PRIVACY

THRIVE PARTNERS LTD – PRIVACY POLICY

THRIVE PARTNERS LTD ("We/us/our") are committed to protecting and respecting your privacy.

This policy (together with our Website Terms of Use and our end-user licence agreement (EULA) and any additional terms incorporated by reference into such documents) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.thrivepartners.co.uk you are accepting and consenting to the practices described in this policy.

For the purposes of this Privacy Policy, the term “personal data” means any information which identifies you or which allows you to be identified when combined with other information, and “sensitive personal data” means information concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning your sex life or sexual orientation.

  1. Who are we?

    Thrive Partners Ltd is a company incorporated in England under company no. 09831900 whose registered office is located at 55 Baker Street, London, W1U 7EU.

    Our nominated data protection representative can be contacted at dataprotection@thrivepartners.co.uk.

  2. When this policy applies

    This policy applies to:

    • our websites www.thrivepartners.co.uk and my.thrivepartners.co.uk (our sites);
    • the MyThrive mobile application software (App) available on our sites and available to download from the Apple App Store of Google Play Store (App Sites), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device); and
    • all of the services offered by us through our sites or through the App Site (Services).

  3. Information we may collect from you

    We may collect and process the following data about you:

    • Information you give us. You may give us information about you:
      • when completing any registration forms or other forms or questionnaires on our sites or the App Sites or otherwise provided by us to you, when you upload materials onto our sites, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our sites, subscribe to any of our Services, sign up to be a coach on our sites, download or register an App, search for an App or Service, search for a product or service, place an order on our sites, participate in forums, discussion boards or other social media functions on our sites, share any documents or other materials with other users of the sites, enter a competition, promotion or survey, send us your details when you express an interest in working with us and when you report a problem with any of our sites an App or our Services. The information you give us may include your name, age range, gender, nationality, email address and phone number, the Device’s phone number, financial and credit card information (where you do not pay us through our chosen third party payment provider), personal description and photograph and in the case of coaches and individuals expressing an interest in working with us includes any additional information you submit to us including information about your expertise, qualifications, skills, interests and your address; and/or
      • (as a client) when attending coaching sessions on our sites and filling in questionnaires and feedback forms on the sessions or (as a coach) when providing coaching sessions and completing post session notes on our sites. As a client this may include information about your relationship with your employer, how long you have worked for the organisation, your experience of the organisation, and what can be improved. As a client you may also discuss personal matters with a coach which could include you disclosing sensitive personal data to them during a coaching session or in any sessions notes that you complete in relation to a coaching session, however this is entirely at your discretion. Coaching sessions may be recorded and transcribed. Outside the sessions themselves, we will only use this information at an aggregate level and on an anonymised basis to feedback on macro issues affecting an industry or organisation and produce the “Thrive Insights” (see below “Uses” for more information).
    • Information we collect about you and your Device. With regard to each of your visits to the sites or use of our Apps we may automatically collect the following information:
      • technical information, including;
        • the type of mobile device you use, your mobile operating system, the type of mobile browser you use, time zone setting;
        • the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
      • information about your visit to our sites, including the full Uniform Resource Locators (URL) clickstream to, through and from our sites (including date and time); your session history in relation to coaching sessions you have booked, received and cancelled (in the case of clients) or performed (in the case of coaches) on the sites; services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
      • details of your use of any of our Apps or your visits to any of the sites including, but not limited to traffic data, weblogs and other communication data and the resources that you access.
        • Information we receive from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
        • Unique application numbers: when you install or uninstall an App containing a unique application number or when such App searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

  4. Uses made of the information

    We use information held about you in the following ways:

