ThinkRite Privacy Policies

Effective Date: January 7, 2020

ThinkRite maintains two Privacy Policies: a European Privacy Policy and a Standard Privacy Policy, both of which are contained in this document. If you are unsure which Privacy Policy applies to your data, please refer to the Applicability section of this document for more information.

Applicability

European data protection law has limited effect on operations outside of the European Union. For that reason, ThinkRite’s European Privacy Policy will only apply to you in strictly limited circumstances. Those two circumstances are:

  1. To the extent that:


  2. To the extent that:

To the extent that you do not fall within one of the above categories of people, ThinkRite’s European Privacy Policy will not apply to you. Instead, ThinkRite’s Standard Privacy Policy will apply to you. Refer to the appropriate section in this document.


European Privacy Policy

To the extent that our processing of your personal information is covered by our Standard Privacy Policy, the rest of this section shall not apply.

This European Privacy Policy describes how ThinkRite collects, uses, stores and (where applicable) shares your personal information if you meet the circumstances described in the Applicability section of this document. This Policy applies to visitors to our website ThinkRite.com (our "Site"), to our customers and users of our products and services (including our software applications, the "ThinkRite Software"); and to our suppliers.

  1. Definitions

    References in this Policy to "data protection law" mean (as applicable) the General Data Protection Regulation (Regulation (EU) 2016/679), and all related data protection legislation from time to time having effect according to your location and the company which is carrying out the processing activities (which in the case of ThinkRite Ltd will include the Data Protection Act 2018).

  2. Our details

    The data controllers with conduct of your personal information are (as applicable):

    For the purposes of data protection law, ThinkRite Ltd has been appointed as representative of ThinkRite, Inc.

    The following sections explain what information we hold about you, why we are processing that information, the legal basis for the processing, the duration for which we keep your information and (if applicable) who your information will be shared with and where those recipients are based.

  3. What information do we process?

    We process information about you from the following sources:

  4. How We Use Your Information. We use your personal information for the following purposes:

  5. Our Legal Grounds for Processing your Personal Information

    In accordance with data protection law, we process your personal information on the following legal grounds:

  6. How Long Do We Keep Your Information For? We only keep your information for so long as it is reasonably necessary. When setting our data retention periods, we consider the amount, nature, and sensitivity of the information we hold, the potential risk of harm from unauthorised use or disclosure of the information and the purposes for which we process the information (including whether we can achieve those purposes by other means). We also take into account our other legal obligations to keep or securely dispose of personal information.

    Generally speaking, we keep your personal information for the following periods of time:

    If we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so.

  7. How We Share Your Information with Third Parties? Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, to improve and expand our products and services or to efficiently operate our business. In order to achieve these purposes, we will share your data with the following people or groups of people:

    Under certain circumstances, ThinkRite may bear liability for onward transfers of personal information from the EU where third-party sub-processors process personal information inconsistent with the EU-U.S. Privacy Shield Principles, unless ThinkRite proves that it is not responsible for the event giving rise to the damages.

    Except as identified above, to the best of our knowledge, understanding and belief we do not transfer your personal information outside of the European Union.

  8. Security. We implement industry standard security measures intended to protect against the loss, misuse and alteration of the information under our control. Please be aware that no data transmission over the internet or telephone can be guaranteed to be 100% secure. As a result, ThinkRite cannot guarantee or warrant the security of any information you transmit on or through the Site and/or the ThinkRite Software and you do so at your own risk.

  9. Your rights. To the extent that this European Privacy Policy applies to the processing of your personal information (please refer to the Applicability section above to establish this), you have the below listed rights under data protection law:

    Should you have any concerns about how we hold and process your information, you have the general right to complain to us (in the first instance) and, if you are not satisfied by our response, to your local supervisory authority.

  10. Cookies. Cookies are small amounts of data that are stored on your device and which are accessed and recorded by the websites that you visit so that they can recognise the same browser navigating online at a later time.

    Information that may be collected by cookies when you use the Site may include:

    You can set your device's browser to reject cookies or to notify you when you are sent a cookie. However, if you disable cookies you may not be able to use certain features of the Site or ThinkRite Software. In addition, your browser may allow you to adjust your browser settings so that "do not track" requests are sent to the websites that you visit; doing so may also impact your ability to use certain features of the Site or ThinkRite Software.

  11. Access to Information

    Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information we hold on you. You must send us proof of your identity, or proof of authority if making the request on behalf of someone else, before we can supply the information to you. Requests should be sent to us using the contact details in section 14 below.

    You do not need to pay a fee to exercise this right unless you are requesting copies of documents you already possess, in which case we may charge our reasonable administrative costs. We are, however, allowed to charge you for our reasonable administrative costs in collating and providing you with details of the requested information which we hold about you if your request is clearly unfounded or excessive. In very limited circumstances, we are also entitled to refuse to comply with your request if it is particularly onerous.

