PRIVACY POLICY

PRIVACY POLICY FOR THINK GREENWICH, INC.

Version effective as of July 2, 2018

At Think Greenwich, Inc. (“Think Greenwich”), protecting your privacy is important to us. This Statement of Privacy applies to the Think Greenwich website (this “Website”)and governs data collection and usage through the Website. By using the Website, you consent to the data practices described in this statement.

Collection of Your Personal Information

Think Greenwich collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number. Think Greenwich also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests, and favorites. There is also information about your computer hardware and software that is automatically collected by Think Greenwich. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by Think Greenwich for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of Think Greenwich website. Please keep in mind that, if you directly disclose personally identifiable information or personally sensitive data through Think Greenwich public/social message boards, this information may be collected and used by others. Think Greenwich does not read any of your private online communications. Think Greenwich encourages you to review the privacy statements of websites you choose to link to from our site so that you can understand how those websites collect, use and share your information. Think Greenwich is not responsible for the privacy statements or other content on websites outside of Think Greenwich family of websites.

Use of Your Personal Information

Think Greenwich collects and uses your personal information to operate our website. Think Greenwich also uses your personally identifiable information to inform you of services available from Think Greenwich. We may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered. Think Greenwich does not sell, rent or lease its customer lists to third parties. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, Think Greenwich may share data with trusted partners to help us perform statistical analysis, send you e-mail or postal mail, or provide customer support. All such third parties are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your information. Think Greenwich does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent. We keep track of the websites and pages our customers visit within our site, in order to determine what services are the most popular. This data is used to deliver customized content and advertising within Think Greenwich to customers whose behavior indicates that they are interested in a particular subject area. Think Greenwich websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Think Greenwich or the site; (b) protect and defend the rights or property of Think Greenwich; and (c) act under exigent circumstances to protect the personal safety of users of the Website or the public.

Use of Cookies

Think Greenwich website uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Think Greenwich pages, or register with the site or services, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your personal information. When you return to our website, the information you previously provided can be retrieved, so you can easily use the features that you customized. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies, if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of Think Greenwich services or websites you visit.

Security of Your Personal Information

Think Greenwich secures your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

Online Community Policy

Think Greenwich’s Website, blog, Facebook page, Twitter page, LinkedIn profile and any other digital platforms are created to encourage conversations about news, Greenwich, personal stories and events related to the social and business community in Greenwich and how we work. We welcome everyone to join the conversation but reserve the right to remove and block users who post content in any of the following categories: graphic, obscene, explicit, abusive or racial comments towards an individual or organization. We understand and respect one’s right to disagree or offer constructive criticism on viewpoints expressed on this page but will not tolerate personal attacks or harassment, third party advertisements and solicitations for products or services, comments that encourage illegal activity, repeated posts to our page, or tagging Think Greenwich in posts containing content that is completely unrelated to our area of focus. Our online community is meant to build relationships and support our community as a whole. Please respect our organization and each other to reach the full benefits of having this place of conversation.

Changes to this Statement

Think Greenwich will occasionally update this Privacy Policy to reflect Think Greenwich and customer feedback. We encourage you to periodically review this Policy to be informed of how Think Greenwich is protecting your information.

Contact Information
Think Greenwich welcomes your comments regarding this Statement of Privacy. If you believe that Think Greenwich has not adhered to this statement, please contact us at privacy@thinkgreenwichct.org. We will use commercially reasonable efforts to promptly determine and remedy the problem.

Think Greenwich, Inc.
101 Field Point Road
Greenwich, CT 06830
Attn: Jane Owen Brash

FOR OUR EUROPEAN VISITORS – DATA PROTECTION STATEMENT OF THINK GREENWICH, INC. UNDER THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR)

Version effective as of July 2, 2018

This Data Protection Statement is intended to be in line with the EU General Data Protection Regulation (GDPR). Although the GDPR is a regulation of the European Union (EU), it may be relevant for us. In addition, organizations outside of the European Union or the European Economic Area (EEA) must comply with the GDPR in certain cases.

With this Data Protection Statement we, Think Greenwich, Inc. (“Think Greenwich”) describe how we collect and further process personal data. This Data Protection Statement is not necessarily a comprehensive description of our data processing. Other data protection statements or General Terms and Conditions or similar documents are applicable to specific circumstances.

The term “personal data” in this Data Protection Statement to shall mean any information that identifies, or could reasonably be used to identify any person.

If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Data Protection Statement and only provide us with their data if you are allowed to do so and such personal data is correct.

