5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In
Short: We may use cookies and other
tracking technologies to collect and store your
information.
We
may use cookies and similar tracking technologies (like web beacons
and
pixels) to gather information when you interact with our Services.
Some
online tracking technologies help us maintain the security of our
Services and your account, prevent crashes, fix
bugs, save your preferences, and assist with basic site
functions.
We
also permit third parties and service providers to use online
tracking
technologies on our Services for analytics and advertising,
including to
help manage and display advertisements, to tailor advertisements to
your interests, or to send abandoned shopping cart reminders
(depending
on your communication preferences). The third parties and service
providers use their technology to provide advertising about products
and
services tailored to your interests which may appear either on our
Services or on other websites.
To the extent these online tracking
technologies are deemed to be a
"sale"/"sharing"
(which includes targeted advertising, as defined under the applicable
laws) under applicable US state laws, you can opt out of these online
tracking technologies by submitting a request as described below under
section "DO UNITED STATES
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
"
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In
Short: If
you choose to register or log in to our Services using a social
media
account, we may have access to certain information about
you.
Our
Services offer you the ability to register and log in using your
third-party social media account details (like your Facebook or X
logins). Where you choose to do this, we will receive certain
profile
information about you from your social media provider. The profile
information we receive may vary depending on the social media
provider
concerned, but will often include your name, email address, friends
list, and profile picture, as well as other information you choose
to
make public on such a social media platform.
We
will use the information we receive only for the purposes that are
described in this Privacy Notice or that are otherwise made clear to
you
on the relevant Services. Please note that we do not control, and
are
not responsible for, other uses of your personal information by your
third-party social media provider. We recommend that you review
their
privacy notice to understand how they collect, use, and share your
personal information, and how you can set your privacy preferences
on
their sites and apps.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In
Short: We may transfer, store, and
process your information in countries other than your
own.
Our servers are located in
the
United States
. If you are accessing our Services
from outside
the
United States
,
please be aware that your information may be transferred to, stored by,
and processed by us in our facilities and in the facilities of the
third parties with whom we may share your personal information (see "WHEN
AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
" above), in
the
United States,
and other
countries.
If
you are a resident in the European Economic Area (EEA), United
Kingdom
(UK), or Switzerland, then these countries may not necessarily have
data
protection laws or other similar laws as comprehensive as those in
your
country. However, we will take all necessary measures to protect
your
personal information in accordance with this Privacy Notice and
applicable law.
European Commission's Standard
Contractual Clauses:
We
have implemented measures to protect your personal information,
including by using the European Commission's Standard Contractual
Clauses for transfers of personal information between our group
companies and between us and our third-party providers. These
clauses
require all recipients to protect all personal information that they
process originating from the EEA or UK in accordance with European
data
protection laws and regulations.
Our Standard Contractual Clauses can
be provided upon request.
We
have implemented similar appropriate safeguards with our third-party
service providers and partners and further details can be provided
upon
request.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In
Short: We keep your information for as
long as necessary to fulfill
the purposes
outlined in this Privacy Notice unless otherwise required by
law.
We
will only keep your personal information for as long as it is
necessary
for the purposes set out in this Privacy Notice, unless a longer
retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will
require us keeping your personal information for longer than
the period of time in which users
have an account with us
.
When we have no ongoing legitimate
business need to process your personal information, we will either
delete or anonymize
such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then
we
will securely store your personal information and isolate it from
any
further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In
Short: We aim to protect your personal
information through a system of
organizational
and technical security measures.
We have implemented appropriate and
reasonable technical and
organizational
security measures designed to protect the security of any personal
information we process. However, despite our safeguards and efforts
to
secure your information, no electronic transmission over the
Internet or
information storage technology can be guaranteed to be 100% secure,
so
we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized
third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although we will
do
our best to protect your personal information, transmission of
personal
information to and from our Services is at your own risk. You should
only access the Services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In
Short: We do not knowingly collect data
from or market to children
under 18 years of age.
