Privacy Policy 

OutThink respects your privacy and is committed to protecting your personal data. 
This privacy notice will inform you as to how we look after your personal data:

• • when you visit our website (regardless of where you visit it from),
  • when you engage with us as a customer,
  • when you access OutThink’s services, applications and platforms (the Platform) as a user.

The policy tells you about your privacy rights and how the law protects you. Please use the Glossary at paragraph 11 below to understand the meaning of some of the terms used in this privacy notice. 

Purpose of this Privacy Notice

This privacy notice gives you information on how OutThink collects and processes your personal data through your use of the OutThink website and Platform, including any data you may provide through the website when you sign up to our newsletter or purchase a product or service.  This website is not intended for children and we do not knowingly collect data relating to children. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

1. IMPORTANT INFORMATION AND WHO WE ARE  

For the purposes of the data protection legislation, OutThink is the controller of your personal data (collectively referred to as OutThink, we, us or our in this privacy notice). We are registered with the Information Commissioners Office in the UK with reference number ZA514868. 

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below. 

CONTACT DETAILS  

Our full details are: 

OutThink Ltd 
Email address: office@outthink.io
Postal address: 80 Cheapside, London, EC2V 6EE, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES 

This version was last updated on 16 May 2024 and historic versions can be obtained by emailing office@outthink.io. 

It is important that the personal data we hold about you is accurate and current. 

Please keep us informed if your personal data changes during your relationship with us. 

THIRD-PARTY LINKS 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

2.  THE DATA WE COLLECT ABOUT YOU 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been irreversibly removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

• • Identity Data includes name, username or similar identifier, title, date of birth and gender. 

• • Contact Data includes billing address, delivery address, business email address or academic email address (as applicable) and telephone numbers.  

• • Transaction Data includes details of products and services we have provided you with. 

• • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 

• • Profile Data includes your username and password, your interests, preferences, feedback and survey responses.  

• • Usage Data includes information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including data and time), reports, information you viewed or searched on our site, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs, sometimes accessed via heatmaps or user recordings), completion activity and methods used to browse away from the page. 

• • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.  

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. 

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. 

We do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences. 

IF YOU FAIL TO PROVIDE PERSONAL DATA 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to the Platform). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.  

3. HOW YOUR PERSONAL DATA IS COLLECTED 

We use different methods to collect data from and about you including through: 

• • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • • apply for our products or services; 
    • • create an account on our Platform; 
      • use the platform as an end-user;
    • • subscribe to our service or publications; 
    • • request marketing to be sent to you; 
    • • enter a competition, promotion or survey; or 
    • • give us some feedback.  

• • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar 

• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • • Technical Data from the following parties:
      • • analytics providers; 
      • • advertising networks; and 
      • • search information 

  • • Contact, Financial and Transaction Data from providers of technical, payment and delivery. 

• Identity and Contact Data from data brokers. 

4. HOW WE USE YOUR PERSONAL DATA 

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

• • Where we need to perform the contract we are about to enter into or have entered into with you.  

• • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.  

• • Where we need to comply with a legal or regulatory obligation.  

See below to find out more about the types of lawful basis that we will rely on to process your personal data. 

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via phone call or email. 

You have the right to withdraw consent to marketing at any time by emailing office@outthink.io, unsubscribing from any emails or logging onto the platform and changing your preferences. 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 

We have linked below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. 

We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 

Please contact us if you need details about the specific legal ground we are relying on (where there is more than one listed in the table above) to process your personal data. 

MARKETING 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

PROMOTIONAL OFFERS FROM US 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us or registered for a promotion and, in each case, you have not opted out of receiving that marketing. 

THIRD-PARTY MARKETING 

We will get your express opt-in consent before we share your personal data with any company outside OutThink for marketing purposes. 

OPTING OUT 

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing office@outthink.io at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service transaction. 

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

For more information about the cookies we use, please see our Cookie Policy available at www.outthink.io. 

CHANGE OF PURPOSE  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email office@outthink.io. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

5. DISCLOSURES OF YOUR PERSONAL DATA 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 

• • External Third Parties as set out in the Glossary below.  

• • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

6. INTERNATIONAL TRANSFERS 

Your personal information may be stored and processed in any country where we engage External Third Parties, including outside the EEA. Whilst these counties will have data protection rules that differ from the EEA, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected to the standards described in this privacy notice. 

7. DATA SECURITY 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

8. HOW LONG WE WILL RETAIN YOUR DATA FOR  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. 

In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

Once it is no longer necessary to process your personal data, your personal data will be anonymised so that you are no longer identified or identifiable from such information, or it will be securely deleted/destroyed. 

We may retain personal information about you for statistical purposes. Where data is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that data. 

For a list of all retention periods, please contact office@outthink.io. 

9. YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection legislation in relation to your personal data. You have the right to: 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 

Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please email us at office@outthink.io.

NO FEE USUALLY REQUIRED 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

WHAT WE MAY NEED FROM YOU 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 

This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

We may also contact you to ask you for further information in relation to your request to speed up our response. 

TIME LIMIT TO RESPOND 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

10. PLATFORM PROVIDED BY YOUR ORGANIZATION – NOTICE TO END USERS

If you use the Platform with access granted to you by an organization you are affiliated with, such as your employer, that organization can access and process your data, including:

• • Corporate contact details, including business email address, business location, department, manager, and company name, if elected to be included by your organization.

