We’ve created this policy which covers how ThinkBDW Ltd including ThinkMedia and Robson Brown (all referred to as ThinkBDW within this policy)…..
…. your data.
1. Introduction and General Terms
ThinkBDW is committed to protecting your personal information when you are using ThinkBDW services. We want our services to be safe and enjoyable environments for our clients and contacts. This Privacy and Cookies Policy relates to our use of any personal information we collect from you via the following online services:
- any ThinkBDW website that links to this Privacy and Cookies Policy;
- social media or official ThinkBDW content on other websites;
- mobile device and Applications (“Apps”);
It also relates to our use of any personal information you provide to us by phone, SMS, email, in letters and other correspondence and in person.
In order to provide you with the full range of ThinkBDW services we sometimes need to collect information about you.
This Privacy and Cookies Policy explains:
- what information ThinkBDW may collect about you;
- how ThinkBDW will use information we collect about you;
- when ThinkBDW may use your details to contact you;
- whether ThinkBDW will disclose your details to anyone else;
- your choices regarding the personal information you provide to us;
- how you can change the way we hold and use your personal information.
Whenever you provide personal information, we are legally obliged to use it in line with all applicable laws concerning its protection, including the Data Protection Act 1998 and the General Data Protection Regulations (referred to collectively in this Privacy and Cookies Policy as the “data protection regulations”).
2. Who are we?
ThinkBDW Ltd is a UK based marketing and communications agency offering a fully integrated service to our clients so they can deliver the most appropriate marketing information or other relevant communications to their end users.
We are a subsidiary of the listed UK company The Mission Marketing Group Plc and we sometimes work with other companies in the group to help deliver services to clients.
3. What information will ThinkBDW collect about me?
When you participate in, access or sign up to any of ThinkBDW’s services, activities or online content we may receive personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, gender or date of birth.
4. How will ThinkBDW use the information it collects about me?
ThinkBDW will use your personal information for a number of purposes including:
- to provide our services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
- to analyse the information you supply as well as your activity on our (and other) services so that we can offer a more relevant, tailored service where we provide personalised services;
- to use IP addresses and device identifiers so we can identify the location of users, block disruptive use, establish the number of visits from different countries and determine whether or not you are accessing the services from the UK;
- for analysis and research purposes so that we can improve the services offered by ThinkBDW. This can include using geo-demographic information from external sources where this helps us;
- we may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
Where ThinkBDW proposes using your personal information for any other use we will ensure that we notify you first. Please see section 18 for details.
5. Your ThinkBDW Contact Request
If you fill out one of our on-line contact forms your details will be added to our CRM system so we can effectively manage your enquiry. You will be contacted regarding your enquiry using the information you submit on the form.
If you choose you will be added as a subscriber to our newsletter emails. You can unsubscribe from these at any point using the unsubscribe link at the bottom of those emails.
6. When will ThinkBDW contact me?
ThinkBDW may contact you:
- in relation to any correspondence we receive from you or any comment or complaint you make about ThinkBDW products or services;
- in relation to any services you are using;
- to update you on any material changes to ThinkBDW’s policies and practices; and
- for marketing purposes, as set out in section 7.
7. Will I be contacted for marketing purposes?
ThinkBDW will only send you marketing communications where you have agreed to this.
We offer occasional emails, to let you know about ThinkBDW initiatives and services. We may personalise the message content based on any information you have provided to us and on your use of ThinkBDW platforms.
We may use information we hold about you to show you relevant advertising on third-party sites (e.g. Facebook, Google, Instagram, Snapchat and Twitter).
8. Will ThinkBDW share my personal information with anyone else?
We will keep your information within ThinkBDW except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies, including for child protection reasons) or as described in this section and section 9.
We may share your information across ThinkBDW and, where this is necessary to provide you with a service you have requested, other Mission Marketing Group agencies.
We will use your information within ThinkBDW and will only share it outside the Mission Marketing Group where you have requested it or given your consent. However, we may share with third party sites (e.g. Facebook, Google, MailChimp, credit reference suppliers, Instagram, Snapchat and Twitter) some data, with appropriate security measures, to show you relevant advertising on third party sites, as set out in section 7
Sometimes ThinkBDW uses third parties to process your information on our behalf for example to provide services or analysis. ThinkBDW requires these third parties to comply strictly with our instructions and ThinkBDW requires that they do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in that way.