We
do not knowingly collect, solicit data from, or market to children
under 18 years of age, nor do we knowingly sell such personal
information. By using the Services, you represent that you are at
least
18 or that you are the parent or guardian of such a minor and
consent to
such minor dependent’s use of the Services. If we learn that
personal
information from users less than 18 years of age has been collected,
we
will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data
we
may have collected from children under age 18, please contact us at
founders@thorntale.com
.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In
Short:
Depending on your state of
residence in the US or in some
regions, such as the European
Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada
, you have rights that allow
you greater access to and control over your personal
information.
You may review, change, or
terminate your account at any time, depending on your country,
province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada
),
you have certain rights under applicable data protection laws. These
may include the right (i) to request access and obtain a copy of
your
personal information, (ii) to request rectification or erasure;
(iii) to
restrict the processing of your personal information; (iv) if
applicable, to data portability; and (v) not to be subject to
automated
decision-making. In certain circumstances, you may also have the
right
to object to the processing of your personal information. You can
make
such a request by contacting us by using the contact details
provided in
the section "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
" below.
We will consider and act upon any
request in accordance with applicable data protection laws.
Withdrawing your
consent: If we are relying on your consent to
process your personal information,
which may be express and/or implied consent depending on the
applicable law,
you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the
contact
details provided in the section "
HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
" below or updating your preferences.
However, please note that this will not
affect the lawfulness of the processing before its withdrawal nor, when applicable law allows,
will it affect the processing of your personal information conducted
in
reliance on lawful processing grounds other than consent.
Opting out of marketing and
promotional communications: You
can unsubscribe from our marketing and promotional communications at
any time by clicking on the
unsubscribe link in the emails that we send,
replying "STOP" or "UNSUBSCRIBE" to the SMS messages that
we send,
or by contacting us using the
details provided in the section "
HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
"
below. You will then be removed from the marketing lists. However, we
may still communicate with you — for example, to send you
service-related messages that are necessary for the administration and
use of your account, to respond to service requests, or for other
non-marketing purposes.
Account Information
If you would at any time like to review or
change the information in your account or terminate your account, you
can:
-
Contact us using the contact information
provided.
Upon
your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we
may
retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal terms
and/or
comply with applicable legal requirements.
Cookies and similar
technologies:
Most Web browsers are set to accept cookies by default. If you
prefer,
you can usually choose to set your browser to remove cookies and to
reject cookies. If you choose to remove cookies or reject cookies,
this
could affect certain features or services of our Services.
For further information, please see our
Cookie Notice:
https://app.termly.io/document/cookie-policy/43ab763f-e135-4f2d-9abb-5630ec38d05c
.
If you have questions or comments about your
privacy rights, you may email us at
privacy@thorntale.com.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile
operating systems and mobile applications include a Do-Not-Track (
"DNT")
feature or setting you can activate to signal your privacy
preference
not to have data about your online browsing activities monitored and
collected. At this stage, no uniform technology standard for recognizing and implementing DNT
signals has been finalized.
As such, we do not currently respond to DNT browser signals or any
other mechanism that automatically communicates your choice not to
be
tracked online. If a standard for online tracking is adopted that we
must follow in the future, we will inform you about that practice in
a
revised version of this Privacy Notice.
California
law requires us to let you know how we respond to web browser DNT
signals. Because there currently is not an industry or legal standard
for recognizing or honoring DNT signals, we do not
respond to them at this time.
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: If you are a resident of
California
, Colorado
, Connecticut
, Utah
or Virginia
,
you may have the right to request access to and receive details
about
the personal information we maintain about you and how we have
processed
it, correct inaccuracies, get a copy of, or delete your personal
information. You may also have the right to withdraw your consent
to our
processing of your personal information. These rights may be
limited in
some circumstances by applicable law. More information is provided
below.
