DATA PROTECTION AND CONFIDENTIALITY

WHO WE ARE?

Think Sigma Ltd of 23 Croye Close, Andover, England SP10 3AF (company number 12563321) (“Think Sigma”, “we”, “our” and “us”). Think Sigma are the controller of your personal data and we have various responsibilities in relation to your personal data. We are committed to protecting your personal data in line with the relevant legislation (“Data Protection Law”).  The relevant legislation includes the United Kingdom General Data Protection Regulation and the UK Data Protection Act 2018, as well any other legislation applicable to the processing and safeguarding of your personal data..

WHY THIS POLICY IS IMPORTANT

This policy is intended to provide information about how we will use (or “process”) personal data about individuals including our current, past and prospective clients, suppliers and other third parties as well as visitors to our website. 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 removed (anonymous data). This information is provided in accordance with the rights of individuals under Data Protection Law to understand how their data is used. This privacy policy applies alongside any other information Think Sigma may provide about a particular use of personal data, for example when collecting data. It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 website is not intended for children and we do not knowingly collect data relating to children.

RESPONSIBILTY FOR DATA PROTECTION

Think Sigma has appointed Richard Ash to oversee its role as Data Protection Manager (DPM), who will deal with all requests and enquiries concerning Think Sigma’s use of your personal data (see section on Your Rights below). Richard Ash may be contacted by:

• e-mail: richard.ash@thinkSigma.co.uk
• telephone: 01189771855
• post: 23 Croye Close, Andover, Hampshire

WHY THINK SIGMA NEEDS TO USE PERSONAL DATA

To carry out its ordinary duties to clients, Think Sigma may need to process personal data about current, past and prospective staff and clients as part of its daily operation. 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 we need to comply with a legal obligation.
• 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. This may include processing for the purposes of:
• Maintaining relationships with clients and the business community.
• For the purposes of management planning.
• For security purposes; and
• Where otherwise reasonably necessary for Think Sigma’s purposes, including to obtain appropriate professional advice and insurance.

TYPES OF PERSONAL DATA OBTAINED BY THINK SIGMA

This will include by way of example:

• 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 products and services you have purchased from us.
• 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, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• 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 could be derived from your personal data but is not considered personal data in law as this data will 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 policy. We do not 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. 

HOW THINK SIGMA COLLECTS DATA

Generally, Think Sigma receives personal data from the individual directly in the ordinary course of interaction or communication (such as verbally, by e-mail or by written documents). However, in some cases personal data may be supplied by third parties (for example an employer or customer)

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 goods or services). 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. 

DATA COLLECTED THROUGH THE THINK SIGMA WEBSITE

Think Sigma may collect the following information from visitors to its website:

• IP addresses and information about the location of the visitor
• the way that a visitor uses the website, including the pages viewed, dates, times, and duration
• data to show where visitors navigated to or from our website and searches made on our website.

This data is used to enable Think Sigma to:

• run the website ensuring that it works properly
• improve the information on the website
• maintain the website’s security

A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our Website are being used. Our Website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences. We only use this information for statistical analysis purposes and then it is removed from our systems. A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the Personal Data you choose to share with us (including Personal Data you automatically share with us by way of your browser settings). We will not use cookies to collect personally identifiable information about you as our cookies are there to simply help with your overall experience on our website. Our cookies help us to analyse how our customers use our website and enables basic personalisation of our site, which further improves your experience. We use several different types of cookies: Session cookies: temporary cookies which remain in your cookie file until you leave our Website Persistent cookies: these remain in place across multiple visits to our Website Third party cookies: these are created by a third party to provide us with statistics. An example of this is Google analytics You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note however that if you block all cookies via your browser settings you may not be able to access all or parts of our Website.

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 and 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 third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us 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 purchase, service experience or other transactions.

WHO HAS ACCESS TO PERSONAL DATA AND WHO THINK SIGMA SHARES IT WITH?

Occasionally, Think Sigma will need to share personal information with third parties, such as professional advisers (lawyers and accountants) or relevant authorities such as the police. For the most part, personal data collected or accessed by Think Sigma will remain within the company and will be processed by appropriate individuals only in accordance with access protocols (i.e., on a “need to know” basis). In accordance with Data Protection Law, some of Think Sigma’s processing activity is carried out on its behalf by third parties, such as cloud services and storage providers.  This is always subject to undertakings from such third parties that personal data will be kept securely and only in accordance with Think Sigma’s specific direction. Examples of the third parties that may process your personal data include Mailchimp, Cisco and other tele-conferencing providers. We may share your personal data with 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 or restructure internally within our group. 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 policy. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

HOW LONG THINK SIGMA KEEPS PERSONAL DATA

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, regulatory, tax, accounting or other requirements. If you have any specific queries about how this policy is applied or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the DPM.  However, please bear in mind that Think Sigma may be legally required to retain certain types of personal data.

SECURITY

Think Sigma has implemented and shall maintain appropriate technical and organisational security measures, processes, and controls to safeguard all Personal Data processed by them against unauthorised and unlawful processing and accidental loss, disclosure, or destruction. 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.

THIRD-PARTY LINKS

Our 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 policy of every website you visit.

YOUR RIGHTS

Under certain circumstances, you have rights under Data Protection Law in relation to your personal data:

• 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:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • 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;
  • 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.

Any individual wishing to access or amend their personal data or wishing it to be transferred to another person or organisation should put their request in writing to the DPM. Think Sigma will endeavour to respond to any such legitimate written requests as soon as is reasonably practicable and within one month in the case of requests for access to information.  Occasionally it could 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.  Think Sigma will be better able to respond quickly to smaller, targeted requests for information.  If the request is manifestly excessive or similar to previous requests, Think Sigma may ask you to reconsider, refuse your request or charge a proportionate fee, but only where Data Protection Law allows it.  Think Sigma shall also provide its clients with such assistance as the client reasonably requests to comply with its obligations and to fulfil a data subject’s rights. You should be aware that certain data is exempt from the right of access.  This may include information which identifies other individuals or information which is subject to legal professional privilege.

DATA ACCURACY AND SECURITY

Think Sigma will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible.  Individuals must please notify the DPM of any changes to information held about them. An individual has the right to request that any inaccurate or out-of-date information about them is erased or corrected (subject to certain exemptions and limitations under Act): please see above. Think Sigma will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to company systems.  All staff will be made aware of this policy and their duties under Data Protection Law.

QUERIES AND COMPLAINTS

Any comments or queries on this policy should be directed to the DPM. If an individual believes that Think Sigma has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should notify the DPM.  An individual can also make a referral to or lodge a complaint with the Information Commissioner’s Office (“ICO”). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 contact us. 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 where this is required or permitted by law.

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

We keep our privacy policy under regular review. 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.

GLOSSARY

Legitimate Interest means the interest of our business 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 contacting us. 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.