Privacy Policy

Thoughtcrew is com­mit­ted to safe­guard­ing your pri­vacy. Con­tact us at if you have any ques­tions or prob­lems regard­ing the use of your Per­son­al Data and we will gladly assist you.

This Pri­vacy Policy is a part of our Terms and Con­di­tions; by agree­ing to Terms and Con­di­tions you also agree to this Policy. In the event of col­li­sion of terms used in Terms and Con­di­tions and Pri­vacy Policy, the lat­ter shall pre­vail.

By using this site or/and our ser­vices, you con­sent to the Pro­cessing of your Per­son­al Data as described in this Pri­vacy Policy.

Table of Contents

  1. Defin­i­tions used in this Policy
  2. Data pro­tec­tion prin­ciples we fol­low
  3. What rights do you have regard­ing your Per­son­al Data
  4. What Per­son­al Data we gath­er about you
  5. How we use your Per­son­al Data
  6. Who else has access to your Per­son­al Data
  7. How we secure your data
  8. Inform­a­tion about cook­ies
  9. Con­tact inform­a­tion

Definitions

Per­son­al Data – any inform­a­tion relat­ing to an iden­ti­fied or iden­ti­fi­able nat­ur­al per­son.
Pro­cessing – any oper­a­tion or set of oper­a­tions which is per­formed on Per­son­al Data or on sets of Per­son­al Data.
Data sub­ject — a nat­ur­al per­son whose Per­son­al Data is being Pro­cessed.
Child — a nat­ur­al per­son under 16 years of age.
We/us (either cap­it­al­ized or not) – Thoughtcrew Lim­ited

Data Protection Principles

We prom­ise to fol­low the fol­low­ing data pro­tec­tion prin­ciples:

  • Pro­cessing is law­ful, fair, trans­par­ent. Our Pro­cessing activ­it­ies have law­ful grounds. We always con­sider your rights before Pro­cessing Per­son­al Data. We will provide you inform­a­tion regard­ing Pro­cessing upon request.
  • Pro­cessing is lim­ited to the pur­pose. Our Pro­cessing activ­it­ies fit the pur­pose for which Per­son­al Data was gathered.
  • Pro­cessing is done with min­im­al data. We only gath­er and Pro­cess the min­im­al amount of Per­son­al Data required for any pur­pose.
  • Pro­cessing is lim­ited with a time peri­od. We will not store your per­son­al data for longer than needed.
  • We will do our best to ensure the accur­acy of data.
  • We will do our best to ensure the integ­rity and con­fid­en­ti­al­ity of data.

Data Subject’s rights

The Data Sub­ject has the fol­low­ing rights:

  1. Right to inform­a­tion – mean­ing you have to right to know wheth­er your Per­son­al Data is being pro­cessed; what data is gathered, from where it is obtained and why and by whom it is pro­cessed.
  2. Right to access – mean­ing you have the right to access the data col­lec­ted from/about you. This includes your right to request and obtain a copy of your Per­son­al Data gathered.
  3. Right to rec­ti­fic­a­tion – mean­ing you have the right to request rec­ti­fic­a­tion or eras­ure of your Per­son­al Data that is inac­cur­ate or incom­plete.
  4. Right to eras­ure – mean­ing in cer­tain cir­cum­stances you can request for your Per­son­al Data to be erased from our records.
  5. Right to restrict pro­cessing – mean­ing where cer­tain con­di­tions apply, you have the right to restrict the Pro­cessing of your Per­son­al Data.
  6. Right to object to pro­cessing – mean­ing in cer­tain cases you have the right to object to Pro­cessing of your Per­son­al Data, for example in the case of dir­ect mar­ket­ing.
  7. Right to object to auto­mated Pro­cessing – mean­ing you have the right to object to auto­mated Pro­cessing, includ­ing pro­fil­ing; and not to be sub­ject to a decision based solely on auto­mated Pro­cessing. This right you can exer­cise whenev­er there is an out­come of the pro­fil­ing that pro­duces leg­al effects con­cern­ing or sig­ni­fic­antly affect­ing you.
  8. Right to data port­ab­il­ity – you have the right to obtain your Per­son­al Data in a machine-read­able format or if it is feas­ible, as a dir­ect trans­fer from one Pro­cessor to anoth­er.
  9. Right to lodge a com­plaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reas­on as to why. If you are not sat­is­fied with the way your request has been handled please con­tact us.
  10. Right for the help of super­vis­ory author­ity – mean­ing you have the right for the help of a super­vis­ory author­ity and the right for oth­er leg­al rem­ed­ies such as claim­ing dam­ages.
  11. Right to with­draw con­sent – you have the right with­draw any giv­en con­sent for Pro­cessing of your Per­son­al Data.

