Last updated 1st March 2018
Your privacy: our General Data Protection Regulation compliance statement
This is a statement of the General Data Protection Regulation compliance policy that is adopted by Thoughtful Web Ltd t/a Thoughtful for delivering our services. Thoughtful Web Ltd will, when delivering these services, collect and use personal information only which is relevant to the work that we are undertaking and which will be controlled, stored and processed in accordance with the General Data Protection Regulations (GDPR), howsoever it is collected, recorded and used; whether it be on paper, in electronic media form (e.g. in a computer system), or recorded by other means.
We consider the lawful and correct treatment of personal information by the company as critical in maintaining the confidence of our clients; we therefore manage and process personal information lawfully and correctly.
Information is defined under the GDPR as being Personal Information if any of the following criteria are met:
- Can a living individual be identified from the data, or, from the data and other information in the possession of, or likely to come into the possession of, the data controller?
- Does the data “relate to” the identifiable living individual, whether in their personal or family life, business or profession?
- Is the data “obviously about” a particular individual?
- Is the data “linked to” an individual so that it provides particular information about that individual?
- Is the data used, or is it to be used, to inform or influence actions or decisions affecting an identifiable individual?
- Does the data have any biographical significance in relation to the individual?
- Does the data focus or concentrate on the individual as its central theme rather than on some other person, or some object, transaction or event?
- Does the data impact or have the potential to impact on an individual, whether in a personal, family, business or professional capacity?
We adhere to the Principles of Data Protection, as set out in The Data Protection Act 1998 and the General Data Protection Regulations (GDPR), which come into force in May 2018.
Specifically, these Principles require that personal information:
- Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met.
- Shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
- Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
- Shall be accurate and, where necessary, kept up to date.
- Shall not be kept for longer than is necessary for that purpose or those purposes. Shall be processed in accordance with the rights of data subjects under the Act.
- Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
- Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Thoughtful Web Ltd will, through appropriate management and by strict application of criteria and controls:
- Observe fully the conditions regarding fair collection and use of information.
- Meet its legal obligations to specify the purposes for which information is used.
- Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements.
- Ensure that the quality and accuracy of information used is adequate and is maintained.
- Apply strict checks to determine the length of time information is held and that it is stored for no longer than is necessary.
- Ensure that the rights of people about whom information is held are able to be fully exercised under the Act and Regulations. These include: the right to be informed that processing is being undertaken, the right of access to one’s personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase information.
- Take appropriate technical and organisational security measures to safeguard personal information.
- Ensure that personal information is not transferred abroad to countries to which transfers are not permitted under the GDPR.
The information storage and processing systems used by Thoughtful Web Ltd are designed to ensure that:
- Should you have an enquiry relating to data protection, you may contact us by telephone on 44 (0) 1732 525911, via e-mail at firstname.lastname@example.org, via the contact form on our web site or by letter addressed to The DPO, Thoughtful, Suite 33, 80 Churchill Square, Kings Hill, Kent ME19 4YU.
- Everyone handling, managing and working with personal information understands that they are contractually and legally responsible for following the GDPR and good data protection practice.
- Everyone handling, managing and working with personal information is appropriately trained to do so.
- Everyone handling, managing and working with personal information is appropriately supervised.
- Anyone wanting to make enquiries about personal information knows how to do so.
- Queries about personal information are promptly and courteously dealt with, in accordance with the GDPR.
- Methods of handling, managing and working with personal information are clearly described.
- A regular review and audit is made of the way personal information is managed.
- Methods of handling, managing and working with personal information are regularly reviewed, assessed and evaluated.
- The performance of the methods and process is regularly reviewed, assessed and evaluated.
Information processing - general
We do not undertake automated decision making about, or profiling of personal data.
Data subjects have a right, as set out in the GDPR, to obtain the personal information which is stored and used by us, and can obtain this information by contacting the Data Protection Officer whose details are given in this document. The data comprising the personal information will be delivered to the data subject in a secure manner and in a format which is readily accessible using common proprietary data access tools (such as word processor document or spreadsheet viewer programs).
GDPR compliant policy for marketing and general information
What information we collect
We acquire and use information relating to commercial organisations and individuals for use in our marketing and sales activities.
Our clients provide some of this information directly to provide services or when contacting us for the purposes of making an enquiry.
We also obtain information by recording how persons use our websites by means of embedded technology such as cookies, and by receiving written enquiries and usage data from relevant forms hosted on our website.
If you are requested by us to provide your personal data, you may of course decline to do so. However, if you do choose not to provide data that is necessary to enable us to provide a service to you, we may not be able to deliver that service to you.
The information that we obtain may be dependent upon the nature and context of your enquiry. The information that we collect can include the following:
Name and contact data
We collect your first and last name, postal address, phone number and e-mail address.
We may on occasion collect data about you such as your profession, country and preferred language.
Where it is necessary to process your payment, sensitive information such as your credit card number and security code are not collected by Thoughtful Web Ltd: the payment is processed using external secure processing websites operated by our bank and the information is not processed or stored by our systems or personnel.
