This privacy notice sets out how we will process personal data we collect from or about you, or which you provide to us.

This privacy policy applies to the “Thriver” online application and the websites available via the domains hellothriver.com and app.hellothriver.com (“our App”).

Please read this policy carefully to understand why data is being collected and what we do with that data.

We may change the privacy policy of the terms of business from time to time by amending this page.

For the purpose of the Data Protection Act 1998 and General Data Protection Regulation EU 2016/679, the data controller is Together Futures Limited, a limited company registered in England and Wales (No. 15503010). Registered office: Flat A St Clements Church Hall, Davey Close, London, United Kingdom, N7 8BB.

What Type of Information Will We Collect from You?

The personal information we collect will depend on the nature of the services we are providing and the type of legal entity under which you are trading. Typically, this will include the following:

1. Business details which, depending on whether you are trading under your own name, may include your personal data, such as your name and address, work email, website address and working hours.
2. Your opinions on our services and those of selected vendors.
3. Information you provide when you participate in discussion boards or other social media functions on our App.
4. Details of visits to our website (which enable our website to remember information about you and your preferences) and use of our App. [Please read our ‘Cookies Policy‘ for further details.] This may include information about your visit, including but not limited to the full Uniform Resource Locators (URL), clickstream to, through and from our App (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
5. Technical information, including but not limited to the Internet protocol (IP) address used to connect your computer to the Internet, your login information to our App, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

On What Basis can we Process Your Information?

The legal grounds for processing any personal data that you provide us are as follows:

1. It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, for example to fulfil an order you place with or through us, to provide you with information and personalised recommendations on products and services you have requested information on, either from ourselves or third party vendors. Our terms of business sets out the terms of the contract and the services we will provide.
2. In the event that you have given us consent to the processing of your personal data for one or more specific purposes, including to send you marketing communications by sending you offers by email of other products and solutions.
3. It is necessary for the purposes of our legitimate interests, to provide you with a more satisfying experience using our App, enable you to take better informed business decisions and allow us to improve your use of our App and other services, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.

What we are going to do with your information?

We will hold and use any personal information about you that you provide us (which will depend on the type of legal entity under which you are trading) in the following ways:

1. Communicate with you during the course of providing our services, for example providing you with advice and dealing with your enquiries and requests.
2. Carry out obligations arising from any contract entered into with you.
3. To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
4. To make suggestions and recommendations to you and other users of our App about goods or services that may interest you or them.
5. To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, unless we have your prior consent to contact you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
6. Process and fulfil solutions ordered by you, including passing your details on to your selected vendor and to our service providers.
7. To make introductions, with your permission, to other users of our services and allow you to participate in interactive features of our service, when you choose to do so.
8. Track your use of our service including your use of our App, completion of surveys via our App in order to personalise your repeat visits to our App and to administer and improve these.
9. To notify you about changes to our service;
10. To ensure that content from our App is presented in the most effective manner for you and for your computer.
11. Statistical purposes so we can analyse figures to help us manage our business and plan strategically for the future.
12. Respond to any complaint against us.

How Long We Keep Your Data for

We sill store personal data for as long as you have an account with us. If you wish to close your account, you can do so by contacting us at [email protected]. Once your account is closed, your personal data will be deleted.

Who Your Information will be Shared with

Based upon the services you need we may pass your details to selected people or organisations (data processors) to carry out certain activities on our behalf, and to other data controllers, including business partners, sub-contractors in technical, payment and delivery services for the performance of any contract we enter into with you, advertising networks, analytics providers, search information providers, credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. For example, personal information you provide may be provided to vendors where you have expressed an interest in their goods or services.

Where we have your prior permission where required, we will also share your information with selected third parties for marketing purposes and to other people subscribed to our service where you have asked to be introduced to them.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Together Futures Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Together Futures Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Security of Your Data

Your personal data will be held on secure servers within the European Economic Area (“”EEA””) with all reasonable technological and operation measures put in place to safeguard it from unauthorised access. Where possible any identifiable information will be encrypted or minimised.

If we have given you a username and password which enables you to access certain parts of your matter on our systems, you are responsible for keeping it confidential. Please do not share it with anyone.

Measures when Transferring Your Data to others Outside of the EEA

There may be occasions where we need to send your data outside the EEA. This would cover situations where we need to deal with international aspects of your matter and instruct overseas organisations to assist.

Some organisations may be located in countries outside of Europe where data protection laws are not as strict as they are in the UK. Where your personal data is being transferred outside the EU, we will undertake an assessment of the level of protection in light of the circumstances surrounding the transfer. We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information.

How You can Access and Update Your Information

You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, incomplete, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to [email protected]

How You can Object to us Using Your Data

You can ask us to limit the way in which we are using your information or object to certain types of processing. We will do our best to comply with your request unless we have to use the information for legitimate business or legal purposes.

Please note that if you want us to restrict or stop processing your data, this may impact on our ability to provide our services.

Any queries or concerns about the way in which your data is being used can be sent to contact [email protected]

Moving Your Information to Another Organisation

You have the right to request that we send an electronic copy of your personal data we hold to you or to another organisation for your own purposes, for example when you are dealing with a different service provider. If you would like us to provide you or to move, copy, or transfer your information to another organisation please let us know. We will respond to you within one month after assessing whether this is possible, taking into account the technical compatibility with the other organisation in question.

How You can Withdraw Your Consent

You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so please email [email protected] or you can change your consent preferences at any time on your account settings on our App.

Automated Decision Making and Profiling

In order to provide you with the personalised services you have subscribed to, we use your information for profiling using automated decision making, which consists of cards shown to you through our App will be chosen based on factors such as the characteristics of your business, your stated business goals, challenges and circumstances, the systems, tools and other business capabilities you already have and your stated experience in using them, and the business data you give us access to manually or automatically on products, inventory, sales, marketing campaigns and marketing effectiveness, web, social, footfall and other analytics.

Thriver will give you increasingly personalised cards over time, possible through the increasing use of automation in decision-making and profiling your business information – for example this helps Jo to suggest what similar businesses to yours have found to be impactful.

Thriver will send you emails as part of fuflilling each solution and for notifying you of outstanding and time-sensitive actions and cards on your account.

We carry out such profiling in order that you will have a more personalised, relevant and satisfying experience using our App and to enable you to take better informed business decisions. We aim for this to result in greater success in you achieving your stated goals.

Children

Our services are not aimed at children

Complaints About the Use of Your Personal Data

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by writing to contact [email protected]

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.

LAST UPDATED: 05 December 2024