Trust Us With Your Data. We Promise We’ll Keep It Safe!
GDPR and Privacy Policy
Trust Us With Your Data. We Promise We’ll Keep It Safe!
GDPR and Privacy Policy
At Thrive Marketing Communications, your privacy is important to us and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy explains what we do with your personal data, whether we are in the process of creating a statement of work or enacting a planned strategy for your recruitment marketing, receiving a service from you, or you are visiting our website.
We reserve the right to update this policy where necessary, which includes updates to comply with any future amendments to data protection regulations.
When you visit or register on the Site (www.thrivermo.com) you may be asked to provide certain information about yourself including your name, address, email address, and telephone number. If you enquire about our service, the information you provide in any application form will also be stored. We may also collect information about your usage of our Site, as well as information about you from emails or letters you send to us.
Your information will enable us to provide you with access to all parts of our Site and to supply our services, which include providing you with our newsletter, and to contact you where necessary. We will also use and analyse the information we collect so that we can administer, support, improve and develop our business, which may include contacting you to notify you of our current or future services.
In particular, we may use your information to contact you for your views on our services and to notify you occasionally about important changes or developments to the Site or our services. Further, where you have consented, we might also use your information to let you know about other services that we offer which may be of interest to you and we may contact you by post, telephone or email.
We retain all information indefinitely. If you change your mind about being contacted in the future, please let us know or, if you would like us to delete your personal information, please send an email to contact@thrivemarcoms.co.uk and provide details of your request.
We collect a limited amount of data from our website users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, the times that our website is most popular, how you open our newsletter, the content you are most interested in, and the times that our newsletter is most popular.
We need a small amount of information from our suppliers to ensure that things run smoothly. We’ll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details so that we can pay you. We may also hold extra information that someone in your organisation has chosen to provide us.
We need to know certain information about you to provide a tailored service. This will enable us to provide you with the best opportunities that are not relevant to you.
There are numerous ways you can share your information with us. These may include:
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website, for example by using the ‘contact us’ or ‘enquiry’ function.
We collect your data automatically via cookies, in line with cookie settings in your browser.
We use third-party social media sites and data aggregators to access publicly-available information such as your name, title, company name, e-mail, country and/or phone number. This information has been captured from information you have provided and within the terms and conditions as stipulated on these sites and/or platforms.
A “cookie” is a piece of information that is stored on your computer’s hard drive and records your navigation of a website. This means that when you revisit that website it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
To track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer.
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).
Cookies can also be categorised as follows:
Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make (such as your username, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Given the niche nature of the sectors we work in, we may periodically send you information that we think you may find interesting. In particular, we may wish to use your data if you have so specified we may (via an opt-in sign-up form) or via third-party information for the purposes listed below, where appropriate and in accordance with any local laws and requirements, to:
Please note that this list is not exhaustive.
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in.
We want to make you aware that in some rare circumstances even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn’t happen, but if it does, we’re sorry. We’d just ask that in those circumstances you opt out again. You have the right to withdraw your consent at any time, details of which are under ‘How to amend or withdraw consent’.
Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our ‘Industry Insights’ to a corporate postal or email address. You have the right to opt out of receiving marketing materials from us and can find out more about how to do so.
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
We will only use your information:
We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
Given the niche nature of Thrive Marketing Communications services and market, we have legitimate interests in keeping data for market intelligence purposes.
We will attempt to verify the data we hold for you at least every two years.
We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for four years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data).
When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
One of the GDPR’s main objectives is to protect and clarify the rights of GB and NI citizens and individuals in the GB/NI and the EU with regards to data privacy. This means that you retain various rights in respect to your data, even once you have given it to us. These are described in more detail below.
To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our website users, clients and suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or email automation), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request.
If we refuse your request we will always tell you the reasons for doing so.
You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
If we process the data because we believe it necessary to do so for our legitimate interests, or you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for one of the following reasons:
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important GB&NI / EU or member state public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
You also have the right to lodge a complaint with your local supervisory authority.
If you would like to exercise any of these rights or withdraw your consent of the processing of your personal data (where consent is our legal basis for processing your personal data), please contact contact@thrivemarcoms.co.uk. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
I.e. can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
In an endeavour to provide you a more tailored service, we will process your data under the following legitimate interests.
To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, deliverables and timeframes. From time to time, we may also ask you to undertake a customer onboarding and/or satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment marketing services to you.
We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
We will keep records of the consents that you have given in this way.
We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment marketing services we provide as long as you do not actively opt-out from these communications.
As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found under ‘How to amend or withdraw consent’.
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. This may arise, for example, where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
Any changes to our privacy policy in the future will be posted to the Site and, where appropriate, communicated through email notification.
If you have any further questions regarding our GDPR Privacy Policy or our Cookie Policy, please get in touch.