9. Offensive or inappropriate content on ThinkBDW websites
If you post or send content which we consider offensive, inappropriate or objectionable anywhere on or to ThinkBDW websites or otherwise engage in any disruptive behaviour ThinkBDW may remove that content and/or block access.
Where ThinkBDW considers that you may be in breach of any applicable laws, for example on hate speech, ThinkBDW may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. ThinkBDW would only do so in circumstances where such disclosure is permitted under applicable laws, including data protection regulations.
10. What if I am a user aged under 18?
If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to ThinkBDW.
11. How long will ThinkBDW keep my information?
We will hold your personal information for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with ThinkBDW.
12. Can I delete my data?
You can request that ThinkBDW delete any personal information we hold about you at anytime by contacting firstname.lastname@example.org with your request. Alternatively you can write to Security Data Controller, ThinkBDW Ltd 4 Wyncolls Road, Severalls Business Park, Colchester, Essex, CO4 9HU.
13. Can I find out what personal information ThinkBDW holds about me?
Under the data protection regulations you have the right to request a copy of the personal information ThinkBDW holds about you and to have any inaccuracies corrected. We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information about you in our files. If you are within the UK, please address requests and questions about this or any other question about this Privacy and Cookies Policy to the Data Protection Officer, 4 Wyncolls Road, Severalls Business Park, Colchester Essex. CO4 9HU (Email: email@example.com )
(We may charge for information requests in relation to copying and postage costs and require you to prove your identity with 2 pieces of approved identification – one from each list below).
Passport Utility bill (from within the last 3 months)
Driving licence Current vehicle registration document
Birth certificate Bank statement (from within the last 3 months)
14. Web browser cookies
a) What is a Cookie?
A cookie is a small amount of data, which often includes a unique identifier, that is sent to your computer, tablet or mobile phone (all referred to here as a “device”) web browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your web browser if your browser’s preferences allow it. Many websites do this whenever a user visits their website in order to track online traffic flows. Similar technologies are also often used within emails to understand whether the email has been read or if any links have been clicked. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on the ThinkBDW website. However, you can change your cookie settings at any time.
On ThinkBDW websites, cookies record information about your online preferences and allow us to tailor our websites to your interests.
c) Third party cookies in embedded content on ThinkBDW pages
Please note that during your visits to ThinkBDW websites you may notice some cookies that are not related to ThinkBDW or ThinkBDW’s contractors.
We sometimes embed content from social media and other third party websites. These may include YouTube, Vimeo, Google Maps, Twitter, Facebook, SoundCloud, Vine, Instagram, Pinterest and Flickr. As a result, when you visit a page containing such content you may be presented with cookies from these websites and these third party cookies may track your use of ThinkBDW website. ThinkBDW does not control the dissemination of these cookies and you should check the relevant third party’s website for more information. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on the ThinkBDW website. However, you can find out about changing your cookie settings here.
Where ThinkBDW embeds content from social media and other third party websites some websites may use Google Analytics to collect data about user behaviour for their own purposes. ThinkBDW does not control this. For more information, see the Google webpage “How Google uses data when you use our partners’ sites or apps”.
d) ThinkBDW cookies and how to reject cookies
Below are details of cookies set by services we use to better understand the use of the ThinkBDW owned websites. We use this data to continuously improve our service we offer.
|These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form that does not identify a visitor, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This helps us to improve the way our website works, for example by making sure users are finding what they need easily.||Click here for an overview of privacy at Google To opt out of being|
tracked by Google Analytics across all websites visit the Google site.
|Infinity Call Tracking||ictf_*||To identify the search keywords that drive phone call enquiries we use Infinity Call Tracking cookies. These simply assign a unique number to a visitor so that if a phone call enquiry is made, it is possible to track which keywords led to the original enquiry.||To find out more visit Infinity|
You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies Learn how.
It is important to note that if you change your settings and block certain cookies you may not be able to take full advantage of some features of ThinkBDW services, and we might not be able to provide some features you have previously chosen to receive.
e) Other information collected from web browsers
Your web browser may also provide ThinkBDW with information about your device such as an IP address and details about the browser that you are using. Where requesting specific service it may be possible for you to choose to provide ThinkBDW with access to your device’s location through the web-browser. We use information provided by your browser or by the link that you have clicked to understand the webpage that directed you to ThinkBDW and this may be captured by performance cookies.
