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The Think Pool | Privacy policy · How we manage your data

Privacy policy

Effective date: April 21, 2025

CARNEIRO Santana EI (hereinafter “The Think Pool”, “us”, “we”, or “our”) operates the thethinkpool.com website (the “Service”).

The Think Pool is committed to the protection of your personal data and privacy. In this regard, and in accordance with the General Data Protection Regulation (hereinafter referred to as "GDPR"), we hereby inform you of the conditions under which your personal data is intended to be processed by us.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Definitions

Service

Service is the thethinkpool.com website operated by The Think Pool.

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Nickname
  • Comments on the articles pages of the Blog section
  • Name of the company/organization
  • Business ID
  • Company name
  • Postal address
  • Phone number
  • Invoicing information
  • Website URL
  • Country
  • Cookies and Usage Data
  • Information about ordered services
  • Other information related to the client relationship or ordered services
  • Technical and location information generated in the context of using our services

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Your personal or business information will be stored every time you complete our forms or send us emails. This information will be used to contact you, to meet your requests and for internal reviews.

Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You can find more information about adjusting or changing your browser settings in your browser’s “Help” menu. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Essential cookies

These cookies are essential for the proper functioning of my website. Without these cookies, the website would not work properly.

  • Preference Cookies (cc_cookie). This first-party cookie is generated to remember your cookies preferences.
  • Cookie (PHPSESSID) used by Simplymeet for the scheduling pages. PHPSESSID is a first-party Session Cookie generated by applications based on the PHP language. This is a general purpose identifier used to maintain user session variables. It is normally a random generated number, how it is used can be specific to the site, but a good example is maintaining a logged-in status for a user between pages.
  • Local storage cookie (ml_guid) used by Mailerlite to identify users that submit to the newsletter.

Analytics cookies

These cookies help us understand how you interact with the website.

  • Cookies (^_ga) installed by Google Analytics. It is used to distinguish unique users by assigning a randomly generated number as a client identifier. It helps calculate visitor, session, and campaign data for the analytics reports.
  • Cookies (^_hjSession) set by Hotjar to identify a current session of the user on the website. It ensures that subsequent interactions within the same session are associated with the same session ID.

Other cookies

  • Cookies that may be set by third-party services used through our website.

Use of Data

The Think Pool uses the collected data for various purposes:

  • To provide, maintain, and manage the proper functioning and customization of our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To improve our monitoring and customer service
  • To process and respond to your messages
  • To receive and process your orders
  • To manage your subscriptions to our newsletters
  • To establish and ensure the follow-up of the commercial relationship that may result from your messages
  • To ensure accounting and management
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To send you commercial and advertising information based on your preferences
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
  • To detect attacks and legal recourse against fraud
  • To memorize your choices regarding the use of cookies
  • To process and respond to your requests to exercise rights
  • To respond to current or upcoming regulatory requirements

If you are from the European Economic Area (EEA), The Think Pool legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

The Think Pool may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it’s not overridden by your rights
  • To comply with the law

We process analytics and device/location data based on your consent under Article 6(1)(a) of the GDPR. You may withdraw your consent at any time by adjusting your cookie preferences on our website or disabling location services on your device.

Retention of Data

The Think Pool will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Think Pool will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside France and choose to provide information to us, please note that we transfer the data, including Personal Data, to France and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Think Pool will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, The Think Pool may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

The Think Pool may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of The Think Pool
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. The overall risk includes the following factors:

  • Failure to identify the information and related assets that must be protected;
  • Failure to protect information from unauthorized disclosure, modification, or corruption and systems being compromised
  • Failure to detect a breach or malicious attack on Group information or systems;
  • Failure to respond to a breach or malicious attack on Group information or systems;
  • Failure to recover from a breach or malicious attack on Group information or systems;
  • Failure to manage Information Security and Cyber risk with suppliers and 3rd parties.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. The Think Pool aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where The Think Pool relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

Newsletter

We use MailerLite to manage our email marketing subscriber list and to send emails to our subscribers. MailerLite is a third-party provider, which may process your data using industry-standard technologies to help us monitor and improve our newsletter.

MailerLite’s privacy policy is available at https://www.mailerlite.com/legal/privacy-policy

You can unsubscribe from our newsletter by clicking on the unsubscribe link provided at the end of each newsletter.

Booking

Simplymeet.me provides our appointment booking solution to allow users to self-book appointments with us. Simplymeet.me is a third-party provider, which may process your data using industry-standard technologies to help us monitor and improve our booking feature.

Simplymeet.me’s privacy policy is available at https://simplymeet.me/en/policy

Comment system

We utilize the Cusdis comment system, enabling users to comment on articles within the Blog section at their discretion. Cusdis, as a third-party provider, may process your data using industry-standard technologies to facilitate the monitoring and enhancement of the comments feature.

For further details, you can refer to Cusdis’s privacy policy, accessible at https://cusdis.com/privacy-policy.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

We may employ Google Analytics, Umami, and Hotjar to help us understand how our Service is used. These tools collect and process data such as pages visited, time spent on pages, and user interactions with the website.

Google Analytics with Google Signals

  • We use Google Analytics, a web analysis service provided by Google LLC, to better understand how users interact with our website. Google Analytics collects information such as your device type, browser, IP address (anonymized where required), and pages visited.
  • We have activated Google Signals, which enables cross-device tracking and allows Google to collect additional information such as interests, demographics, and location data, when users have agreed to ad personalization in their Google account. This helps us analyze user behavior across multiple devices and tailor our services accordingly.
  • The data collected is aggregated and anonymized. We do not receive personally identifiable information from Google. You can manage or deactivate this data collection via your Google Ad Settings: https://adssettings.google.com/authenticated
  • You can opt out of Google Analytics tracking by using the official Google Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout. For more details, see the privacy policy: https://policies.google.com/privacy.

Umami

  • Umami is a privacy-focused, open source analytics platform. It is designed to minimize data collection, typically does not use cookies, and avoids storing personally identifiable information. If your browser has ‘Do Not Track’ enabled, Umami will respect this setting and will not collect any usage data from your session. Learn more: https://umami.is/docs/privacy.

Hotjar

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: site@thethinkpool.com