Privacy Policy

This Privacy Policy was updated on April 26, 2017.

Your privacy is important to us. So, we have developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your information. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person.

You may be asked to provide your personal information anytime you are in contact with us or an affiliated company. We and our affiliates may share this personal information with each other and use such information in a manner consistent with this Privacy Policy. We may also combine your personal information with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you choose not to do so, we may not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information we may collect and how we may use it:

What Personal Information We Collect

When you use our products or services or interact with our company, we may collect a variety of information, including your location, name, mailing address, phone number, email address, contact preferences, shopping preferences, your calendar, usage data about our products, information about your actions on social media and impact of those actions on other users and information about yourself and your contacts. We may collect this information from our application, from credit card information, and from other social media platforms, such as your login credentials, your “real” name, profile picture, and other information that you share or your social network shares with you.

When you share content with our service or any connected third-party source, whether inside or outside your company community, we may collect data about such posts including, content, likes, views, comments, and other responses. We may collect the information you provide about others such as names, mailing address, email addresses, and phone numbers. We will use such information to provide our services, link your account with us to your social networking account, or for anti-fraud purposes. Furthermore, information that you share and the data about how you share it through our service could become collected and viewed by other members of the company community.

In certain jurisdictions, we may ask for a government issued ID in limited circumstances and when required by law.

How We Use Your Personal Information

The personal information we collect allows us to create a platform from which to provide the services integrated with existing social media networks, you can opt out at any time by updating your preferences or deleting the application from your device. This will not delete previously collected data.

We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content, and advertising, and for loss prevention and anti-fraud purposes.

We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of our users, and we may use that information to deny service to users that do not meet our minimum user requirements.

From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions, and policies. Because this information is important to your interaction with us, you may not opt out of receiving these communications. If you would like to unsubscribe to any other emails follow the instructions at the bottom of each email and we will removes you from our subscribers list.

We may also use personal information for internal purposes such as auditing, data analysis, and research to improve our products, services, and customer communications. We may occasionally ask users of our service to complete online surveys and opinion polls about their activities, attitudes, and interests. These surveys help us better serve you and improve the usefulness of the service.

If you are an administrator, you may import your contacts from another device or program. When you import your contacts, we will ask you if you wish to invite your colleagues from your same domain. If you indicate that you would like to invite them, we will send them an invitation from you to activate an account and join the same community as you.

We may share the information in your account, and user content you elect to share via the service, with the social media outlets with whom you choose to share user content, provided the social media outlet has been approved by an administrator of your company. By publishing user content to your social media outlet, you are allowing us to access your social media outlet account information and you are agreeing to the applicable social media outlet terms and conditions. Other than what we may share with a social media outlet in connection with your use of the service, the personal information a social media outlet has collected from you is obtained and maintained by them independently of our service. Other services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other online services you use.

If you email us through the website, we may ask you for additional information so we can respond to your questions and comments. If you choose to correspond with us via email, we may retain the content of your email messages, your email address and our response to you. In certain cases, we may post content from your emails addressed to us.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, time zone, and other details, so that we can better understand user behavior and improve our products, services, and advertising.

We may collect information regarding customer activities on our website, mobile applications, and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are most effective. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.

We may collect and store details of how you use our services. This information may be used to improve the relevancy of results provided by our services. In limited instances, to ensure the quality of our services over the Internet, such information could be associated with your IP address.

If we do combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.

Cookies and Other Technologies

Our websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags, clear GIFs, and web beacons. These technologies help us better understand user behavior, streamline the user experience, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of our services. We treat 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, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

You can choose to limit the transmission of this data in your account preferences, or via your web browser. If you do not accept cookies you may unable to utilize the full functionality of the services.

We also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Knowing your contact information, hardware identifiers, and information about your computer or device helps us reduce bugs and coding errors to provide you with the best customer service possible. Collecting user usage data allows us to prioritize the aspects of our services that are used more frequently and to generate statistics about how the services are being used.

As is true of most internet services, we 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 websites and applications, operating system, date/time stamp, and clickstream data.

We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our products and services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services.

Pixel tags enable us to send email messages in a format which customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

In some of our email messages, or as a feature of the services, we use a “click-through URL” linked to content on our website or the website of third parties. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in email messages. If you click on another third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you.

Disclosure to Third Parties

At times we may make certain personal information available to strategic partners that work with us to provide products and services, or that help us market to customers. Before sharing personal information with third parties we will take all reasonable measures to ensure that the third parties will abide by this policy.

At times we may make certain non-personal information available to third parties for reasons other than providing the services. We may disclose non-personally identifiable aggregate statistics regarding user behavior as a measure of interest in, and use of, our service to third parties in the form of aggregate data, such as overall patterns or demographic reports, which do not describe or identify any individual user. Information relating to aggregate statistics may be collected through the use of third-party cookies and other third-party tracking devices. We may share aggregated information that does not include personal information and we may otherwise disclose non-identifying Information and log data with third parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your personal information.

Service Providers

We use your personal information to provide, maintain, protect, and improve the service, to authenticate you as a user, to communicate with you, to assist you in using the service, and allow your company to track and measure the publicity you generate related to the company and its products. We may combine your personal information with non-personal information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the service, and to analyze and understand how our service is used. We will not share, rent, or sell your personal information to other parties, except to our service providers as set forth below.

We may match information collected from you through different means or at different times, including both personal information and site usage information, and use such information along with information obtained from other sources, including (without limitation) any of our other websites and third parties. We may send you notices (for example, in the form of emails, mailings, and the like), and otherwise correspond with you about products, services, companies, events sponsored by us and others, and other information that we think might interest you.

