Privacy Policy
Last updated: 28 March 2024
THINKERS50 – Privacy policy for commercial activities
- Controller
- Filing systems
- For what purposes do we use your personal data?
- What is our data processing based on?
- What personal data do we collect?
- Where do we collect the personal data from?
- With whom might we share your personal data?
- How long do we process your personal data?
- How can you exercise your rights relating to your personal data?
- Do we make decisions affecting you based on automated means?
- Principles of protection
- Do we transfer your personal data outside of the UK and/or EU/EEA area?
- Other terms
This privacy policy applies to all external commercial activities by Thinkers50 (“Thinkers50”, “we”, “us”). We pledge to honour the following privacy policy, designed with our customers and other stakeholders in mind. We collect information responsibly, in accordance with the applicable data protection legislation.
1. Controller
The controller is Thinkers50 Limited.
Thinkers50 Limited
The Studio
Highfield Lane
Wargrave RG10 8PZ
UNITED KINGDOM
Tax ID: GB 244505031
Email address for privacy issues: enquiries@thinkers50.com
2. Filing systems
This privacy policy describes how we process the personal data of our customers, potential customers, and other interest groups such as persons and nominees in rankings and lists, event guests and media representatives.
3. For what purposes do we use your personal data?
Thinkers50 processes personal data of data subjects for the following purposes (one or more at the same time):
3.1. To manage and analyse customer and stakeholder relations
Thinkers50 may use your personal data to manage, analyse and develop a customer relationship or stakeholder relationship with you or a company or other entity you represent. Processing may include using your personal data for research purposes such as feedback questionnaires.
3.2. Provision of products and services
Thinkers50 may use your personal information to provide products and services to you or to a company or other entity you represent, for example, if you have purchased a product from us, used our digital services, subscribed to our newsletter, or participated in our events. Personal data is used to exercise the rights and obligations arising from a contract or other commitment between Thinkers50 and the data subject.
If you participate in any marketing lotteries or contests, we may collect and process your personal data in connection with the selection and delivery of prizes.
3.3. Communications
Thinkers50 may use your personal data in its communications, for example, to send you notifications about products and services as well as media announcements, to inform you about changes to services and to request feedback on products and services.
3.4. Direct marketing
Thinkers50 may carry out marketing both to customers registered in the customer register and to potential customers registered in the marketing register. You can always opt-out of receiving direct marketing through the opt-out link in each message or by contacting our customer service.
The marketing register contains personal data of entirely new, potential customers as well as personal data of persons who have been customers of Thinkers50 in the past. When a set number of years have passed since the end of the customer’s last transaction, Thinkers50 will delete part of the data and stop processing the data in its customer register and keep the more limited data relevant for marketing purposes in its marketing register.
3.5. Developing products and services
Thinkers50 may use your personal data to develop its products and services, as well as developing the content and targeting of marketing.
3.6. Processing of data on identified website visitors
Thinkers50 has various ways of identifying visitors to its online services. Identification can be done, for example, by logging into an Thinkers50 online store account and by clicking on a unique link in a direct marketing email or newsletter.
Thinkers50 may process data for the purposes of targeted advertising and advertising measurement, both for Thinkers50’s own advertisements and those of its group companies, as well as those of its possible co-operation partners.
4. What is our data processing based on?
The legal basis for the processing of personal data is the following (one or more purposes may apply simultaneously):
- you have given your consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are party or in order to carry out, at your request, pre-contractual measures;
- processing is necessary for compliance with a legal obligation of Thinkers50; and / or
- processing is necessary for the purposes of the legitimate interests pursued by Thinkers50 or by a third party, such as those arising from the customer relationship between the customer and Thinkers50 and the right to engage in promotional activities.
Thinkers50 processes your data on the basis of a valid contract (e.g. subscription to our newsletter, online shopping, participation in our events).
Thinkers50 has legitimate interests in the conduct of its business, such as the right to promote its products and services through marketing and sales.
Thinkers50 may engage in direct marketing and targeted online advertising based on your contact information and your usage of our digital services, including the processing of personal data for profiling purposes, based on legitimate interests.
Other legitimate interests on the basis of which your personal data may be processed by Thinkers50 include, for example, providing advice and other customer service to non-customers, developing the business and investigating possible misconduct.
If the processing is not based on a contractual need or legitimate interest, Thinkers50 may ask for your consent to process your personal data in other ways.
Thinkers50 may also process your personal data where required to do so by law, for example, on the basis of the retention obligation under the accounting legislation.
5. What personal data do we collect?
The filing systems may include the following types of personal data and their updates, either in part or in full:
5.1. Basic data of all data subjects
- first and last names
- professional title
- name of the company or other entity you represent
- contact data (telephone, email, postal address)
- communication and direct marketing directed to you and your activities thereof
- direct marketing choices
- use of your rights related to your personal data
5.2. Additional data for customers and event participants as well as persons in other content production
- information pertaining to all purchases and orders on the web shop, such as invoicing address and payment details
- dietary requirements for events (if it includes health data, such data is given to us by the data subject based on your consent)
- notes of discussions and feedback
- interests and other information or survey data provided by the data subject
- photos and/or videos recorded during our events
- photos, audio and/or videos recorded for commercial and/or non-commercial activities
5.3. Additional data for persons on rankings and lists
- relevant background information publicly available or provided to us by you, related to candidacy and decisions on our rankings and lists
5.4. Additional data for visitors of our website and social media accounts
- information of the use of our digital services as well as digital content created by an identifiable data subject
- automatically collected data (such as IP Address, your device’s operating system, browser type and language)
- mobile device identifiers (such as your unique device ID and device name)
6. Where do we collect the personal data from?
Our filing systems are derived mostly from information given by you via different interaction channels such as online forms, e-mail, chat, telephone calls, our social media accounts and meetings.
