THOR - Website and Privacy Policy
Updated May 2018

THOR is committed to protecting your privacy.

We operate in accordance with the Data Protection Act 1998, the Freedom of Information Act 2000 and the General Data Protection Regulation (EU) 2016/679. This policy explains when, why and how we collect personal information from the people who visit our websites or contact us through our online forms. The policy also details the conditions under which we may disclose the information to others and how we keep it secure.

It is THOR’s policy not to distribute or sell your information on to any third party.

1. Introduction
2. Company Information
3. When do we collect your personal data
4. What personal data do we collect
5. Cookies and IP Addresses
6. Where we store and process your personal data
7. How we Protect your personal data
8. Uses we make of personal data
9. Legal basis for the collection and processing
10. How long we keep personal data
11. Who we share personal data with
12. Ads and Remarketing
13. Google Analytics
14. Newsletter and Marketing Emails
15. Disclosure of your personal information
16. External links
17. Your rights under GDPR
18. Changes to our privacy policy
19. Contacting us
20. Contacting the regulator

1. Introduction

We operate in accordance with the Data Protection Act 1998, the Freedom of Information Act 2000 and the General Data Protection Regulation (EU) 2016/679.
We encourage clients to read our privacy policy in full.

These are the THOR Groups guiding principles:

  • We will never sell your data on.
  • We will never share your data with third parties for marketing purposes.
  • We will always keep your personal data secure using strong encryption, abiding by data protection rules and by implementing good security practice.
  • We will never send you direct email marketing without your consent, any newsletter will require you to explicitly opt-in, and the ability to opt-out at any time using an unsubscribe link contained within the email.

If you are ever concerned or have question about how your personal data is collected or used, please contact us at webmaster@thor.com.

Full privacy policy below.

2. Company Information

THOR is part of THOR Group Ltd. The THOR Group Ltd head office is registered at the following address:

Bramling House, Bramling, Canterbury, Kent, CT3 1NB

Company number: 03074026

This policy (together with our terms of use Terms and Conditions) sets out the basis on which any personal data you provide to us, or we collect from you will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act) and GDPR (General Data Protection Regulation), the data controller is THOR GROUP LTD, a company registered in England and Wales under company number 03074026 and with Our registered office at Bramling House, Bramling, Canterbury, Kent, CT3 1NB

3. When do we collect your personal data

We may collect data about you in the following ways:

  • We collect data from you when you complete our Request Data Form. We may also ask you for information if you visit or report a problem with our site.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of information requests you carry out through our site and of the fulfilment of your requests.
  • Visiting our sites, including, but not limited to, traffic data, location data and other communication data required for our own security, diagnostics and authentication.

4. What personal data do we collect

If you are simply viewing our website then we will collect the following information within our logs:

  • IP Address (See cookies and IP addresses)

If you request information or technical support for or about our products we will then collect the following information:

  • Name
  • Email Address(s)
  • Company Name
  • Country

We may also collect:

  • IP address

5. Cookies and IP Addresses

IP Addresses

We collect IP address information for security, diagnostics and statistical analysis of traffic used for improvements to the performance and usability of our website, for GDPR purposes we collect this information under legitimate interest.

Cookies

A cookie is a small file saved on your computer that is used to help store preferences and other information that is used by websites you may visit.

We use cookies for the Following:

  • Authentication of users when logging in or out of our services.
  • Analysis of traffic to our website via Google Analytics (see Google Analytics).
  • Tracking of website preferences.

If you register with us or if you continue to use our site, you agree to the use of cookies.

You can block cookies by activating the setting in your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be allowed access to all or parts of our site.

Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies as soon as you visit our site.

6. Where we store and process your personal data

The data that we collect from you is stored in the UK but it may be processed by staff operating outside the EEA (European Economic Area) who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of technical services.

By submitting your personal data, you agree to the processing of this data outside of the EEA.

We take all steps necessary to ensure that your data, is treated securely and in accordance with this privacy policy and the GDPR (General Data Protection Regulation).

7. How we Protect your personal data

We treat all data with the utmost care and take appropriate steps in compliance with data protection regulation to ensure it is kept safe.

  • All data we collect is done so over encrypted connections (https).
  • All data is stored securely.
  • All systems storing personal data have access logging.
  • All passwords are encoded at rest.

8. Uses we make of personal data

We use information we collect from you only in accordance with the following guidelines:

  • To verify your identity.
  • To provide the technical product information you request
  • To carry out our obligations arising from any contracts entered into between you and us.
  • To pass details to your local Thor representative so that they can contact you and provide the appropriate technical support.
  • To ensure that content from our site is presented in the most effective manner for your device.
  • To respond to queries.
  • To provide you with information, products or services that you request from us where you have consented to be contacted.
  • To notify you about changes to our services.
  • To send you marketing emails where you have given explicit consent.
  • To display personalised Ads from us.
  • To prevent fraud.
  • To detect, prevent and diagnose potential security breaches.

Data protection law sets out the conditions under which personal data can be collected and which we use as the basis for collection and processing, these include:

Contractual obligations

When you purchase a service, we need to collect personal data to fulfill our legal contractual obligation, for example: so we can manage and invoice your account and contact you for technical support purposes.

