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Privacy Policy

Last Modified: 06/11/2018

We respect your privacy and are committed to protecting it through our compliance with this Policy. This Policy describes the types of information we may collect from you or that you may provide when you visit the website www.thinQ.com (our “Website”) or when you use our application for your mobile device (our “Application”), and our practices for collecting, using, maintaining, protecting and disclosing that information. We refer to our Website and our Application cumulatively as our “Platform.”

 This Policy applies to any information that we collect on the Platform, including any information in any emails, posts, texts and other electronic messages between you and the Platform and any information about you transferred to the Platform from other websites. This Policy also applies to any related information that we collect about you offline but that will be processed by automated means using the Platform. This Policy does not apply to any other information that we collect by any means.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you can choose not to use our Platform. By accessing or using our Platform, you agree to this Policy. This Policy may change from time to time. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Platform, including information by which you may be personally identified, such as your name, postal address, email address, telephone number and photograph. In addition, if we sell any goods or services on our Platform, we may collect information required for the payment for goods or services, including credit card numbers, security codes and other financial information. All of this information is cumulatively referred to in this Policy as “Personal Information.”

The information we collect on or through our Platform may include information that you provide by registering to use our Platform, using our services, posting material, requesting further services or reporting a problem with our Platform. We may also collect call detail, call signaling, CallerID/Name and MMS/SSMS information. We will also retain records and copies of your correspondence (including email addresses), if you contact us.

 As you navigate through and interact with our Platform, we may automatically collect certain traffic data and usage information to help us manage our content and improve your use of the Platform. This may include information about your equipment, your IP address, and your browsing actions and patterns when you visit our Platform, including the referring and exit pages.

Legal Basis for Processing

We have the legal right to use your Personal Information in the ways described in this Privacy Policy based on your consent, or on the need to use the Personal Information to provide you with goods or services that you request, or for the legitimate purposes of furthering our existing relationship with you or preventing fraud. Accordingly, you have a contractual rather than a statutory obligation to provide such information. If you do not provide such information, you may be unable to use our Platform and we may be unable to provide any goods or services that you request.

 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, to present our Platform and its contents to you, to provide you with information, products or services that you request from us, and to fulfill any other purpose for which you provide the information. If you purchase products or services, we may transmit your Personal Information to payment processors. We may also use your Personal Information to notify you about changes to our Platform or any products or services we offer or provide through it and to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. We may also use the information that you provide in any other way that we describe when you provide the information and for any other purpose with your consent. We may use your Personal Information for any permitted marketing purposes described in this Policy.

We retain your Personal Information while you are using the Platform to improve your use of the Platform. Once you are no longer using our Platform, we will store your Personal Information for so long as we may need it to answer questions about the products or services that we provided, or to comply with the recordkeeping requirements of applicable law.


Disclosure of your information

We may disclose your Personal Information for any permitted marketing purposes described in this Policy. We may also disclose your Personal Information for any other purpose disclosed when the information is provided, and for any other purpose with your consent.

We may pseudonymize some of your Personal Information so that it can no longer be attributed to you without the use of other separately maintained information, or convert or combine some of your Personal Information into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user. We may disclose any such pseudonymized, de-identified or aggregated data without restriction.

We may disclose Personal Information to our subsidiaries and affiliates, if any, and to any contractors, service providers and other third parties who need to know such information to support our permitted uses of Personal Information. We may disclose such Personal Information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction, and any due diligence review with respect to any such proposed transaction.

We may also disclose your Personal Information to comply with any court order, law or legal process, including to meet national security and law enforcement requirements and to respond to any government or regulatory request or audit, and to enforce or apply our Acceptable Use Policy, including for billing and collection purposes, or if we believe disclosure is necessary or appropriate to protect the rights, property or safety of our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.


Use of Personal Information for Marketing Purposes


We may use your Personal Information to provide you with promotional information about our own products and services. We may use your Personal Information for our tracking purposes. Currently, we do not provide any of your Personal Information to third parties to use for advertising, marketing or tracking purposes.


Tracking

Tracking involves the use of cookies, web beacons, or other embedded code or tracking technologies to collect, analyze and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions. Tracking information can be used to enable companies to make interest-based (behavioral) advertising available to users on multiple sites that they visit. We do not currently collect Personal Information about your online activities over time and across third-party sites for tracking purposes. We do not currently allow third parties to collect Personal Information on the Platform that could be used by them to analyze and store information about your online activities over time and across third-party sites for tracking purposes.


Accessing and Correcting Your Information

You can review and change certain portions of your Personal Information by logging into the Platform and visiting your account profile page. You may also send us an email at legal@thinQ.com to request the right to view any of your Personal Information that we store and use, and to correct, amend or delete any such Personal Information that is inaccurate. Unless you have provided EU Personal Information, which is covered by the Users Outside of the United States section of this Policy, we will evaluate requests on a case-by-case basis.

We may not be able to delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users.


Children

Our Platform is not intended for children under 13 years of age, and no one under age 13 may provide any information to this Platform. We do not knowingly collect personal information from children under the age of 13. If you are under age 13, do not use or provide any information on this Platform, make any purchases through this Platform, use any of the interactive or public comment features of this Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under age of 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under age 13, please contact us at legal@thinQ.com.   


Data Security


We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information that you provide to us is stored on our servers behind firewalls, and certain Personal Information will be encrypted using secure socket layer (SSL) technology.

The safety and security of your information also depends on you. When we have given you (or when you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping that password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform such as message boards. The information you share in public areas may be viewed by any user of the Platform.

