Privacy Policy for Thinkio Ltd

1. Introduction

1.1 We are fiercely committed to safeguarding the privacy of our service visitors, users,  individual customers and customer personnel.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. By signing up to thinkio, you agree to our use of cookies. 

1.4 In this policy, "we", "us" and "our" refer to Thinkio Ltd. For more information about us, see Section 14.

1.5 Note about Children: As required by applicable law, children under the age of 13 (and a higher age if required by the applicable law in your country) may only use our Services with the express prior consent of a parent or legal guardian.  If you are a Teacher or Administrator, ensure you obtain demonstrable parental consent before allowing a student to use our service.

2. Credit

2.1 This document was created using Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3. The personal data that we collect

3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

3.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address and/or social media account identifiers. The source of the contact data is you. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

3.3 We may process your Thinkio user account data ("account data"). The account data may include your name, email address, account creation and modification dates, and website settings. The primary source of the account data is you and, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.

3.4 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website and or services] ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.

3.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

3.6 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as but not limited to information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. As far as possible we try to refrain from storing, transmitting or processing IP addresses.

3.7 We may process data submitted to our service or website by student visitors. (“student data”). When a teacher shares a document (“worksheet”) with a student, they are prompted to input their name to allow the teacher to identify their work for marking. This means that their name along with all the modifications the student has made to the worksheet will be shared with the account from which the worksheet was uploaded. The source of the student data is the student. Please be aware that due to the nature of our service, (sharing worksheet via URL) all shared material and subsequent modifications may be available publicly via the internet, (see article 6.1), for this reason, we highly recommend that neither teachers nor students include and add any personal or sensitive information on worksheets 

4. Purposes of processing and legal bases

4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2 Operations - We may process your personal data for the purposes of operating our website and service, providing our service and processing payments. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.

4.3 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, providing support services, handling individuals requests and complaints. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

4.5 Direct marketing - We may process contact data, account data and/or transaction data] for [the purposes of creating, targeting and sending direct marketing communications by email. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users. If you no longer wish to receive communications for Thinkio via email, you can unsubscribe from the mailing list by selecting the unsubscribe button at the bottom of every email.

4.6 Research and analysis - We may process usage data and transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

4.7 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

4.8 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

4.9 Special consideration for users - Student data will be shared with the user who originally sent the worksheet. For example, the teacher who uploads a file and shares a worksheet with a student will see all the information they choose to add to the editable worksheet, including the student’s name. 

5. Providing your personal data to others

5.1 We may disclose your personal data to the third party (www.mailchimp.com) insofar as reasonably necessary for the purposes of communicating with you through mailing list management software.

5.2 Your personal data held in our website database will be stored on the servers of our hosting services providers Amazon Web Services.

5.4 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. 

5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. International transfers of your personal data

6.1 Due to the nature of our Service, namely the use of URLs to share material, you acknowledge that personal data (files, worksheets and information added by both teachers and students while editing and marking) submitted through our website and services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. The source of this data will always be you or a student or third party (“student”) you invite to use the Service by sharing material. Do not upload to the Service, or share or ask students to include sensitive or private data to the service. AS AN ACCOUNT HOLDER YOU MUST ALSO EXPLAIN THIS TO ANY “STUDENT” YOU INVITE TO USE THE SERVICE, OR SHARE MATERIAL WITH VIA THE SERVICE.  

7. Retaining and deleting personal data

7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3 We will retain your personal data as follows:

(a) contact data will be retained for a minimum period of 6 months following the date of the most recent contact between you and us, and for a maximum period of 12 months following that date;

(b) account data will be retained for a minimum period of 6 months following the date of closure of the relevant account, and for a maximum period of 12 months following that date;

(c) transaction data will be retained for a minimum period of 6 months following the date of the transaction, and for a maximum period of 12 months following that date];

(d) communication data will be retained for a minimum period of 6 months following the date of the communication in question, and for a maximum period of 12 months following that date;

(e) usage data will be retained for a minimum period of 6 months following the date of collection and for a maximum period of 12 months following that date

7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Your rights

8.1 In this Section 8, we have listed the rights that you have under data protection law.

8.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure - you can ask us to erase your personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

8.4 You may exercise any of your rights in relation to your personal data by emailing us at info@thinkio.it

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) authentication and status - we use local storage to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website 

(b) [analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: (google analytics cookies)

 

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.

11.3 We use [identify service provider] to [specify service]. This service uses cookies for basic user analytics without trackin IP addresses. 

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Amendments

13.1 We may update this policy from time to time by publishing a new version on our website.

13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

14. Our details

14.1 This website and service is owned and operated by Thinkio Ltd.

14.2 We are registered in England and Wales under registration number 13180708, and our registered office is at Piccadilly Business Centre, Aldow Enterprise Park, Manchester, M12 6AE.

14.3 You can contact us:

(a) by post, at the postal address given above;

(b) using our website contact form found at www.thinkio.it;

(c) by email at info@thinkio.it.

Our Privacy Policy was last updated 23rd February 2021