We may gather personal data from business-to-business data subjects also when the representative of the company or other entity gives personal data of other employees to us.
We may also obtain and update the personal data in our filing systems from officials and companies offering personal data services as well as other publicly available sources such as websites and social media accounts.
7. With whom might we share your personal data?
Thinkers50 does not sell, lease, or otherwise disclose your personal data to third parties outside of its group of companies and affiliate companies unless otherwise stated below.
The name, title and organisation of attendees of our events can be published. Please contact us if you would prefer that your information is not shared or published.
Thinkers50 may share your personal data with authorised third parties that perform services for us for the purposes described in this privacy policy, within the limits of the applicable legislation. This may include, for example, providing services such as customer service and software services, managing and analysing personal data, conducting market research, and managing marketing and execution of diverse campaigns as well as delivery of physical products such as books.
Thinkers50 may share your personal data when obtaining payment for products and services, including the transfer or sale of delinquent accounts to third parties for collection.
Because Thinkers50 takes the responsibility to safeguard your personal data seriously, Thinkers50 does not allow these companies to use it for any purpose other than to perform those services, and Thinkers50 requires them to protect your personal data in a way consistent with this privacy policy.
Thinkers50 may share your personal data based on a valid order from a court or other official body with sufficient authority.
Thinkers50 may share your personal data as part of any merger, acquisition, establishment of new group companies, sale of company assets, or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy, or receivership in which your personal data would be transferred to another entity as a result of such a proceeding.
When a customer is buying a product or service from a Thinkers50 co-operating partner, Thinkers50 has the right to give the relevant personal data required for the purchase to the co-operating partner.
8. How long do we process your personal data?
Thinkers50 will process the personal data of its customers until the end of the year of the last purchase plus 6 years.
Potential customers’ data is processed in our marketing database until a customer relationship has started or until the data subjects ask their data to be deleted. For information on how this data can be deleted, see section 9.
9. How can you exercise your rights relating to your personal data?
9.1. Right of access
You have the right to obtain from us confirmation as to whether or not your personal data are being processed, and, where that is the case, access to the personal data and other information related to the processing if your data (such as purposes of the processing and the recipients or categories of recipient to whom the personal data have been or will be disclosed).
9.2. Right to rectification
You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
9.3. Right to erasure (‘right to be forgotten’)
You have the right to obtain from us the erasure of personal data concerning you without undue delay where one of the following grounds applies:
- your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw consent on which the processing is based, and where there is no other legal ground for the processing;
- you object to the processing and there are no overriding legitimate grounds for the processing;
- your personal data have been unlawfully processed;
- your personal data have to be erased for compliance with a legal obligation in law to which Thinkers50 is subject; or
- your personal data have been collected in relation to the offer of information society services.
The above shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by law to which Thinkers50 is subject; or
- for the establishment, exercise or defence of legal claims.
9.4. Right to restriction of processing
You have the right to obtain from us restriction of processing where one of the following applies:
- the accuracy of your personal data is contested by you, for a period enabling us to verify the accuracy of your personal data;
- the processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead;
- Thinkers50 no longer needs your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; or
- you have objected to processing pending the verification whether the legitimate grounds of Thinkers50 override those of you.
9.5. Right to data portability
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:
- the processing is based on your consent or on a contract between us and you; and
- the processing is carried out by automated means.
9.6. Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on the legitimate interests pursued by Thinkers50 or by a third party, including profiling. We shall no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where your personal data are processed for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
10. Do we make decisions affecting you based on automated means?
Thinkers50 does not make decisions based solely on automated processing, which produces legal effects concerning you or similarly significantly affect you.
11. Principles of protection
Access to any personal data in Thinkers50 personal data files is restricted to designated individuals with personal usernames and passwords and 2FA processes. Access to any digital or manual database is given only based on a need related to the person’s work tasks. These individuals are bound to keep the data confidential and only process and share such data when it is specifically allowed by legislation and work tasks.
We protect your personal data using appropriate technical and organisational safeguards. These include proactive and reactive risk management, the use of firewalls, encryption technologies and secure equipment rooms, access control and security systems. Other safeguards include security planning, controlled granting and monitoring of access rights, ensuring the competence of staff involved in the processing of personal data and careful selection of subcontractors.
12. Do we transfer your personal data outside of the UK and/or EU/EEA area?
Thinkers50’s services may be provided using resources and servers located in various countries around the world. Therefore we may transfer your personal data outside the country where you use our services, including to countries outside the UK, EU and EEA that do not have laws providing specific protection for personal data or that have different legal rules on data protection.
In such cases, Thinkers50 will ensure that a legal basis for such a transfer exists and that adequate protection for your personal data is provided, as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organisational information security measures.
Thinkers50 is concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to us or guarantee that your information stored by us may not be accessed, disclosed, altered, or destroyed by breach of any of our industry-standard physical, technical, or managerial safeguards. When you enter information (such as login credentials) on our registration or order forms, we encrypt all transmitted data using HTTPS with TLS (Transport Layer Security). However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.
We do not collect credit card information from our customers. If a customer chooses to pay with a credit card or online bank etc., the payment is made through an external site administered by the credit card payment processor or the bank etc., and is subject to their data protection policy and process.
13. Other terms
We are constantly developing our business and this may also mean changes in the processing of personal data. We will update this privacy policy as necessary to reflect any changes in our practices. Changes may also be based on changes in legislation. We recommend that you review the contents of the privacy policy regularly.
Thinkers50 Limited is partially owned by the Business Forum Group Oy (business registration ID at Finnish Trade Register: 2474817-9). Thinkers50 Limited is a UK company, within a group of companies in the EU. UK, EU and; where applicable, Finnish data protection legislation applies to our personal data files and the processing of personal data contained in them.
