Privacy Policy

Modular Software Limited trading as Reflective Thinking ("We") are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting reflectivethinking.com and/or thinking-kit.com you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Modular Software Limited registered in England with company number 02963444 at No. 1 Olympic Way, Wembley, Middlesex, HA9 0NP. We are registered with the Information Commissioner’s Office as a data controller under number ZA144775.

Information we may collect from you

We may collect and process the following data about you:

    Information you give us. You may give us information about you by filling in forms on our site reflectivethinking.com and/or thinking-kit.com our sites), by using our “Thinking Kit” mobile device application (our app) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our sites, subscribe to our service, place an order on our sites, download and register to use our app, enter a competition, promotion or survey and when you report a problem with our site or app. The information you give us may include your name, address, e-mail address, phone number, age-group, profession / position, employer and interests.

    Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:

    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, device type, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

    With regard to your use of the app, when your device synchronises with our systems via the Internet we may automatically collect information about your use of the app, including which tasks and features are selected, the time spent on a task and how often a task is completed.

    Information we receive from other sources. We may receive information about you if you use any of the other services we provide.


Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

Uses made of the information

We use information held about you in the following ways:

    Information you give to us. We will use this information:

    • to carry out our obligations arising from any contracts entered into between you and us or your education provider and us to provide the information, products and services requested from us;
    • to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
    • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
    • to notify you about changes to our products and services;
    • to ensure that content from our site and app is presented in the most effective manner for you and for your computer/device.

    Information we collect about you. We will use this information:

    • to administer our site and app and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve our site and app to ensure that content is presented in the most effective manner for you and for your computer;
    • to allow you to participate in interactive features of our service, when you choose to do so;
    • as part of our efforts to keep our site and app safe and secure;
    • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
    • to make suggestions and recommendations to you and other users of our site and app about products or services that may interest you or them.

    Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).


Disclosure of your information

We may share your information with selected third parties including:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Modular Software Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it 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 of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Modular Software Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions are processed by Braintree (a division of PayPal) and we do not receive any payment information. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@reflectivethinking.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@reflectivethinking.com.