Privacy Policy

Last updated: March 17, 2026
This Privacy Policy describes Our policies and procedures on the collection, use and
disclosure of Your information when You use the Service and tells You about Your privacy
rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You
agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following
conditions. The following definitions shall have the same meaning regardless of whether
they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of
our Service.
Affiliate means an entity that controls, is controlled by, or is under common control
with a party, where “control” means ownership of 50% or more of the shares, equity
interest or other securities entitled to vote for election of directors or other
managing authority.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy
Policy) refers to Thrive-Renew Limited, 80 St Georges Road, Bolton BL1 2DD.
For the purposes of the GDPR, the Company is the Data Controller.
Cookies are small files that are placed on Your computer, mobile device or any
other device by a website, containing the details of Your browsing history on that
website among its many uses.
Country refers to: United Kingdom
Data Controller, for the purposes of the GDPR (General Data Protection
Regulation), refers to the Company as the legal person which alone or jointly with
others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cell
phone or a digital tablet.
GDPR refers to EU General Data Protection Regulation.
Personal Data (or “Personal Information”) is any information that relates to an
identified or identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You
such as a name, an identification number, location data, online identifier or to one or
more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity.
We use “Personal Data” and “Personal Information” interchangeably unless a law
uses a specific term.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on
behalf of the Company. It refers to third-party companies or individuals employed
by the Company to facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist the Company in
analyzing how the Service is used. For the purposes of the GDPR, Service Providers
are considered Data Processors.
Usage Data refers to 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).
Website refers to Thrive-Renew, accessible from http://thrive-renew.co.uk.
You means the individual accessing or using the Service, or the company, or other
legal entity on behalf of which such individual is accessing or using the Service, as
applicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you are the
individual using the Service.

Collecting and Using Your Personal Data

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. Personally identifiable information
may include, but is not limited to:

By visiting this page on our website: http://www.thrive-renew.co.uk/contact

Email address
First name and last name
Phone number

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’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.

When You access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile device You use,
Your mobile device’s unique ID, the IP address of Your mobile device, Your mobile
operating system, the type of mobile Internet browser You use, unique device identifiers
and other diagnostic data.
We may also collect information that Your browser sends whenever You visit Our Service or
when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and
store certain information. Tracking technologies We use include beacons, tags, and scripts
to collect and track information and to improve and analyze Our Service. The technologies
We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can
instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.
However, if You do not accept Cookies, You may not be able to use some parts of our
Service.
Web Beacons. Certain sections of our Service and our emails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel tags, and
single-pixel gifs) that permit the Company, for example, to count users who have visited
those pages or opened an email and for other related website statistics (for example,
recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your
personal computer or mobile device when You go offline, while Session Cookies are deleted
as soon as You close Your web browser.

Where required by law, we use non-essential cookies (such as analytics, advertising, and
remarketing cookies) only with Your consent. You can withdraw or change Your consent at
any time using Our cookie preferences tool (if available) or through Your browser/device
settings. Withdrawing consent does not affect the lawfulness of processing based on
consent before its withdrawal.
We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through
the Website and to enable You to use some of its features. They help to authenticate
users and prevent fraudulent use of user accounts. Without these Cookies, the
services that You have asked for cannot be provided, and We only use these Cookies
to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the
Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow Us to remember choices You make when You use the
Website, such as remembering your login details or language preference. The
purpose of these Cookies is to provide You with a more personal experience and to
avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please
visit our Cookies Policy or the Cookies section of Our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our
Service.
To manage Your Account: to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of the
Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking
of the purchase contract for the products, items or services You have purchased or
of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent
forms of electronic communication, such as a mobile application’s push notifications
regarding updates or informative communications related to the functionalities,
products or contracted services, including the security updates, when necessary or
reasonable for their implementation.
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 inquired about unless You have opted not to receive such
information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your Personal Data to evaluate or conduct a
merger, divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of Our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us
about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data
analysis, identifying usage trends, determining the effectiveness of our promotional
campaigns and to evaluate and improve our Service, products, services, marketing
and your experience.

We may share Your Personal Data in the following situations:

With Service Providers: We may share Your Personal Data with Service Providers to
monitor and analyze the use of our Service, for payment processing, to contact You.
For business transfers: We may share or transfer Your Personal Data in connection
with, or during negotiations of, any merger, sale of Company assets, financing, or
acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your Personal Data with Our affiliates, in which case we
will require those affiliates to honor this Privacy Policy. Affiliates include Our parent
company and any other subsidiaries, joint venture partners or other companies that We
control or that are under common control with Us.
With business partners: We may share Your Personal Data with Our business partners
to offer You certain products, services or promotions.
With other users: If Our Service offers public areas, when You share Personal Data or
otherwise interact in the public areas with other users, such information may be viewed
by all users and may be publicly distributed outside.
With Your consent: We may disclose Your Personal Data for any other purpose with
Your consent.

Retention of Your Personal Data

The Company 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.
Where possible, We apply shorter retention periods and/or reduce identifiability by
deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods
below are maximum periods (“up to”) and We may delete or anonymize data sooner when
it is no longer needed for the relevant purpose. We apply different retention periods to
different categories of Personal Data based on the purpose of processing and legal
obligations:
Account Information

User Accounts: retained for the duration of your account relationship plus up to 24 months after
account closure to handle any post-termination issues or resolvedisputes.

Customer Support Data

Support tickets and correspondence: up to 24 months from the date of ticket closure
to resolve follow-up inquiries, track service quality, and defend against potential
legal claims
Chat transcripts: up to 24 months for quality assurance and staff training purposes.

