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Information for individuals connected with our business customers (B2B), suppliers, business partners, stakeholders and/or investors.
ThinkOnward is part of the Shell group of companies. As such, this Privacy Policy aligns with the standards and practices adopted across Shell entities and reflects our commitment to safeguarding personal data in accordance with applicable laws and Shell’s global privacy principles. This notice sets out what personal information we collect, for what purposes and your rights in this respect.
What does this Privacy Notice cover?
This Privacy Notice provides information regarding the personal information which is processed by ThinkOnward in relation to (i) individuals who work for, or on behalf of, or who are shareholders of our business customers (‘Business Customers’), (ii) suppliers or vendors (‘Suppliers’), (iii) business partners, including within non Shell-operated joint ventures, as well as investors and shareholders (‘Business Partners’).
For individuals who require access to a ThinkOnward site on behalf of a Business Customer, Supplier or Business Partner you will be asked to provide additional information to enable you to be identified for health, safety and security purposes and to manage the relationship between ThinkOnward and the relevant Business Customer, Supplier or Business Partner. For further information please refer to the Privacy Notice - Employee, Contractor and Dependents’ at https://thinkonward.com/employee-privacy-notice.
For visitors of ThinkOnward websites or users of ThinkOnward applications, please refer to the Privacy Notice -
For individuals who apply to work for ThinkOnward, or who attend a recruitment event or undertake an assessment please refer to the Privacy Notice – https://thinkonward.com/recruitment-privacy-notice.
Bespoke notices and supplementary privacy statements may contain further information about how ThinkOnward is processing your personal data. In such cases, additional privacy notices will be communicated to you separately.
This Privacy Notice explains what personal data are processed about you; why we are processing your personal data and for which purposes; for how long we hold your personal data for; how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.
Special Notice - if you are under 16 years old. Processing children’s personal data
ThinkOnward does not knowingly collect, use, process, or disclose the personal information of children under 16 years old without parental consent.
What categories of personal information do we process about you?
We process personal information from and in relation to individuals who are, or who work for or on behalf of or who are shareholders in our Business Customers, Suppliers, Business Partners in the following categories:
Private contact information (such as name, postal or e-mail address, and phone number) only if necessary; or
Business contact and other information (such as job title, department, name of organization and your dealings with ThinkOnward on behalf of yourself or the relevant Business Customer, Supplier, Business Partner).
Screening
In order to comply with legal and regulatory obligations, to protect the Shell Group’s assets and employees/contractors and specifically to ensure that the Shell Group, which includes ThinkOnward, can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our Business Customers, Suppliers and Business Partners. This screening takes place against publicly available or government issued sanctions lists and media sources.
The screening does not involve profiling or automated decision making in relation to the counterparties or potential counter-parties.
Who is responsible for any personal information collected?
ThinkOnward LLC will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.
For what purposes do we process your personal information?
We process personal information covered by this Privacy Notice for the following purposes:
Business execution - including providing, researching, developing and improving products or services; concluding and executing agreements with Business Customers, Suppliers and Business Partners; recording and settling services, products and materials to and from ThinkOnward managing relationships and marketing such as maintaining and promoting contact with existing and prospective customers, account management, customer service, and development, execution and analysis of market surveys and marketing strategies;
Organization and management of the business - including financial management, asset management, mergers, demergers, acquisitions and divestitures, implementation of controls, management reporting, analysis, internal audits and investigations;
Health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of ThinkOnward and its staff, authentication of individual status and access rights; or
Legal and/or regulatory compliance - including compliance with legal or regulatory requirements.
or for a secondary purpose where it is closely related, such as:
storing, deleting or anonymizing personal information;
fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defense of claims; or
statistical, historical or scientific research.
Communication and marketing
You may receive offers on behalf of the relevant Business Customer, Supplier or Business Partner. On all occasions you will be given the opportunity to use the unsubscribe functionality through the different digital channels we use to interact with you.
Why do we process your personal information?
The personal information covered by this Privacy Notice is only processed:
in order to take steps at the request of an individual prior to entering into a contract;
where it is necessary to comply with a legal or regulatory obligation to which ThinkOnward is subject to;
where it is necessary for the purposes of the legitimate interests pursued by ThinkOnward except where such interests are overridden by the interests or fundamental rights and freedoms of the individual/s; or
(only if legally required) with the explicit consent of the individual.
In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.
Security of your personal information
We have implemented technology and policies with the objective of protecting your privacy from unauthorized access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification process for access to ThinkOnward services and we regularly test, assess and evaluate the effectiveness of our security measures.
Who will we share or disclose your personal information with?