We may share personal information with, agents, contractors, controllers, third party individuals and other companies to assist us in providing the services, or who provide ancillary services such as information processing, extending credit, fulfilling customer orders, delivering products, managing and enhancing customer data, providing customer service, assessing customer interest in our products operation and maintenance of the service, database management, web analytics, and improvement of the services, and conducting customer research or satisfaction surveys. These third parties have access to your personal information and other information collected as set forth in this policy, only to perform these tasks on our behalf and are obligated not to disclose your personal information or use it for any other purpose. Said third parties may be located anywhere in the world. Furthermore, your private information may be transferred and processed in the United States of America.

Accountability for Onward Transfer

When transferring personal information to a third party acting as a controller, we must comply with the Notice and Choice Principles (“Principles”). We must also enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify us if it makes a determination that it can no longer meet this obligation. The contract shall provide that when such a determination is made, the third-party controller ceases processing or takes other reasonable and appropriate steps to remediate.

When transferring personal data to a third party acting as an agent, we must: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles; (iv) require the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department of Commerce or its designated agent upon request.

Other

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 us to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our property and rights and the rights of our suppliers, or other third parties, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Our organization and activities are subject to investigatory and enforcement powers of the Federal Trade Commission, the Department of Transportation, and the Department of Commerce, and we comply with the Fair Information Practices act, the CAN SPAM Act and the California COPP Act. It may be possible, under certain conditions, for you to invoke binding arbitration under Annex I of the Privacy Shield Act. We adhere to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. Individuals must have enforceable rights against data users, and recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors. We have chosen to fully comply with the Data Protection Authorities and you may utilize the International Centre for Dispute Resolution-American Arbitration Association to resolve any violation of the Privacy Shield Act.

Protection of Personal Information

We take the security of your personal information very seriously. Our online services protect your personal information during transit using encryption such as Secure Sockets Layer (SSL). When your personal data is stored by us, we use computer systems with limited access housed in facilities using physical security measures. We restrict access to personal information to those employees, contractors, and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations. Data is stored in encrypted form including when we utilize third-party storage. All transactions are processed through a gateway provider and are not stored or processed on our servers.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting via the service in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement, or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. While we endeavor to protect the security and integrity of sensitive personal information provided to the Company, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be safe from intrusion by others. In the event of a data breach and consistent with the above will notify users over email within seven (7) business days after becoming aware and a data breach.

When you use some products, services, or applications or post on a forum, chat room, or social networking service, the personal information and content 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 share or submit in these instances. For example, if you list your name and email address in a posting, that information is public. Please take care when using these features.

Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, login information, or national identification numbers in a non-secure or unsolicited email or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

Integrity and Retention of Personal Information

We intend to make it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the services and other purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. All authorized users may review, update, correct, or delete the personal information in their account by making edits via the service. If you would like us to delete your account in our system, please contact us at [email protected] with a request that we delete your personal information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Access to Personal Information

You can help ensure that your contact information and preferences are accurate, complete, and up to date by updating your account preferences. For other personal information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by email in the contact us page on our website.

Children & Education

We understand the importance of taking extra precautions to protect the privacy and safety of children using our products and services. Children under the age of eighteen (18), or equivalent minimum age in the relevant jurisdiction, are not permitted to create accounts. However, it is not possible for us to independently verify the age of our customers. It is the responsibility of every parent to monitor his or her child’s online activities. This service is not directed to children. We do not knowingly collect personal Information from children. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, please contact us. If we become aware that a child has registered for the service and has provided us with personal information, we will delete such information from our files.

Location-Based Services

To provide location-based services on our platform we, our partners, third-party servicers, and licensees may collect, use, and share precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. By accepting the terms and conditions you have consented to transmission of your location data. This location data is not anonymous, could personally identify you, and is used by us and our affiliates to provide and improve our services.

International transfer

Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, we may transfer said personal information to local or foreign processing centers and process it there.

International Users

All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Personal information, relating to our services, regarding individuals who reside in a member state of the European Economic Area and Switzerland is subject to the Privacy Policy and we make all reasonable efforts to remain in compliance with European Privacy laws.

Thought Horizons LLC, complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Thought Horizons LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, Thought Horizons LLC commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Thought Horizons LLC at: [email protected].  Thought Horizons LLC has further committed to cooperate with the panel established by the EU data protection authorities (“DPAs”) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

We will also make reasonable efforts to abide by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System (CBPR). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.

Residents living outside the United States should investigate local privacy laws and are only licensed to use our products if our products are in compliance with local laws.

Our Company-Wide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have any questions or concerns about our Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us by phone at the number found on the contact us section of our website.

All such communications are examined, and replies are issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

We may update this Privacy Policy from time to time. When we change the Policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.

You may contact us by email at [email protected]

Or by mail at: 101 Marietta St NW, Suite 1625, Atlanta, Georgia 30303, USA

 

California

Tracking

We track our customers over time and across third-party websites to provide targeted advertising and we respond to Do Not Track (DNT) signals. If you set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked, we will recognize the signal and take appropriate actions. However, many of our services will not be available to you if you set a DNT signal.

Third parties that have content embedded on our websites or applications may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific website from a certain IP address. Third parties may be able to collect other personally identifiable information provided or collected by us from our websites and applications.

Notice for Minors

We offer interactive services which allow you to post content to share publicly or with coworkers, friends, and family. At any time, you can delete or remove content you have posted using the deletion or removal options within our services. If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion, you can contact our support team directly. Although we offer deletion capability for our services, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the services.

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