Privacy Policy

We Are Thrive is committed to protecting your privacy when you visit our website or access or engage with our services. This privacy policy explains how we use your information and protect your right to privacy.

Any personal information We Are Thrive obtains is processed, held and/or controlled in accordance with the General Data Protection Regulations (2016/679) under the Data Protection Act (2018).

Who we are

We Are Thrive is a private limited company (10988846) incorporated and registered in England and Wales. We have a Data Protection Lead which makes sure we respect your rights and follow the law. 

You may contact us at any time to:

• request access to information which We Are Thrive has about you;
• correct any information which We Are Thrive has about you;
• ask for any information which We Are Thrive has about you to be deleted;
• discuss any concerns or ask any questions about how we look after your personal information.

To do any of the above, please contact hello@wearethrive.marketing.

How the law allows us to use your personal information

BSME processes personal data, both as a Data Controller and as a Data Processor, as defined by relevant Data Protection Legislation: the General Data Protection Regulations 2016/679, the Data Protection Act 1998, the EU Data Protection Directive 95/46/EC, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and all applicable laws and regulations relating to processing of personal data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner.

There are a number of legal reasons why we need to collect and use your personal information.

Generally, we collect and use personal information where:

• you, or your legal representative, have given consent;
• you have entered into a contract with us;
• it is necessary to perform our statutory duties;
• it is required by law;
• it is necessary for employment purposes;
• you have made your information publicly available;
• it is necessary for legal cases;
• it is to the benefit of society as a whole;
• it is necessary for archiving, research, or statistical purposes.

If we have consent to use your personal information, rather than legal or contractual reasons, you have the right to revoke your consent at any time. If you want to revoke your consent, please contact hello@wearethrive.marketing and tell us which service you’re using so we can deal with your request.

Information we collect

Personal information can be anything that identifies and relates to a living person and can include information that when put together with other information can then identify the person. For example, this could include (but is not limited to) your name, contact details, demographic information or IP address. We Are Thrive may collect such personal information, in accordance with this Privacy Policy.

Cookies

The We Are Thrive website may place and access certain Cookies on your computer. All Cookies used by this website are used in accordance with current UK and EU Cookie Laws. These include (but may not be limited to):

1. Google Analytics: to improve website and marketing
2. Strictly necessary cookies: cookies that are required for the operation of our website

You may, if you wish, deny consent to the placing of Cookies; however certain features of the website may not function fully or as intended. You can also choose to delete Cookies at any time; however, you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings.

Why we collect personal information

We collect personal information so that we may provide the best possible service and experience to our users and clients.  

Specifically, we may need information about you to:

• Deliver and manage the services we provide to you;
• Train and manage the employment of our staff who deliver those services;
• help investigate any worries or complaints you have about your services and to answer your questions and enquiries;
• check and improve the quality of our services
• research and plan new services;
• send you information which we think might be of interest to you where we believe there is legitimate interest to do so;
• carry out our obligations arising from any contracts entered into between you and us;
• market our related products and services to you, where we believe they will be of interest;
• Internal record keeping.

How we collect information

Information is either given to us by you, or collected automatically.

Given to us by you

You may provide We Are Thrive with your information in a number of ways:

• When you contact us through the website, by telephone, post, e-mail or through any other means;
• When you elect to receive marketing communications from us;
• When you make online enquiries;
• Completion of surveys;
• When you use our services.

Collected automatically

When you access the We Are Thrive website, we automatically collect some information about your visit. This information helps us to make improvements to website content and navigation and includes your IP address, the date, times, and frequency with which you access the website and the way you use and interact with its content. We will collect your data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the website, see the section below, headed “Cookies”.

Third Parties

On occasion, third parties will provide your information to We Are Thrive. This includes professional networks and public information sources like LinkedIn.

How we use information

We will only use information required for the efficient execution of services to clients. If we use any of your personal information for research and analysis, we will always keep you anonymous or use a different name, unless you’ve agreed that your personal information can be used for that research.  

We don’t share it unnecessarily

We use a range of systems to store personal information, share information with clients or help deliver our services to you. These systems contain databases which hold your information. Where we have these arrangements, there is always an agreement in place to make sure that the organisation complies with data protection law. We don’t sell your personal information to anyone else.

