Privacy policy

Last updated 17th November 2025

1. Introduction

Purpose of this Privacy Policy

This privacy policy aims to give you information about how ThisThat Ltd (“ThisThat”,"we,""us,"or "our") collects and uses your personal data through your use of this Website, our survey interface at web.thisthatapp.com (“Survey Platform") and/or use our services (together the “Digital Platforms”) and tells you about your privacy rights and how the lawprotects you.

Controller

ThisThat Ltd (company number: SC576515), a company incorporated in Scotland with its registered address at C/O CMS Cameron Mckenna Nabarro Olswang LLP 4th Floor, Saltire Court, 20 Castle Terrace, Edinburgh, Midlothian, United Kingdom, EH12EN is the controller and is responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: ThisThatLtd

DPO: Maximilian Osborne

Email address: privacy@thisthat.tt

Postal address: ThisThat Ltd, C/O CMS Cameron Mckenna Nabarro Olswang LLP 4th Floor, Saltire Court, 20 Castle Terrace, Edinburgh, Midlothian, United Kingdom, EH1 2EN

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

The Digital Platforms 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 policy of every website you visit.

2. The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

· Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.

· Contact Data includes billing address, email address, telephone numbers and social media account login data.

· Financial Data includes bank account and payment card details.

· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Digital Platforms.

· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

· Usage Data includes information about how you interact with and use our Digital Platforms and Services.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

· Special Category Personal Data includes personal data that reveals racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, data concerning health, sex life or sexual orientation of an individual. We will only process any Special Category Personal Data with your explicit consent.

We also collect, use and share Aggregated Data such as statistical, demographic data or survey responses which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Digital Platforms to help improve the Digital Platform and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data when:

· you register an account via our Digital Platforms;

· express an interest in obtaining information about us or our products and Services;

· when you participate in the activities on the Services; or

· by corresponding with us by post, phone, email or otherwise.

Automated technologies or interactions. As you interact with our Digital Platforms, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy (https://www.thisthat.tt/legal/cookie-policy) for further details.

Third parties or publicly available sources.We will receive personal data about you from various third parties and public sources as set out below:

· Technical or Usage Data from Google Cloud, Analytics, Firebase, Smartlook, Mixpanel, TrackJS and Loom.

· Technical, Usage or Contact Data from Hubspot, Allega, Apollo and Gong.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· Where we need to perform the contract we are about to enter into or have entered into with you.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

· Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

As our customer, we may send you marketing messages about our products or Services. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at privacy@thisthat.tt, following the opt-out links on any marketing message sent to you orby contacting us at any time.

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

‍

Purpose/Use	Type of data	Legal basis
When you register to use our Services via our Digital Platforms or share your social media account information with us.	(a) Identity (b) Contact (c) Profile (d) Technical (e) Usage	Necessary for our legitimate interests
Uploading content to your account for use of the Digital Platforms in the performance of the Services.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Usage	Necessary for our legitimate interests.
To administer and protect our business and the Digital Platforms and our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Usage	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant Digital Platforms content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Digital Platforms, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Digital Platforms updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) or consent, having obtained your prior consent to receiving direct marketing communications.
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)
To monitor trends so we can improve the Services.	(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage	Necessary for our legitimate interests (to develop our Services, define types of customers for our products and services, to develop our business and to inform our marketing strategy).
To enable you to partake in a competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Special Category	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
In relation to your use of our Survey Platform, we use advertising and analytics tools provided by Social Media Platforms. We use server-side tracking technologies that do not rely on cookies stored on your device. Instead, we send limited event data directly from our secure servers to the Social Media Platforms via encrypted API connections. This helps us measure performance in a privacy-preserving way and reduces our reliance on browser identifiers.	(a) Technical (b) Usage	Necessary for our legitimate interests (advertising measurement, optimisation and reporting).

Direct marketing

We may send direct marketing communications to you via email or telephone from time to time where permitted to do so and you have not otherwise opted out of receiving such communications from us.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

6. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

7. Cookies

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 Digital Platforms may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.thisthat.tt/legal/cookie-policy

8. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

· Third parties for the purpose of providing the Services to you.

· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. Marketing and Analytics Tools

This section 9 applies only when you use our Survey Platform

We use advertising and analytics tools provided by Social Media Platforms.

These tools help us measure the effectiveness of our advertising, understand how users interact with our website, and improve the relevance of our marketing.

We use server-to-server integrations or APIs (rather than browser-based cookies or pixels) to send limited information about interactions on our website or app to these platforms.

Each Social Media Platform acts as a controller (or joint controller with us) of the data we share with it through its advertising tools.

This means that both we and the relevant platform determine our own purposes and means of processing that data.

Each Social Media Platform has its own privacy policy explaining how it processes personal data it receives. You can view these here:

TikTok
Meta
LinkedIn
Google

You have the right to object at any time to the processing of your data as described in this Section 9. Please see Section 13 for details on how to do this.

10. International transfers

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that our arrangements have a legal basis or, if necessary, an appropriate safeguard is in place to protect your personal data during and after the transfer.

11. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

12. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have a right to:

Request access to your personal data (commonly known as a"data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

· If you want us to establish the data's accuracy.

· Where our use of the data is unlawful, but you do not want us to erase it.

· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 consent at anytime where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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 you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. Glossary

Consent means that you have given us permission (your consent) to process your personal data for one or more specific purposes.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Website means our website at https://www.thisthat.tt/ where the Services can be accessed.

Services means the services provided by ThisThat that can be accessed via our Digital Platforms .

Social MediaPlatforms means the following third-party platforms: TikTok, Meta (Facebook and Instagram), LinkedIn, and Google.

We keep our Privacy Policy under regular review. Any changes we make to this privacy statement in the future will be posted to the Website. Any such changes will ensure that your rights are fully safeguarded. In any event, we encourage you to check the updated statement published on this Website from time to time.

‍