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This Privacy Notice explains how Thornton & Lowe Ltd collects, uses, stores and shares personal information.
It applies when you purchase a product or service from us, including through our website, use our website or submit an online form, make an enquiry or request a proposal, receive consultancy, bid writing, bid management, training or other services from us, attend meetings or calls with us, work for or represent one of our clients, prospective clients, suppliers or business partners, subscribe to marketing communications, or otherwise communicate or interact with Thornton & Lowe.
It also applies where information about you is provided to us by another organisation, such as your employer or one of our clients.
Thornton & Lowe Ltd is responsible for the personal information covered by this Privacy Notice where we act as data controller.
Our address is:
Thornton & Lowe Ltd
The Wellsprings
Howell Croft South
Bolton
Greater Manchester
BL1 1SB
You can contact us at:
Email: hello@thorntonandlowe.com
Telephone: +44 (0)1204 238046
Please use these details if you have any questions about this Privacy Notice, our use of personal information or your data protection rights.
Thornton & Lowe will normally act as a data controller for personal information we collect and use for our own business purposes, including managing enquiries, client relationships, purchases, training, marketing and administration.
In some circumstances we process personal information solely on the instructions of a client as part of providing services to that client. In those circumstances, the client will generally be the data controller and Thornton & Lowe will act as a data processor.
Where we act as a processor, our use of the information is governed by our agreement with the relevant client and their instructions.
The information we collect depends on your relationship with us and the services involved.
We may collect identity and contact information such as your name, employer, job title, address, telephone number, email address and signature.
Where you purchase products or services from us, including online, we may collect billing details, order information, payment information, invoices and transaction records. Payment card information may be processed by our payment provider and we do not normally retain complete card details ourselves.
We may also collect and use:
We may also create information through our own interactions with you, such as meeting notes, service records, assessments and correspondence.
Our services may occasionally involve processing more sensitive information contained in materials supplied by a client. This may include information concerning health, equality characteristics, DBS status or other background information included within tender, employment, training or compliance documentation.
We do not seek to collect this type of information unless it is reasonably necessary.
Where Thornton & Lowe acts as controller, we will only process this information where the requirements of data protection law are met. Where we process it solely on behalf of a client, the relevant client is responsible for determining the appropriate lawful basis and conditions for that processing.
We may receive personal information directly from you through our website, telephone calls, emails, meetings, purchases, training sessions, proposals and other communications.
We may also receive information from:
your employer or another organisation for which you work;
our clients and prospective clients;
colleagues, representatives, suppliers and other organisations involved in an engagement;
publicly available sources such as company websites, Companies House, LinkedIn and public procurement information; and
suppliers and service providers involved in areas such as website hosting, analytics, CRM, payment processing and technology.
We may also create information ourselves through our interactions and business relationship with you.
We may use personal information to process purchases and payments, provide products and services, respond to enquiries, prepare proposals and quotations, arrange meetings, deliver consultancy, bid writing, bid management, training and other services, and manage our relationships with clients and suppliers.
We may also use information to understand training or service requirements, maintain project and customer records, provide customer service, manage complaints, operate and secure our systems, improve our services, maintain financial records, comply with legal and regulatory obligations and protect our legal rights.
Where permitted, we may also use business contact information to communicate with existing and prospective clients about relevant Thornton & Lowe products and services.
The lawful basis we rely on will depend on the reason we are using the information.
We may rely on contract where processing is necessary to enter into or perform a contract with you.
We may rely on our legitimate interests where processing is reasonably necessary to operate our business, respond to enquiries, provide and improve services, manage client relationships, maintain appropriate records, protect our business and carry out appropriate business-to-business marketing.
Where we rely on legitimate interests, we consider the impact of the processing on the individuals concerned.
We may process information where necessary to comply with a legal obligation, including accounting, taxation and regulatory requirements.
We may rely on consent where that is the appropriate basis, for example for certain marketing activities or non-essential cookies. Where we rely on consent, you can withdraw it at any time.
Some information is necessary for us to process an order, enter into a contract or provide a requested service.
If you do not provide information that is reasonably required for these purposes, we may be unable to process an order or provide the relevant product or service.
We may send information about Thornton & Lowe services, training, events or other relevant business services where we are permitted to do so.
