Website Privacy Notice
This is the privacy notice of the Extended Thinking Ltd. On this page, “we”, “our”, or “us” refers to ‘Extended Thinking’ as an organisation. We are a marketing consultancy.
Introduction
This is a notice to inform you of our policy about all the information that we record about you via our website. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. If you do not like any of the following points that follow, your only recourse is to leave our website immediately and to contact us by phone (t +44 (0) 1483 429111) if you need information about us and our services.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine defined bases by which we process different categories of your personal information, and to notify you of the basis for each category. These follow in points numbered 1 to 4. If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.
If the basis changes then, if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you have any contractual relationship with us i.e. purchase a service from us to separately agreed terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- Support the commercial relationship
- Provide you with our services and related consultancy advice
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
We should add however, such ‘processing’ is not performed via / using our website. Alternative means would be employed whenever this was applicable.
This would include data relating to supporting ‘software package’ user names and passwords to log into systems that we use to help deliver our services. Reference: Where we do need to communicate regarding these, they will NEVER be communicated together in electronic format. Passwords will always only be advised separately from log in details, and will generally be via a different medium.
2. Information we process with your consent
Through certain actions when there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including our services, you provide your consent to us to process information you give us that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by our website’s contact page or published email addresses to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally, although in theory we could identified the IP address of the terminal it is sent from. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us accordingly.
3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would in judgement consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage any related business risk
- protecting your interests where we believe we have a duty to do so
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
Specific uses of information you provide to us
Information provided on the understanding that it will be shared with a third party
Such activities are NOT possible via our website. Alternative means would be employed whenever this was applicable.
Via these alternative means, ‘if’ you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider can provide supporting ‘services and expertise’ you would find useful. We would also advise you of these organisations before contacting them with your details.
Complaints regarding content on our website
Our website is a publishing medium. It reflects how we want to portray our business and services.
If you were to complain about any of the content on our website, we would investigate your complaint.
If we feel it is justified, or if we believe the law requires us to do so, we would remove the content while we investigate. If we think your complaint is vexatious or without any basis, we would not correspond with you about it.
Should you make complaints about other matters, non-website related, they will fall under separate protocols.
Use of information we collect through our website
Cookies
This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics.
As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser.
We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.
Personal identifiers from your browsing activity
Requests by your web browser to our server for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Disclosure and sharing of your information
Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. For example, summary reports from social media site or website analytics you may ask us to use on your behalf. No such information is personally identifiable to you.
Data processing outside of the UK & the European Union
Our website is hosted in the United States of America.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. This means data obtained within the UK or any other country could be processed outside the European Union. For example, some of the software our services use may have been developed in or are hosted in other countries i.e. the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union:
- The processor is within the same type of business group as our business and abides by the same binding corporate rules regarding data processing.
- The data protection clauses in our contracts with data processors include transfer clauses to ensure they do not perform any other actions with that data.
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by;
- Our US-based providers are part of EU-US Privacy Shield, so we may transfer data to them, as they have equivalent safeguards in place.
Access to your own information
Access to your personal information
At any time you may review or update personally identifiable information that we hold about you, by contacting us.
After receiving the request, we will tell you when we expect to provide you with the information.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information or any financial aspect of our relationship with you, we shall first take reasonable steps to verify your identity before granting or otherwise taking any action. This is important to safeguard your information.
Other matters
Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by UK tax authorities;
- to support any claim or defence in court.
Compliance with the law
Our privacy policy has been compiled so as to comply with UK law. If you think it fails to satisfy this in anyway, we would like to hear from you.
Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. If you have any question regarding this privacy policy, please contact us.
Reference(s) = The Principles of good Data Protection =
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
To support the above…
We have relevant security controls in place, both physically and electronically to protect your data. These are supported by Data Audits we conduct to check related controls remain effective. All Extended Thinking staff have been suitably trained in GDPR requirements and involved controls / disciplines.
