Who we are
Our website address is: https://www.brandbuilding.works.
Brandbuilding.works is owned and run by Thinking Loud & Clear Limited (TLC).
We are committed to safeguarding the privacy of our subscribers, contributors, website visitors, service users, individual customers and customer personnel.
In this policy, “we”, “us” and “our” refer to Thinking Loud & Clear Limited.
What personal data we collect and why we collect it
If you subscribe to brandbuilding.works we will collect and process data that enables us to fulfill our subscription service to you and to keep in touch with you from time to time (“contact data“). The contact data will include your name and email address and may include your business name, business telephone number and business postal address and/or social media account identifiers if you subscribe using a business email account address for the purposes of subscribing to brandbuilding.works.
If you have a website account with us we may process your website user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences.
If you become a customer of ours we may process information relating to our customer relationships (“customer relationship data“). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer.
We may also process any personal data that you provide in the course of the use of any of our services and generated by our services in the course of such use (“service data“).
We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details..
We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We may process other categories of data not covered in the list above.
Where we get your personal data
The source of the contact data we collect is primarly you and/or your employer. If you log into our website using a social media account, we may obtain elements of the contact data from the relevant social media account provider. Some elements of data may be generated automatically by our website analytics tracking system or by our CRM software. The source of the transaction data is you and/or our payment services provider.
How and on what basis we use your personal data
Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders or subscriptions, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Publications – We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and compliant handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
Personalisation – We may process account data, service data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
Direct marketing – We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
Research and analysis – We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Who we share your personal data with
Your personal data maybe disclosed to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Your personal data will be stored on the servers of our data hosting service providers Hubspot.com.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
We may disclose specific personal data to our suppliers or subcontractors insofar as reasonably necessary.
Financial transactions relating to our website and services may be handled by a payment services provider. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You will be able to find information about the payment services providers’ privacy policies and practices at their URL.
In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data: You acknowledge that personal data or content that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
How long we keep your personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 12 months following the date of the most recent contact between you and us, and for a maximum period of 24 months following that date;
(b) account data will be retained for a minimum period of 6 months following the date of closure of the relevant account, and for a maximum period of 12 months following that date;
(c) profile data will be retained for a minimum period of 6 months following the date of deletion of the profile by you, and for a maximum period of 12 months following that date;
(d) customer relationship data will be retained for a minimum period of 12 months following the date of termination of the relevant customer relationship and for a maximum period of 18 months following that date;
(e) service data will be retained for a minimum period of 9 months following the date of termination of the relevant contract, and for a maximum period of 12 months following that date;
(f) transaction data will be retained for a minimum period of 5 years following the date of the transaction, and for a maximum period of 7 years following that date;
(g) communication data will be retained for a minimum period of 12 months following the date of the communication in question, and for a maximum period of 18 months following that date;
(h) usage data will be retained for 3 years following the date of collection;
If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period in accordance with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified, that personal data will be retained for minimum period of 12 months and a maximum period of 60 months following the date that publication ceases.
Notwithstanding the other provisions, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
How we protect your personal data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data. The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
What your rights are
In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
the right to access – you can ask for copies of your personal data;
the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
the right to erasure – you can ask us to erase your personal data;
the right to restrict processing – you can ask us to restrict the processing of your personal data;
the right to object to processing – you can object to the processing of your personal data;
the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You may exercise any of your rights in relation to your personal data by written notice to us.
Embedded content and third party websites
Our website may include hyperlinks to, and details of, third party websites. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
Our website and services are targeted at persons over the age of 13. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
Updating your personal information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
Amendments to our privacy and cookies policy
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of significant changes to this policy by email.
This website is owned and operated by Thinking Loud & Clear Limited. We are registered in England and Wales under registration number 10123326, and our registered office is at 96 Pinchbeck Road, Spalding, Lincolnshire PE11 1QL.
Our principal place of business is at 96 Pinchbeck Road, Spalding, Lincolnshire PE11 1QL.
You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
Data protection registration
We are registered as a data controller with the UK Information Commissioner’s Office. Our data protection registration number is ZA321703
Data protection officer: Our data protection officer’s contact details are: Martin Devlin and you can contact him via email to firstname.lastname@example.org.