Privacy policy

Thinkology processes your data in accordance with the data protection provisions set forth specifically in the Data Protection Act 2018 (DPA 2018), and in Regulation (EU) 2016/679 (General Data Protection Regulation–GDPR).

A. Responsibility for the processing of your personal data
The data controller that is responsible for the processing of your personal data within the meaning of Art. 4 (7) GDPR is Thinkology Limited (hereinafter “Thinkology”).

B. Data that is processed as part of various data processing situations
1. What types of data are processed when a person visits a Thinkology website?
When a person visits a Thinkology website, Thinkology’s servers automatically store various data conveyed via that person’s accessing system. These data include the type of browser, the browser version and the operating system used, the website from which the Thinkology website is accessed, the Thinkology website sub-pages that are accessed, the date and time of such access, the internet protocol address (IP address), the internet service provider and any data comparable with the aforementioned data. Thinkology uses these data to render its website accessible, to identify and remedy any technical problems that may arise, and to prevent and, if necessary, take action against any abuse of Thinkology’s services. Thinkology moreover uses this data in anonymised form–that is, without being able to infer the user’s identity from the data provided–for statistical purposes and for purposes of improving its websites. The legal basis for processing personal usage data is Art. 6 (1) Sentence 1 (f) GDPR.

2. How are cookies used?
The Thinkology websites use cookies. Cookies are small text files that are stored on the user’s data carrier and that, via the browser, exchange certain data as well as settings-related information with Thinkology’s system. A cookie normally contains the name of the domain from which the cookie data were sent, information about the cookie’s age, and an alphanumeric identifier.

If a user visits the password-protected area of a Thinkology website, session cookies are used for the duration of that user’s visit. These enable Thinkology to avail of the user-friendly single sign-on method as a means of authenticating users and controlling access to the various password-protected areas of its websites. This method enables users to move around the website’s entire password-protected area without having to log in to each area separately. Cookies are also used to collect information on how users use and navigate Thinkology’s websites, and what specific areas and products they are interested in. This information in turn enables Thinkology to improve its websites and the online experiences of website users. The information stored in the cookies is neither used to identify the user nor is it combined with other stored personal data concerning the user. The legal basis for processing personal data in connection with the use of cookies is Art. 6 (1) Sentence 1 (f) GDPR.

Users can deactivate or restrict the transmission of cookies by changing the settings of their internet browsers accordingly. Any cookies already stored can be erased at any time. Such erasure can be automated. If a user deactivates cookies for the Thinkology websites, he/she may not be able to make full use of all the websites’ functions.

3. For how long will my personal data be stored?
The personal data concerning visitors to our website will be erased as soon as knowledge thereof is no longer required for the purposes described above, unless statutory provisions stipulate that the data be stored for a longer period. Usage data is generally stored for a period of 120 days.

C. Processing where direct contact with Thinkology in made (e.g. via contact form or email)
If you contact Thinkology directly, e.g. via a contact form on a website or via email, then the personal data you transmit to Thinkology as a result, e.g. your email address, your name, the content of your enquiry, etc., will be used solely for processing the respective enquiry. Your data may be passed on to other Thinkology companies if this is necessary to respond to your inquiry. Only the data required for such response is passed on. Depending on the manner in which contact was made, the legal basis for processing the aforementioned data is Art. 6 (1) Sentence 1 (b) or (f) GDPR. If data is transmitted to Thinkology companies outside the European Union or European Economic Area in order to respond to your inquiry, then Thinkology undertakes that it has adopted the European Commission’s standard contractual clauses for these countries and has thus provided the requisite additional safeguards for the protection of personal data. These can be accessed and perused here: https://eur-lex.europa.eu/eli/dec/2004/915/oj.

D. Passing on personal data to (other) third parties
Thinkology relies on the support of specialised technical service providers for the technical processing of personal data. These service providers are carefully selected and are legally and contractually committed to ensuring a high level of data protection. The legal basis for our partnerships with these service providers is Art. 28 GDPR.

In individual cases, Thinkology works with companies and other entities that have special expertise in specific areas or subject knowledge (such as tax auditors, lawyers, and consulting firms, for example). These entities are either subject to a professional duty of confidentiality or have been obliged by Thinkology to maintain confidentiality. If it is necessary to pass personal data on to these agencies, then the legal basis for this is Art. 6 (1) Sentence 1 (f) GDPR.

Thinkology will only pass on personal data to third parties for purposes other than those specified in this Privacy Policy if there is a legal obligation to do so or if you have provided your express consent to such disclosure.

E. Duration of the retention of your data
Unless otherwise stated in this Privacy Policy, personal data will be erased by Thinkology if it is no longer needed for the purposes for which it was processed and if the retention periods prescribed by law have expired. Contractually relevant data are usually erased ten years after the termination of the respective contract with Thinkology.

F. Rights in relation to data processing
If you would like detailed information on the personal data that has been stored by Thinkology about you, you can contact Thinkology. You may also request to receive information about any data that you have provided to Thinkology in accordance with applicable law in a structured, commonly used, and machine-readable format, or you may also request Thinkology to submit such information to a third party. If you discover that personal information that has been stored about you is incorrect or incomplete, you may request that such data be immediately corrected or completed at any time. If the requirements stipulated in Art. 17 and 18 GDPR are met, you may also request the erasure of your personal data or that processing of it be restricted. You also have the right to lodge a complaint with the relevant supervisory authority for data protection issues.

Insofar as the processing of your personal data is based on legitimate interests as per Art. 6 (1) Sentence 1 (f) GDPR, you are invariably entitled to object to such processing based on reasons arising from your particular situation. This entitlement also applies to any profiling that is conducted on the basis of the above provision. Thinkology will then no longer process the personal data unless Thinkology can prove compelling legitimate grounds for data processing that override your interests, rights and freedoms, or the data processing is for the purpose of establishing, exercising or defending legal claims. If personal data is processed for the purposes of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising. This also applies to any profiling insofar as it is associated with such direct advertising.

G. Contact data
If you have any questions about how Thinkology processes personal data or about exercising your rights against data processing, you can contact Thinkology at any time. Please send all inquiries to: admin@thinkology.co.uk. The data privacy officer at Thinkology can be contacted at the same email address.