Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
Key Terms:
‘We’, ‘us’ or ‘our’ means ThisAbility Limited, a company registered in England and Wales under company number: 11230707, with a registered office is at: is Kemp House, 128 City Road, London, EC1V 2NX, UNITED KINGDOM.
‘You’ or ‘your’ means the person using our site.
‘Personal data’ means any information relating to an identified or identifiable individual.
‘Special category personal data’ means personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data (when processed to uniquely identify an individual), data concerning health, sex life or sexual orientation.
‘Data subject’ means the individual who the personal data relates to.
If you don’t understand any of this policy and want to talk to us about it, please contact us by:
Email admin@thisability.net. Emails will be responded to between 11am to 6pm, Monday to Friday; or
Telephone +44 (0) 20 7459 4847. Calls will be answered between 11am and 5pm, Tuesday to Thursday.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals and our wider operations in the European Economic Area (EEA).
1. Personal data we collect about you
1.1. The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:
your name and contact information, including email address and telephone number and company details
information to check and verify your identity, eg your date of birth
your billing information, transaction, and payment card information
your professional interests
your professional online presence, eg LinkedIn profile
Information about how you use our website, IT, communication and other systems
your responses to surveys, competitions, and promotions
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
2. How your personal data is collected
2.1. We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
from publicly accessible sources, eg Companies House;
directly from a third party, eg: your employer or the company you are engaged with;
from cookies on our website. We may store some information (commonly known as a ‘Cookie’) on your computer when you look at our Site. This information facilitates your use of our Site and helps us to understand how our Site is used. You can erase or block some cookies from your computer if you want to, however, our certain services may not work correctly or at all if you set your browser not to accept cookies. Our Site is hosted on Squarespace. Please refer to Squarespace Cookie Policy for additional information.
3. How and why we use your personal data
3.1. Under data protection law, we can only use your personal data if we have a proper reason, eg:
where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
4. Marketing
4.1. We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
4.2. We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
4.3. You have the right to opt out of receiving marketing communications at any time by:
contacting us at admin@thisability.net or
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
4.4. We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
4.5. We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
5. Who we share your personal data with
5.1. We routinely share personal data with:
third parties we use to help deliver our services to you, eg payment service providers, companies who provide administrative services or sub-contractors;
other third parties we use to help us run our business, eg marketing agencies or website hosts;
third parties approved by you, eg social media sites you choose to link your account to or third party payment providers.
5.2. We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
5.3. We or the third parties mentioned above occasionally also share personal data with:
external auditors, eg in relation to the audit of accounts, in which case the recipient of the information will be bound by confidentiality obligations;
professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with legal and regulatory obligations;
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
5.4. If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
6. Where your personal data is held
6.1. Personal data may be held at our offices, on our secure CRM system, in our emails, Google Drive or on Dropbox, at third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
6.2. Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’
7. How long your personal data will be kept
7.1. We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, we will keep information about contracts for 6 years. Different retention periods apply for different types of personal data. Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
8. Transferring your personal data out of the UK and EEA
8.1. Countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
8.2. We will transfer your personal data to our service providers located outside the UK in Ghana. As we are based in the UK we will also transfer your personal data from the EEA to the UK.
8.3. Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
a specific exception applies under relevant data protection law.
8.4. Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) we enter into a contract to protect your rights. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
8.5. Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
8.6. If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).
9. Your rights
9.1. You have the following rights, which you can exercise free of charge:
Access—the right to be provided with a copy of your personal data
Rectification—the right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)—the right to require us to delete your personal data—in certain situations
Restriction of processing—the right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability—the right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object—the right to object:
at any time to your personal data being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making—the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents—if you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting us at admin@thisability.net. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
9.2. For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
9.3. If you would like to exercise any of those rights, please:
email, call or write to us—see below ‘How to contact us’; and
provide enough information to identify yourself (eg your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
let us know what right you want to exercise and the information to which your request relates.
10. Keeping your personal data secure
10.1. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
10.2. We also have procedures 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.
11. How to complain
11.1. Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
11.2. You also have the right to lodge a complaint with the Information Commissioner in the UK. The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
12. Changes to this privacy policy
12.1. This privacy notice was published on 2 April 2021.
12.2. We may change this privacy notice from time to time. You will receive an email or it will be notified to you via a pop up on our website.
13. How to contact us
13.1. You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
ThisAbility Limited
Kemp House
128 City Road
London, EC1V 2NX
UNITED KINGDOM