Privacy Policy
Last updated: January 2024
We have worked hard developing our app, and work even harder to build a trust relationship with our users. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) on which this Privacy Policy is linked (collectively, “Sites”), such as www.thrivedx.com, and any transactions, interactions, or other engagements you might have with us.
Definitions. For purposes of this Agreement, the following terms have the following meanings:
“Affiliates” shall mean an entity controlled by, under common control with, or controlling such party, where control is denoted by having fifty percent (50%) or more of the voting power (or equivalent) of the applicable entity.
"Updates" means any updates, bug fixes, patches, or other error corrections to the Sites ThriveDX makes available.
2. This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.
3. Please carefully read this Privacy Policy, which is part of our End User License Agreement (“EULA”), before using our Sites. If you do not agree with our EULA or this Privacy Policy, you must refrain from using our Sites. By accessing or using our Sites, you agree to our use of your information consistent with our EULA and this Privacy Policy.
4. This Privacy Policy does not apply to our collection, use, or disclosure of Personal Information (as defined below) in performing services on behalf of our educational institution partners and other clients (collectively, “Clients”).
This Privacy Policy also does not apply to our collection, use, or disclosure of Personal Information related to job applicants, employees, or their dependents and beneficiaries, or the collection, use, or disclosure of Personal Information by third parties.
5. This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. If we make any material changes to this Privacy Policy, the revised policy will be posted on the Sites with the date of revision. Changes will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide notice, such as by a posting on the Sites or an email to your last known email address, before using your Personal Information in the new way.
6. Conflict Between this Policy and Laws and Regulations
When federal, state, or local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. The specific requirements of this Privacy Policy apply unless disallowed by applicable laws or regulations. Please be aware that the Sites are subject to the laws of the country in which they operate, or are registered, and your Personal Information may be processed in the United States and other jurisdictions.
INFORMATION WE COLLECT
7. Personal Information
You agree that ThriveDX may collect and use the content, technical data, and related information, that is gathered periodically to facilitate the provision of software updates, product support and improving our website and content. ThriveDX may also collect data related or generated from your use of the Sites for statistical analysis and usage patterns analysis, to make the sites more intuitive. ThriveDX may use or share this information, as long as it is in a form that does not personally identify You, to improve its products or to provide Platforms or technologies that better suit Your preference.
We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
a. Unique Identifiers such as name, social media identifiers;
b. Contact Information such as mailing address, billing address, email address, phone number;
c. Characteristics of Protected Classifications such as age, gender, race, ethnicity, national origin, military or veteran status;
d. Commercial Information such as inquiries about or purchases of our products and services, use of our products and services (e.g., course completion status, program completion status), participation in promotional events, participation in surveys;
e. Internet and Network Information such as IP address, device ID, browsing/search history, browser type, device type and settings;
f. Audio/Visual Information such as images, call recordings, video or audio testimonials;
g. Educational Information such as educational institutions attended, dates of attendance, degrees earned, grades, instructor reviews/feedback, transcripts;
h. Professional Information such as past and current employers, job title, salary earned, professional association membership, professional credentials and certifications;
Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., consumer response models, propensity to purchase models).
The specific Personal Information we collect about you may vary based on how you use the Sites and your relationship with us.
8. Usage Data and Sites Activity
We automatically collect information in connection with the actions you take on the Sites (“Usage Data”). For example, each time you visit our website, we automatically collect the type of web browser you use, the type of device you use, the type of your operating system, the name of your internet service provider, the pages you view on our Sites, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites. If this information is reasonably capable of being associated with you, we treat it as Personal Information under the category "Internet and Network Information”. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.
9. Communication Recordings
We may record calls and retain the content of written/electronic communications between you and us (such as emails, or web-forms). By communicating with us, you explicitly consent to our recording and retention of communications.
HOW WE COLLECT INFORMATION
10. Voluntary Disclosure
We may ask you to provide us with Personal Information when you communicate with us, use the Sites, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or we may not be able to fulfill your requested interaction.
11. Social Media
If you engage with us via social media, use your social media credentials to access the Sites, or interact with social media buttons or widgets embedded in our Sites, we may collect Personal Information available on your social media profile and Usage Data. For information about privacy controls available through your social media provider, please visit their website.
12. Cookies and Other Automated Tools
We use cookies (a small text file placed on your computer) and other automated tools such as tracking pixels to improve the experience of the Sites, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can change your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. However, certain features of the Sites may not work properly if you delete or disable cookies.
We use the following types of cookies:
a. Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Sites and are typically deleted once you close your browser.
b. Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Sites. For example, persistent cookies may allow us to remember your preferences and provide you with personalized content.
c. Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
d. Analytics Cookies: Analytics cookies help us understand how our Sites work and who is visiting our Sites. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Policy.
e. Functional Cookies: Functional cookies allow our Sites to work as intended such as by allowing us to recognize and honor your login and take other actions for authentication and security.
