Privacy Policy

1. Introduction

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.firstthoughtthinking.com. By providing us with your data, you warrant to us that you are over 13 years of age. First Thought Thinking Ltd is the data controller and we are responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).

Contact Details

Our full details are: Full name of legal entity: First Thought Thinking Ltd t/a First Thought Thinking Email address: firstthoughtthinking@gmail.com Postal address: 128 City Road, London, EC1V 2NX It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstthoughtthinking@gmail.com or by submitting through our contact form.

2. What Data We Collect, Why, and On What Ground

Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you: Communication Data — any communication you send to us through our contact form, email, text, social media messaging, social media posting or any other channel. We process this data to communicate with you, for record keeping and for the establishment, pursuance or defence of legal claims. Lawful ground: our legitimate interests in replying to communications, keeping records and establishing, pursuing or defending legal claims. Customer Data — data relating to purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Lawful ground: performance of a contract between you and us and/or taking steps at your request to enter into such a contract. User Data — data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website, ensure relevant content is provided to you, ensure security, maintain back-ups and enable publication and administration of our website and business. Lawful ground: our legitimate interests in properly administering our website and business. Technical Data — data about your use of our website such as IP address, login data, browser details, length of visit, page views, navigation paths, frequency of visits, time zone settings and other technology on the devices you use to access our website. The source is our analytics tracking system. We process this data to analyse use of our website, administer and protect our business, deliver relevant content and advertisements, and understand the effectiveness of our advertising. Lawful ground: our legitimate interests in administering our website and business, growing our business and deciding our marketing strategy. Marketing Data — data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to take part in promotions, deliver relevant content and advertisements and measure or understand the effectiveness of this advertising. Lawful ground: consent, contract or our legitimate interests in studying how customers use our products/services, developing them, growing our business and deciding our marketing strategy. We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Lawful ground: legitimate interests, namely to grow our business. We may also use such data to send other marketing communications to you. Lawful ground: consent or legitimate interests (namely to grow our business or for direct marketing).

Required Processing

Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don't provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time. We may process your personal data without your knowledge or consent where this is required or permitted by law. Purposes of Processing — we will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information, please email us at firstthoughtthinking@gmail.com. If we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing. We may also use Communications Data, Customer Data, User Data, Technical Data and Marketing Data for the establishment, pursuance or defence of legal claims. Lawful ground: our legitimate interests in establishing, pursuing or defending legal claims.

Sensitive Data, Criminal Conviction Data and Automated Processing

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences. Automated Decision-Making (Non-Significant Decisions) — we may use automated processes to assist us in making certain decisions about you. This means we may use systems or tools to analyse your personal data in order to help us operate our business more efficiently. These automated processes are used for purposes such as: • improving our services • analysing trends or preferences • managing administrative processes These decisions do not have a legal or similarly significant effect on you. They support our internal processes and do not materially affect your rights, opportunities or access to services. Where appropriate, we ensure that human oversight is applied to these processes.

3. How We Collect Your Personal Data

We may collect data about you when you provide it directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies — please see the Cookies section below for more details. We may receive data from third parties such as analytics providers (e.g. Google) based outside the UK and/or the EU, advertising networks (e.g. Facebook) based outside the UK and/or the EU, search information providers based outside the UK and/or the EU, and providers of technical, payment and delivery services such as data brokers or aggregators.

4. Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and, in each case, you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. You can still opt out of receiving marketing emails from us at any time. Before we share your personal data with any third party for their own marketing purposes we will get your express consent. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at firstthoughtthinking@gmail.com. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

5. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below: • Service providers who provide IT and system administration services and marketing services. • Professional advisers including lawyers, bankers, auditors and insurers. • Government bodies that require us to report processing activities. • Third parties to whom we sell, transfer, or merge parts of our business or our assets. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Where you are within the United Kingdom

We are subject to the provisions of the UK General Data Protection Regulations (UK GDPR) that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such: • We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data; or • If we use US-based providers that are part of the UK-US Data Bridge (the UK Extension to the EU-US Data Privacy Framework), we may transfer data to them, as they have equivalent safeguards in place; or • Where we use certain service providers established outside of the UK, we may use specific contracts approved by the ICO (the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses), or codes of conduct or certification mechanisms approved by the UK government, which give personal data the same protection it has in the UK. If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Where you are within the EEA

We are subject to the provisions of the EU General Data Protection Regulation (EU GDPR) that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such: • We may transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection for personal data; or • If we use US-based providers that are part of the EU-US Data Privacy Framework, we may transfer data to them, as they have equivalent safeguards in place; or • Where we use certain service providers established outside of the EEA, we may use specific contracts (the EU Standard Contractual Clauses adopted by the European Commission in June 2021), or codes of conduct or certification mechanisms approved by the European Commission, which give personal data the same protection it has in the EEA. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know. They will only process your personal data on our instructions and they must keep it confidential. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding the correct retention period, we look at the amount, nature and sensitivity of the data, potential risk of harm from unauthorised use or disclosure, the processing purposes, whether these can be achieved by other means, and legal requirements. For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/ If you wish to exercise any of the rights set out above, please email us at firstthoughtthinking@gmail.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response. When responding to a request to access your personal data, we are only required to carry out searches that are reasonable and proportionate in the circumstances (as now expressly recognised in the Data (Use and Access) Act 2025). This means we will take into account factors such as the nature of the information sought, the context in which it is held, any difficulty involved in locating it and the potential benefit to you of receiving it. We try to respond to all legitimate requests within one month of receiving the request (or, where applicable, of receiving the identity verification information or clarification we have asked for — the response period is paused, or "stopped", while we wait for that information, in line with the Data (Use and Access) Act 2025). Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests, in which case we may extend the response period by up to a further two months. We will notify you within one month of receiving your request if an extension is needed and explain why.

10. How to Complain

If you have a complaint about how we handle your personal data, we ask that you contact us first so that we can try to resolve it for you. You can submit a data protection complaint to us by: • completing our online form at www.firstthoughtthinking.com/contact • emailing us at firstthoughtthinking@gmail.com • writing to us at 128 City Road, London, EC1V 2NX We will acknowledge your complaint within 30 days of receiving it. We will investigate your complaint without undue delay, keep you informed of our progress, and communicate the outcome to you clearly with sufficient detail for you to understand how we reached our conclusion. If you are within the UK and are not satisfied with our response, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you are within the EU and are not satisfied with our response, you have the right to complain to the data protection authority of the country in which you are based.

11. Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

12. Cookies

Our website uses only strictly necessary cookies required for the site and checkout to function. We do not currently set non-essential cookies for analytics, advertising or tracking, so no cookie consent banner is required under UK PECR or the EU ePrivacy Directive. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website (including the cart and checkout) may become inaccessible or not function properly. If we introduce non-essential cookies in the future (for example, analytics or marketing pixels), we will update this notice and request your consent before they are placed on your device.