Ver. 5.0/27042018
The Thinxtream Privacy Policy covers how Thinxtream collects, uses, discloses, transfers, and stores your information. Your privacy is important to Thinxtream and to ensure that your personal information is secure, Thinxtream communicates its privacy and security guidelines to Thinxtream employees and strictly enforces privacy safeguards within the company. Please familiarize yourself with our privacy practices. If you have any questions, or concerns about this Privacy Policy or data processing, please contact our Data Protection Officer at: legal@thinxtream.com
1. Collection & Usage of Personal Information
- Personal information is data that can be used to uniquely identify or contact a single person. You may be asked to provide your personal information anytime you are in contact with Thinxtream or Thinxtream affiliates or Thinxtream authorized business partners (which includes agents, contractors, vendors, licensors, resellers, system integrators, etc.).
- When you purchase Thinxtream products/services, register for utilizing Thinxtream products/services, contact Thinxtream to report product/service issues, apply for credit, or participate in an online survey, Thinxtream, its affiliates or authorized business partners may collect various information, including your name, mailing address, phone number, email address, contact preferences, unique device identifier and credit card information
- Thinxtream, its affiliates and its business partners may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve Thinxtream’s products, services, content, and advertising
- The personal information Thinxtream collects allows it to keep you posted on the latest products/services announcements, products/services updates and upcoming events. It also helps Thinxtream to improve its content, and advertising. You can opt out by sending a notice to our return email address at anytime. Please note that opting out may impact your ability to use some Thinxtream products/services
- Thinxtream may use your personal information to send important notices, such as communications about purchases, changes to the terms, conditions, and policies, your compliance/non-compliance with the terms and conditions of usage of Thinxtream products/services, etc. Because this information is important to your interaction with Thinxtream, you may not opt out of receiving these communications
- Thinxtream may also use personal information for internal purposes such as auditing, data analysis, and research to improve Thinxtream’s products, services, and customer communications
- If you enter into a sweepstake, contest, or similar promotion Thinxtream may use the information you provide to administer those programs
- You have the right to access any personal information that you have provided to Thinxtream or that Thinxtream maintains about you. In addition, you have the right to withdraw any consent previously granted or to request correction, amendment, restriction or deletion of your personal information and to request an explanation about the processing. In certain cases, your request may be denied on the basis of a legitimate exception such as where making information available would reveal personal information about another person or where Thinxtream is legally prevented from disclosing such information
- Exercising these rights may result in reduced functionality or complete inability to use Thinxtream products/services
2. Collection & Usage of Non-Personal Information
- Non-personal information is data in a form that does not permit direct association with any specific individual. Thinxtream may collect, use, transfer, and disclose non-personal information for any purpose
- Thinxtream may collect information that includes but is not limited to details about the device being used, operating system, application software, peripheral devices, unique device identifier, location, details on products/services usage and the geographic location/time zone where a Thinxtream product/service is used so that Thinxtream can better understand customer behaviour and improve its products, services, and advertising. Where applicable, Thinxtream may collect and review your content to ensure your compliance with the terms and conditions of usage of its products/services, etc.
- Thinxtream also may collect information regarding customer activities on the Thinxtream website and its products/services. This information is aggregated and used to provide more useful information to its customers and to understand which parts of the Thinxtream website, products, and services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy
- Thinxtream may use analytics tools, such as Google Analytics, to collect non-personal information. Information on how Google Analytics collects and processes information can be obtained from the website “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners). Google may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services. You may opt out of Google Analytics by visiting the Google Analytics opt out page
- If Thinxtream combines non-personal information with personal information the combined information will be treated as personal information, as long as it remains combined and will be subject to the policy mentioned in section 1 above
3. Cookies & Other Technologies
- Thinxtream’s website, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies enable Thinxtream to understand user behaviour, identify which parts of the website the users have visited, and facilitate and measure the effectiveness of advertisements and web searches
- Thinxtream treats information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, Thinxtream also treats these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, Thinxtream treats the combined information as personal information for the purposes of this Privacy Policy
- Thinxtream and its partners may also use cookies and other technologies to remember personal information when you use the website, online services, and products/services. The objective in such instances is to make your experience with Thinxtream more convenient and personal. Knowing your contact information, product serial numbers, and information about your device enables Thinxtream to register your products and provide you with better customer support
- When you visit the website, Thinxtream may gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit pages, operating system, date/time stamp, and clickstream data. Thinxtream uses this information to understand and analyze trends, to administer the site, to learn about user behaviour on the site, and to gather demographic information about its user base as a whole. Thinxtream may use this information in its marketing and advertising
- In some of its email messages, Thinxtream may use a “click-through URL” linked to content on the Thinxtream website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on the website. This click-through data is tracked to enable the determination of interest in particular topics and measure the effectiveness of the customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages
- Pixel tags enable Thinxtream to send email messages in a format customers can read, and they indicate whether mail has been opened. Thinxtream may use this information to reduce or eliminate messages sent to customers
- You are always free to decline cookies if your browser has this functionality. If you do so, you may not be able to use certain features on the website which are dependent on the information which the cookies collect and you may be required to re-entre certain information more frequently during a session. If you do not want Thinxtream to collect the information about your website visit through the use of cookies, please set your browser to reject these cookies