You can ask us to stop sending direct marketing at any time by using the unsubscribe option in an email or contacting us at hello@thorntonandlowe.com.
If you opt out of marketing, we may retain limited information on a suppression list so that we can continue to respect your preference.
Opting out of marketing will not prevent us from sending necessary communications concerning services, contracts, transactions or enquiries.
We do not sell personal information.
Our website uses cookies and similar technologies for purposes including essential website functionality, analytics and, where applicable, advertising and marketing.
You can manage your preferences using the cookie controls available on our website.
Where consent is required for non-essential cookies, those cookies will only be used where the appropriate consent has been obtained.
We may use appropriately selected technology, including AI-supported drafting, analysis and transcription tools, to assist with the delivery and administration of our services.
Where personal information is processed using these tools, we take steps designed to ensure that their use is consistent with our contractual, confidentiality and data protection obligations and that appropriate safeguards are in place.
We do not use solely automated decision-making, including profiling, to make decisions about individuals which produce legal or similarly significant effects.
Access to personal information within Thornton & Lowe is restricted to people who reasonably need it for their work.
Where necessary, we may also share information with clients or organisations for which we are providing a service, IT and cloud providers, CRM and communications providers, website and analytics providers, payment processors and banks, accountants, auditors, insurers, lawyers and other professional advisers, subcontractors and consultants assisting with service delivery, procurement portals and contracting authorities where necessary to perform an agreed service, and other companies within our corporate group where necessary for legitimate administration or service delivery.
We may also disclose information to HMRC, regulators, courts, law enforcement bodies or other authorities where disclosure is required or permitted by law.
Information may also be shared with appropriate advisers or counterparties in connection with a proposed investment, restructuring, merger, sale or acquisition involving all or part of our business.
Some of the technology and service providers we use may process or store personal information outside the United Kingdom.
Where this involves a restricted international transfer, we take appropriate steps in accordance with UK data protection law. Depending on the circumstances, this may include relying on UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another lawful transfer mechanism.
We apply any additional assessments or safeguards required by law.
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected.
As a general guide:
Enquiries and prospective clients: up to two years after our last meaningful contact where an engagement does not proceed.
Client, project, consultancy, bid support and training records: normally for six years after the relevant engagement ends.
Financial, payment and accounting records: normally for six years, or longer where required by law.
Marketing information: for as long as it remains reasonably relevant or until you opt out. Where you opt out, we may retain limited information to ensure we continue to respect your preference.
Website, analytics and cookie information: in accordance with the applicable cookie and analytics retention settings.
We may retain information for longer where required by law or contract, or where it is reasonably necessary in connection with a complaint, dispute or legal claim.
We take appropriate technical and organisational measures designed to protect personal information against accidental loss, misuse, unauthorised access, alteration or disclosure.
Access is restricted to employees, contractors and service providers who have an appropriate business need to use the information.
We maintain procedures for responding to suspected personal data breaches and will notify affected individuals and the Information Commissioner's Office where required by law.
Depending on the circumstances, you may have the right to access personal information we hold about you, have inaccurate or incomplete information corrected, request erasure of information in certain circumstances, request restriction of processing, object to processing based on legitimate interests, object to direct marketing, receive certain information in a portable format and withdraw consent where processing is based on consent.
These rights are not absolute and exemptions or other legal requirements may apply.
Where Thornton & Lowe is processing information solely on behalf of another organisation as its processor, we may need to refer your request to the relevant data controller.
To exercise your rights, contact hello@thorntonandlowe.com.
We may ask for proportionate information to verify your identity where necessary.
If you have concerns about how Thornton & Lowe uses your personal information, please contact us at hello@thorntonandlowe.com so that we can investigate.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator.
Further information is available at www.ico.org.uk.
Our website and business services are not primarily directed at children and we do not knowingly seek to collect children's personal information through our general business activities.
Where information relating to a child is necessarily included in client materials, we handle that information in accordance with our contractual and data protection obligations.
Our website may contain links to websites operated by other organisations.
Thornton & Lowe is not responsible for those organisations' privacy practices. We recommend reviewing their privacy information when visiting external websites.
We may update this Privacy Notice from time to time to reflect changes to our services, technology, suppliers or applicable law.
The current version will always be published on this page.
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