Legal compliance

The law requires we collect and process data for certain purposes such as for keeping financial records (i.e. invoicing) and that we can comply with law enforcement requests for data.

Legitimate interest

We collect data under legitimate interest in a way that is reasonably expected as part of the day to day running of our business.

For example, we collect and log IP addresses for fraud protection and security as well as analysis of our site usage.

Consent

In certain cases, we may collect and process your data with your consent, for example our newsletter or events correspondence. Consent to receive these can be withdrawn at any time.

10. How long we keep personal data

Your data will be kept until it is no longer required for the purpose of its collection.

At the end of the retention period the data will either be deleted or anonymised so it can no longer be linked back to an individual.

Personal data linked to purchases or any other financial transaction are kept for a minimum of 6 years as required by UK law to retain financial data.

11. Who we share personal data with

Like many websites we may use third-party services for functionality. All the suppliers will be carefully selected to ensure they provide suitable protections under GDPR.

12. Ads and Remarketing

We may use Google AdWords remarketing services to display our ads on third party websites (including Google) to previous visitors of those pages, this is done in the form of a cookie that contains anonymous data regarding your visit.

If you have a google account you can opt-out of receiving these ads here http://www.google.com/settings/ads

Google are also a member of the NAI (Network Advertising Initiative), you can also use their site to opt out here http://www.networkadvertising.org/managing/opt_out.asp

13. Google Analytics

We use Google Analytics including Google Analytics Demographics and Interest Reporting to monitor how people use our websites and aggregate general statistics about customers, traffic patterns and related site information in an anonymous form. Any demographic reports produced using this data will be used to better understand our website traffic and visitor needs and tailor future content and website functions.

This data is collected using cookies and from your IP address, the resulting statistics are used for the following purposes:

  • Improving website usability
  • Tracking the success of marketing campaigns
  • Pattern analysis

You can prevent Google Analytics from collecting this information by installing the google opt-out browser addon: https://tools.google.com/dlpage/gaoptout

To learn how Google uses data collected from our sites please see the following link: https://policies.google.com/privacy/partners?hl=en-GB&gl=uk

14. Newsletter and Marketing Emails

All our marketing emails are opt-in, we will never sell on your details or pass them on to third parties for marketing purposes. If you have opted in to receive these then you can opt out at any time in the following ways:

  1. If you have received an email, click on the unsubscribe link located in the email footer.
  2. By contacting webmaster@thor.com

15. Disclosure of your personal information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties:

If THOR Group Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it (THOR Group Ltd) 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 and conditions of supply Terms and Conditions and other agreements; or to protect the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Our site may, from time to time, contain links to and from the websites of our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

17. Your rights under GDPR

Under GDPR (General Data Protection regulation) you have a number of rights relating to your personal data, these will come into force on the 25th May 2018, for further information please see https://ico.org.uk

Right to Restrict Processing

You have the right to request we restrict processing of your personal data where there is no legitimate interest for us to do so:

  • Where the accuracy of the personal data is contested, to restrict the processing until such time as the accuracy has been sufficiently verified.
  • Where you object to the processing (See Right to Object), and where we are considering whether there are legitimate grounds to override the request.
  • When processing is unlawful and you oppose erasure and request restriction instead.
  • If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

You can exercise the right at any time by contacting our team (see Contacting Us).

Right of Access (Access to Information)

The GDPR Act gives you the right to access information held about you.

You can exercise this right by contacting us (see Contacting Us).

We are required to verify your identify before processing any right to access request, once verified the data shall be provided within 28 days.

The data shall be provided free of charge however an admin fee may be applied where a request is manifestly unfounded or excessive, particularly if it is repetitive.

Right to Erasure (Also known as the right to be forgotten)

As an individual you have the right to request the erasure of any data we hold on you, this is not an absolute right, for example it does not override our requirement under UK law to keep financial data such as invoice information.

You can make a request where your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed, for example if you cancel all services you have with us.

To make a right to erasure request please contact our customer services team (see Contacting Us).

Right to Rectification

The GDPR provides the right to have any personal data rectified that may be incorrect or incomplete.

Customers can update their own personal details via the client area however if this is not sufficient please contact our customer services team (See contacting Us).

Right to Object

You have the right to object to the processing of your personal data where there is no legitimate or lawful reason to do so.

To make a right to object request please contact our customer services team (see Contacting Us).

18. Changes to our privacy policy

We keep our privacy policy under regular review, you can always find the latest version at the URL below:

http://www.thor.com/privacy-policy.html

19. Contacting us

Questions, comments and requests regarding this privacy policy are welcomed, you can contact us in the following ways:

  • Email us at webmaster@thor.com
  • Or write to us at: Thor Group Ltd, Bramling House, Bramling, Canterbury, Kent, CT3 1NB

20. Contacting the regulator

While we will make every attempt to rectify any situation, where you feel your data has not been handled appropriately you have the right to contact the regulator. In this case the regulator is the Information commissioner’s office (ICO).

You can contact them on 0303 123 113
or by visiting https://www.ico.org.uk/concerns