4. Disclosure to Third Parties
- At times Thinxtream may make certain personal information available to partners that work with Thinxtream to provide products/services, or that help Thinxtream market to customers. For example, when you purchase and activate your Thinxtream products/services, you authorize Thinxtream and its service providers to exchange the information you provide during the activation process to carry out services. If you are approved for services, your account will be governed by Thinxtream and its service providers’ privacy policies. Personal information will only be used by Thinxtream to provide or improve its products, services and advertising; unless otherwise specified (for e.g., adenabled free usage) it will not be shared with third parties for their marketing purposes
- Thinxtream shares personal information with partners who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in Thinxtream products/services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Thinxtream operates
- It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Thinxtream to disclose your personal information. Thinxtream may also disclose information about you if Thinxtream determines that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate
- Thinxtream may also disclose relevant information if Thinxtream determines that disclosure is reasonably necessary to enforce its terms and conditions or protect its operations or users. Additionally, in the event of a reorganization, merger, or sale, Thinxtream may transfer any and all personal information Thinxtream collects to the relevant thirdparty
5. Protection of Personal Information
- Thinxtream takes precautions including administrative, technical, and physical measures to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction
- Thinxtream online services used in connection with certain Thinxtream products/services use Secure Sockets Layer (SSL) encryption as specified in the respective documentation
- When you use some Thinxtream products, services, or applications or post on a Thinxtream forum, chat room, or social networking service, the personal information you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to submit in these instances
6. Integrity and Retention of Personal Information
- Thinxtream will continue to expand your ability and make it easy for you to keep your personal information accurate, complete, and up to date
- Thinxtream will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or prescribed by law
- For certain products, Thinxtream requires access to user personal information such as photos and documents to provide the specific functionality stated in the product documentation. Such personal information may be (a) cached in the user’s computing system and periodically updated with the option for the user to delete such information, or (b) stored on our computing systems for the duration required and automatically deleted thereafter, or (c) dealt with as stated in the product documentation
7. Access to Personal Information
- For certain products, Thinxtream requests user personal data such as email address information to complete product registration and authenticate you as a valid user of the product. In the future, as additional information is required for renewals or future registrations, Thinxtream will make good faith efforts to provide you with access so that you can request for Thinxtream to correct the data if it is inaccurate or delete the data if Thinxtream is not required to retain it by law or for legitimate business purposes. Thinxtream may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law
- For certain products, Thinxtream requires access to user personal information such as user log-in credentials to thirdparty sites/services to provide the specific functionality stated in the product documentation. Such personal information is dealt with as stated in the product documentation and you have the option of not providing or deleting such personal information
- Exercising these rights may result in reduced functionality or complete inability to use Thinxtream products
8. Your rights on Personal Information
- If you are an individual, this Section sets out your legal rights in respect of any of your personal information that Thinxtream holds and/or processes. If you wish to exercise any of your legal rights you should put your request in writing to Thinxtream’s Data Processing Officer providing enough information to identify you. Thinxtream shall respond to your request within one (1) month from the date of receipt of your request
- You have the right to request details about personal information that Thinxtream may hold and/or process about you, including whether or not Thinxtream is holding and/or processing your personal information; the extent of the personal information Thinxtream holds; and the extent of the processing
- You have the right to have any inaccurate personal information Thinxtream holds about you be corrected and/or updated. If any of the personal information that you have provided changes, or if you become aware of any inaccuracies in such personal information, please let Thinxtream know in writing giving enough information to make the change or correction
- You have the right in certain circumstances to request Thinxtream to delete all personal information Thinxtream holds about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, (for e.g., where Thinxtream needs to retain the personal information for legal compliance purposes)
- You have the right in certain circumstances to request Thinxtream to restrict the processing of your personal information, (for e.g., where the personal information is inaccurate or where you have objected to the processing)
- You have the right in certain circumstances to request a copy of the personal information Thinxtream holds about you and to have it provided in a structured format suitable for you to be able to transfer it to a different service provider (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, (for e.g., where the processing is carried out by automated means). If you request the right to data portability and it is not available to you Thinxtream will let you know
- You have the right in certain circumstances to object to the processing of your personal information. If so, Thinxtream shall stop processing your personal information unless Thinxtream can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then Thinxtream will let you know
- You have the right in certain circumstances not to be subject to a decision based solely on automated processing, (for e.g., where a computer algorithm (rather than a person) makes decisions which affect your contractual rights)
- You have the right to object to Thinxtream processing your data even if it is based on Thinxtream’s legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics
- Exercising these rights may result in reduced functionality or complete inability to use Thinxtream products/services
9. Third-Party Sites and Services
- Thinxtream websites, products, applications, and services may contain links to third-party websites, products, and services. Thinxtream products and services may reference other sites offered by third parties. Information collected by third parties, which may include additional information or requirements, is governed by their respective privacy practices. Thinxtream encourages you to learn about the privacy practices of those third parties
10. Changes to Privacy Policy
- Thinxtream’s Privacy Policy may change from time to time. Thinxtream will post any Privacy Policy changes on this page, clearly indicating the version number. Access to previous versions of this Privacy Policy can be obtained by emailing the Data Protection Officer at legal@thinxtream.com
