Privacy and cookies policy
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) 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);
(b) information that you provide to us when registering with our website (including your email address);
(c) information that you provide when/if completing your profile on our website (this may include your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details);
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(e) information that you provide to us when using any services that may be included on our website, or that is generated in the course of the use of any such services (including the timing, frequency and pattern of service use);
(f) information relating to any purchases you make of any goods and/or services that may be available on our website or any other transactions that it may be possible to enter into through our website (including your name, address, telephone number, email address and card details);
(g) 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);
(h) 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);
(i) any other personal information that you choose to send to us;
2.2 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.
3. Using personal information
3.1 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.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of any services available on our website;
(d) send you non-marketing commercial communications;
(e) send you email notifications that you have specifically requested;
(f) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(g) send you marketing communications relating to our business 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);
(h) 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);
(i) deal with enquiries and complaints made by or about you relating to our website;
(j) keep our website secure and prevent fraud;
(k) verify compliance with the terms and conditions governing the use of our website.
3.3 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.
4. Disclosing personal information
4.1 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.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information to the extent that we are required to do so by law;
4.4 Except as provided in this policy, we will not provide your personal information to third parties.
5. Retaining personal information
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 information.
5.2 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.
5.3 Notwithstanding the other provisions of this Section 5, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) 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).
6. Security of personal information
6.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) 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)].
8.2 We may withhold personal information that you request to the extent permitted by law.
8.3 You may instruct us at any time not to process your personal information for marketing purposes.
9. Third party websites
9.1 Our website may include hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9.3 If at any point you believe the information we process on you is incorrect you request to see this information and even have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
9.4 If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).
9.5 Our Data Protection Officer is Martin Devlin and you can contact them at email@example.com.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
12. Our cookies
12.1 We use both session and persistent cookies on our website.
12.2 The purposes for which they are used, are set out below:
13. Analytics cookies
13.1 We use Google Analytics to analyse the use of our website.
13.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
13.3 The analytics cookies used by our website have the following names: _ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv.
13.4 The information generated relating to our website is used to create reports about the use of our website.
14. Third party cookies
14.1 Our website may also uses third party cookies. Details of these will be added to this policy as and when their usage arises.
15. Blocking cookies
15.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
(b) in Firefox (version 39) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
(c) in Chrome (version 44), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you may not be able to use all/any the features that may be included on our website.
16. Deleting cookies
16.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 39), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and
(c) in Chrome (version 44), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".
16.2 Deleting cookies will have a negative impact on the usability of many websites.
17. Our details
17.1 This website is owned and operated by Thinking Loud & Clear Limited.
17.2 We are registered in England and Wales under registration number 10123326, and our registered office is at Kemp House, 160 City Road, London EC1V 2NX.
17.3 Our principal place of business is at Kemp House, 152 City Road, London EC1V 2NX
17.4 You can contact us by writing to the business address given above, by using our website contact form, by email to firstname.lastname@example.org.
18. Data protection registration
18.1 We are registered as a data controller with the UK Information Commissioner's Office.
18.2 Our data protection registration number is ZA321703.