Contacts and relationships
We may collect such information that you provide us relating to your contacts and business relationships.
Our on-line services may obtain imprecise location data: e.g. a location derived from your IP address or data, that indicates where you are located with low precision, such as at a city or postcode level.
We may collect the content of any data files and communications that you may send us in the course of a project, together with any physical documents that you may give us when these are necessary to provide you with the service you have purchased. Data we collect may include:
- the address, subject line and body of an email,
- text or other content of an instant message,
- audio and video recording of a video message or attachment, and
- audio recording and transcript of a telephone call or voice message you send to us or receive from us.
What we use the data we collect for
We use the data that we collect to operate our business and to deliver the services that we provide, to send communications, including marketing promotional materials, and to deliver advertising of our services.
We use information which we collect to provide and to improve the services which we offer and to undertake essential business operations. This includes service delivery and monitoring, maintaining and improving the quality standards, security and performance of our services, developing new services, conducting research and providing focused advice to our clients. Examples of such uses include the following:
We use information which we collect to communicate with our clients and with their staff, and thus to and personalise our communications. We may contact you by telephone or by e-mail or other means to inform you when a publication or presentation which may be of professional interest is available or to enquire or to advise about a service enquiry that you have made, or to invite you to participate in a survey or to attend a commercial event.
For information about how to manage, edit or to delete contact data which contains your personal information, please use the How to access & control your personal data found in this privacy statement.
We may use personal information contained in e-mail, telephone calls or voicemail, or your documents, or data files to target advertisements to you.
We do not share any data which we collect with third parties. The advertisements that you see on our interactive media may be targeted based upon information stored, such as IP address.
For advertising and marketing, we retain data for no longer than 24 months, unless we obtain your consent to retain the data for a longer period.
How to access & control your personal data
You can submit a request to view, edit or delete any personal data that we hold.
You may do so by submitting a request in writing or by using our contact form. We will respond to requests to access or delete your personal data within 30 days.
Your marketing choices
You may opt out of receiving marketing information by un-subscribing using the link incorporated into all our e-mail communication.
Storing your preferences and settings
Settings that enable our products to operate correctly or that maintain your preferences over time may be stored on your device. For example, if you enter your city or postcode to get information on our website, we may store that data in a cookie so that you will see the relevant local information when you return to the site. We also save preferences, such as language, browser and multimedia player settings, so those do not have to be reset each time you return to the site.
Sign-in and authentication
When you sign into a website using your account credentials, we store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.
Storing information you provide to a website
When you provide information on our websites, we store the data in a cookie to remember the information you have added.
Some of our websites include social media cookies, including those that enable users who are logged in to the social media service to share content via that service.
First party cookies
Created by the Content Management System (CMS) as an anonymous session identifier.
Duration: End of session
Created by the Content Management System (CMS) and used as protection against Cross-Site Request Forgery attacks (CSRF), where form submissions can be hijacked.
Duration: End of session
The "__cfduid" cookie is set by the CloudFlare service to identify trusted web traffic. It does not correspond to any user id in the web application, nor does the cookie store any personally identifiable information.
Duration: 5 years
Universal Google Analytics
These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.
Neither Thoughtful Web Ltd or Google associate your IP address with any personally identifiable information.
A mixture of both persistent and session cookies are used to enable Google to determine whether you are a return visitor to this site and to track the pages that you visit during your session.
More information about Google’s policies can be read at www.google.com/intl/en/analyti...
Used to distinguish users
Duration: 2 years
Used to distinguish users
Duration: 24 hours
Used to throttle request rate
Duration: 1 minute
How to control cookies
Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. Most browsers allow you to refuse to accept cookies, however, blocking cookies will have a negative impact upon the usability of some websites.
Certain features of our websites depend upon cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost. If you choose to delete cookies, the settings and preferences controlled by those cookies will be deleted and may need to be recreated.
You can opt out of data collection or use by some of these analytics providers by clicking the following links:
- AppsFlyer: www.appsflyer.com/optout
- Flurry Analytics: https://aim.yahoo.com/aim/us/e...
- Google Analytics: tools.google.com/dlpage/gaoptout (requires you to install a browser add-on)
- Kissmetrics: kissmetrics.com/user-privacy
- Mixpanel: mixpanel.com/optout
- Nielsen: https://priv-policy.imrworldwi...
- Omniture (Adobe): www.d1.sc.omtrdc.net/optout.ht...
- Visible Measures: www.visiblemeasures.com/viewer...
- WebTrends: ondemand.webtrends.com/support/optout.asp
Changes to this privacy statement
We will update this privacy statement when necessary to reflect customer feedback and changes in our services. When we post changes to this statement, we will revise the "last updated" date at the top of the statement. If there are material changes to the statement or in how we will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how we are protecting your information.
How to contact us
If you have a privacy concern, complaint or a question, please contact us by using our Contact form. We will respond to questions or concerns within 30 days.
Unless otherwise stated, Thoughtful Web Ltd is a data controller for personal data we collect through the products subject to this statement.
Our address is:
Suite 33, 80 Churchill Square,
Kings Hill, West Malling,
Kent ME19 4YU