Categories of Personal Information We Collect
The
table below shows the categories of personal information we have
collected in the past twelve (12) months. The table includes
illustrative examples of each category and does not reflect the
personal
information we collect from you. For a comprehensive inventory of
all
personal information we process, please refer to the section "WHAT
INFORMATION DO WE COLLECT?
"
|
Category
|
Examples
|
Collected
|
|
A.
Identifiers
|
Contact
details, such as real name, alias, postal address, telephone
or mobile
contact number, unique personal identifier, online
identifier, Internet
Protocol address, email address, and account
name
|
YES
|
|
B. Personal information as
defined in the California Customer Records
statute
|
Name, contact information,
education, employment, employment history, and financial
information
|
YES
|
|
C
. Protected classification characteristics under state
or federal law
|
Gender, age, date of birth,
race and ethnicity, national origin, marital status, and
other demographic data
|
NO
|
|
D
. Commercial information
|
Transaction information,
purchase history, financial details, and payment
information
|
NO
|
|
E
. Biometric information
|
Fingerprints and
voiceprints
|
NO
|
|
F
. Internet or other similar network activity
|
Browsing history, search
history, online behavior
, interest
data, and interactions with our and other websites,
applications, systems, and
advertisements
|
NO
|
|
G
. Geolocation data
|
Device
location
|
NO
|
|
H
. Audio, electronic, sensory, or similar information
|
Images and audio, video or
call recordings created in connection with our business
activities
|
NO
|
|
I
. Professional or employment-related information
|
Business
contact details in order to provide you our Services at a
business
level or job title, work history, and professional
qualifications if you
apply for a job with us
|
NO
|
|
J
. Education Information
|
Student records and directory
information
|
NO
|
|
K
. Inferences drawn from collected personal information
|
Inferences
drawn from any of the collected personal information listed
above to
create a profile or summary about, for example, an
individual’s
preferences and characteristics
|
NO
|
|
L
. Sensitive personal Information
|
|
NO
|
We
may also collect other personal information outside of these
categories
through instances where you interact with us in person, online, or by
phone or mail in the context of:
- Receiving help through our customer support
channels;
- Participation in customer surveys or
contests; and
- Facilitation in the delivery of our Services
and to respond to your inquiries.
We will use and retain the
collected personal information as needed to provide the Services or for:
- Category A - As
long as the user has an account with us
- Category B - As
long as the user has an account with us
Will your
information be shared with anyone
else?
We
may use your personal information for our own
business purposes, such
as for undertaking internal research for
technological development and
demonstration. This is not considered to be "selling" of
your personal information.
We
have not disclosed, sold, or shared any personal
information to third
parties for a business or commercial purpose in
the preceding twelve
(12) months. We will
not sell or share personal information in the
future belonging to website visitors, users, and
other consumers.
Your Rights
You
have rights under certain US state data protection
laws. However, these
rights are not absolute, and in certain cases, we
may decline your
request as permitted by law. These rights
include:
- Right to
know whether or not we are processing
your personal data
- Right to
access your personal data
- Right to
correct inaccuracies in your
personal data
- Right to
request the deletion of your personal
data
- Right to obtain a
copy of the personal data you
previously shared with us
- Right to
non-discrimination for exercising your
rights
- Right to opt
out of the processing of your personal
data if it is used for targeted advertising (or sharing as
defined under California’s privacy law), the
sale of personal data, or profiling in furtherance
of decisions that produce legal or similarly
significant effects (
"profiling")
Depending upon the
state where you live, you may also have the
following rights:
- Right
to obtain a list of the categories of third
parties to which we have
disclosed personal data (as permitted by
applicable law, including the
privacy law in
California
)
- Right
to limit use and disclosure of sensitive
personal data (as permitted by
applicable law, including the privacy law in
California)
How to Exercise Your Rights
To
exercise these rights, you can contact
us by
submitting
a data
subject access
request,
by emailing us at
support@thorntale.com,
or by
referring to the contact details at the
bottom of this document.