We also employ web beacons, local shared objects (sometimes referred to as “flash cookies”), and other technologies that enable us to track certain aspects of a user’s visit to the Sites. For example, web beacons generally consist of an object embedded on a webpage or in an email that is invisible to the user but allows us to understand whether a user has viewed a particular webpage or email and to deliver certain services. Web bacons typically help us collect Usage Data such as the time and date of a page or email view and a description of the page or email viewed.
If you arrive at the Sites by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching that led you to our Sites, may be transmitted to us and we may use it. You should review the privacy policy of any website from which you reached the Sites to determine what information was collected by that website and for what purposes you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.
13. Interest-Based Advertising
We work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you our ads or other of our content that we believe would be relevant to you. Advertisers may also show you third-party ads or content when you engage with our Sites. Advertisers may collect and use information about your use of the Sites as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information, including across time, devices, and websites. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Sites, on third-party websites, or on social media properties. Using a tool created by the Network Advertising Initiated, you can opt out of several Advertisers’ activities. For more information, please visit the Network Advertising Initiative or the Digital Advertising Alliance (“DAA”) Consumer Choice Page. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Please note that opt-outs only apply to interest-based advertising and not all advertising networks participate. You may still receive other types of online advertising.
14. Information from Advertisements
If you arrive at the Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date, and time).
Certain third parties, including but not limited to those identified below, collect Personal Information and/or Usage Data from users of our Sites using automatic information collection tools such as APIs, cookies, and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their respective privacy policies.
Third Party
Privacy Policy
Hotjar
15. HOW WE USE AND SHARE INFORMATION
We use Personal Information for internal purposes, including:
a. Providing the Sites ;
b. Account creation, fulfillment, servicing and customer support: such as to create client and user accounts, provide products or services, keep clients and users informed about the status of products and services, respond to questions and address client and user concerns, and deliver updates, upgrades, and product improvement information;
c. Marketing and market research: such as to send communications and offers and place advertisements for our university partners’ products and services, including offers based on interests and organizational characteristics, perform analytics for market research, trend analysis, and financial analysis;
d. Surveys, promotional events, contests: such as to administer surveys, polls, sweepstakes, contests, and other promotional events and contests;
e. Other company communications: such as to provide You with information that may be of interest such as company newsletters, announcements, reminders, and service bulletins;
f. Sites use and analytics: such as to provide You with access to and use of our Sites, and to analyze use of our Sites including through use of third-party web analytics services which may utilize automated technologies to collect data (such as email and IP addresses);
g. Eligibility and pricing: such as to determine if individuals and organizations are eligible for certain products, services, or offers and the pricing related to such products, services, or offers;
h. Product research: such as to conduct research and analysis for maintaining, protecting, and developing our products and services, increase and maintain the effectiveness of our products and services, and prevent misuse;
i. Compliance: such as to comply with applicable legal requirements, government requests, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights or the rights of others; and
j. Information security and fraud prevention: such as operating information security and anti-fraud programs that might e targeting our Sites.
16. Testimonials
If you provide a testimonial, we may post it publicly on the Sites or in other advertising material. By providing a testimonial, you give us permission to use it and your likeness in any manner and for any purpose, including in marketing and advertising communications, without any compensation or notice to you.
17. Third-Party Selling
We do not sell your Personal Information to third-party companies or share it with third-party companies for their direct marketing purposes.
18. OTHER PRIVACY AND SECURITY PROVISIONS
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use, both in transit and at rest. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites, you do so at your own risk.
19. Other Websites
Please be aware that third-party websites accessible through the Sites or recommended through our services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties before providing information.
20. COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our sole discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands, and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
21. Other Transfers
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
22. How Long We Retain Your Data
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is a legitimate ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations.
26. Children’s Privacy
The Sites are not intended for the use of children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.
27. California “Do Not Track” Disclosure
“Do Not Track” is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites do not respond to “Do Not Track” signals.
28. Data Processing Addendum
All further data-related aspects concerning the processing, storage, and security of Personal Information shall be governed by the Data Processing Addendum available under https://thrivedx.com/for-enterprise/dpa (the "DPA").
29. What are your data protection rights?
ThriveDX would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
a. The right to access - You have the right to request a copy of your personal data. We may charge you a small fee for this service.
b. The right to rectification - You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we to complete information you believe is incomplete.
c. The right to erasure - You have the right to request that we erase your personal data, under certain conditions.
d. The right to restrict processing - You have the right to request that we restrict the processing of your personal data, under certain conditions.
e. The right to object to processing - You have the right to object to our processing of your personal data, under certain conditions.
f. The right to data portability - You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
30. How to contact the appropriate authority
Should you wish to report a complaint or if you feel that Our Company has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner's Office in your home country.
31. CONTACT US
If you have any questions about our Sites, services, or this Privacy Policy, please contact our Data Privacy Department by email: DPO@thrivedx.com.
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