Thorogood Associates Limited (”We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.thorogood.com you are accepting and consenting to the practices described in this policy.
For personal information received from the European Union and European Economic Area, Thorogood complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. More information can be found in the “EU-U.S. Privacy Shield” section below.
For the purpose of the Data Protection Act 1998 (the “DPA”) and the General Data Protection Regulation (“GDPR” and with the DPA, the “Act”), the data controller is Thorogood Associates Limited of 2nd Floor, International House, 7 High Street, London, W5 5DB.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
- Information you give us. This is information about you that you give us on behalf of your employer by filling in forms on our site www.thorogood.com (our site), by signing up for an event or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you access our site, subscribe to our service and when you report a problem with our site. The information you give us may include your name, address, e-mail address, IP address, and phone number.
- Information we receive from your employer. This is information we receive about you from your employer.
Whether we receive this information from you on behalf of your employer, or directly from your employer, we will (1) have entered into a contract for the supply of services or consultancy services with your employer and may be required to access your personal data to carry out our contractual obligations; and (2) be pursuing a legitimate business interest in responses to your or your Employers interest in our services.
USES MADE OF THE INFORMATION
We use information held about you to allow us to understand your needs and provide you with a better service in the following ways:
Companies and Businesses and their Employees who have expressed an interest in Thorogood’s Products and Services
It may be that you and/or your company already has a relationship with Thorogood, either as a customer or on the basis of an earlier expression of interest in our products and services.
We will continue to hold your details on our system and in addition to our initial response to this enquiry we will continue to contact you in response to this interest of the products, services and consultancy services we offer. We will remove your details upon your request, provided, however, that we may retain certain information as necessary to fulfil our contractual relationships and/or to enforce or defend our contractual rights and obligations, and for our normal business records and activities, as permitted by law.
The information we may hold about you includes but is not limited to your name, job title, location, company email address and company mobile phone number and we hold this information because of your employer’s interest in our services and our interaction establishes a legitimate business interest. We recommend that you only provide employer-related contact information, and further recommend that you only connect with us through employer-owned devices. This way, we do not receive or retain your non-work related information.
In order to pursue that legitimate business interest, we will send you details of the products, services and events that we offer and which match and satisfy that interest.
In order to support and maintain the legitimate business interest we may transfer, store and process your data at our offices outside of the European Economic Area.
If your information changes and you no longer work for your Employer and/or are not part of the involvement in the interest developed by your Employer and you want your details removed from our system, then please email email@example.com and we will remove your details. Please note, however, that we will retain the prior email communications (which may include in the header your name and email address, and which may include your work signature information) as they relate to our business with your employer.
Customers and Employees of Customers
We hold this information because your employer has entered into a Contract with Thorogood for the Supply of our Consultancy and development Services and we may need to contact you in order to implement and programme the Contract and deliver ongoing advice and services as well as market updates as part of the contractual relationship.
The information we hold about you includes your name, job title, location, company email address and company mobile number.
Under our Contractual arrangement we may transfer, store and process your data outside the European Economic Area.
If your circumstances change and you no longer work for your employer or are not a party to our Contractual relationship and want your details removed from our system then please email firstname.lastname@example.org and we will remove your data as you request. Please note, however, that we will retain the prior email communications (which may include in the header your name and email address, and which may include your work signature information) as they relate to our business with your employer.
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
WHERE WE STORE YOUR PERSONAL DATA
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our good faith efforts to protect your personal data, we cannot guarantee the security of your data transmitted to our site; to the fullest extent allowed by law, any transmission is at your own risk. Once we have received your information, we will use reasonable and appropriate procedures and security features to try to prevent unauthorised access.
EU-U.S. Privacy Shield
Thorogood is pursuing certification that it complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Thorogood is undertaking to certify to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability, and the 16 Supplemental Principles (collectively, “Privacy Shield Principles“), and such adherence is subject to investigation and enforcement by the U.S. Federal Trade Commission.
Thorogood’s participation in the Privacy Shield will apply to all personal information transferred from the European Union and European Economic Area to Thorogood in the United States, including (but not limited to), personal information collected or otherwise processed by Thorogood regarding its Europe-based applicants, on behalf of its Europe-based customers and other users of its Website and Services. Thorogood will comply with the Privacy Shield Principles in respect of such personal information. If there is any conflict between the terms in this policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Thorogood’s adherence to the Privacy Shield Principles may be limited to the extent necessary to meet national security, public interest, or law enforcement requirements.
Thorogood’s accountability for personal information that it will receive under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Thorogood remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal information on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless Thorogood proves that it is not responsible for the event giving rise to the damage (if any).
Individuals whose personal information is transferred to Thorogood under the Privacy Shield will have the right to access their personal information maintained by Thorogood, and to correct, amend or delete such information where it is inaccurate or processed unlawfully, as described in the Privacy Shield Principles. To exercise any of these rights, please email the Thorogood Legal Department at email@example.com.
In addition, Thorogood provides individuals with certain choices regarding how we use and disclose personal information. First, if Thorogood uses your personal information for a materially different purpose than that for which it was originally collected or discloses your personal information to a third party (other than third party providers acting on our behalf), we will first provide you with a clear, conspicuous and readily available mechanism to opt-out of any such use or disclosure (e.g., by sending you an email seeking your consent). In addition, all of our email communications include the ability to opt-out from receiving future emails, except those emails that are necessary to provide you with the Services you have requested or purchased. If you have any questions about your choices regarding how we use and disclose your personal information, or how to exercise these choices, please email the Thorogood Legal Department at firstname.lastname@example.org.
We encourage you to contact us should you have a Privacy Shield-related (or general privacy-related) complaint or inquiry by emailing the Thorogood Legal Department at email@example.com.
For any complaints that cannot be resolved with Thorogood directly, Thorogood has chosen to cooperate with JAMS, an alternative dispute resolution provider, to resolve such complaints at no cost to you. Please visit www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.
Thorogood is a Business-to-Business organisation, therefore you should only communicate with us only business emails and business devices. Nevertheless, subject to our legitimate business needs, you have the right to ask us not to process your personal data for marketing purposes; but absent that request, we intend to use your data for such purposes; and further, we intend to disclose your information to third parties to assist in those purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at 2nd Floor, International House, 7 High Street, London, W5 5DB, or by email at: firstname.lastname@example.org.
THIRD PARTY LINKS
This website may include links to third parties’ websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
If we believe a request for information submitted by you or in relation to your data is manifestly unfounded or excessive, we may at our discretion charge a reasonable fee for producing and delivering up the information requested by you or your employer.
SALE OF BUSINESS
If the business of Thorogood Associates Ltd is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed onto the new owners of the business in the event of a sale.