Privacy Policy

PRIVACY POLICY

POLICY CONTEXT

The Think Eunoia Website (the “Website”) is owned and operated by Think Eunoia (“the Owner”) who will be referred to as “we”, “our” and “us” in this Privacy Policy.

By accessing the Website, you agree to be bound by this Privacy Policy and our Terms of Use.

The Privacy Policy relates to the collection and use of customer information which we may gather through your use of the Website.

PRIVACY POLICY

We reserve the right, at our discretion, to modify or remove portions of this Privacy Policy at any time. This Privacy Policy is in addition to any other terms and conditions applicable to the Website.

We do not make any representations about third party websites that may be linked to the Website.

RESPONSIBILITY

We recognise the importance of protecting the privacy of information collected about visitors to our Website, information that can identify an individual (“Personal Information”).

This Privacy Policy governs the way your Personal Information, obtained through the Website, will be dealt with.

This Privacy Policy should be reviewed periodically so that you are updated on any changes. We welcome your comments and feedback.

OUR COMMITMENT

We are committed to protecting your Personal Information and giving you choice in who can use your Personal Information and how it can be used.

We undertake to comply with any laws introduced to strengthen protections for our consumers’ privacy.

PERSONAL INFORMATION

Personal Information about visitors to our site is collected only when knowingly and voluntarily submitted. For example, we may need to collect such information to provide you with further services or to answer or forward any requests or enquiries.

It is our intention that our Privacy Policy will protect your Personal Information from being dealt with in any way that is inconsistent with applicable privacy laws in the United Kingdom.

USE OF INFORMATION

Personal Information that visitors submit to our site is used only for the purpose for which it is submitted (the “Primary Purpose”) or for such other secondary purposes that are related to the Primary Purpose, unless we disclose other uses in this Privacy Policy or at the time of collection.

Copies of correspondence sent from the Website, that may contain Personal Information, are stored as archives for record-keeping and back-up purposes only. 

COLLECTING INFORMATION ON REGISTERED MEMBERS

We will not collect or monitor any Personal Information about you without your consent unless we believe it is necessary:

• to comply with the law.

• to provide you with a service which you have requested.

• to implement our terms of service.

• to protect our rights or property, or the rights or property of any of our other users or any

• member of the public; or

• to lessen a serious threat to a person’s health or safety.

You may provide us with information directly, such as through subscribing to email lists, registering with us, or identifying yourself when using our services. The amount of information we collect about you depends on how you use the Website or our services. The only personal information we collect is what you tell us about yourself, for example, by subscribing to e-mail newsletters or registering with us. Registration may include submitting your name, email address, postal or residential address, telephone numbers and by asking to receive updates, promotional material, or other information.

COOKIES

We use cookies to help maximise your enjoyment of the Website. Cookies themselves do not personally identify users, although they do identify a user’s browser. Please see further information on how we use cookies below.

DISCLOSURE

Apart from where you have consented or disclosure is necessary to achieve the purpose for which it was submitted, Personal Information may be disclosed in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities. Also, we may disclose Personal Information when we believe in good faith that the law requires disclosure.

We may engage third parties to provide you with goods or services on our behalf. In that circumstance, we may disclose your Personal Information to those third parties to meet your request for goods or services.

For the avoidance of any doubt, we will not disclose any Personal Information about you without your consent unless we believe it is necessary.

• to comply with the law.

• to provide you with a service which you have requested.

• to implement our terms of service.

• to protect our rights or property, or the rights or property of any of our other users or any member of the public; or to lessen a serious threat to a person’s health or safety. 

SECURITY

We strive to ensure the security, integrity and privacy of Personal Information submitted to our sites, and we review and update our security measures considering current technologies.

Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.

However, we will endeavour to take all reasonable steps to protect the Personal Information you may transmit to us or from our online products and services. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any Personal Information held by us. However, we will not be held responsible for events arising from unauthorised access to your Personal Information.

You can also play an important role in keeping your Personal Information secure by maintaining the confidentiality of any password, PINs and accounts used on the Website. Please notify us immediately if there is any unauthorised use of your account by another person or any other breach of security.

COLLECTING INFORMATION FOR USERS

IP ADDRESSES

Our web servers gather your IP address to assist with the diagnosis of problems or support issues with our services. Information is gathered in aggregate only and cannot be traced to an individual user.

COOKIES

Cookies are pieces of information that a Website transfers to your computer’s hard disk for record-keeping purposes. Most web browsers are set to accept cookies. If you do not wish to receive any cookies, you may set your browser to refuse cookies. In some instances, this may mean you will not be able to take full advantage of parts of the Website.

The use of cookies can enhance your enjoyment of what we offer, because they can help personalise your experience of our Website. They can ensure that information provided to you is most relevant to your interests. Cookies can also provide us with aggregate information on how people use our Websites and which advertisements are effective. This helps us to keep improving our site.

As explained above, cookies do not of themselves personally identify users. The cookies simply operate as a unique identifier which helps us to know what our customers find interesting and useful on our Website, almost like a continuing

questionnaire. We do not link this information back to other information that you have provided to us.

ACCESS TO INFORMATION

Your trust in us is very important to us. If at any time you want to know exactly what Personal Information any part of our site is holding about you, you are welcome to request that information by contacting us.

Our file of your information will be made available to you within a reasonable period.

We will endeavour to take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate and up to date. If, at any time, you discover that information held about you is incorrect, you may contact us to have the information corrected.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any Personal Information held by us.

LINKS TO OTHER SITES

We may provide links to websites outside of our Websites, as well as to third party websites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our Website.

Before disclosing your Personal Information on any other website, we advise you to examine the terms and conditions of using that website and its privacy statement.

TRANS-BORDER DATA EXCHANGE

The Owner may transfer (and you are deemed to consent to the Owner transferring) your Personal Information outside of the United Kingdom:

where the Owner reasonably believes that the person who will receive your Personal Information is subject to effective data protection obligations.

where the transfer is necessary for the performance of any contract between you and the Owner or for the implementation of pre-contractual measures.

where the transfer is for your benefit and it is impractical for the Owner to obtain your consent, but if it were practical you would be likely to consent; and

as required or authorised by or under law, and where you subsequently consent from time to time.

PROMOTIONAL EMAIL

We will not send you “spam” (advertising information) without first asking you whether you wish to have promotional information sent to you.

If you are receiving promotional information from us and do not wish to receive this information any longer, you may remove your name from our list by asking to be removed from our mailing list. Please allow five days for this request to be processed.

FUTURE CHANGES

Think Eunoia may from time to time (with or without notice to you) amend or update our Privacy Policy at our sole discretion. Accordingly, you should ensure that you regularly review our Privacy Policy.

We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version of the policy on the Website.

PROBLEMS OR QUESTIONS

If we become aware of any ongoing concerns or problems with our Website, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our Privacy Policy, or you have a problem or complaint, please contact us.