HOW WE TREAT YOUR DATA

Applicable since September 23, 2022 From THINKING HEADS GROUP, S.L. (hereinafter, “THINKING HEADS”) we want to give you some details about how we process the personal data that you provide us when interacting with us. Thus, this privacy policy applies to all people who provide us or have provided personal data through our website https://www.thinkingheads.com (hereinafter, the “Website”). We have called this document “How we process your personal data” because it is important for us that this information is as accessible as possible for you, but in case you prefer the more traditional denominations, this document is the Privacy Policy of our company.

Basic information on how we treat your data

Controller THINKING HEADS GROUP, S.L. Registered office: Velázquez, 24-7º planta C.P.: 28001 N.I.F. B-83220475
Purpose We use your data for some of these purposes: – Maintenance and management of the relationship with you when the hiring of any of the services is required. – Management of your CV once you send it through our Website. – Management of our Newsletter service when you request it. – Respond to your inquiry or contact made through our Website.
Lawful Basis The processing of your data is always legitimized by your consent or by the need of processing for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
Recipients of the personal data The data will not be transferred without express consent, except legal obligation.
Rights Access, rectification or erasure, restriction of processing, objection to processing, as well as the right to data portability, by contacting gdpr@thinkingheads.com

  By providing data through any of the means enabled, you freely accept that such personal data will be subject to the corresponding processing activities in each case, depending on the consent and purpose for which you have facilitated the personal data to us. According to the provisions of Regulation (EU) 2016/679, of April 27, General Data Protection (hereinafter, we will call it “GDPR”) we must provide you with information regarding the processing of your data that we are going to carry out in order to ensure the validity of your consent whenever necessary and for you to understand at all times how we process your data. That is why it is essential that you read carefully the information that we detail below.  

Why will we treat your data?

We will use the personal data that you provide us in the different forms enabled for this purpose to manage the relationship we have with you depending on how you want to get involved with THINKING HEADS. This data allows us to maintain the relationship with users, as well as the management, administration, provision and improvement of our services, and without them, we would not be able to provide services. For this reason, if you do not want us to process your data, you will not be able to use our services. Likewise, in the case that there is a contractual relationship, we will send you information about our products and services that are similar to those already hired by you. For such communication, the legal basis is at article 21 of Law 34/2002 on E-Commerce and Information Society Services. If you do not want to receive any information about our services or at any time you want to stop receiving it, please let us know by sending an email to the address info@thinkingheads.com, or by postal mail to the THINKING HEADS address that we have indicated above. In any case, all our commercial communications will allow you to object against the processing of your data for promotional purposes.  

Why do we use your personal information?

We will only process the data that you provide through any of the means available on the Website, and the processing will depend on the purpose indicated by you through the selection of one of the different options available. The options available on the Website to send your data are:

  • Processing of data for the maintenance and management of the relationship with you when you require our services.
  • Processing of data for the management of your CV once you send it through our Website.
  • Processing of data to manage the sending of our Newsletter when you request us to receive it.
  • Processing of data to respond to your inquiry or contact made through our Website.

Why do we use your personal information?

The legal basis for the processing of your data is the informed and express consent that you give us at the moment of giving your data for each of the options available on the Website or, given the case, when required for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.  

To whom do we communicate your data?

We do not give your personal information to anyone. We will only communicate them when we are bound by law or when you have previously given us your express authorization. In order to provide our services we need to work with companies that process your data on our behalf (hosting providers, email, etc.), as part of the provision of a service that we have hired, with whom we sign the corresponding data processing agreements and to which we demand compliance with the regulations on personal data.  

How long will we keep your data?

Regarding each data processing for which you have given your consent, we will keep the data for as long as necessary to ensure the correct development of our relationship with you as a client, candidate in the selection processes, subscriber of the newsletter, contact and comply with our legal obligations. The personal data provided will be retained while you continue to maintain a relationship with us and / or continue to subscribe to our newsletter or until you request your withdrawal and deletion of the data. When the contractual relationship or consent ends, we will keep the data secured during the statute of limitations and once such period ends, we will delete your personal data. You can request the cancellation of your account when you deem appropriate.  

How do we protect your data?