Unfortunately, the transmission of information over the Internet is not completely secure. Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to our Platform. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Platform.


Users Outside the United States

Our Platform is hosted in the United States and our services are provided from the United States. It is possible that certain information will be stored on servers in multiple other countries on the “cloud” or other similar distributed hosting platforms. If you are a resident of any country other than the United States, please note that by providing your Personal Information to us, you are consenting to the transfer of your Personal Information to the United States and other jurisdictions as indicated above, and to our use and disclosure of your Personal Information in accordance with this Policy.

If you are a resident of the European Union, please note that the EU has determined that the laws of the United States do not provide adequate protection for your Personal Information. Accordingly, we are transferring your Personal Information from the EU to the United States under the terms of our certification with the U.S. Department of Commerce under the Privacy Shield. You can find more information on your rights under the Privacy Shield at https://www.privacyshield.gov/welcomeon. Under the Privacy Shield, we have committed to treat all Personal Information received from the EU (“EU Personal Information”) in the manner required by the Privacy Shield Principles, and we follow internal procedures for verifying that our commitments under this Policy have been implemented. Our compliance with this obligation can be investigated and enforced by the FTC.

If you are a resident of the European Union, you will have the following additional rights with respect to EU Personal Information:

  • If we intend to disclose your EU Personal Information to any third party that will have the right to process your EU Personal Information, we will enter into a contract with that third party that provides that your EU Personal Information may be processed only for limited and specified purposes consistent with the consent that you have provided to us, and that the third party must provide the same level of protection for your EU Personal Information that we are obligated to provide under this Policy while it is processing your EU Personal Information. In addition, we will notify you if that third party will have the right to determine the purposes for which it will process your EU Personal Information and the means it will use to process your EU Personal Information (rather than just providing requested assistance to us in support of our permitted uses of your EU Personal Information). 
  • If your EU Personal Information is being processed by automated means, you have the right to obtain a copy of your provided EU Personal Information, together with certain additional Personal Information that we have generated as a result of your use of our services, in a structured and commonly used and machine-readable format, and to transfer such Personal Information to another service provider. Upon your request, we will transfer that Personal Information directly to another service provider if it is feasible for us to do so. 
  • If we are processing your EU Personal Information based on your consent, you may withdraw that consent at any time.   
  • You may restrict our use of your EU Personal Information, by sending us an email stating your request to legal@thinQ.com, if you have contested the accuracy of that information, or if the processing is unlawful or you need the information to establish, exercise or defend a legal claim. We will then store your EU Personal Information and process it only with your consent, or to establish, exercise or defend a legal claim or to protect the rights of others. The restriction with respect to information claimed to be inaccurate would end if we verify the accuracy of that contested information.  
  • We do not collect any EU Personal Information that constitutes sensitive information related to your racial or ethnic identity, political opinions, religious or philosophical beliefs, trade union membership, health (including genetic and biometric data), sex life, or sexual orientation (“EU Sensitive Information”). In the event that we inadvertently obtain EU Sensitive Information about you, we will not otherwise use or disclose any of your EU Sensitive Information without your express consent, subject to certain limited exceptions. Should we wish to make any such use or disclosure, we will notify you by email and request that you authorize such use or disclosure by responding to the email with your express consent.  
  • We do not create profiles to analyze or predict your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.   
  • Upon our receipt of your request by email at legal@thinQ.com and our verification of your identity, we will advise you whether or not we are processing EU Personal Information concerning you and, if so, will provide you with a copy of your EU Personal Information being processed and certain information about the nature and purposes of the processing. If your EU Personal Information is used for automated decision-making, we will provide you with information on the logic being used and the types of decisions being made. You may correct any such EU Personal Information that is inaccurate or incomplete. 
  • Upon your request, we will erase any of your EU Personal Information that is no longer needed for the purpose for which it was collected, or that is being used for direct marketing purposes, or if our use is based on your consent and you withdraw that consent.   
  • Our Platform is not intended to be used by children in the European Union between the ages of 13 and 16 only with parental consent. Notwithstanding this policy, if we are informed or otherwise learn that we have collected or received Personal Information from a child in the European Union under the age of 16 without verification of parental consent, we will delete that information.     
  • If we are using your EU Personal Information on the basis of your consent, and we change our Policy to permit any use or disclosure of your EU Personal Information that is materially different than the uses for which it was originally collected or subsequently authorized by you, we will obtain your consent before we make such further uses of your EU Personal Information. 

If you have a complaint about our compliance with this Policy or the Privacy Shield, you may contact us at legal@thinQ.com If you are an EU resident and you are not satisfied with our response, you will have a prompt, no-cost way of asserting your claim by contacting legal@thinQ.com. If you are an EU resident and you still are not satisfied, you may have the right, under certain conditions, to invoke binding arbitration. Alternatively, you will have the right to lodge a complaint with the Supervisory authority in your country of residence in the EU. You can find more information on your enforcement rights at https://www.privacyshield.gov/welcomeon.



Changes to our Privacy Policy

We post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Platform home page.


The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting our Platform and this Policy to check for any changes.


Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at:

legal@thinQ.com

919-890-0000

If you have concerns about our Privacy Policy or the way in which we are processing your Personal Information, you can contact our Data Controller at: legal@thinQ.com.

If you have a complaint that has not been satisfied by contacting us at one of the addresses above, you have the right to complain to the independent public authority created by your country of residence with the responsibility for monitoring the laws governing the processing of Personal Information.