Data we gather

Inform­a­tion you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly inform­a­tion that is neces­sary for deliv­er­ing you a product/service or to enhance your cus­tom­er exper­i­ence with us. We save the inform­a­tion you provide us with in order for you to com­ment or per­form oth­er activ­it­ies on the web­site. This inform­a­tion includes, for example, your name and e-mail address.

Inform­a­tion auto­mat­ic­ally col­lec­ted about you
This includes inform­a­tion that is auto­mat­ic­ally stored by cook­ies and oth­er ses­sion tools. For example, your shop­ping cart inform­a­tion, your IP address, your shop­ping his­tory (if there is any) etc. This inform­a­tion is used to improve your cus­tom­er exper­i­ence. When you use our ser­vices or look at the con­tents of our web­site, your activ­it­ies may be logged.

Inform­a­tion from our part­ners
We gath­er inform­a­tion from our trus­ted part­ners with con­firm­a­tion that they have leg­al grounds to share that inform­a­tion with us. This is either inform­a­tion you have provided them dir­ectly with or that they have gathered about you on oth­er leg­al grounds. See the list of our part­ners here.

Pub­licly avail­able inform­a­tion
We might gath­er inform­a­tion about you that is pub­licly avail­able.

How we use your Personal Data

We use your Per­son­al Data in order to:

  • provide our ser­vice to you. This includes for example regis­ter­ing your account; provid­ing you with oth­er products and ser­vices that you have reques­ted; provid­ing you with pro­mo­tion­al items at your request and com­mu­nic­at­ing with you in rela­tion to those products and ser­vices; com­mu­nic­at­ing and inter­act­ing with you; and noti­fy­ing you of changes to any ser­vices.
  • enhance your cus­tom­er exper­i­ence;
  • ful­fil an oblig­a­tion under law or con­tract;

We use your Per­son­al Data on legit­im­ate grounds and/or with your Con­sent.

On the grounds of enter­ing into a con­tract, accept­ing our terms or ful­filling con­trac­tu­al oblig­a­tions, we Pro­cess your Per­son­al Data for the fol­low­ing pur­poses:

  • to identi­fy you;
  • to provide you a ser­vice or to send/offer you a product;
  • to com­mu­nic­ate either for sales or invoicing;

On the ground of legit­im­ate interest, we Pro­cess your Per­son­al Data for the fol­low­ing pur­poses:

  • to send you per­son­al­ized offers* (from us and/or our care­fully selec­ted part­ners);
  • to admin­is­ter and ana­lyse our cli­ent base (pur­chas­ing beha­viour and his­tory) in order to improve the qual­ity, vari­ety, and avail­ab­il­ity of products/ ser­vices offered/provided;
  • to con­duct ques­tion­naires con­cern­ing cli­ent sat­is­fac­tion;

As long as you have not informed us oth­er­wise, we con­sider offer­ing you products/services that are sim­il­ar or same to your pur­chas­ing history/browsing beha­viour to be our legit­im­ate interest.

With your con­sent we Pro­cess your Per­son­al Data for the fol­low­ing pur­poses:

  • to send you news­let­ters and cam­paign offers (from us and/or our care­fully selec­ted part­ners);
  • for oth­er pur­poses we have asked your con­sent for;

We Pro­cess your Per­son­al Data in order to ful­fil oblig­a­tion rising from law and/or use your Per­son­al Data for options provided by law. We reserve the right to anonymise Per­son­al Data gathered and to use any such data. We will use data out­side the scope of this Policy only when it is anonymised. We save your billing inform­a­tion and oth­er inform­a­tion gathered about you for as long as needed for account­ing pur­poses or oth­er oblig­a­tions deriv­ing from law, but not longer than six years.

We might pro­cess your Per­son­al Data for addi­tion­al pur­poses that are not men­tioned here, but are com­pat­ible with the ori­gin­al pur­pose for which the data was gathered. To do this, we will ensure that:

  • the link between pur­poses, con­text and nature of Per­son­al Data is suit­able for fur­ther Pro­cessing;
  • the fur­ther Pro­cessing would not harm your interests and
  • there would be appro­pri­ate safe­guard for Pro­cessing.

We will inform you of any fur­ther Pro­cessing and pur­poses.

