2. Who we are
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR), says we have to give you as a ‘data controller’:
- Our site address is www.thrivecommunications.co.uk
- Our company name is Thrive Communications Ltd.
- Our company is registered in England and Wales and our company number is 09094722
- Our registered address is 29 Freelands Road, Bromley, Kent BR1 3HZ, United Kingdom
- Our nominated representative for policy queries is our Managing Director, who can be reached at firstname.lastname@example.org.
3. What we may collect
We may collect, store and use the following kinds of personal information:
- information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
- information you put into forms or surveys on our site at any time, including email addresses;
- a record of any correspondence between us;
- details of your visits to our site and the resources you use
information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
- information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);
- information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication);
- any other personal information that you choose to send to us.
Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
4. How we use what we collect
Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information to:
- administer our website and business;
- personalise our website for you;
- enable your use of the services available on our website;
- tell you about our charges;
- send you goods purchased through our website;
- supply to you services purchased through our website;
- send statements, invoices and payment reminders to you, and collect payments from you;
- send you non-marketing commercial communications;
- send you email notifications that you have specifically requested;
- send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
- send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
- provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
- deal with enquiries and complaints made by or about you relating to our website;
- keep our website secure and prevent fraud; and
- verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).
If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
If you don’t want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at email@example.com and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
5. Where we store your data
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
6. Retaining personal information
This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
- to the extent that we are required to do so by law;
- if we believe that the documents may be relevant to any on-going or prospective legal proceedings; and
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Disclosing personal information
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information:
- to the extent that we are required to do so by law;
- in connection with any on-going or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Except as provided in this policy, we will not provide your personal information to third parties.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
8. Updating your personal information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
9. Security of personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
10. Your rights
In a majority of instances, our justification for processing your personal data will be consent or legitimate interests.
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes.
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
11. Third party websites
Our website includes hyperlinks to, and details of, third party websites.
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of changes to this policy by email.
All Cookies used by and on our website are used in accordance with current English and EU Cookie Law.
A few of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the site and will last for longer.
All cookies used on our site are set by us.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can prevent the setting of cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site.
We use Google Analytics to improve our website’s usability.
Our cookies will be used for:
Essential session management
- recognising when a user of the site has visited before allowing us to identify the number of unique users we receive to the site and make sure we have enough capacity for the number of users that we get;
- recognising if a visitor to the site is registered with us in any way;
- we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our site.
Functionality & reporting
- customising elements of the promotional layout and/or content of the pages of the site.
- performance and measurement
- collecting statistical information via Google Analytics about how our users use the site so that we can improve the site and learn which parts are most popular to users.