PRIVACY NOTICE
1. Information About Us
A limited company registered in England under company number 08711278.
Registered address: 25 City Road, London EC1Y 1AA, UK.
VAT number: GB 184 6798 47.
Data Protection Officer:
Telephone number: +44 20 3963 1950
Postal Address: 25 City Road, London EC1Y 1AA, UK
Controller or Processor
2. What Does This Notice Cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.
| Data Collected | How We Collect the Data |
|---|---|
|
Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact data includes billing address, delivery address, email address and telephone numbers Financial data includes bank account and payment card details. Transaction data includes details about payments to and from you and other details of services you have purchased from us. Marketing and Communications data includes your preferences in receiving information and marketing from us and your communication preference. |
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 in person. This includes personal data you provide when you:
|
|
Usage data includes information about how you use our website and services. Profile data including your username and password. Technical data including cookies for login authentication, 2 step verification and CSRF token. |
Automated Technologies: as you interact with our website and our services, 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 technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. |
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
|---|---|---|
Register you as a new client. |
(a) Identity data (b) Contact data |
Performance of a contract with you. |
To process and deliver services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity data (b) Contact data (c) Financial data (d) Transaction data (e) Profile data (f) Technical data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent |
To manage our relationship including: (a) Notification about changes to our Terms or Privacy Notice (b) Asking you to leave a review or take a survey. |
(a) Identity data (b) Contact data (c) Profile data (d) Marketing & Communications data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
(a) Identity data (b) Contact data (c) Technical data |
(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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. |
(a) Identity data (b) Contact data (c) Profile data (d) Usage data (e) Marketing and Communications data (f) Technical data |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical data (b) Usage data |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
7. How Long Will You Keep My Personal Data?
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.
We will not delete any data which relates to financial transactions that is less than seven years old as we are legally required to hold this information for seven years.
8. How and Where Do You Store or Transfer My Personal Data?
We take reasonable steps to protect 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 also have procedures in place to deal with any suspected data security breach. We will notify you and the relevant Regulator(s) such as the ICO of a suspected data security breach where we are legally required to do so.
Where you have a username and password (or other identification information) which enables you to access TGConnect or other TGC online services, it is your responsibility to keep this information secure. Please do not share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to the TGC website; any transmission is at your own risk. Once we have received your personal data, we will use strict protocols and security features to try to prevent unauthorised access.
9. Do You Share My Personal Data?
Some of our external third parties are based outside EEA so their processing of your personal data will involve a transfer of data outside the EEA.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within week, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: info@thinkglobalcompliance.com
Telephone number: +44 20 3963 1950
Postal Address: 25 City Road, London EC1Y 1AA, UK
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
This Privacy Notice was last updated on December 4, 2020.
