Privacy Policy

Your privacy is important to ThinkBe. We developed this Privacy Policy so you know how we collect, use, disclose, transfer and store your information. Please read through this Privacy Policy to familiarize yourself with our privacy practices.

This Privacy Policy describes the treatment of information ThinkBe collects on the websites where this Privacy Policy is posted and from certain of our products and applications. Certain ThinkBe websites or those of our affiliates may be governed by privacy practices different from those set forth below. In addition, users of certain of our products and applications are provided with Privacy Policies that are specific to those products and applications — in those instances, those Privacy Policies supplement and should be read in conjunction with this Privacy Policy. Where there is a conflict, the supplement is controlling.

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 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.


A. Personal Information

“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:

  1. Communications We may communicate with you, such as to provide you with the products and services you request, to communicate with you about your account or transactions with us, to give you important information about your products or applications, and (consistent with applicable laws and the choices available to you as described in Paragraph 6 below) send you offers and promotions for our products and applications.
  2. Customer Support When you interact with our customer support representatives via email, telephone or in person, we may collect Personal Information relevant to the situation, such as your name, mailing address, phone number, email address and contact preferences; information about the ThinkBe products you own, such as their serial numbers, date of purchase and (if applicable) event logs that are useful in diagnosing product or application performance related issues; and information relating to a support or service issue. We use this information to provide you with customer and product support.
  3. Purchases If you provide your payment card information on a ThinkBe website or directly on your ThinkBe product, then ThinkBe will use your payment card information and related payment and account information, as well as your name and mailing address if applicable, for the purpose of filling your purchases or collecting payment of recurring fees, if applicable.
  4. Promotions If you enter into a sweepstakes, contest or similar promotion, we may use the information you provide to administer those promotions. To the extent that the terms and conditions of any such promotion regarding the treatment of Personal Information about you conflict with this Privacy Policy, the terms and conditions of the promotion will control.
  5. Information Posted by Visitors ThinkBe may make available through certain of our sites’ services (for example, message boards, forums, chat functionality and blogs, among other services) to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on our sites may become public information, and may be available to visitors to the sites and to the general public. We urge you to exercise discretion and caution when deciding to disclose Personal Information, or any other information, on our sites. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH THE SITES.

B. Other Information

“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:

  1. Location Information If you elect to use location-based services on your ThinkBe application or device, then the physical location of your device will be collected in order to provide you with location-based services. This location data is collected anonymously in a form that does not personally identify you. ThinkBe does not sell information collected from the device that can identify individual users (personal information). ThinkBe may collect aggregate information that cannot be linked back to an individual user, such as aggregated gender, age, height, weight, and usage data. This data would be aggregated with data from devices of other users to enhance the quality of data and other content provided by ThinkBe or content providers. ThinkBe may also share this data with or sell this data to third parties. This data would be shared and sold anonymously in a form that would not personally identify you.
  2. Ad Event Logs If you choose to use applications that contain advertisements, we may collect information such as which advertisements were viewed, how often they were clicked and how often certain actions such as saving a coupon or calling or routing to a location corresponding to an advertisement were performed so that the advertising providers can provide you with content and advertising that might be of particular interest to you. This information is collected and shared with our applicable partners anonymously in a way that does not personally identify you.
  3. Activities and Activity Data ThinkBe websites and mobile applications may allow you to voluntarily upload activities (for example, runs, walks, swims, hikes, geocaches, adventures, etc.) and activity data (for example, steps, location, distance, pace, activity time, calories burned, sleep, etc.) from your ThinkBe device. On those websites and applications you can control who can access see such activities and activity data by managing the privacy settings on those websites and applications. ThinkBe may use uploaded activity data in an anonymous and aggregated manner that would not personally identify you for purposes of enhancing the quality of its products and applications. ThinkBe may share activity data with strategic partners in an anonymous manner that would not personally identify you for the purpose of enhancing the quality of such strategic partners’ products and applications.
  4. Server Log Information We and our service providers use server log information for purposes such as calculating site usage levels, helping diagnose problems with ThinkBe’s servers and administering ThinkBe’s websites. These server logs may include information such as your Internet Protocol (IP) address, browser type, browser language, the date and time of your request, the time(s) of your visit(s) and the web page(s) that you visited. Collecting IP addresses is standard practice on the Internet and is done automatically by many web sites. Please note that we treat IP Addresses, server log files, and related information as Other Information, except where we are required under applicable laws to treat any such information as Personal Information.
  5. Cookies and Other Technology We may use cookies, pixel tags, web beacons, clear GIF’s or other similar tools on our websites or in our email messages. These technologies help ThinkBe keep track of your movements within our sites, measure the effectiveness of advertisements, and compile aggregate statistics about site usage and response rates. They also help you to more smoothly navigate our websites. In addition, ThinkBe uses Google Analytics as a method of tracking site statistics and user demographics, interests and behavior on many of our sites. We may also engage one or more third party service providers to serve online advertisements on our behalf. They may use a pixel tag or other similar technology to collect anonymous information about your visits to sites, and they may use that information to target advertisements for goods and services. This information is collected anonymously, in a manner that does not personally identify you. For more information regarding this practice and to opt-out of such collection and use of this information by our third party service providers, please see

