Last updated: August 6, 2019
Thrive Learning Limited (Thrive) is committed to protecting and respecting your privacy. This policy and any other documents referred to on it, set out the basis on which any Personal Data (as defined below) we collect from you or which you provide to us will be processed by us as a result of using or interacting with our website as set out below. We aim at all times to process and collect your data lawfully, transparently, fairly and without adversely affecting your rights as a Data Subject (as defined below). Please read the following carefully to understand our practices and procedures. The website we operate is https://www.thrivelearning.com, its related domains and sub domains (Thrive Site) which is hosted by TSO in UK data centres.
By giving your consent, you are accepting and consenting to the practices described in this policy. If you do not give your consent, please navigate away from the Thrive Site.
You may withdraw your consent at any time. An explanation of your rights is set out below.
For the purpose of the Data Protection Legislation (as defined below), the data controller is Thrive Learning Limited, a limited liability company with company number 10988277, whose registered office is at 6B Oldknows Factory, St Anns Hill Road, Nottingham, NG3 4GN.
Our nominated representative, as Data Protection Officer for the purpose of the Data Protection Legislation is Mark Ward.
If you are not satisfied with any action taken by us or response given, you have the right to complain to Information Commissioner at www.ico.gov.uk, or help line telephone number: 0303 1231113.
In this policy the following terms shall have the following meanings:
Cookie: a small file placed on your computer or device by the Thrive Site when you visit certain parts of the Thrive Site and/or when you use certain features of the Thrive Site.
Cookie Law: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Data Protection Legislation:
(a) unless and until the General Data Protection Regulation ((EU) 2016/679) (GDPR) is no longer directly applicable in the UK, the GDPR and the Data Protection Act 2018 any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK; and then
(b) any successor legislation to the GDPR or the Data Protection Act 2018.
Data Subject: a natural identifiable person.
Personal Data: has the meaning set out in the Data Protection Legislation, being as at the data of this policy, any data which identifies a natural person (by way of example, name, address, phone number and so on).
What this policy also covers
This policy also explains:
- What personally identifiable information of yours is collected:
- on the Thrive Site, when you interact with it;
- when you download from the Thrive Site;
- when you interact with Thrive’ advertising and applications on third party websites and services.
- What organisation is collecting the information;
- How the information is used;
- With whom the information may be shared;
- What choices are available to you regarding collection, use and distribution of the information;
- What kind of security procedures are in place to protect the loss, misuse or alteration of information under Thrive’s control;
- How you can correct any inaccuracies in the information; and
- How you can request the information we process and store to be removed.
We may make changes to these terms and our website
We may update and change these terms and our website from time to time for a variety of reasons. By way of examples: to reflect changes to the services we offer, user’s needs, regulatory or legal requirements. Every time you wish to use the Thrive Site, please check these terms to ensure you understand the terms that apply at that time.
Children under the age of 18
Persons under the age of 18 are not eligible to use our services and we ask that minors do not submit any personal information to us. We will not knowingly accept any data from a person who is under the age of 18 years.
Information We Collect from you
We will collect and process the following information:
- technical information, including 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;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
- If you: (a) complete one of our enquiry forms on the Thrive Site; (b) enter into a contract with us for our services; (c) report a problem with the Thrive Site; or (d) otherwise correspond with us, we may collect your name, address (including e-mail address), other contact details, job title, business sector/industry, phone numbers, identification and bank details.
- We also track and analyse user behavioural data using Hubspot, Google Analytics/Google Tag Manager and via a Facebook pixel.
Use of your information
We will use the data collected about you in the following ways:
- to provide services to you, or to offer you our services;
- improve the efficiency of the Thrive Site;
- to develop services;
- to notify you of changes to our services;
- to track your behaviour as a user of the Thrive Site;
- to understand our customer requirements and preferences, perform analysis and comparisons;
- to administer and update our website to ensure it runs smoothly on your hardware;
- to perform market research or analysis on customer preferences or trends and
- to deal with your enquiry with a view to entering into a contract with you.
Please also see below under “Cookies”.
Where we store your personal data
- When you submit your Personal Data to the Thrive Site it will be stored on HubSpot which is a type of CRM software, subject to their terms and conditions, privacy and cookies policy which can be found at: legal.hubspot.com/cookie-policy and: legal.hubspot.com/privacy-policy.
- We take all reasonable technical, organisation and security steps to ensure that the information you supply to us over the internet is secure.
As a Data Subject under the Data Protection Legislation you have the following rights:
- You have the right to ask us not to process your personal data for marketing purposes. If you submit an enquiry form on the Thrive Site, you give your consent to Thrive contacting you for marketing purposes. We will not share your information with third party marketing agencies without your consent. 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 exercise the right at any time by contacting us at: email@example.com.
- The Thrive Site may, from time to time, contain links to and from other websites. 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.
- You have the right to ask us to supply to you the information we hold, this is known as a data subject access request. For further details please contact us on: firstname.lastname@example.org.
- You have the right to ask us to rectify the data we hold in the event that it contains inaccuracies or is incomplete. To discuss this please contact us on: email@example.com.
- You have the right to ask us to erase the Personal Data we hold if: (i) it is no longer necessary for us to hold the data; (ii) you wish to withdraw your consent to us holding the data; (iii) you object to us holding or processing the data; (iv) you believe that we have processed the data unlawfully; or (v) the data needs to be erased for us to comply with a particular legal obligation. To make a request please contact us on: firstname.lastname@example.org.
Disclosure of your information
You agree that we have the right to share your Personal Data 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.
- Selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of the Thrive Site and Hubspot.
- To a prospective buyer or seller if we sell or buy any business or assets.
- If any of the shares in Thrive are sold 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.
All Cookies used by Thrive on the Thrive Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
- Strictly Necessary Cookies – a Cookie falls into this category if it is essential to the operation of the Thrive Site, supporting functions such as logging in.
- Analytics and Flash Cookies – it is important for Thrive to understand how you use the Thrive Site. For example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Thrive to improve the Thrive Site and your experience of it. We use Google Analytics.
- Functionality Cookies – enable us to provide additional functions to you on the Thrive Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
- Persistent Cookies – any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit the Thrive Site.
- Session Cookies – any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit the Thrive Site until you close your browser. Session Cookies aren’t deleted when you close your browser, to delete these cookies you will need to clear your browser history.
- Web beacons – certain pages on the Thrive Site and e-mails may contain small electronic files known as web beacons. Web beacons permit Thrive to monitor the volume of users of the Thrive Site and the popularity of certain pages.
Before Cookies are placed on your computer or device you will be shown a cookie compliance statement, requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide you with the best possible experiences and services to you. You may wish to deny consent to the placing of the Cookies at which point we request you cease using the website.
In addition to the controls that Thrive provide, you can choose to enable or disable Cookies and the web beacons referred to above in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please access the help menu in your internet browser.
Suppliers and Other Service Providers
In addition, where any other service provider collects information directly from you (for example, if we ask a service provider to conduct a survey for us) you will be notified of the involvement of the supplier or service provider, and all information disclosures you make will be strictly optional.