2. Contact details for the controller and processor of your personal data
Re-thinking Ltd, Axholme House, 47 London Road, Marlborough, Wiltshire, SN8 2RN Tel: 01672 516688
3. The personal data we collect
We will collect a limited amount of personal information provided during a product or service enquiry. The reason we hold data is to progress a product or service enquiry, to deliver a product or service or to administer our staff and associates. The data we collect from you is limited to:
Your name and title
Your company or business address
Your email address
Your telephone number
360 feedback from your colleagues with your prior permission Observations by our facilitators as part of an agreed contract Delegate feedback following training
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.
4. Why we hold your data
The contact information that we hold allows us to deal with your order or enquiry more quickly and efficiently and allows us to retain a record of historical enquiries or orders so that we are better placed to advise you. Occasionally, we may communicate with you regarding our offers and services that we believe will be relevant to you. Any marketing communication from us will give you the option of ‘unsubscribing’ from future marketing communications. Your data will only be used by us or our ‘partner processors’ (see below); we will never sell your data to a third party. We hold data on individuals as part of contract of work we have with our clients.
5. What about legally compelled disclosure of information?
We may disclose information when legally compelled to do so. In other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights. We may also disclose account information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service, IP or to protect the safety of our users and the Public.
6. The lawful basis and purpose for processing personal data
We refer to the Legitimate Interest Purposes – Article 6 of the GDPR
- Processing your limited personal data benefits both you and Re-thinking Ltd since by holding limited personal information we can respond more quickly and accurately to your enquiries by accessing your account or enquiry history. We can also recommend future products or services which may be of interest to you and this helps us by making our communications more relevant to you. You always have the option to ‘unsubscribe’ from future communications from us.
- The processing of your data is based on your relationship with us as an existing or future customer.
- We do not ‘buy-in’ personal data and the reason we hold this personal information is that you have supplied it to us.
- If you instruct us to remove your personal data from our databases, we will do this within 28 days and acknowledge your request.
7. Others that process data on our behalf (our partner processors’)
Other people and organisations that process data on our behalf include:
Our Directors, employees and associates employed by Re-thinking Ltd or work under the Rainmaker Coaching brand.
MS365 (our email database system) and our marketing database and document filing storage – https://www.microsoft.com/en-us/trustcenter/privacy/gdpr/gdpr-overview
Xero (our accounting system for invoicing and billing) https://www.xero.com/uk/campaigns/xero-and-gdpr/
John Wiley Ltd (Leadership Practices Inventory) https://www.wiley.com/en-gb/privacy
Personal Strengths Publishing (SDI Profiles) https://my.totalsdi.uk/privacyLegacy.asp
Just Host web hosting https://www.justhost.com/terms
8. The length of time we hold personal data
Our sales cycle can be extremely long between orders from the same business or contact and it is not unusual for these periods to span many years. To ensure that we can maintain a history of continuity with our customers, we will retain personal data for a period of 15 years from the date of last contact.
9. Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no lawful basis for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to the processing of your personal data. If having provided us with your personal data, something changes in your personal situation, you may object on these grounds. You also have the right to object where we are processing your personal data for direct marketing processes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the personal data we hold; (b) you have objected to our use of personal data, but we need to verify whether we have legitimate grounds to use it.
If you wish to exercise your rights above, please contact us using the details at the top of this page. You will not have to pay a charge to exercise any of the rights listed above but we may make a reasonable charge if your request for access is clearly unfounded or excessive
10. Web site use information
When you visit either the Re-thinking or the Rainmaker-Coaching (a brand of Re-thinking Ltd) sites you may provide us with two types of information: personal information you knowingly choose to disclose that is collected on an individual basis as described above and web site use information collected on an aggregate basis when you browse our web site.
Our web site utilises a standard technology called “cookies” (see explanation below, “What are cookies?”) and web server log files to collect information about how our web site is used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our web site, and the web sites visited just before and just after our Web site.
11. What are cookies?
11.1 How do we use information we collect from cookies?
11.2 IP addresses
IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as traffic data so that data (such as the Web pages you request) can be sent to you.
11.3 What about other web sites linked to our web site?
We are not responsible for the practices employed by web sites linked to or from our Web site or the information or content contained therein. Often links to other web sites are provided solely as pointers to information on topics that may be useful to the users of our web site.
11.4 Our website – your consent
12. Data security
12.1 How we will keep your data secure
Your data will be stored and processed on our computers in the United Kingdom and USA. Re-thinking Ltd has in place appropriate security measures designed to keep your personal data secure, preventing it from being lost, stolen, accessed or disclosed in an unauthorised way. These measures include:
- Limiting access of your personal data to only individuals that have a genuine need to access it.
- Only allowing these individuals to use your personal data in accordance with your/our instructions.
- Having procedures in place to deal with any suspected or confirmed personal data breach and to notify you and the supervising authority of a breach where we are legally obliged to do so.
12.2 A special note about children
Children are not eligible to use our services unsupervised and we ask that children (under the age of 18) do not submit any personal information to us. If you are a minor, you can use this service only in conjunction with permission and guidance from your parents or guardians.
12.3 Acquisition or changes in ownership
In the event that the web site (or a substantial portion of its assets) is acquired, your information would be considered part of those assets and may be part of those assets that are transferred.
14. In the event of a complaint
If you wish to complain, please do so in the first instance to Re-thinking Ltd using the contact details at the top of this page. We will seek to investigate your complaint within 48 hours.
You can also obtain further GDPR information or exercise your right to make a complaint if you feel we have not handled your personal data correctly by contacting the Information Commissioner’s Office at:
Information Commissioner’s office, Wycliffe House, Wilmslow, Cheshire SK9 5AF Telephone: 0303 123 1113