THNK Holding B.V. is responsible for processing your personal data (the ‘controller’) within the meaning of the General Data Protection Regulation (‘GDPR’).
THNK is located at Keizersgracht 264, 1016 EV Amsterdam, The Netherlands. Any questions you might have can be emailed to firstname.lastname@example.org.
Under the GDPR, THNK does not have the obligation to appoint a data protection officer (‘DPO’).
What information do we collect about you?
By using THNK’s products and/or services, it processes the personal data of its users. THNK collects information about you when you complete a form and when you voluntarily complete surveys and provide feedback. Moreover, website usage information is collected using cookies. This data is collected for certain purposes on a legitimate legal basis.
The following Data is collected from prospective participants when completing a registration form for the order of a product and/or service of THNK:
• email address
• first and last name
• telephone number
• data of birth
• years of work experience;
• current job title and organization
• organization’s name, address and VAT number (in case the company is paying the program fee)
• topics of interests
• social media profiles
• other information related to the motivation, needs and expectations of the products THNK offers
In the case of surveys or feedback, in addition to the above, we process additional personal data. The nature and scope of the personal data can vary in these cases; further information on this will accompany the survey or feedback concerned.
The following Data is collected from participants using products and/or services of THNK:
• Marketing and Sales Data – personal data geared at marketing programs, recruiting and selecting participants
• Operational Data – Information geared at facilitating operational procedures, e.g. onboarding and ensuring best experience for the participants
• Individual evaluation data – data provided by the participants through evaluation surveys and self-assessment questionnaires
• Marketing Evaluation Data –evaluation data provided by participants during program onboarding to understand decision making for the program and improve our marketing
The following Data is collected from visitors to the THNK website:
• website visit and use;
• IP address;
• duration and time of visit to the website;
• use of social media.
How do we collect data from you?
You directly provide THNK with most of the data we collect. We collect data and process data when you:
• register online via submitting an online form and place an order for any of our services
• voluntarily complete a participant survey or provide feedback
• use of view our website via your browser’s cookies
For what purposes do we process personal data?
We process personal data for the purposes of our service provision, within the framework of training programs and education, and in order to comply with statutory obligations.
Personal data supplied by participants (or prospective participants) is processed for the following purposes:
• registration for the purposes of education/training program;
• to provide education (including online education);
• administrative purposes, to enable courses to be attended and the payments for these to be collected
• to process requests for information about training programs;
• to provide course choice support;
• to monitor study progress;
• to provide study counselling;
• information purposes;
• to provide (more detailed) updates on current developments, events, webinars, etc.;
• to email newsletters, invitations to participate in surveys, information on your participant account, your participant status and other (necessary) information from THNK School of Creative Leadership;
• the continuous improvement of the quality and accessibility of facilitating and social impact by, among other things, conducting research and carrying out and processing surveys and their results.
The personal data supplied by visitors to our websites is processed for the following purposes:
• to compile user statistics;
• to promote security and improvement of our website; and
• to improve our services.
In the case of surveys or feedback, personal data is processed for the purposes of the survey or feedback. Further information on the way in which personal data is processed will accompany the survey or feedback concerned.
On what legal grounds do we process your data?
The processing of personal data of prospective participants are essential for the execution/performance of the agreement by THNK. All personal data of prospective participants, for example an e-mail address, used by THNK for promotional use and the ability to send a newsletter is on the basis of consent.
The processing of personal data of participants are essential for the execution/performance of the agreement. All personal data of participants, for example an e-mail address, used by THNK for promotional use and the ability to send a newsletter is on the basis of consent.
The processing of personal data of our website users is on the basis of consent of the user of the website.
For the processing of personal data of participants and/or prospective participants and/or website users for managing, analyzing, maintaining, optimizing, and securing our products and/or services and/or for preventing abuse and/or fraud of our products and/or services and/or determining strategic analyses and reports on our products and/or services THNK has a legitimate interest.
How will we use the information about you?
We collect information about you in order to answer your queries, to assess if you could be a candidate for our programming, and, if you agree, to email you about products and services we think may be of interest to you. We use your information collected from the website to personalize your repeat visits to our website. THNK does not share your information for marketing purposes with other companies.
THNK shares personal data with third parties to support the performance of its services, on the basis of a statutory provision or in case of an emergency if this is, in the reasonable opinion of THNK , in the interest of it users. This includes legitimate requests of authorities, summons or court orders, acts to investigate or prevent damages or fraud, or acts to guarantee the safety of our network and our Products and/or Services.
You can think of a software supplier or other service providers who need personal data to deliver their services. We formalize the processing and security of personal data through agreements with these parties.
How do we store your data?
THNK securely stores your data online, through verified and trusted, GDPR-compliant software providers like Google, Hubspot, Box, Salesforce among others.
THNK may use the services of third parties to process your data in accordance with this privacy statement. These parties can be located outside the European Union or they can use servers located outside the European Union, including in the United States. The level of the right to protection of personal data may be lower in these countries than in the European Union.
Data collected automatically
In case a participant or other user visits our website, our services may store automatic information, such as URLS, IP addresses, browser types. THNK has a legitimate interest in processing the personal data in question.
Third party data
THNK processes personal data of third parties by using for example HubSpot to capture where the marketing leads come from – from ads on Facebook, ads on LinkedIn and so on. THNK has a legitimate interest in processing the personal data from third parties in question.
Sensitive personal data
THNK does not process sensitive personal data.
All (prospective) participants and users of our website have certain rights under the GDPR to manage their own personal data.
• The right to access;
• The right to rectification;
• The right to erasure;
• The right to object;
• The right to data portability;
• The right to restriction of processing.
A user may also withdraw the consent he/she has granted for the processing of his/her data at any time.
In case the user wishes to invoke on or more of these rights, he/she may contact THNK through email@example.com.
How long do we keep your personal data?
We will not keep your personal data for longer than is necessary for the purposes for which we use it. We are required by law to keep some data for a certain period of time.
For example, it could be that after you have completed a course we have to keep certain personal data for administrative purposes or due to a legal obligation. Wherever possible, we will pseudonymise or anonymise your personal data.
We would like to send you information about products and services of ours and possibly other companies which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please unsubscribe from our mailing list using the Unsubscribe link at the bottom of our marketing emails or send us an email to firstname.lastname@example.org.
Access to your information and correction
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email email@example.com or write to us at the following address: Keizersgracht 264, 1016 EV, Amsterdam, Netherlands. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. If in doubt about your identity, we are entitled to ask you to provide proof of your identity first.
THNK has taken adequate technical and organizational measures to protect personal data of participants and other users against loss of unlawful processing, for example, by using passwords to protect a database.
In the unlikely event that you discover a data breach, it of utmost importance that we are informed immediately. You can report data leaks directly through: firstname.lastname@example.org. Your report and data will be treated confidentially at all times.
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:
• functionality – THNK uses these cookies so that we recognize you on our website and remember your previously selected preferences. A mix of first-party and third-party cookies are used.
• advertising – THNK uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device and your IP address
• other – for example, LinkedIn and Facebook. These cookies are used just to connect these services to our website so that we can understand where the leads are coming from (e.g. from Facebook or Linkedin ads pointing to www.thnk.org)
How to contact us