    If you do not want information collected through the use of these technologies there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them. In addition, if you reside in a jurisdiction that requires us to obtain your consent to use cookies on our sites then you will have an opportunity to manage your cookie preferences on the sites; except that certain cookies are required to enable core site functionality and you cannot choose to disable those cookies.

    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.

  6. Use of Apps When you download and use apps, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number. ThinkBe may use a third-party service provider to collect analytical information related to the use of its mobile apps, such as device state information, device hardware and OS information, information relating to how an app functions, and the physical location of a user’s device at the time the device crashes. This information may be collected and stored in a way that does not personally identify any particular user. ThinkBe uses this aggregated data to improve the quality and functionality of its mobile apps.


A. Affiliated Entities

We may share information that you provide to ThinkBe with our affiliates worldwide for the purposes described in this Privacy Policy. You may access a list of our affiliates in our latest Annual Report on Form 10-K, which can be found at Our affiliates are required to protect Personal Information about you in a manner consistent with this Privacy Policy. ThinkBe is the party responsible for managing jointly used Personal Information.

B. Service Providers

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.

C. Other Disclosures

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.

D. Assignment

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.


You might have an opportunity to choose to use a ThinkBe or third party application on your device that allows you to invite third parties to view your location or have access your personal information on another ThinkBe device and/or on a website. If you choose to use such an application, then you should use caution when determining to whom you want to make this information available. If you choose to post an invitation to view your location information on third party social networks, then, depending on the privacy practices of those social networks, it is possible that persons in addition to those to whom you intended to invite to view your location information could have access to such information. Accordingly, you should use caution when making such an invitation via third party social networks and you should carefully review the privacy practices of such social networks. If you use a ThinkBe application or product to invite third parties to view your location, then ThinkBe may also provide you with a Privacy Policy that relates specifically to such application or product and which would supplement this Privacy Policy.


Our websites, applications and products may contain links to other sites that are not operated by ThinkBe, and our websites or your product may contain applications that you can download from third parties. These linked sites, services, and applications are not under ThinkBe's control and we are not responsible for the privacy practices or the content of any linked sites, services, and applications. If you provide any Personal Information through any third-party sites, services, or applications, your transaction will occur on the third party's site, service, and/or application and the information you provide will be collected by, and controlled by, the Privacy Policy of that third party. ThinkBe IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OR THE CONTENT OF THIRD-PARTY WEB SITES OR THIRD-PARTY APPLICATIONS. We recommend you review the Privacy Policy of any third parties.


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 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.


We may change this Privacy Policy from time to time as we add new products and applications, as we improve our current offerings, and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy on our affected websites. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice may be provided by email, by posting notice of the changes on our affected websites or by other means prior to the change becoming effective, consistent with applicable laws.


We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.


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