    • Information you give to us. We will use this information:
      • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
      • to provide you, with information about goods or services we feel may interest you. You can change your marketing preferences at any time in accordance with section 9 below;
      • to notify you about changes to our Services;
      • to ensure that content from our sites and Apps is presented in the most effective manner for you and for your computer or Device; and
      • to compile and produce “Thrive Insights” which are real time, aggregated data giving macro analytics on key trends, experiences, and attitudes within organisations and industry sectors. In order to compile the Thrive Insights coaching sessions may be recorded and transcripts made from which the data is extracted. We also extract data from coaching session notes completed by users of the Service to compile the Thrive Insights. We do not disclose information about identifiable individuals in our Thrive Insights, instead we use aggregate information about our users (for example, we may say that 30% of employees in a given organisation think annual review process needs to be improved). We will only share information that is not traceable back to an individual;
      • in the case of information provided by coaches and anyone expressing an interest in working with us to ensure you have the requisite skills and experience to provide coaching services to our clients and to monitor our compliance with equal opportunities legislation.
    • Information we collect about you and your Device. We will use this information:
      • to administer our Services, sites and Apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      • to improve our Services, sites and Apps to ensure that content is presented in the most effective manner for you and for your computer or Device;
      • to allow you to participate in interactive features of our Services, when you choose to do so;
      • as part of our efforts to keep our sites safe and secure;
      • to make suggestions and recommendations to you about goods or services that may interest you.
    • Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
    • Unique application numbers. We do not store this information at a user level, but use the unique identifiers to track overall usage of our App and services.

  5. Disclosure of your information

    We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

    We may share your information with selected third parties including:

    • service providers who provide IT and system administration services;
    • our professional advisers including lawyers, accountants, bankers, auditors and insurers who provide professional services to us;
    • service providers who provide outsourced business functions on our behalf;
    • other users of the sites in relation to the provision or receipt of coaching services by you on the sites;
    • analytics and search engine providers that assist us in the improvement and optimisation of our sites; and
    • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

    We may disclose your personal information to third parties:

    • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
    • if THRIVE PARTNERS LTD or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
    • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use, EULA and other agreements; or to protect the rights, property, or safety of THRIVE PARTNERS LTD, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

  6. Our legal basis for processing your personal data

    We process your information for the above purposes on the basis it is necessary to perform a contract with you (where you are a coach or a consumer) or because it is in our legitimate interests and your interests and fundamental rights do not override our interests, except where you have given us your consent to the processing or where we need to process your information to comply with a legal obligation.

    You may object to any processing by us on the basis it is in our legitimate interests or withdraw your consent at any time in accordance with section 9 below.

  7. Where we store your personal data

    The data that we collect from you will be stored within the European Economic Area (“EEA”). Information about you which is displayed on our sites and material which you upload onto our sites may be transferred outside the EEA if it is accessed by another user of our sites located outside the EEA in accordance with the purposes set out above. We will only transfer your personal data outside the EEA where such transfer is in compliance with applicable laws, which may include transferring the data to a country in respect of which an adequacy decision has been issued by the European Commission, or where the transferee is bound by a specific contract deemed adequate by the European Commission. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the US. By submitting your personal data, you agree to this transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

    All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using PKI encryption technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We will collect and store personal data on your Device using application data caches and other technology.

    Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

  8. How long we keep your personal data

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    For details of our retention periods for your personal data please contact us.

  9. Your rights

    1. Right to object to processing based on our legitimate interests: You have the right to object to us processing your personal data on the grounds of it being in our legitimate interests.
    2. Right to withdraw consent: You have the right to withdraw any consents you have previously given us to process your personal data. If you withdraw your consent to a coaching session being recorded, currently this means we will delete the recording promptly after its creation and no data will be used from the recording prior to its deletion. In the future we will be introducing functionality to ensure that such coaching sessions are not recorded.
    3. Right to opt-out of receiving marketing communications: You have the right to opt-out of receiving marketing communications from us at any time by contacting us. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.
    4. Right to access your personal data: You have the right to request a copy of the personal data we hold about you and to check that we are lawfully processing it.
    5. Right of rectification: You have a right to correct data that we hold about you that is inaccurate or incomplete.
    6. Right to be forgotten: In certain circumstances you can ask for the personal data we hold about you to be erased from our records.
    7. Right to restriction of processing: You have a right to restrict the 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 data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    8. Right to request a transfer of your personal data: You may request us to transfer certain personal data to you or to a third party. We will provide you, or a third party you have chosen, any such personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    You can exercise any of these rights at any time by contacting us at dataprotection@thrivepartners.co.uk or by contacting our data protection representative at the above address.

  10. Third party sites

    Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

  11. Changes to our privacy policy

    Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

  12. Contact

    Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to dataprotection@thrivepartners.co.uk or to our data protection representative at the address set out at the top of this privacy policy.