Under
certain US state data protection laws, you
can designate an authorized
agent to make a request on your
behalf. We may deny a request from an authorized
agent that does not submit proof
that they have been validly authorized
to act on your behalf in accordance
with applicable
laws.
Request Verification
Upon
receiving your request, we will need to
verify your identity to
determine you are the same person about
whom we have the information in
our system. We will only use personal
information provided in your
request to verify your identity or
authority to make the request.
However, if we cannot verify your identity
from the information already
maintained by us, we may request that you
provide additional information
for the purposes of verifying your
identity and for security or
fraud-prevention purposes.
If you
submit the request through an authorized
agent, we may need to collect additional
information to verify your
identity before processing your request
and the agent will need to
provide a written and signed permission
from you to submit such request
on your behalf.
Appeals
Under
certain US state data protection laws, if
we decline to take action
regarding your request, you may appeal our
decision by emailing us at
privacy@thorntale.com
.
We will inform you in writing of any
action taken or not taken in
response to the appeal, including a
written explanation of the reasons
for the decisions. If your appeal is
denied, you may submit a complaint
to your state attorney general.
California "Shine
The Light"
Law
California
Civil Code Section 1798.83, also known as
the
"Shine The Light"
law, permits our users who are California
residents to request and
obtain from us, once a year and free of
charge, information about
categories of personal information (if
any) we disclosed to third
parties for direct marketing purposes and
the names and addresses of all
third parties with which we shared
personal information in the
immediately preceding calendar year. If
you are a California resident
and would like to make such a request,
please submit your request in
writing to us by using the contact details
provided in the section "
HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
"
14. DO OTHER REGIONS HAVE SPECIFIC
PRIVACY RIGHTS?
In
Short: You
may have additional rights based on the
country you reside in.
Australia
We collect
and process your personal information
under the obligations and conditions set
by
Australia's Privacy Act 1988
(Privacy Act).
This Privacy
Notice satisfies the notice requirements
defined in
the Privacy Act
,
in particular: what personal information
we collect from you, from
which sources, for which purposes, and
other recipients of your personal
information.
If you do
not wish to provide the personal
information necessary to fulfill
their applicable purpose, it may
affect our ability to provide our
services, in particular:
- offer you
the products or services that you
want
- respond to
or help with your requests
- manage
your account with us
- confirm
your identity and protect your
account
15. USE OF GOOGLE WORKSPACE APIS
Thorntale
adheres to Google's Limited Use Policy.
Thorntale does not use any data obtained
through Google Workspace APIs
to develop, improve, or train
generalized artificial intelligence (AI)
or machine learning (ML) models.
16. DO WE MAKE UPDATES TO
THIS NOTICE?
In
Short: Yes, we will
update this notice as necessary to
stay compliant with relevant
laws.
We may
update this Privacy Notice from time to
time. The updated version will be
indicated by an updated
"Revised"
date at the top of this Privacy Notice.
If we make material changes to
this Privacy Notice, we may notify you
either by prominently posting a
notice of such changes or by directly
sending you a notification. We
encourage you to review this Privacy
Notice frequently to be informed of
how we are protecting your
information.
17. HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
If you
have questions or comments about this
notice, you may
contact our Data
Protection Officer (DPO) by
email
at
founders@thorntale.com
, by
phone at
14159150699
,
or
contact
us by post
at:
Thorntale
Inc.
Data
Protection Officer
2261 Market
Street STE 5822
San Francisco
,
CA
94114
United States
18. HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based
on the applicable laws of your country
or
state of residence in the US
, you may
have the right to request access to
the personal information we collect
from you, details about how we have
processed it, correct inaccuracies,
or delete your personal information.
You may also have the right to
withdraw
your consent to our processing of
your personal information. These
rights may be limited in some
circumstances by applicable law. To
request to review, update, or delete
your personal information, please
fill out and submit a
data subject
access
request
.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.