Who else can access your Personal Data

We do not share your Per­son­al Data with strangers. Per­son­al Data about you is in some cases provided to our trus­ted part­ners in order to either make provid­ing the ser­vice to you pos­sible or to enhance your cus­tom­er exper­i­ence. We share your data with:

Our pro­cessing part­ners:

  • Mailchimp for news­let­ters and sur­veys

Our busi­ness part­ners:

  • None

Con­nec­ted third parties:

  • Mailchimp for news­let­ters and sur­veys

We only work with Pro­cessing part­ners who are able to ensure adequate level of pro­tec­tion to your Per­son­al Data. We dis­close your Per­son­al Data to third parties or pub­lic offi­cials when we are leg­ally obliged to do so. We might dis­close your Per­son­al Data to third parties if you have con­sen­ted to it or if there are oth­er leg­al grounds for it.

How we secure your data

We do our best to keep your Per­son­al Data safe.  We use safe pro­to­cols for com­mu­nic­a­tion and trans­fer­ring data (such as HTTPS). We use anonymising and pseud­onymising where suit­able. We mon­it­or our sys­tems for pos­sible vul­ner­ab­il­it­ies and attacks.

Even though we try our best we can not guar­an­tee the secur­ity of inform­a­tion. How­ever, we prom­ise to noti­fy suit­able author­it­ies of data breaches. We will also noti­fy you if there is a threat to your rights or interests. We will do everything we reas­on­ably can to pre­vent secur­ity breaches and to assist author­it­ies should any breaches occur.

If you have an account with us, note that you have to keep your user­name and pass­word secret.

Children

We do not intend to col­lect or know­ingly col­lect inform­a­tion from chil­dren. We do not tar­get chil­dren with our ser­vices.

Cookies and other technologies we use

We use cook­ies and/or sim­il­ar tech­no­lo­gies to ana­lyse cus­tom­er beha­viour, admin­is­ter the web­site, track users’ move­ments, and to col­lect inform­a­tion about users. This is done in order to per­son­al­ise and enhance your exper­i­ence with us.

A cook­ie is a tiny text file stored on your com­puter. Cook­ies store inform­a­tion that is used to help make sites work. Only we can access the cook­ies cre­ated by our web­site. You can con­trol your cook­ies at the browser level. Choos­ing to dis­able cook­ies may hinder your use of cer­tain func­tions.

We use cook­ies for the fol­low­ing pur­poses:

  • Neces­sary cook­ies – these cook­ies are required for you to be able to use some import­ant fea­tures on our web­site, such as log­ging in. These cook­ies don’t col­lect any per­son­al inform­a­tion.
  • Func­tion­al­ity cook­ies – these cook­ies provide func­tion­al­ity that makes using our ser­vice more con­veni­ent and makes provid­ing more per­son­al­ised fea­tures pos­sible. For example, they might remem­ber your name and e-mail in com­ment forms so you don’t have to re-enter this inform­a­tion next time when com­ment­ing.
  • Ana­lyt­ics cook­ies — these cook­ies are used to track the use and per­form­ance of our web­site and ser­vices
  • Advert­ising cook­ies — these cook­ies are used to deliv­er advert­ise­ments that are rel­ev­ant to you and to your interests. In addi­tion, they are used to lim­it the num­ber of times you see an advert­ise­ment. They are usu­ally placed to the web­site by advert­ising net­works with the web­site operator’s per­mis­sion. These cook­ies remem­ber that you have vis­ited a web­site and this inform­a­tion is shared with oth­er organ­isa­tions such as advert­isers. Often tar­get­ing or advert­ising cook­ies will be linked to site func­tion­al­ity provided by the oth­er organ­isa­tion.

You can remove cook­ies stored in your com­puter via your browser set­tings. Altern­at­ively, you can con­trol some 3rd party cook­ies by using a pri­vacy enhance­ment plat­form such as optout.aboutads.info or youronlinechoices.com. For more inform­a­tion about cook­ies, vis­it allaboutcookies.org.

We use Google Ana­lyt­ics to meas­ure traffic on our web­site. Google has their own Pri­vacy Policy which you can review here. If you’d like to opt out of track­ing by Google Ana­lyt­ics, vis­it the Google Ana­lyt­ics opt-out page.

Contact Information

Super­vis­ory Author­ity in the UK is the Inform­a­tion Com­mis­sion­ers Office who can be con­tac­ted at https://ico.org.uk/

Changes to this Privacy Policy

We reserve the right to make change to this Pri­vacy Policy.
Last modi­fic­a­tion was made May 2018