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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.   

  1. 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.   

  1. 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. In order to complete your profile on the ThinkOnward platform, you will have the option to upload a profile picture and additional information about your professional background and interests. 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.   

  1. Why do we process your personal data? 

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

  • with your explicit consent; 

  • where it is necessary to carry out and/or conclude transactions, requests, and/or contractual obligations with you (such as payment information); 

  • where it is necessary for the purposes of the legitimate interests pursued by ThinkOnward, except where such interests are overridden by your interests or fundamental rights and freedoms;  

  • where it is necessary for the legitimate interests, such as for marketing and promotional purposes, for providing offers tailored to your preferences, for detecting and investigating fraud, and/or responding to security threats; or 

  • where it is necessary for ThinkOnward to comply with a legal or regulatory obligation.   

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.   

  1. 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.   

  1. 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.   

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

We process your personal data for the purposes of:   

  • performing activities related to your participation in any of the ThinkOnward offerings, such as bounties, challenges, project assignments or accelerator incubation programs; 

  • managing relationships and marketing such as maintaining and promoting contact with you; 

  • account management including account verification (that is, ensuring that only you or someone you have authorized can access your account and information); 

  • user support and development of our offerings; 

  • performance of and analysis of market surveys and marketing strategies; 

  • promotions and contests offered to ThinkOnward subscribers, including offering you digital rewards to recognize you as a valued member of the ThinkOnward community; 

  • health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of ThinkOnward and staff, authentication of individual status and access rights; 

  • legal and/or regulatory compliance - including compliance with legal or regulatory requirements and performing necessary screening to meet such requirements; 

  • or for a secondary purpose where it is closely related, such as: 

  • storing, deleting or anonymizing your personal data; 

  • audits, investigations, dispute resolution or insurance purposes, litigation or defense of claims; or 

  • statistical, historical or scientific research.   

  1. 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.   

  1. Your rights in relation to your personal data 

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

  • access to your personal data; 

  • correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction); 

  • that you no longer receive marketing communications; 

  • that the processing of your personal data is restricted; 

  • combining of your personal data from different sources to create a personal profile no longer takes place; and/or 

  • that you receive personal data that you have provided to ThinkOnward, in a structured, digital form to be transmitted to another party, if this is technically feasible.   

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

  1. 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.   

  1. 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.

  1. 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.   

  1. Who will we share your personal data with? 

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:   

  • Other companies within the Shell group of companies, including to those which may be located outside of your location; 

  • Authorized agents, licensees, service providers, external auditors and/or subcontractors of ThinkOnward; 

  • A competent public authority, government, regulatory, supervisory, investigative or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which ThinkOnward is subject to or as permitted by applicable law; or 

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

  1. 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.    

  1. 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.   

  1. 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);   

  • every 8 years unless you remain a customer during this period; 

  • without undue delay upon you requesting that your ThinkOnward account profile is deleted or to discontinue your participation to the ThinkOnward platform; or 

  • after 3 years for all subscribed services from our last interaction with you (that is where you have not used our services for 3 years).   

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. 

  1. 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 2023.