I. Name and address of the responsible authority
The responsible authority in terms of the basic data protection regulation and other national data protection laws of the member states as well as other data protection regulations is:
Think 360 Solutions Private Limited
BG 22, Third Floor, Central Plaza,
Sector 105, SAS Nagar (Mohali),
Managing Director: Prince Pal Singh
Phone: +91 99151 06790 | e-mail
II. Data protection officer
You can reach the data protection officer by e-mail
III. General information on data processing
1/ Scope of the processing of personal data
In principle, we process personal data of our users only tot he extent necessary to provide a functional website including our contents and services. The regular processing of personal data of our users occurs only with consent of the user. An exception applies to cases in which prior consent cannot be obtained for reasons of fact and the processing of the data is permitted by legal regulations.
2/ Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 Para. 1 lit. a EU Data Protection Regulation (GDPR) serves as the legal basis. In the processing of personal data necessary for the performance of a contract of which the data subject is a party, Art. 6 (1) (b) GDPR serves as the legal basis.This also applies to processing operations required to carry out pre-contractual measures.
Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 (1) (c) GDPR serves as the legal basis. In the event that vital interests of the data subject or any other natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis. If processing is necessary to safeguard the legitimate interests of our company or a third party, and if interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) (f) GDPR serves as the legal basis for the processing.
3/ Deletion of Data and Duration of Storge
The personal data of the affected person will be deleted or blocked as soon as the purpose of the storage ceases to exist. In addition, storage may also occur if this storage is intended by the European or national legislator in EU regulations, laws or other guidelines to which the responsible authority is subject. Blocking or deletion of the data also occurs upon the expiration of a storage period prescribed by the aforementioned standards, unless there is a need for further storage of the data for conclusion or fulfilment of a contract.
4/ Cooperation with contract processors and third parties
Insofar as we transfer data to other persons and companies (contract processors or third parties) within the scope of our processing or otherwise grant them access to the data, this shall only take place on the basis of legal permission, you have consented, a legal obligation this provides or on the basis of our legitimate interest (e.g. when using agents, web hosts, etc.). If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 DGPR.
5/ Company profiles in social media
We operate company profiles within social networks and platforms in order to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply. Unless otherwise stated in our private policy, we process the data of users who communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
IV. Provision of the website and creation of log files
Every time our website is visited, information is automatically sent to the server of our website by the browser used on your end device. This information is temporarily stored in a so-called log file. The following information is recorded without your intervention and stored until it is automatically deleted:
The mentioned data will be processed by us for the following purposes:
The data processed by cookies is required for the purposes mentioned to protect our legitimate interests and those of third parties in accordance with Art. 6 Para. 1 S. 1 lit. f GDPR. Most browsers automatically accept cookies. However, you can configure your browser in such a way that no cookies are stored on your terminal devices or that a message always appears any time a new cookie is about to be created. However, the complete disablement of cookies may result in you not being able to use all the functions of the website.
On our website, you have the possibility to subscribe to a free newsletter. When registering for the newsletter, the following data from the input mask is transmitted to us:
In addition, according to its own information, Mailchimp may use this data in a pseudonymous form, i.e. without attribution to a user, for the optimization or improvement of its own services, e.g. for the technical optimization of the sending and presentation of newsletters or for statistical purposes to determine from which countries the recipients come. However, Mailchimp does not use the data of our newsletter recipients to approach them or to pass them on to third parties.
Legal basis for the processing of data after registration for the newsletter by the user is Art. 6 Para. 1 lit. a GDPR if the user has given his consent. The collection of the user's e-mail address serves to deliver the newsletter. The collection of other personal data during the registration process serves to prevent misuse of the services or the e-mail address used. The data is deleted as soon as it is no longer required for the purpose of its collection. The user's e-mail address is therefore stored as long as the subscription to the newsletter is active.
Users may at any time revoke their consent to receiving the newsletter and unsubscribe from the latter. The revocation can be made by clicking on the corresponding link in every newsletter. This also enables revocation of the consent to the storage of personal data collected during the registration process. Alternatively, you can send your revocation request at any time by sending an e-mail to email@example.com.
VII. E-mail contact
It is possible to contact us via the provided e-mail address firstname.lastname@example.org. In this case, the personal data of the user transmitted with the e-mail will be stored. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.