We only use what we need

We’ll only collect and use personal information if we need it to deliver a service or meet a requirement.  If we don’t need personal information, we won’t ask for it. If we already have the data, we will keep you anonymous. 

We will only keep your information for as long as we need it

We will retain your personal information only for as long as we need it in order to fulfil the purposes for which we have initially collected it, unless otherwise required by law or tax, regulatory, or contractual requirements.

What you can do with your information

The law gives you a number of rights to control what personal information is used by us and how it is used by us. In addition to the subheading outlined below, this may also include:

• asking us to restrict what we use your personal information for where
• asking us to stop using your personal information for any service we provide
• unsubscribing from any materials we may send you (however, this may cause delays or prevent us delivering services to you).
• requesting that we move, copy, or transfer your data to another service provider of your choice (data portability). 
• objecting to our use of your data including where we use it for our legitimate interests.

Where possible we’ll seek to comply with these requests, unless otherwise required to by law or by contract.

Request access to information which We Are Thrive has about you

You have the right to ask for all the information we have recorded about you. To see this, please submit a written request on hello@wearethrive.marketing. We will ask you to provide evidence so that we can verify your identity and, when proven, will provide a record of all the personal information that we have on file for you with the exception of any parts of your record which contain:

• confidential information about other people; or
• data a professional advisor thinks will cause serious harm to your or someone else’s physical or mental wellbeing; or
• if we think that giving you the information may stop us from preventing or detecting a crime.

Correct any information which We Are Thrive has about you

You should let us know if you disagree with information we hold about you. To do so, we will need to ask you to provide evidence so that we can verify your identity. We may not always be able to change or remove that information, but it is our duty to correct factual inaccuracies, and your comments will be recorded. 

The quickest way to inform us of any inaccuracies is to email hello@wearethrive.marketing.

Ask for any information which We Are Thrive has about you to be deleted (the right to be forgotten)

In some circumstances you can ask for your personal information to be deleted, for example:

• where your personal information is no longer needed for the reason it was collected in the first place;
• where you have removed your consent for us to use your information (where there is no other legal reason for us to use it);
• where there is no legal reason for the use of your information;
• where deleting the information is a legal requirement;

Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure.

Please note that we can’t delete your information where:

• we’re required to have it by law;
• it is used for freedom of expression;
• it is for, scientific or historical research, or statistical purposes where it would make information unusable;
• it is necessary for legal claims.

Discuss any concerns or ask any questions about how we look after your personal information

If you would like to discuss any concerns or ask any questions about how we look after your personal information, please contact hello@wearethrive.marketing. If you are not satisfied with the way a complaint you make in relation to your data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/. You can also contact the ICO for independent advice regarding data protection, privacy and data sharing issues.

How we keep your data secure

We’ll do what we can to make sure that your data is kept secure, and we’ll only make them available to those who have a right to see them. Examples of our security include:

• Storing data on secure servers
• Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it; all data is stored on password-protected systems;
• Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong;
• Regular testing of our technology and ways of working including keeping up to date on the latest security updates.

Links to other websites

Our website may contain links to other websites of interest. We have no control over such websites and are not responsible for the content of these websites. However, once you have used these links to leave our site, you should note that we do not have any control over other websites and therefore cannot be held responsible for the protection and privacy of any information which you provide whilst visiting such sites. You are advised to read the privacy policy or statements of other websites prior to using them.

Changes to this privacy policy

We Are Thrive reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website, and you are deemed to have accepted the terms of the privacy policy on your first use of the website following the alterations. 

Change of business ownership and control

1. We Are Thrive may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of We Are Thrive. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the data for the purposes for which it was originally supplied to us.
2. We may also disclose data to a prospective purchaser of our business or any part of it.
3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Interpretations

In this privacy policy, unless the context requires a different interpretation:

1. The singular includes the plural and vice versa;
2. References to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
3. A reference to a person includes firms, companies, government entities, trusts and partnerships;
4. “Including” is understood to mean “including without limitation”;
5. Reference to any statutory provision includes any modification or amendment of it;
6. The headings and subheadings do not form part of this privacy policy.

General

1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal, or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
3. Unless otherwise agreed, no delay, act, or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
4. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

End of policy