We are Fresh Thinking Group, a company incorporated in British Virgin Islands. (“Fresh Thinking Group” / “we”/ “our” / “us”).
At Fresh Thinking Group we are committed to safeguarding and preserving the privacy of our visitors. We will continue to comply with the provisions of the Data Protection Act 1998 (“DPA”) until and including 24th May 2018, after which we will comply with The General Data Protection Regulation (GDPR) (EU) 2016/679 (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the GDPR and the DPA (together “Data Protection Legislation”).
Fresh Thinking Group receives your information through you signing up to our newsletters, contacting us via our contact us and/or careers page, from our APIs, applications and from our partners and other third parties. Irrespective of which country you reside in or supply information from, you authorise Fresh Thinking Group to use your information in any country where Fresh Thinking Group operates.
If you wish to no longer receive newsletters or other marketing communication from us, you can opt out via the unsubscribe link in the marketing emails or by following the process mentioned below in the ‘your rights in respect of your data’ section.
We will not share any of the information you provide during a recruitment process with any third parties outside of Fresh Thinking Group and we do not collect more information than we need to fulfil this purpose, nor will we retain it for longer than is necessary. Once the position has been filled, we will not retain your information unless you consent for us to keep it on file.
INFORMATION COLLECTION AND USE
We collect and use your information below to provide our services and to measure and improve our services from time to time.
Location Information: We may use other data from your device to determine location, for example, information about wireless networks or mobile phone towers near your mobile device, or your IP address. We may use and store information about your location to provide features of our services to improve and customise the services, for example, with more relevant content like local trends, stories, ads, and suggestions for people to follow.
Links: Fresh Thinking Group may keep track of how you interact with links across our website, including our third-party services, and client applications, by redirecting clicks or through other means. We do this to help improve our services, to provide more relevant advertising, and to be able to share aggregate statistics such as the frequency of a particular link being clicked on.
Google Analytics: We will also install Google Analytics in the apps, devices, or mobile apps to collect your behaviours in using our services. We will also recommend some other services that may be suitable or appeal to you based on our analysis.
Facebook Pixel: These cookies allow us to create custom audiences based on our website traffic in order to market to them on Facebook. For more information about Facebook’s ToS please visit this link: https://www.facebook.com/terms.
LinkedIn: These cookies allow us to collect user data through our website for the purposes of marketing to on LinkedIn.
Other Google Technologies: From time to time, we may also use Google’s advertising products, such as AdWords, to deliver marketing messages. To understand how Google uses information from sites and apps in these services, refer to Google’s articles here – https://policies.google.com/technologies/partner-sites.
Log Data: When you use the Fresh Thinking Group website, we may receive information (“Log Data”) such as your IP address, device information (including device and application IDs) and search terms. Fresh Thinking Group uses Log Data to provide, understand, and improve our services.
We process personal information for certain legitimate business purposes, which include some or all the following:
where the processing enables us to enhance, modify, personalise or otherwise improve our website, our services and communications for the benefit of our customers;
to identify and prevent fraud;
to enhance the security of our network and information systems;
to better understand how people interact with our website;
administer the website and carry out data analysis, troubleshooting and testing; and
to determine the effectiveness of promotional campaigns and advertising.
We do not disclose your private personal information except in the limited circumstances as listed below;
Your Consent: We may share or disclose your information at your direction, such as when you authorise a third-party web client or application to access the Fresh Thinking Group website.
Non-Private or Non-Personal Information: We may share or disclose your non-private, aggregated or otherwise non-personal information, such as your public user profile information, the people you share your information with, or the number of users who clicked on a particular link (even if only one did), or reports to advertisers about unique users who saw or clicked on their ads after we have removed any private personal information (such as your name or contact information).
You have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent or prefer not to receive any information from us, please let us know by emailing us at email@example.com
If you do not want us to contact you for marketing purposes, please let us know by clicking the “Unsubscribe” option in any marketing email we send to you and providing the details requested or by contacting us by emailing firstname.lastname@example.org and we will take steps to ensure that this information is deleted as soon as reasonably practicable. In this scenario, we will retain your personal data on a suppression list to the extent we need it to ensure we don’t send you any further marketing communications.
YOUR RIGHTS IN RESPECT OF YOUR DATA
If any of the information you provide to us changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us by emailing us at email@example.com.
If you wish to see the information we hold on you, or request that such information be transmitted directly to another data processor, please contact us by emailing us at firstname.lastname@example.org.We shall process your request to access your information and provide this information to you free of charge unless your request is manifestly unfounded or excessive.
To request that your information is deleted or if you wish to restrict / object to the processing of your information, please contact us by emailing us at email@example.com.
If you have any complaints about our use of your personal data, please contact us. You may also have the right to complain to the Information Commissioner’s Office at https://ico.org.uk/ or other relevant supervisory authority in your jurisdiction.
FUTURE CHANGES TO THIS POLICY