The legal basis for the processing of the data transmitted in the course of sending an e-mail is Art. 6 Para. 1 lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 Para. 1 lit. b GDPR.
The processing of the personal data from the e-mail serves us solely to process the contact. This also includes the necessary legitimate interest in the processing of the data. The data will be deleted as soon as they are no longer required for the purpose of their collection. For personal data sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be concluded from the circumstances that the matter in question has been finally clarified.
The user has the possibility to revoke his or her consent to the processing of personal data at any time. If the user contacts us by e-mail (email@example.com), he/she can object to the storage of his/her personal data at any time. In such a case the conversation cannot be continued. All personal data stored in the course of the contact will be deleted in this case.
VIII. Tracking tools
The tracking measures listed below and used by us are carried out on the basis of Art. 6 Para. 1 sentence 1 lit. f GDPR. The tracking tool is used in order to ensure that our website is user-oriented and constantly optimized. We also use tracking tools to statistically record and evaluate the use of our website in order to optimise our services for you. These interests are to be considered legitimate in terms of the aforementioned regulation. The respective data processing purposes and data categories can be derived from the corresponding tracking tools.
1/ Google Analytics
For the purpose of designing our website to meet your needs and continuously optimizing it, we use Google Analytics, a web analysis service by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google"). In this context, pseudonymized user profiles are created and cookies (see section V) are used. The information generated by the cookie about your use of this website such as
are transmitted to a Google server in the USA and stored there. The information is used in order to evaluate the use of the website in order to compile reports on the website activities and to provide further services associated with the use of the website and the Internet for the purposes of market research and demand-oriented design of these Internet pages. This information may also be transferred to third parties where required by law or as far as third parties process this data on our behalf. Under no circumstances will your IP address be combined with other data of Google. The IP addresses are rendered anonymous, so that an assignment is not possible (IP masking). You may refuse the generation of cookies by selecting the appropriate settings on your browser; however, please note that in case of refusing such cookies you may not be able to make full use of all website functions. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a Browser Add-on. As an alternative to the Browser Add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting the data by clicking on this link. An opt-out cookie will be set to prevent the collection of your data during your visit to the website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will have to reinstall opt-out cookie. Further information on data protection in connection with Google Analytics can be found in the Google Analytics Help.
IX. Rights of the data subject
If personal data are processed by you, you are the data subject within the meaning of the GDPR and entitled to the following rights in relation to the person responsible:
1/ Right of access by the data subject
You can request confirmation from the person responsible as to whether personal data concerning you are being processed by us. If personal data are processed, you may request the following information from the data controller:
You are entitled to the right to access information as to whether your personal data is being transferred to a third country or to an international organization. In this context and pursuant to Art. 46 GDPR, you may request to be informed of the appropriate safeguards in connection with the transfer.
2/ Right to rectification
You have the right to obtain from the data controller the rectification and/or integration of your personal data if it is incorrect or incomplete. The data controller shall make the rectification without delay.
3/ Right to restriction of processing
Under the following conditions, you shall request that the processing of personal data concerning you be restricted:
Where the processing of personal data relating to you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the purpose of pursuing, exercising, or defending legal claims or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or of a Member State. If you have obtained a restriction of processing in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4/ Right to erasure
a) Duty to delete
You shall have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
The right of cancellation does not exist in so far as the processing is necessary
5/ Right to information
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data have been disclosed unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
6/ Right to object
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on point (e) or (f) Art. 6 Para. 1 of GPDR, including profiling based on those provisions. The controller no longer processes the personal data concerning you, unless he can demonstrate compelling legitimate grounds for the processing that are worthy of protection and which outweigh your interests, rights, and freedoms or for the establishment, exercise or defense of legal claims.
Where personal data relating to you are processed for direct marketing, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
7/ Right to revoke the declaration of consent under the data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of your consent does not affect the legality of the processing carried out on the basis of your consent until you revoke it.
8/ Right to lodge a complaint with the supervisory authority
Without prejudice to any other administrative or judicial remedy, you are entitled to the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
The supervisory authority with which the complaint has been lodged shall inform the complainant of the progress and the outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.
Status: May 2018