For individuals who provide information online to our affiliates in the European Economic Area ("EEA"), our affiliates may share such information with ThinkBe in the U.S. ThinkBe complies with the U.S. - E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. ThinkBe has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. For additional information regarding the Safe Harbor Program and to view ThinkBe’s certification, see the U.S. Dept. of Commerce.
If you have questions or complaints regarding our compliance with the Safe Harbor Privacy Principles, please contact us by email at firstname.lastname@example.org. If you are not satisfied with our response, you can submit an eligible Safe Harbor mediation claim to JAMS International to be mediated in accordance with the JAMS International Mediation Rules.
“Personal Information” is information that identifies a particular individual. When you create an account on a ThinkBe website, register your products, purchase or otherwise obtain a product update or product on a ThinkBe website, sign up for a newsletter, participate in promotional activities, or contact our product support personnel, we may collect a variety of Personal Information, which depending on the circumstances may include your name, mailing address, phone number, email address, and payment card information. We may use Personal Information about you for the following purposes:
“Other Information” is any information that does not identify, and cannot reasonably be used to identify, a particular person, such as: browser and device information, app usage data, information collected through cookies, pixel tags and other technologies, demographic information and other information provided by you, anonymous information and aggregated information. Please note we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal information under applicable law, then we may use it as described in “Personal information” section above. In some instances, we may combine Other Information with Personal Information. If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined. Examples of Other Information include:
We use locally stored objects, also known as Flash cookies, in certain situations where we use the Adobe Flash Player to provide special content such as videos or video clips. Flash uses this technology to remember settings, preferences and usage similar to browser cookies but Flash cookies are not managed through your web browser. Learn how to manage privacy and storage settings for Flash cookies.
We may use third party service providers to help us operate our business and websites or administer activities on our behalf, such as fulfilling purchases, processing payment card payments and shipping products to you. We may share Personal Information about you, including payment card information, with these third parties to enable them to perform the services.
We may disclose Personal Information about you to others if we have your consent to do so in such form of consent as may be required under applicable law. We may also disclose Personal Information about you to others as we believe to be necessary or appropriate: (a) under applicable law or regulation, including laws or regulations outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public authorities and law enforcement officials, including officials outside your country of residence; (d) to assist or support theft investigations involving ThinkBe products or property, (e) to enforce any of our terms and conditions or policies; (f) to protect our operations or those of any of our affiliates and subsidiaries; (g) to protect the rights, privacy, safety or property of ThinkBe, its affiliates and subsidiaries, you, or others; or (h) to permit us to pursue available remedies or limit the damages that we may sustain.
We may transfer information to an affiliate, a subsidiary, or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of ThinkBe's business, assets, or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.
ThinkBe takes reasonable security measures to help protect against loss, misuse, unauthorized access, and unauthorized disclosure or alteration of the Personal Information under its control. On some of our sites you can create an account to participate or secure additional benefits. The transmission of information you provide to ThinkBe during the registration processes is encrypted using secure socket layer technology (SSL). If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with Paragraph 10 below.
We will not share your Personal Information that identifies you with third parties (other than our affiliates) for the third parties’ marketing purposes unless you opt-in if and when we give you the opportunity to do so. We and our affiliates may use your Personal Information to send you marketing-related correspondence (including emails) related to ThinkBe products or applications unless you explicitly opt-out of receiving them. To opt out of receiving marketing-related correspondence from ThinkBe and our affiliates, or to withdraw your previously given consent for us to share Personal Information about you with third parties for the third parties' marketing purposes, please email us at email@example.com. Please tell us whether you are opting out of receiving marketing-related correspondence from ThinkBe and our affiliates and/or withdrawing your previously given consent to share Personal Information about you with third parties for their marketing purposes.
Our products and applications are not directed to individuals under the age of 13, and we request that individuals under 13 not provide Personal Information to ThinkBe through any ThinkBe website or through our products and applications. If we learn that we have collected the Personal Information of a child under 13, we will take steps to delete the information as soon as possible.
ThinkBe takes reasonable steps to ensure that the Personal Information we collect from you is accurate, complete, and current. You may request access and request that erroneous or inaccurate Personal Information be updated. You may also request that your Personal Information be deleted. Consistent with applicable law, ThinkBe will respond promptly to your requests and in any event within 30 days. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We may decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain in our databases and other records, which will not be removed.
Access, correction or deletion requests can be made as follows:
Mail: ThinkBe Inc., Palo Alto, CA