1 . Purpose of this Policy

This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use.

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties (including but not limited to our client publication on behalf of whom we process personal data as a data processor).

2 . Who are we and what do we do?

The Site and our services are operated by Think Publishing Limited, (“we”, “us” or “our”).

Think Publishing Limited is the data controller responsible for your personal information and is registered at the UK Information Commissioner’s Office with registration number: ZA273071

Think Publishing Limited is an English company with registered company number: 03817566 and whose registered office is at Capital House, 25 Chapel Street, London, NW1 5DH.

3 . How to contact us?

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:
• sending an e-mail to [email protected]; or
• calling us on: 020 3771 7200

4 . What personal information do we collect and how do we use it?

Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our services and develop and market our services; (iii) carry out requests made by you on the Site; (iv) investigate inquiries; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law.

Client enquiries and services

Our Site uses user interfaces to allow you to request information about our services: these electronic enquiry forms and a telephone enquiry options. Contact information will be requested when you are making enquiries, together with details of other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests, and contact you with information and notices related to your use of the our services and the Site.

Who do we share your personal information with for this purpose?
We do not share your personal information for this purpose

What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you.

Marketing communications and sales

Our sales team sometimes collect personal data such as names and contact details of potential new clients and new advertiser from publically available third party sources. We use this information for business to business marketing purposes in order to make people aware of the services that we offer as well as opportunities to advertise in our client publications.

Our sales team make all individuals who we contact in this way aware that they can opt out of receiving any further communication from us in this regard and we maintain a database of individuals that clearly highlights those who opted out on this basis.

Who do we share your personal information with for these purposes?
We do not share your personal information for this purpose

What is our legal basis?
Where we use your personal information in connection with business to business sales it is in our legitimate interest to do so.

Business administration and legal compliance

We use your personal information for the following business administration and legal compliance purposes:

• to comply with our legal obligations;
• to enforce our legal rights;
• protect rights of third parties; and
• in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

5 . How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or
• by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

6 . Our use of cookies and similar technologies

Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

7. Third party links and services

Our Site may contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers.

8 . How long do we keep your personal information for?

We keep your personal information indefinitely so that we have a record of requests you have made in the past e.g. requests for information in relation to our products and services. It is also important for us to maintain a record of your personal information in the event that you have asked us to no longer contact you.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.

9 . Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

10 . How to access your information and your other rights?

You have the following rights in relation to the personal information we hold about you:

Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right of rectification
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right of erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing.

Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

11 . Changes to this privacy policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.