• • Security awareness training interaction data, such as answers to questions, elapsed time spent on aspects of training, date & time of completions, any comments and ratings you give.
  • Phishing simulation interaction data, such as whether you interacted with a phishing simulation, date & time of such interactions, comments and ratings you give.
  • Diagnostic data, including your IP Address and Browser User Agent.
  • Data related to your interaction and usage of Microsoft, Google or other vendor’s products, where provided for your use by your organization, and integrated with the Platform by your organization’s administrators.

11. GLOSSARY  

Legitimate Interest means the interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing office@outthink.io.   

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

THIRD PARTIES 

EXTERNAL THIRD PARTIES  

1. 1. Service providers acting as processors who provide IT and system administration services such as Amazon Web Services.  

2. 2. Google Analytics, a web analytics tool that helps us to understand how users engage with the Platform. It provides us with information relating to the number of users in the Platform, their characteristics and where they come from and it enables us to measure what actions users are taking. The information collected through analytics tools will always be anonymised and will never contain information that can be used to identify you. We use this information to understand users’ behaviour and to make improvements to the Platform. 

3. 3. Professional advisers acting as processors or joint controllers based in the EEA including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.  

4. 4. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.  

5. 5. Business acting as processors based in the EEA who provide feedback to us on placement of our academy users.  

PRIVACY POLICY – VERSION 2024.05.16

Cookie Policy 

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve the website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy below. 

OUTTHINK COOKIE POLICY

OutThink Limited (“OutThink”) is committed to protecting you and any data that we collect about you online. This section tells you how and why we use cookies and how this allows us to improve our service. It also tells you how you can manage what cookies are stored on your device. By using our websites (through any device) you agree that this Cookie Policy applies to that use in addition to any other terms and conditions which may apply. 

We reserve the right to make changes to our Cookie Policy. Any such changes shall appear here and become effective immediately. Your continued use of our websites is taken as meaning that you agree to any such changes. 

WHAT IS A COOKIE?

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs, such as remembering your preferences, recording data about the pages you visit, and generally improving your online experience. We do not collect any personal data and will never share any information we do collect with any third parties. 

WHY DO WE USE COOKIES?

Using cookies allows us to record information which helps us to improve our service to you. By storing preferences that you select on some pages of the site, we can display pages in the way you choose across all pages of the site, rather than having to continually ask you (as we would have to do if we did not use cookies). And by tracking the way you use the site and the pages you visit, we can see which pages are most popular and see how you navigate around the site, which allows us to optimise the site’s content and layout to make subsequent visits easier and better. 

We use third party analytical services to help us record and analyse how our visitors use our website. 

Such third party use cookies record information about your visit to our site, including your IP address. This information is transmitted to and stored by the third party. 

Details of third party analytical service providers can be requested from us via a written request sent to the registered office. 

We use a third party service provider for remarketing capabilities to help us present suitable online context based advertising. Our re-marketing tag based cookie is used to determine which pages of our website users have visited so that appropriate online adverts can be displayed. Please note that: 

• • Third party vendors show our ads on sites on the internet. 

• • Third party vendors use cookies to serve ads based on a user’s prior visits to our website. 

• • Users can opt-out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. 

WHAT IF I DON’T WANT TO ALLOW THE USE OF COOKIES?

If you wish to restrict or block the cookies which are set by any website, you can adjust the browser settings for each browser you use, on each device you use to access the Internet. Please be aware that some of our services may not function if your browser does not accept cookies. For information on how to adjust your browsers’ cookie settings, visit www.allaboutcookies.org. 

USES MADE OF THE INFORMATION

We use information held about you in the following ways: 

• • Information you give to us. We will use this information:
    • • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us; 
    • • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; 
    • • to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your data in this way, please send us an email if you which to opt-out to office@outthink.io. 
    • • to notify you about changes to our products and services; 
    • • to administer the website, systems, software, and services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; 
    • • to ensure that content from the website, systems, software and services is presented in the most effective manner for you and for your computer; 
    • • undertake research and development for future products and services; and 
    • • make technical improvements to the website, any of our products and services. 
        
        

• • Information we collect about you. We will use this information:
    • • to administer the website, systems, software, and services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; 
    • • to ensure that content from the website, systems, software and services is presented in the most effective manner for you and for your computer; 
    • • to allow you to participate in interactive features of our systems, software, and services, when you choose to do so; 
    • • as part of our efforts to keep the website, systems, software, and services safe and secure; 
    • • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; 
    • • to make suggestions and recommendations to you and other users of the website about products or services that may interest you or them. 
        
        

• • Information we receive from other sources. We may combine this information with the information you give to us and the information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive). 

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and the Act. 

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the website, systems, software, and services you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website, systems, software, and services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us at office@outthink.io or writing to us at our registered office address. 

The website, systems, software, and services may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. 

ACCESS TO INFORMATION

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. 

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our cookie policy in the future will be posted on this page or notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. 

CONTACT

Questions, comments, and requests regarding this cookie policy are welcomed and should be addressed to office@outthink.io. 

COOKIE POLICY – VERSION 2022.06.06