THRIVE PARTNERS LTD ("We") are committed to protecting and respecting your privacy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Thrive Partners Ltd of 55 Baker Street, London, W1U 7EU.
Our nominated representative for the purpose of the Act is Wendy Robertson.
When this policy applies
This policy applies to:
- our website www.thrivepartners.co.uk and my.thrive.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)
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 (together the Sites) or otherwise provided by us to you, 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, place an order on our Sites, participate in discussion boards or other social media functions on our Sites, enter a competition, promotion or survey, 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, address, date of birth, e-mail address and phone number, the Device’s phone number, financial and credit card information, personal description and photograph and in the case of coaches and coachees may include additional information about your age, ethnicity, gender, location and national identity; and/or
- (as a coachee) when attending coaching sessions and filling in questionnaires and feedback forms on the sessions or (as a coach) when providing coaching sessions and completing post session notes. As a coachee 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. Coaching sessions may be voice 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, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, 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 Site, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products 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.
- 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, whether this is required for our own billing purposes or otherwise and the resources that you access;
- technical information, including;
- Information we receive from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, 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.
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 other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
- 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" 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 are recorded and transcripts made from which the data is extracted. 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 regarding age, national identify, location and gender, to monitor our compliance with equal opportunities legislation.
Information we collect about you and your Device. We will use this information:
- to administer our Sites and Apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our 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 and other users of our Sites about goods or services that may interest you or them.
- 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.
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:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. We may provide them with aggregate and anonymised information about our users. Transcripts from recordings of sessions on our platform may be used to provide analysis on key trends, experiences and attitudes within organisations and industry sectors to our clients (“Thrive Insights”). Any data extracted from such transcripts will be aggregated prior to being used to provide Thrive Insights. We will not disclose information about identifiable individuals in Thrive Insights.
- Analytics and search engine providers that assist us in the improvement and optimisation of our Sites.
- 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.
Where we store your personal data
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 not keep personal data for more 24 months for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.
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.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our Sites may, from time to time, contain links to and from the websites of our partner networks 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.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.