access information held about you by making a subject access request in accordance with the Data Protection Legislation. Until 25 May 2018 we may charge a fee of £10 for any requests. After 25 May 2018 we may charge a reasonable fee when a request is manifestly unfounded or excessive;
  • the right to request us to rectify personal information concerning you which is inaccurate or incomplete;
  • the right to request us to erase personal information concerning you (in certain conditions as set out in the Data Protection Legislation);
  • the right to object to the processing of your information by us as well as the right to request us to restrict the extent to which we process your personal information (both in certain conditions as set out in the Data Protection Legislation);
  • the right to data portability (in certain conditions out in the Data Protection Legislation);
  • the right to ask us not to process your personal information for marketing purposes. You can exercise your right by contacting us at info@thinkwhere.com;
  • the right to know about any automated decision-making or profiling;
  • where you have provided your consent to us for us to process your personal information, you have the right to withdraw your consent by informing us (which will not affect the lawfulness of any processing carried out before you withdraw consent); and
  • the right to lodge a complaint with the Information Commissioner’s Office in the UK.
  • The above rights may be exercised in accordance with data protection law.

11. ACCESS TO YOUR PERSONAL INFORMATION

You have the right to request a copy of personal information that we hold about you under the Data Protection Legislation. To do this, simply contact us. Should we be prevented from disclosing your personal information, reasons will be given for the refusal. We may also request that you provide further information and identification to enable your request to be processed.

If you believe that any information we hold about you is incorrect or incomplete, please contact us. We will thereafter correct any information found to be incorrect. You can find detailed information about your rights under the Data Protection legislation on the UK Information Commissioner’s website: http://www.ico.org.uk/.


12. RETENTION PERIODS

We will not store your personal data longer than necessary for the uses outlined above, unless it is required to do so to comply with the law and / or any regulatory requirements.

When you contact us with a query or complaint by email or telephone we will retain your information for the purposes of dealing with your query and /or for entering into a contract with you.

When you apply for a job vacancy, we will retain your information for a period of 6 months after we have communicated to you our decision about your application. After this period, and if you are not successful in your application, we will securely destroy or anonymise your personal information. If you would like us to retain your personal information on file in case another opportunity may arise in the future so that we can consider you for that opportunity, please e-mail or write to us at info@thinkwhere.com. We will continue to hold your personal information for this purpose for 12 months after receipt of your written confirmation.


13. COOKIES

This website uses cookies. Cookies enable our system to recognise your computer and allow us to see how you use our site. Cookies enhance website performance in several ways, including provision of a secure way to measure website usage. This helps us to determine what is popular and can influence future content and development of our site.


14. ABOUT COOKIES

14.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

14.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

14.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.


15. COOKIES THAT WE USE

15.1  We use cookies for the following purposes:

(a)    authentication – we use cookies to identify you when you visit our website and as you navigate our website;

(b)    status – we use cookies to help us to determine if you are logged into our website;

(c)    personalisation – we use cookies to store information about your preferences and to personalise the website for you;

(d)    security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e)    advertising – we use cookies to help us to display advertisements that will be relevant to you;

(f)    analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(g)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.


16. COOKIES USED BY OUR SERVICE PROVIDERS

16.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

16.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: www.google.com/policies/privacy.


17. MANAGING COOKIES

17.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

17.2  Blocking all cookies will have a negative impact upon the usability of many websites.

17.3  If you block cookies, you will not be able to use all the features on our website.


18. CHANGES TO OUR PRIVACY POLICY

We keep this Policy under regular review and in the event we make any changes we will place an updated version on our Website and, where appropriate, notify you by e-mail, seek your consent or place a notification on the Website. Please review this page regularly to ensure that you are always aware of what personal information we collect, how we use it and under what circumstances we will share it with other parties.

This policy was last amended on 18 May 2018.