Who we are
https://www.thinkshifts.com and https://www.thinkshifts.co.uk (Websites) is operated by Thinkshifts Limited. We are an experience design and software development firm, incorporated and registered in Nigeria, England and Wales under company number 9907739 and CAC RC number 1412070, whose registered office address is at 8C Atinuke Ologunde Crescent Ogudu-G.R.A (‘We’ or ‘us’) collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and the Data Protection Act 2018. We are responsible as ‘controller’ of that personal information for the purposes of those laws.
Information that you provide
We collect personal information about you when you send feedback, post material, contact us for any reason and by any medium, sign up to a service, share information via the Website’s social media functions, or report a problem with the Website. We collect this personal information from you either directly, such as when you contact us via our Website or indirectly, such as your browsing activity while on our Website (see ‘Cookies’ below). We collect data that is specifically and voluntarily provided by a visitor to our Website. In most circumstances, this data includes limited identifiable information. Where we store any information collected via our Website we will ensure that it is adequately protected. We may ask you to provide sensitive personal data from time to time which may include data relating to health conditions or for equality purposes. If such data is requested, you will be given additional information as to why the sensitive personal data is being requested and how it will be used. We may retain a record of any contact you make with us. The personal information we collect about you depends on the particular activities carried out through our Website. Such information includes:
-Your name, address and contact details;
-Your business address and name;
-Details of any feedback you give us by phone, email, post or via social media; and
-Information about the services we provide to you.
Personal information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
-Give consent on his/her behalf to the processing of his/her data;
-Receive on his/her behalf any data protection notices;
-Give consent to any transfer of his/her data.
Information from third parties
Occasionally we may receive information about you from other sources, which will be added to the information already held about you in order for us to help supply our services and products to you.
Information that will be collected automatically
How your personal data will be used
We use this personal information to:
-Create and manage your account with us;
-Verify your identity;
-Enquire for further information;
-Provide services to you;
-Fraud prevention and detection;
-Customise our Website and its content to your particular preferences;
-Notify you of any changes to our Website or to our services that may affect you;
-Improve our services.
Our legal basis for processing your personal information
-Consent: where you have given us clear consent for us to process your personal information for a specific purpose;
-Contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
-Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations);
-Legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
Disclosure of your personal data
We may disclose your personal data to:
-Other companies that become partners or part of a group with Thinkshifts;
-A third party who acquires Thinkshifts or acquires substantially all of its assets, in which case the personal data shall be one of the acquired assets;
-Our agents and service providers;
-Law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by applicable law;
-Our clients when as part of a contracted service such as collating data sets collected from surveys.
Our Website does not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.
Transfer of your information out of the EEA
Your personal information may be transferred to third party service providers who process information on Thinkshifts behalf, including providers of information technology, identity management, Website hosting and management, data analysis, data back-up, security and storage purposes. As a result, your personal data may be transferred outside of the country where you are located, including outside of the European Economic Area (EEA). Where we use data servers that may transfer data out of the EEA we will take steps to ensure adequate protections are in place to ensure the security of your information and give you remedies in the unlikely event of a security breach. Please note that we review all processors we utilise and ensure that there are adequate safeguards in place to protect your personal data, such as adherence to binding corporate rules or compliance with the EU-US Privacy Shield Framework, which is a mechanism that ensures compliance with EU data protection requirements when transferring personal data from the European Union to the United States. You can learn more about Privacy Shield here: https://www.privacyshield.gov/welcome If you would like further information regarding the transfer of your information out of the EEA please contact our Data Protection Officer using the details provided in the ‘How to contact us’ section below.
You have the right of access to your personal records or other information that we hold about you. There is no administrative charge for this service.
You have the right to rectify any errors in the data we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this immediately.
You may have the right to have the data we hold about you erased.
If you wish us to continue to store your information but wish us to keep your data separate and not process it in any way, please let us know.
You have the right to ask us to stop processing your personal data for direct marketing purposes. You may also specify that you object to direct marketing by particular channels such as by email of telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
You have the right to data portability. If you wish to obtain your data for your own purposes across different services, we will provide this information to you in a CSV file. There is no administrative charge for this service.
To revise your consent, access, amend or remove your records or assert any of your rights set out above, you should send your request in writing to us at email@example.com You may need to provide proof of identity and address (eg a copy of your driving licence or passport, and a recent utility or credit card bill); and specify the personal data you want access to, amended or removed. For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
How long we will store your data
We will store your data for as long as necessary for the purpose of processing. The data may be deleted in the following circumstances:
you have withdrawn your consent to data processing;
the original purpose for processing the data is no longer relevant or cannot be performed any more;
the data is no longer up to date or accurate; or
where we no longer have a reason to store your data as determined by our Data Retention Policy.
We do not contract directly with individuals below the age of 18. Therefore, we do not process the personal data of children. In using our services, you confirm that you have read and consented to this Policy and verify that you are over the age of 18.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also confirm that your data will be stored on secure servers. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may change this Policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you use the Website.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you. If you wish to contact us, please send an email to firstname.lastname@example.org, write to Thinkshifts, 8C Atinuke Ologunde Crescent, Ogudu-G.R.A, Lagos Nigeria or call +234 9065 379596.