15. Do Not Track (DNT) browser setting
DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked such as by third party ad networks, social networks and analytic companies. This website does not currently respond to DNT requests.
16. ThinkBDW Developed Apps
When you download or use ThinkBDW apps on your mobile device or TV information may be accessed from or stored to your device. Most often this is used in a similar way to a web browser cookie such as by enabling the app to ‘remember’ you or provide you with the content you have requested.
Your web browser or device may also provide ThinkBDW with information about your device such as a device identifier. Device identifiers such as the device ID, IP address, MAC address, IMEI number or app ID (a unique identifier relating to the particular copy of the app you are running) may be collected automatically.
Information collected automatically
The Application may automatically collect information related to:
- The device running the Application, including any unique device identifier, IP address, operating system the device uses
- The date and time the Application is used
- The location of the device when the Application is used
Use of automatically collected information
This type of data would only be used by us in aggregated and anonymised form in order to provide information that helps us understand the use of our Applications and to improve the Applications we create.
User Provided information
If our Application requires you to provide and share personal information or needs to access other information on your device or to access information used by other applications on your device then we will require you to register with us and provide positive acceptance of this Policy. Many of our Applications will not collect or use this type of information. Where registration is required if you do not accept the Policy then the functionality of the Application may be restricted.
Examples of personal information include:
- Name, age, gender, your contact details
- Credit card details (only where the Application provides opportunities for purchasing)
- Your contact lists or preferences in other applications
- Your use of other applications
- Images, comments and other materials on your device or in other applications accessed by your device (eg profile pictures, preferences) and used by the
Use of user provided information
We will only use this type of information:
- for purposes implicit in the intended use of the Application; and/or
- in anonymised and aggregated form for more detailed analysis of the use of the Application; and/or
- For internal operations, including troubleshooting problems, data analysis, testing, research, improvements to the Application; and/or
- to contact you regarding important information or required notices; and/or
- to contact you regarding marketing promotions unless you have opted out of this in your registration details.
Sharing of your information
We will not provide access to your information to third parties for commercial gain.
Except as below we will not disclose or share your information. We may disclose user provided and automatically collected information:
- as specifically requested by you from within the Application.
- as required by law, such as to comply with a court order, or similar legal process;
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set out in this Policy.
- In connection with a corporate transaction involving the Application, such as the purchase or sale of a business unit, an acquisition, merger, sale of assets, or other similar event.
Storing your information
Your information may be stored and processed in any country and may include outsourced cloud facilities. In this regard, or for purposes of sharing or disclosing data as described in this Policy, we reserve the right to transfer information outside of your country. By using the Application, you consent to any such transfer of information outside of your country.
We will retain user provided data for as long as you remain registered to use the Application and for a reasonable time thereafter. We will retain automatically collected information for up to 24 months and thereafter may store it in aggregate.
If you’d like us to delete user provided data that you have provided via the Application because you no longer wish to use the Application then you should de-register your account with us; simply removing the Application from your device will not automatically delete your information.
Please note that some or all of the User Provided Data may be required in order for the Application to function properly.
Safeguarding the confidentiality of your information is a priority for us. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, due to the inherent nature of the internet and related technology no security system can prevent all potential security breaches.
Third party links
Occasionally, at our discretion, our Applications may include or offer third party products or services or provide links to other organisations or services. These third parties have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked applications, however, to protect the integrity of our applications, we welcome feedback regarding any breach of privacy policies by those third parties.
Many of our Applications will be suitable for children (under 16) and will not require user provided personal information.
Where an Applications requires registration with us (and hence access to user provided information) we will ask for the user’s age and appropriately restrict the information the Application can access or share.
17. Changes to ThinkBDW’s Privacy and Cookies Policy
18. Contacting ThinkBDW about this Privacy and Cookies Policy
If you have any questions or comments about this Privacy and Cookies Policy please contact:
Data Controller, 4 Wyncolls Road, Severalls Business Park, Colchester Essex. CO4 9HU