Usage Data
Website analytics data (cookies, IP addresses, device identifiers): up to 24 months
from the date of collection, which allows us to analyze trends while respecting
privacy principles.
Server logs (IP addresses, access times): up to 24 months for security monitoring
and troubleshooting purposes.
Financial and Transaction Data

Payment information: credit/debit card details are not stored on Our servers; they
are processed by our Payment Service Providers. We retain transaction records
(invoice details, purchase history, amounts) for up to 10 years from the date of
transaction to comply with tax laws and financial regulations.
Billing and invoice records: up to 10 years to meet accounting and tax compliance
requirements.

Usage Data is retained in accordance with the retention periods described above, and may
be retained longer only where necessary for security, fraud prevention, or legal compliance.
We may retain Personal Data beyond the periods stated above for different reasons:

Legal obligation: We are required by law to retain specific data (e.g., financial records
for tax authorities).
Legal claims: Data is necessary to establish, exercise, or defend legal claims.
Your explicit request: You ask Us to retain specific information.
Technical limitations: Data exists in backup systems that are scheduled for routine
deletion.

You may request information about how long We will retain Your Personal Data by
contacting Us.
When retention periods expire, We securely delete or anonymize Personal Data according
to the following procedures:

Deletion: Personal Data is removed from Our systems and no longer actively processed.
Backup retention: Residual copies may remain in encrypted backups for a limited
period consistent with our backup retention schedule and are not restored except
where necessary for security, disaster recovery, or legal compliance.
Anonymization: In some cases, We convert Personal Data into anonymous statistical
data that cannot be linked back to You. This anonymized data may be retained
indefinitely for research and analytics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices
and in any other places where the parties involved in the processing are located. It means
that this information 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 from those from Your jurisdiction.
Where required by applicable law, We will ensure that international transfers of Your
Personal Data are subject to appropriate safeguards and supplementary measures where
appropriate. The Company 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.

Delete Your Personal Data

you have the right to delete or request that We assist in deleting the Personal Data that We
have collected about You.
Our Service may give You the ability to delete certain information about You from within
the Service.
You may update, amend, or delete Your information at any time by signing in to Your
Account, if you have one, and visiting the account settings section that allows you to manage
Your personal information. You may also contact Us to request access to, correct, or delete
any Personal Data that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal
obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be
transferred. We will provide notice before Your Personal Data is transferred and becomes
subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company 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).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is
necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal 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 reasonable means to protect Your Personal Data, We cannot
guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party
vendors collect, store, use, process and transfer information about Your activity on Our
Service in accordance with their Privacy Policies.

Payments

We may provide paid products and/or services within the Service. In that case, we may use
third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly
to Our third-party payment processors whose use of Your personal information is governed
by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS
as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure
handling of payment information.

Stripe
Their Privacy Policy can be viewed at https://stripe.com/us/privacy

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more
specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual obligations
thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal
obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital
interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the
public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the
legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal Data is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.

International Transfer of Personal Data

We may transfer, store, and process Personal Data in countries other than the country in
which You are located, including countries outside the European Economic Area (“EEA”)
and the United Kingdom (“UK”), where data protection laws may differ.
Where we transfer Personal Data outside the EEA/UK to a country that has not been
recognized as providing an adequate level of protection, We rely on appropriate safeguards,
such as:

The European Commission’s Standard Contractual Clauses (“SCCs”) and/or the UK
International Data Transfer Agreement (“IDTA”) or the UK Addendum to the SCCs (as
applicable)
Supplementary measures where appropriate, such as encryption in transit and at rest,
access controls, data minimisation, and vendor security reviews.

We transfer Personal Data internationally only as needed to provide the Service and to
work with our Service Providers (for example, hosting, analytics, email delivery). You may
contact Us using the details in the “Contact Us” section of Our Privacy Policy to request
further information about the safeguards We use for international transfers, including
copies of relevant contractual protections (redacted where necessary).

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to
guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or 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. This
also enables You to receive a copy of the Personal Data We hold about You.
Request restriction of processing. You have the right to ask Us to restrict processing
of Your Personal Data in certain circumstances (for example, while We verify accuracy
or consider an objection).
Request correction of the Personal Data that We hold about You. You have the right
to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on
a legitimate interest as the legal basis for Our processing and there is something about
Your particular situation, which makes You want to object to our processing of Your
Personal Data on this ground. You also have the right to object where We are processing
Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or
remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a thirdparty You have chosen, Your Personal Data in a structured, commonly used, machinereadable format. Please note that this right only applies to automated information
which You initially provided consent for Us to use or where We used the information to
perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your
Personal Data. If You withdraw Your consent, We may not be able to provide You with
access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by
contacting Us. Please note that we may ask You to verify Your identity before responding to
such requests. If You make a request, We will try our best to respond to You as soon as
possible. We generally respond within one month, and may extend by two further months
where necessary, in accordance with applicable law.
You have the right to complain to a Data Protection Authority about Our collection and use
of Your Personal Data. For more information, if You are in the European Economic Area
(EEA), please contact Your local data protection authority in the EEA.

Children’s Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect
personally identifiable information from anyone under the age of 16. 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 anyone under
the age of 16 without verification of parental consent, We take steps to remove that
information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your
country requires consent from a parent, We may require Your parent’s consent before We
collect and use that information.

Links to Other Websites

Our Service may contain links to other websites 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.

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 “Last updated” 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, You can contact us:

By visiting this page on our website: http://www.thrive-renew.co.uk/contact