1. Introduction
1.1 We are committed to putting the privacy of our service users and website visitors at the heart of everything we do.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors, service users or prospective users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website only uses cookies that are essential for it to work and, if you agree, cookies for our live chat. Our Cookies Policy at the end of this page explains them.
1.4 You can access privacy controls which affect how we will process your personal data via your web browser. 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 controlling your privacy via your browser's help pages, or at aboutcookies.org.
1.5 In this policy, “we”, “us” and “our” refer to Think Comms Limited. For more information about us, see Section 8.
2. How we collect and use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process; (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing.
2.2 We do not currently use analytics or tracking tools on our website. If we introduce them, we will update this policy and ask for your consent where the law requires it.
2.3 We may process your (“acquired data”). The acquired data will be minimised for its purpose, including your business name and/or personal name, job title, job description, mobile number, landline number, email address and relevant public information. The sources of your acquired data are from credit reference agencies or third-party UK direct marketing companies who are members of the Data & Marketing Association and are subject to our internal compliance checks. These agencies and/or companies can be disclosed upon request. This acquired data may be processed for the purposes of marketing suitable services and/or products we may offer. The legal basis for this processing is consent for individuals, or legitimate interests for corporate subscribers.
2.4 We may process your account data (“account data”). The account data may include your business name and/or personal name, date of birth, job description, mobile number, landline number, email address and relevant public information. The source of the account data is you. The account data may be processed for the purposes of providing our services, operating our website, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you securely. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and the proper administration of the business and/or website.
2.5 We may process your personal data that is provided in the course of the use of our services (“service data”). The service data may include your name, address, telephone number, email address, gender, date of birth, relationship status, interests and hobbies, and employment details. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services we may offer (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services, goods or employment to you. The legal basis for this processing is legitimate interests.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us (“transaction data”). The transaction data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, residential status, interests, hobbies, employment details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business and/or your interest in being provided the most relevant products and/or services.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you relevant notifications and/or newsletters. The legal basis for this processing is consent, namely communicating updates and benefits surrounding products and ongoing relevant services, which also support the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.10 We may process information contained in or relating to any communication between you and us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the relevant communication. Our website may generate the metadata associated with communications made using contact forms on the website. We will never actively acquire personal sensitive information of any type, however we may hold this if presented by you during any communication. The legal basis for this processing is namely the protection and assertion of our legal rights, your legal rights and the legal rights of others and the proper administration of our business, your services and communications with users.
2.11 We may process information contained in call recordings. This data may include anything set out in clause 2.3 and 2.4. The source of this data is from the individual. This data may be processed for quality monitoring, training, compliance and security purposes. We will never actively acquire personal sensitive information of any type; however we may hold this if presented by you during any communication. The legal basis for this processing is lawful, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others and the proper administration of our business, your services and communications.
These recordings will only be used for the purposes specified in this policy.
2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our lawful, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.15 We do not actively request details about personal sensitive information, including criminal personal data. However, it may be recorded if it is provided by you (or a third party) as part of the quote for our service and /or administration process whether through phone, email letter, or via a website, PDA, social media, online chat, Short Message Service (SMS) and Instant messengers i.e. Whatsapp and Facebook Messenger.
2.16 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We will only disclose your personal data to others as set out in this Section 3.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose your personal data to some of our suppliers identified below insofar for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
List of suppliers:
3.4 We may disclose your personal data to our subcontractor Giacom (https://www.giacom.com/) insofar as reasonably necessary for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.5 Financial transactions relating to our website and services are handled by our payment services provider, Barclays merchant services. We will share transactional data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about Barclays privacy policies and practices at [https://www.barclayscorporate.com/general-info/privacy-and-cookies.html].
3.6 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified during negotiations for the purpose of providing you with relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
3.7 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we explain where your personal data is stored and how it is protected if it is transferred outside the United Kingdom.
4.2 We have offices and facilities in the United Kingdom only. If your personal data is ever transferred outside the UK, it will be protected by the safeguards required by UK data protection law, such as transfers to countries covered by UK adequacy regulations, or the International Data Transfer Agreement or Addendum approved by the Information Commissioner's Office.
4.3 Our website is hosted by GoDaddy. Any personal data processed through our website is protected by the safeguards described in Section 4.2.
4.4 We use Zoho to manage enquiries, live chat and customer records (“enquiry data and account data”). Zoho stores this data on its servers in the United States, and it is protected by the safeguards described in Section 4.2.
4.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 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 data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) personal data categories will be retained for a minimum period of six months following the expiry or termination of services or contract, and for a maximum period of 6 years following the expiry or termination of services or contract
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the retention period of (“acquired data”) will be determined by the terms and conditions set out by relevant third party UK marketing agencies.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 We recommend you check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may also notify you of changes to this policy by email.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.
7.3 You have the right to: confirmation as to whether or not we process your personal data and, where your personal data is processed. You also have the right to have access to the personal data we share together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. For full information regarding Think Comms’s Subject Access Request procedure, visit https://think-comms.com/.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes; including profiling for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or research purposes or statistical purposes on grounds relating to your situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; legitimate interest or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. The UK’s supervisory authority is the Information Commissioners Office details of which can be found at www.ico.org.uk.
7.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by visiting https://think-comms.com/ and following the guidelines we have produced in addition to the other methods specified in this Section 7.
8. Our Details
8.1 We are registered in England and Wales under registration number 09217818, and our registered office is at Kintyre House, 70 High Street, Fareham, Hampshire PO16 7BB.
8.2 This website is owned and operated by Think Comms Limited.
8.3 Our trading address is 54a High Street, Fareham, Hampshire PO16 7BG.
8.4 You can contact us:
(a) by post, to the postal address given above; (b) using our website contact form; (c) by telephone, on the contact number published on our website; or (d) by email, using the email address published on our website.
9. Data protection enquiries
9.1 For all general enquiries relating to your personal data or anything related to this privacy policy please email info@think-comms.com.
Cookies Policy
Cookies are small text files that websites place on your device. Our website uses as few as possible, and none for advertising or analytics.
Essential. We save your cookie choice on your device so we do not ask you again on every page. This is needed for the site to work, so it does not need your consent.
Live chat (only if you agree). Our live chat is provided by Zoho SalesIQ. If you accept chat cookies, Zoho sets cookies that keep your conversation going as you move between pages and recognise you if you come back. If you do not accept, the chat does not load and no Zoho cookies are set. You can still call us or use our contact forms.
Changing your choice. You can change your mind at any time using the Cookie settings link at the bottom of every page. You can also delete or block cookies in your browser settings; aboutcookies.org explains how.
We do not use advertising, tracking or analytics cookies. If that changes, we will update this policy and ask for your consent first.