GLOBAL BLACK THRIVE CIC is a company registered in England and Wales referred to as “Black Thrive”, “we” or “us” in this policy.
Maintaining the security of your data is a priority at Black Thrive, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. Black Thrive is also dedicated to being transparent about what data we collect about you and how we use it.
This policy, which applies whether you visit our offices, website, or use your mobile device and provides you with information about:
– how we use your data;
– what personal data we collect;
– how we ensure your privacy is maintained; and your legal rights relating to your personal data.
HOW WE USE YOUR DATA
Black Thrive (and trusted partners acting on our behalf) use your personal data:
– to provide goods and services to you;
– to make a tailored website available to you;
– to manage any registered account(s) that you hold with us;
– to verify your identity;
– for crime and fraud prevention, detection and related purposes;
– with your agreement, to contact you directly by phone, post and electronically about promotional offers and products and services which we think may interest you;
– for market research purposes – to better understand your needs;
– to enable Black Thrive to manage it’s customer service interactions with you; and
– where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
We may collect data directly from you when you use our website, mobile apps or when you visit/ or meet us in person, as well as analysing your browsing activity on-line, and your responses to marketing communications. The results of this analysis, together with other demographic data, allows us to ensure that we contact you with information on products, services and offers that are relevant to you. To do so, we use software and other technology (automated processing).
Black Thrive uses your personal data for electronic marketing purposes (with your consent) and may send you postal mail to update you on the latest Black Thrive offers and news.
Black Thrive aims to update you about products & services which are of interest and relevance to you as an individual or business.
You have the right to opt out of receiving promotional communications at any time, by:
1. changing marketing preferences via this link;
2. making use of the simple “unsubscribe” link in emails or the “STOP” number for texts; and/or
3. contacting Black Thrive via the contact channels set out in this Policy.
Web Banner Advertising
If you visit our website(s), you may receive personalised banner advertisements whilst browsing other websites. Any banner advertisements you see will relate to products you have viewed whilst browsing our website(s) on your computer or other devices.
Sharing data with third parties
Our service providers and suppliers
In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers.
Black Thrive only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to Black Thrive and to you, and for no other purposes.
Other third parties
Aside from our service providers, Black Thrive will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes.
We may share your data with:
– our carefully selected partners who provide Black Thrive branded products and services (for example Search Engine Optimisation), if we have your consent to do so;
– credit reference agencies where necessary for card payments;
– governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
– to comply with our legal obligations;
– to exercise our legal rights (for example in court cases);
– for the prevention, detection, investigation of crime or prosecution of offenders; and
– for the protection of our employees and customers.
To deliver products and services to you, it is sometimes necessary for Black Thrive to share your data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.
If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed here (https://ec.europa.eu/info/law/law-topic/data-protection_en).
How long do we keep your data?
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years.
WHAT PERSONAL DATA DO WE COLLECT?
Black Thrive may collect the following information about you:
– your name, age/date of birth and gender;
– your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
– transactions made by you;
– your on-line browsing activities on Black Thrive websites;
– your password(s);
– when you make a transaction with us, your payment card details;
– your communication and marketing preferences;
– your interests, preferences, feedback and survey responses;
– your location;
– your correspondence and communications with Black Thrive; and
– other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).
Our website(s) is not intended for children and we do not knowingly collect data relating to children.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our websites, or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
We also receive personal data from trusted third parties who provide services to our customers under the Black Thrive brand, which we use to analyse customer behaviour and improve our tailored marketing.
HOW WE PROTECT YOUR DATA
Black Thrive is committed to keeping your personal data safe and secure.
Our security measures include: –
– encryption of data;
– regular cyber security assessments of all service providers who may handle your personal data;
– regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
– daily penetration testing of systems;
– security controls which protect the entire Black Thrive IT infrastructure from external attack and unauthorised access; and
– internal policies setting out our data security approach and training for employees.
WHAT YOU CAN DO TO HELP PROTECT YOUR DATA
Black Thrive will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from Black Thrive asking you to do so, please ignore it and do not respond.
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety both in relation to Black Thrive and more generally: -
– keep passwords private. Remember, anybody who knows your password may access your account.
– when creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your passwords.
– avoid using the same password for multiple online accounts.
You have the following rights:
– the right to ask what personal data that we hold about you at any time, subject to a fee specified by law (currently £10);
– the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge; and
– (as set out above) the right to opt out of any marketing communications that we may send you.
If you wish to exercise any of the above rights, please contact us using the using this link or the contact details set out below.
Call: +7930 207 944
Postal Address: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF
LEGAL BASIS FOR USING DATA
We are required to set out the legal basis for our ‘processing’ of personal data.
Legal basis for Black Thrive processing customer personal data
Black Thrive collects and uses customers’ personal data because is it necessary for:
– the pursuit of our legitimate interests (as set out below);
– the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
– complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to customers via email or text message.
Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Black Thrive, including:-
– selling and supplying goods and services to our customers;
– protecting customers, employees and other individuals and maintaining their safety, health and welfare;
– promoting, marketing and advertising our products and services;
– sending promotional communications which are relevant and tailored to individual customers;
– understanding our customers’ behaviour, activities, preferences, and needs;
– improving existing products and services and developing new products and services;
– complying with our legal and regulatory obligations;
– preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
– handling customer contacts, queries, complaints or disputes;
– managing insurance claims by customers;
– protecting Black Thrive, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Black Thrive;
– effectively handling any legal claims or regulatory enforcement actions taken against Black Thrive; and
– fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
If you have any questions about how Black Thrive uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact us by any of the following means:
Call: +7930 207 944
Postal Address: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF
You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.
THIRD PARTY SITES AND MICROSITES
Black Thrive has partnered with certain trusted third parties to make additional products and services available to you, including:
These products and services can be accessed online through the relevant third party’s “microsite”. These websites, and others linked to from this Policy, are owned and operated by a third party and they are responsible for processing personal data in accordance with their own privacy policies.
This policy was last updated in March 2021