In compliance with our obligation to keep secret with respect to the personal data collected as well as our duty to safeguard the data, we compromise to adopt the necessary security measures to avoid its modification, alteration, loss, process or unauthorized access, in accordance with what is established in the GDPR. At THINKING HEADS we recognize and take our responsibility very seriously when it comes to protecting your personal data. That is why we maintain security levels of personal data protection in accordance with the Regulation (EU) 2016/679, of April 27, General Data Protection (GDPR) and the Regulation of Security Measures of automated processing that contain personal data, approved by Royal Decree 1720/2007 of December 21, which approves the Regulation for the development of Organic Law 15/1999, of December 13, on the protection of personal data, and we have established all the technical means at our disposal to avoid the loss, misuse, alteration, unauthorized access and theft of the data you have provided us, without prejudice to inform you that security measures on the Internet are not 100% impregnable.  

How can you control the management of your data?

Again we remind you that you can exercise your rights of access, rectification or erasure, restriction of processing, objection to processing, as well as the right to data portability by contacting any of the addresses that we have given you at the beginning or in the email address gdpr@thinkingheads.com, attaching a photocopy of your national identity document and indicating what action on our part you request. The exercise of all these rights is free and, in the interest of greater transparency, we provide you with more information about these rights:  

Right Content
Access, Rectification and Suppression By requesting it to the email address gdpr@thinkingheads.com or to the address of the data controller that we have given you in this document. Remember that your request must clearly state your wish and must be accompanied by a photocopy of your ID and so that we can prove your identity.
Objection In certain circumstances and for reasons related to your particular situation, you can oppose the processing of your data. THINKING HEADS will stop processing the data, except for compelling legitimate reasons, for the exercise or defense of possible claims, or to comply with our legal obligations.
Limitation of the treatment In certain circumstances and for reasons related to your particular situation, you can oppose to the processing of your data. THINKING HEADS will stop processing the data, except for legitimate reasons, for the exercise or defense of possible claims, or to comply with our legal obligations.
Portability You can receive, in electronic format, the personal data that you have given us so that we can provide them to the new data controller or, where appropriate, ask us directly to pass them on to the new data controller.
Withdrawal of consent You can withdraw the consent given at any time without affecting the legality of the data processing. If you request the removal of your data we will stop processing them but keep in mind that we will not be able to continue providing you services and that, in certain cases in which we have the corresponding legal basis, we will continue processing your information after you have withdrawn your consent and requested the elimination of your information.

  We also inform you that you have the right to lodge a complaint before the Spanish Data Protection Agency (www.aepd.es). In any case, due to our strong commitment with data protection, we invite you to contact us directly so we can solve any issue related to your personal data; we will be happy to help you.  

Modification of the privacy policy

THINKING HEADS reserves the right to modify this privacy policy to adapt it to future legislative or case law developments, as well as industry practices, by previously informing the users through our Website. We recommend that you consult this page on a regular basis to review the most recent version. At the top of this document, we indicate the date of the last update. The new privacy policy will be effective from the time of its publication. Under no circumstances will such changes affect the way THINKING HEADS may process your personal data or consent. If at any time we wish to use your data in a way different to that stated at the time of collection, we will notify you be email, requesting your consent. We will also notify you with any material changes to this privacy policy. Likewise, THINKING HEADS reserves the right to terminate the services it provides to users who do not comply with the legal terms and conditions of use, as well as with current legislation.  

Our social networks

Finally, we would like to provide some details about our activity on social networks. THINKING HEADS has user accounts on Youtube, Facebook, Twitter, LinkedIn and Instagram. Through our accounts, we do not share nor communicate any personal data related to our “friends” on Facebook, our “followers” on Twitter, or our videos on Youtube, etc. Given that THINKING HEADS is the administrator of these accounts, it has adopted the adequate security measures and privacy settings, being the users’ responsibility not to send personal data through these platforms. However, we inform you that the accounts we have in social media are public. This is because our profile meets the purpose that our services should be viewed by as many people as possible, being the responsibility of users not to send personal data through such platforms. Therefore, before using such social networks, we advise you to read their Terms of Use and Privacy Policy: Facebook: https://es-es.facebook.com/about/privacy/ Twitter: https://twitter.com/en/privacy Youtube: https://policies.google.com/privacy?hl=en-GB&gl=es LinkedIn: https://www.linkedin.com/legal/privacy-policy? Instagram: https://privacycenter.instagram.com/policy/?entry_point=ig_help_center_data_policy_redirect Whoever wants to end interaction with THINKING HEADS through any of the social media platforms can do so by unfollowing the account through the corresponding platform. In addition, we inform you that all the images that we upload on social media have the express consent from the people that appear or by their legal representatives or tutors. In the case that THINKING HEADS publishes an image without the corresponding consent or the data subject wishes to remove the image, you can contact us through the email address gdpr@thinkingheads.com.