Controller / Data Protection Officer / Representative

The “controller” of data processing as described in this data protection statement is Think Greenwich, Inc., 101 Field Point Road, Greenwich, Connecticut 06830 unless we have informed you differently in certain cases. Our Data Protection Officer is Jane Owen Brash. You can notify us of any data protection related concerns using the following contact details: Data Protection Officer, Think Greenwich, Inc., 101 Field Point Road, Greenwich, Connecticut 06830, or E-Mail to privacy@thinkgreenwichct.org with the subject “Data Protection”.

Collection and Processing of Personal Data

We primarily process personal data that we obtain or collect from our users as well as other individuals when operating our websites, apps and other applications.

Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g., land registries, commercial registers, press and internet) or we may receive such information from affiliated companies, from authorities or other third parties. Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information from public registers, information about you given to us by individuals associated with you (family), information about you found in the media or internet, your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our websites (e.g., IP address, MAC address of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).

Purpose of Data Processing and Legal Grounds

We primarily use collected data in order to provide our services to the general public.
In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties’) legitimate interest, such as:

  • providing and developing our services and websites, apps and other platforms, on which we are active
  • review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition
  • advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings)
  • market and opinion research, media surveillance
  • asserting legal claims and defense in legal disputes and official proceedings
  • ensuring our operation, including our IT, our websites, apps and other appliances

If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters or emails), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

Cookies / Tracking and Other Techniques Regarding the Use of our Website

We typically use “cookies” and similar techniques on our websites [and apps], which allow for an identification of your browser or device. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website. If you revisit our website, we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the website (“session cookies”), we may use cookies in order to save user configurations and other information for a certain time period (“permanent cookies”). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves tem for one session or deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies for the purpose of saving user configuration (e.g., language, automated log in), in order to understand how you use our services and content, and to enable to show you customized offers and advertisement (which may also happen on websites of other companies; should your identity be known to us, such companies will not learn your identity from us; they will only know that the same user is visiting their website has previously visited a certain website). Certain cookies are sent to you from us, others from business partners with which we collaborate. If you block cookies, it is possible that certain functions (such as, e.g., language settings, shopping basket, ordering processes) are no longer available to you.

In accordance with applicable law, we may include visible and invisible image files in our newsletters and other marketing e-mails. If such image files are retrieved from our servers, we can determine whether and when you have opened the e-mail, so that we can measure and better understand how you use our offers and customize them. You may disable this in your e-mail program, which will usually be a default setting.

By using our websites and consenting to the receipt of newsletters and other marketing e-mails you agree to our use of such techniques. If you object, you must configure your browser or e-mail program accordingly.

We may use Google Analytics or similar services on our website. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics Google LLC is in the U.S., www.google.com) and which allow us to measure and evaluate the use of our website (on an anonymized basis). For this purpose, permanent cookies are used, which are set by the service provider. The service provider does not receive (and does not retain) any personal data from us, but the service provider may track your use of the website, combine this information with data from other websites you have visited and which are also tracked by the respective service provider and may use this information for its own purposes. If you have registered with the service provider, the service provider will also know your identity. In this case, the processing of your personal data by the service provider will be conducted in accordance with its data protection regulations. The service provider only provides us with data on the use of the respective website (but not any personal information of you).

In addition, we use plug-ins from social networks such as Facebook, Twitter, Youtube, Google+, Pinterest or Instagram on our websites. This is visible for you (typically based on the respective symbols). We have configured these elements to be disabled by default. If you activate them (by clicking on them), the operators of the respective social networks may record that you are on our website and where on our website you are exactly and may use this information for their own purposes. This processing of your personal data lays in the responsibility of the respective operator and occurs according to its data protection regulations. We do not receive any information about you from the respective operator.

Retention Periods for your Personal Data

We process and retain your personal data as long as required for compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of your use of our Website as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against us or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g., system logs).

Data Security

We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as internal policies, IT and network security solutions, access controls and restrictions.

Profiling [and Automated Individual Decision-Making]

We may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling allows us to inform and advise you about services possibly relevant for you more accurately. For this purpose, we may use evaluation tools that enable us to communicate with you and advertise you as required, including market and opinion research.

Your Rights

In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing in addition to right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. We have already informed you of the possibility to withdraw consent in Section 3 above.

In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us at the addresses provided in Section 1 above.

In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority.

Amendments of this Data Protection Statement

We may amend this Data Protection Statement at any time without prior notice. The current version published on our website shall apply. If the Data Protection Statement is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an amendment.