Last updated on February 24, 2020
1. Types of Information Collected
To better provide you with our services, we collect two types of information about our users: Personally Identifiable Information and Nonpersonally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our Site.
Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on this Site, such as creating an account, ordering a product or service, submitting content, and/or posting content in discussion forums or other public areas, filling out a survey, or sending us feedback, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us with Personal Information, such as your first and last name, mailing address (including zip code), email address, employer, job title and department, telephone and facsimile numbers, and other personal identifying information. When ordering products or services on the Site, you may be asked to provide a credit card number. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data regarding a particular activity, you cannot engage in that activity.
Nonpersonally Identifiable Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Web site’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.
2. Collection Methods and Use of Information
We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you: (a) register for our services and register your email address with us; (b) send email messages, submit forms or transmit other information by telephone or letter; or (c) submit your credit card or other payment information when ordering and purchasing products and services on our Site. We may also collect information from you at other points on our Site that state that such information is being collected.
In addition, we may also collect, or our third-party ad server and/or content server may collect, certain Nonpersonally Identifiable Information. This information is ultimately stored in the form of store categories, and, sometimes, specific URLs. We use your IP address to diagnose problems with our servers and software, to administer our Site, and to gather demographic information. Our third-party ad servers will also provide us with summary, but not individual, reports that tell us how many ads were presented and clicked upon at out Site.
Reasons we can collect and use your Personal Information: The laws in certain jurisdictions require that we notify you of the lawful basis for collecting your Personal Information. If such laws apply, we rely on the following as the lawful basis on which we collect and use your Personal Information:
- Consent: We rely on your implied or explicit consent for the collection, processing, storage, transfer, and disclosure of your contact information and posts.
- To fulfill our contractual obligations: To fulfill our contractual obligations to you, either in providing the service functionality or processing payments and fulfilling and providing the associated purchases and services, we must collect, process, share, and store your Payment Information, Usage Information, and Analytic Information.
- Furtherance of legitimate interests: We may collect, process, store, transfer, or disclose your Usage Information, Analytic Information, and Purchase Information to further those legitimate interests of ours which are not overridden by your interests or fundamental rights and freedoms as set forth in the applicable laws. These legitimate interests include, but are not limited to, (i) providing you with the service(s) and Product(s), (ii) protecting our users, staff, and property from fraud and other harm, and (iii) collecting information on how you use the Site and services to optimize their functionality.
- Legal compliance: We may collect, process, store, transfer, or disclose your contact information, usage information, analytic information, and purchase information to comply with our legal obligations.
3. Release of Information
We do not sell, trade, or rent your Personally Identifiable Information to others. We provide some of our services through contractual arrangements with affiliates, services providers, partners, and other third-parties. We and our service partners use your Personally Identifiable Information to operate our Site(s) and to deliver their services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this Site and provide order information to third-parties that help us provide customer service.
We encourage our service partners to adopt and post privacy policies. However, using your Personally Identifiable Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.
Occasionally we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
We may also provide Nonpersonally Identifiable Information about our customers’ sales, traffic patterns, and related site information to third-party advertisers, but these statistics do not include any Personally Identifiable Information.
4. Updating and Correcting Information
We believe you should have the ability to access and edit the Personally Identifiable Information that you have provided to us. You may change any of your Personally Identifiable Information in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this Site. You may also access and correct your Personal Information and privacy preferences by writing us at:
ThinkThru, Inc. 3102 West End Ave. Ste. 413, Nashville, TN 37203
Please include your name, address, and/or email address when you contact us.
We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this Site. In addition, it may be impossible to completely delete your information without some residual information because of backups.
5. User Choices on Collection and Use of Information
We may, from time to time, send you email regarding our products and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may interest you. Only ThinkThru (or agents working on behalf of ThinkThru and under confidentiality agreements) will send you these direct mailings and only if you indicated that you do not object to these offers. If you do not want to receive such mailings, simply tell us when you give us your Personal Information. Or, at any time, you can easily edit your account information to no longer receive such offers and mailings.
You also have choices regarding cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our Site may not work properly in your case.
6. Security of Information
At our Site you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our users is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Access by you to your Personally Identifiable Information is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you not divulge your password to anyone. In addition, your Personally Identifiable Information resides on a secure server that only selected ThinkThru personnel and contractors have access to via password. We encrypt your Personally Identifiable Information, which prevents unauthorized parties from viewing it when it is transmitted to us.
Personal information that you provide that is not Personally Identifiable Information also resides on a secure server and is only accessible via password. Since this information is not accessible from outside ThinkThru, you will not be asked to select a password to view or modify such information.
To most efficiently serve you, credit card transactions and order fulfillment are handled by established third-party banking, processing agents, and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet taht are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third-party.
7. Sharing with Third-Parties
When you use our Site we will store cookies on your computer to facilitate and customize your use of our Site. A cookie is a small data text file that a web site stores on your computer’s hard drive (if your web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers and where you are located. The cookies make your use of the Site easier, make the Site run more smoothly, and help us to maintain a secure Site. You are always free to decline our cookies if your browser permits, but some parts of our Site may not work properly.
There are a number of different types of cookies our Site uses:
- Functionality—Our Company uses these cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
- Advertising—Our Company uses these cookies to collect information about your visit to our Site, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third-parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another web site, you may be shown advertising based on your browsing patterns on our web site.
How to manage cookies
You can set your browser not to accept cookies. However, sometimes of our Site features may not function as a result.
We also employ third-party tracking utility software technology called clear gifs (a.k.a. Web Beacons/Web Bugs) and tracking pixels. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. In short, clear gifs enable two websites to share information with one another. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and allows for the collection of information regarding the use of the web page that contains the tracking pixel.
“Do Not Track” Signals: Because there is not yet a consensus on how companies should respond to web browser-based or other “do not track” mechanisms, we do not respond to web browser-based “do not track” signals.
8. Privacy Policies of Third-Party Sites
9. Miscellaneous Privacy Issues
You must be at least 18 years old to have our permission to use this Site. Our policy is that we do not knowingly collect, use, or disclose Personally Identifiable Information about visitors that are under 18 years of age.
Attn: Privacy Compliance Officer
3102 West End Ave., Suite 413
Nashville, TN 37211
You may also contact us by email at firstname.lastname@example.org
CALIFORNIA RESIDENTS. Under California Civil Code § 1798.83, California residents who have an established business relationship with us may choose to opt-out of our sharing your Personal Information with third-parties for direct marketing purposes. If you are a California resident and (1) you wish to opt-out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third-parties for the direct marketing purposes, please send that request by email to email@example.com.
In addition, ThinkThru does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “do not track” settings and/or signals.