The personal information covered by this Privacy Notice is exclusively processed for the purposes referred to above and will only be shared or disclosed on a strict need to know basis with the following categories of recipients:
Authorized third party agents, service providers, external auditors and/or subcontractors of ThinkOnward;
A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant ThinkOnward company/companies is subject to or as permitted by applicable local law; or
As necessary or appropriate to enforce our terms and conditions, and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
Interacting with ThinkOnward through social media
If you interact with ThinkOnward through social media, your personal information may be visible to ThinkOnward and other visitors depending on your privacy settings on the social media platform. You can change your settings or delete any information through the platform. ThinkOnward reserves the right to access and aggregate information provided by you through its ThinkOnward Social Media Page for statistics and analytics. For more information on how your personal information is processed on those social media platforms, including any targeted advertising that you may receive, please refer to the social media platform's privacy settings and disclosures. Please contact ThinkOnward at support@thinkonward.com if you have specific questions related to your personal information on a ThinkOnward Social Media Page.
Transfers of your personal data to other countries
Where your personal data has been transferred to companies within the Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Shell group and for Shell companies in the European Union, European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of Shell Binding Corporate Rules at https://www.shell.com/privacy.html or by contacting privacy-office-SI@shell.com.
What are the consequences of not providing your personal information?
Personal information gathered by ThinkOnward for these processes either directly or indirectly are required in order to:
Fulfil legal requirements and/or which is required for entering into a contract with a counter-party and continuing to contract with that counter-party; or
Maintain contact with Business Customers, Suppliers and Business Partners.
Failure to provide us with the information required will negatively affect our ability to communicate with you, or our ability to enter into a contract with a counter-party or continue to contract with a counter-party.
How long do we hold your personal information for?
With some exceptions which are explained in supplementary privacy statements, any personal information that is required for the purposes of conclusion and execution of agreements with Business Customers, Suppliers and Business Partners or for considering bids or tenders, will be held during the duration of the contractual relationship and up to 15 years after. For agreements which have a term of more than five years and for the purposes set out above, these agreements will be held for 35 years with effect from the commencement of the agreement.
In all other cases for the purposes set out above, including personal information gathered as part of any unsuccessful bids to ThinkOnwrad or which relates to the screening against publicly available or government issued sanctions lists and media sources, such personal information is held for no longer than 15 years after it was first gathered.
In all cases, information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal information and there is no longer a legitimate business purpose to retain it.
In addition to the retention periods outlined above, all copies of customer Projects or Challenges data are deleted at the conclusion of the project and/or challenge. However, for business continuity and compliance purposes, a backup archive of this data is retained for a period of one year following project closure. After this one-year retention period, the archived data is permanently deleted from all systems, in accordance with ThinkOnward data lifecycle and retention standards.
Your rights in relation to your personal information
We aim to keep our information as accurate as possible. Any US resident, regardless of state of residency, can request the following information:
access to your personal information, including access to specific piece of personal information where local law applies;
correction or deletion of the personal information (but only where they are no longer required for a legitimate business purpose);
restriction and objection to the processing of your personal information under certain circumstances and where local law applies;
to limit the collection, disclosure or use of your personal information, including sensitive personal information, if collected for unrelated purposes where local law applies;
opt-out from the collection and use and/or to limit the disclosure or use of your personal information, including sensitive personal information if collected and where local law applies;
opt-out from the sale or sharing of your personal information, including for cross-context behavioral advertising or for targeted advertising, if sold or shared and where local law applies;
to no longer receive marketing communications on behalf of the relevant Business Customer, Supplier or Business Partner; and/or
to receive personal information that you have provided to ThinkOnward in a structured, digital form to be transmitted to another party, if this is technically feasible.
How to exercise your rights
To exercise any of your rights listed above, please email us at contact support@thinkonward.com.
Who can you contact if you have a query, concern or complaint about your personal information?
If you have any issues, queries or complaints regarding the processing of your personal information, please contact support@thinkonward.com.
You may also contact the Shell Group Chief Privacy Officer at Shell International B.V. The Hague, The Netherlands - Trade Register, No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague.
Without prejudice to any rights you may have in line with local law you have the right to lodge a complaint with the Dutch Data Protection Authority whose address is Hoge Nieuwstraat 8, 2514 EL The Hague, Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.
Cookies and similar technologies
ThinkOnward uses cookies and similar technologies that collect and store information when you visit a ThinkOnward Website. This is to enable ThinkOnward to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). You can control and manage your cookies preferences by adjusting your browser settings or using the ThinkOnward cookies preference tool on ThinkOnward Websites – for more information, please refer to the ThinkOnward Cookie Policy.
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice periodically and without notice, for example, when a new category of personal information is collected and used and upon changes/enactment of data protection and privacy laws. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in September 2025.