OutThink Limited (“We”) are committed to protecting and respecting your privacy.
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:
The policy tells you about your privacy rights and how the law protects you. Please use the Glossary at paragraph 10 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.
Our full details are:
Email address: email@example.com
Postal address: 35 New Broad Street, London, EC2M 1NH, 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 06 June 2022 and historic versions can be obtained by emailing firstname.lastname@example.org.
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.
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:
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:
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:
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 email@example.com, 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.
|Purpose for processing
|Category of personal data
|Legal basis for processing
|To register you as a new customer
|(a) Identity (b) Contact
|Performance of a contract
|To process and deliver our services to you
|(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications
|Performance of a contract
|To manage our relationship with you which will include: (a) notifying you about changes to our terms of this privacy notice (b) asking you to leave a review or take a survey
|(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
|(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business, website and Platform (including troubleshooting, data analysis, testing, system, maintenance, support, reporting and hosting of data)
|(a) Identity (b) Contact (c) Technical
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
|To make suggestions and recommendations to you about goods and services that may be of interest to you
|(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
|Necessary for legitimate interests (to develop our products/services and grow our business) Consent
|To generate and send user reports to our customers
|(a) Identity (b) Contact (c) Profile
|Necessary for our legitimate interests in keeping our customers updated on user access and performance on the Platform
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.
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.
We will get your express opt-in consent before we share your personal data with any company outside OutThink for marketing purposes.
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 firstname.lastname@example.org 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.
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 email@example.com.
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.
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 firstname.lastname@example.org.
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 email@example.com.
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.
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 firstname.lastname@example.org.
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.
EXTERNAL THIRD PARTIES
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.
We use third party analytical services to help us record and analyse how our visitors use our website.
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:
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:
WHERE WE STORE YOUR PERSONAL DATA
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.
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 email@example.com 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.