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Privacy Policy

1. What does this Privacy Notice cover?

This Privacy Notice provides information regarding the processing of your personal data when in connection with our offerings, such as using services and/or purchasing products from ThinkOnward LLC part of Shell group companies (“ThinkOnward” or “we”) whether as a customer, platform subscriber, and/or a visitor to the ThinkOnward website ('Website' or 'ThinkOnward Website').

This Privacy Notice complements and supplements the privacy notices available on the Shell group of companies website at https://www.shell.com/privacy/b2c-notice.html.

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.

2. Special Notice - if you are under 16 years old. Processing children’s personal data

If you are under 16 years old (or a different age to reflect local legal requirements in your location) please do not send us your personal data, for example your name, address and email address. If you wish to contact ThinkOnward in a way which requires you to submit your personal data (such as for education or innovation events) please get your parent or guardian to do so on your behalf.

3. What personal data do we process about you?

Collection of information. We collect information, including personal data about you, as a ThinkOnward platform subscriber and/or visitor to a ThinkOnward Website or ThinkOnward-administered social media page (‘ThinkOnward Social Media Page’). This information may include, without limitation:

Information that you provide to us. When creating a ThinkOnward account profile, we will ask for your name, e-mail address, your contact preferences and information necessary for answering any security questions. When setting up your community profile on the ThinkOnward platform, you will have the option to upload a profile picture and additional information about your professional background and interests. You will also have the option to modify the parts of your profile that will be publicly visible. If you decide to take part to any of the ThinkOnward offerings, we may ask you to provide further personal data necessary for offering-related activities and/or authentication such as date of birth, nationality, primary address and bank account details.

Information that we obtain through your use of the ThinkOnward platform. We will also collect information about how and when you use the ThinkOnward platform. Such information may include electronic device information, IP addresses, log information, browser type and preferences, location information, online identifiers to enable ‘cookies’ and similar technologies.

Information gathered through social media pages. When you communicate with us through a ThinkOnward Social Media Page (for example, when you comment on, share or react to a post, upload media, send a personal message or subscribe to a ThinkOnward Social Media Page), we may receive personal data about you such as your user name, profile picture, hometown, email address and gender. We will use any personal data received from social media in accordance with this Privacy Notice.

4. Why do we process your personal data?

The personal data covered by this Privacy Notice are only processed:

Where the 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.

5. What are the consequences of not providing your personal data?

Where you choose not to provide us with information set out above for the purposes of using the ThinkOnward platform or any of its offerings, the only consequence is that it will affect your ability to fully navigate through the ThinkOnward platform and/or to fully participate in the ThinkOnward offerings.

6. Who is responsible for any personal data collected?

ThinkOnward LLC will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.

7. For what purposes do we process your personal data?

We process your personal data for the purposes of:

8. Communication and marketing - your choices

If you have consented to receive communications from ThinkOnward, you may receive offers that are tailored towards your preferences based on the information gathered about you from the various sources described above in order to provide you with better opportunities and increasingly tailored offers.

We may send you service updates and notifications without your advance consent only where such updates and/or notifications are necessary for the proper functioning of ThinkOnward or any of the ThinkOnward offerings that you take part in.

You may receive pertinent offers and communications by different channels, and you may update your subscription preferences via your personal profile settings anytime or use the unsubscribe functionality for the different digital channels.

9. Your rights in relation to your personal data

We aim to keep our information as accurate as possible. You can request:

To make any of these requests please contact us at support@thinkonward.com in this respect.

10. Who can you contact if you have a query, concern or complaint about your personal data?

If you have any issues, queries or complaints regarding the processing of your personal data, please contact us at support@thinkonward.com for further information or for submitting such requests.

Since we are part of the Shell Group, you may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands - Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, at privacy-office-SI@shell.com.

If you are unsatisfied with the handling of your personal data by ThinkOnward, then you have the right to lodge a complaint to your local data protection authority (if there is one) or the Dutch Data Protection Authority whose address is Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.

11. 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.

12. Security of your personal data

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 the ThinkOnward platform and we regularly test, assess and evaluate the effectiveness of our security measures.

13. Sharing your information

Certain content related to ThinkOnward services are publicly accessible. For example, Achievement Badges, Leaderboards and Discussion forums related to Challenges are publicly accessible. Any information that you voluntarily choose to include in your public profile page or in a forum posting will also be available to the public.

Otherwise, your personal data are exclusively processed for the purposes referred to in Section 7 above and will only be shared on a strict need to know basis with:

Any person to whom ThinkOnward proposes to transfer any of its rights and/or duties.

14. Transfers of your personal data to other countries

Where your personal data have 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.

15. Interacting with ThinkOnward through social media

If you choose to interact with ThinkOnward through social media on a ThinkOnward administered social media page (‘ThinkOnward Social Media Page’) such as Facebook, Instagram, Twitter or LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in ThinkOnward) will be visible to all visitors of your personal webpage depending on your privacy settings on the relevant social media platform, and will also be visible to ThinkOnward. You can delete any information that you share on these sites at any time through your relevant social media platform’s account. ThinkOnward does not track your activity across the different social media sites that you use. If you send a message to ThinkOnward via any messenger service on a social media platform, these messages are held for no longer than one month after receipt. Please contact ThinkOnward if you wish to make a request that you are unable to action yourself and which relates to a ThinkOnward Social Media Page - see the section below.

Additionally and to the extent ThinkOnward is jointly responsible with a social media platform of a ThinkOnward Social Media Page, ThinkOnward will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on ThinkOnward Social Media Pages. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.

16. How long do we hold your personal data for?

We will only hold your personal data for a defined period. Personal data processed by ThinkOnward in line with this Privacy Notice will be deleted or rendered anonymous (such that it will no longer be possible to identify you);

In relation to any financial transactions, your personal data will be held for 10 years from the transaction.

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 data and there is no longer a legitimate business purpose to retain it.

17. Changes to this Privacy Notice

This Privacy Notice may be changed over time. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in November 2024.