    In certain circumstances, you are entitled to receive the information in a structured, commonly used and machine readable form.

  12. Third Party Sites. Our Site and/or ThinkRite Software may link to third party websites or services. If you follow a link to any of these websites, please note that these sites may have their own privacy policies and that we do not accept any responsibility or liability for those policies. In particular, please check their privacy policies before you submit any personal data to those websites as they may not be on the same terms as ours.

  13. Children. The Site, the ThinkRite Software and our other products and services are not intended for use by children under the age of 18 (or the applicable age of majority in your country of residence). We do not knowingly collect or distribute personal information from or about persons under the age of 18. It is a contractual condition of using our ThinkRite Software that the user be aged 18 (or the applicable age of minority in the user's country of residence) or over.

  14. Data Transfer ThinkRite Inc complies with the EU-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States. ThinkRite Inc 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/

    With respect to personal data received or transferred pursuant to the Privacy Shield Framework, ThinkRite Inc is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, ThinkRite Inc may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

    ThinkRite Inc commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources and non-human resources data transferred from the EU.

  15. Questions? Exercise of Rights. In compliance with the Privacy Shield Principles, ThinkRite Inc 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 us via email: gdpr@thinkrite.com, post: GDPR Administration, ThinkRite Ltd of 26 Basepoint Centre, Harts Farm Way, Havant, PO9 1HS, England

  16. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues: https://ico.org.uk/make-a-complaint/eu-us-privacy-shield/

    Under certain conditions, more fully described on the Privacy Shield website here: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.


Standard Privacy Policy

To the extent that our processing of your personal information is covered by our European Privacy Policy, the rest of this section shall not apply.

This Standard Privacy Policy describes how ThinkRite, Inc. (referred to in this Standard Privacy Policy as "ThinkRite," "Company," "we," "us," or "our") collects, uses, stores and (where applicable) shares your personal information if you do not meet the circumstances for coverage under our European Privacy Policy described in the Applicability section of this document. This Policy applies when you visit or use our website located at ThinkRite.com and any of our other websites, or web pages on third party websites relating to our products or services (such as our product download pages on the Apple iTunes or Google Play app store websites) which display this Standard Privacy Policy (each, a “Site” and collectively, the "Site"), or register to download and use ThinkRite’s software applications (collectively, "ThinkRite Software") via the Site. It also explains how we use and disclose the information we collect from you, and your rights in relation to that information. By accessing, visiting or using the Site or registering to download and use any ThinkRite Software, you expressly consent to our collection, storage, use and disclosure of your information as described in this Standard Privacy Policy. You represent and warrant that you are over the age of 18 and have the capacity and authority to agree to be bound by this Standard Privacy Policy. Please note that if you disagree with anything in this Standard Privacy Policy, you must not use the Site or download or use any ThinkRite Software. This Standard Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Access and Usage Terms and Conditions located at www.ThinkRite.com as well as our End User Software License Agreement for our ThinkRite Software ("User Terms").

  1. Information Collected through the Site.
    1. Information You Directly and Voluntarily Provide to Us. If you are a visitor to our Site or a user of the ThinkRite Software, we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services, and when you register as a user of the ThinkRite Software or purchase any products or services via the Site. For example, you may provide us with your name, photo, company, job title, email address, phone number, and access to your calendars, contacts, conference bridge information, webinar and other URL links, and meeting locations so that we can help you manage your meetings. If you use our Remote Executive Assistant service, you may provide us with information about your meetings, events, or other tasks that you want assistance with. You may also choose to provide to us your physical address, payment account information and other information we may request from you when you visit our Site or use ThinkRite Software. You may also elect to provide information on your collaboration preferences.

    2. Information Automatically Collected Through the Site or ThinkRite Software. We may automatically collect information about you when you use the Site or register to download and use, or use the ThinkRite Software. For example, if you access the Site or the ThinkRite Software through a computer or mobile device, we will automatically collect information such as your browser type and version, computer and connection information, IP address and standard web log information. We may obtain the conference bridge information that you may be using, or the method by which you connected to various servers when you use the ThinkRite Software. We also capture your email address and the fact that you are in a meeting when you join a meeting using ThinkRite Software. We may also gather your email address and other personal information when you notify us regarding a problem or issue. We may also gather information when other ThinkRite users rate you or your meetings.

    We may automatically collect information from you when you use the Site using "cookies." Cookies are small amounts of data that are stored within your computer's Internet browser and that are accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online at a later time.

    Information that may be collected by cookies when you use the Site may include:

    You can set your browser to reject cookies or to notify you when you are sent a cookie. However, if you disable cookies you may not be able to use certain features of the Site. In addition, your browser may allow you to adjust your browser settings so that "do not track" requests are sent to the websites that you visit.

    When you use the ThinkRite Software, we may automatically collect and store certain information. This may include telephony log information like your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, routing information and types of calls, IP address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL. We may collect and store information (including personal information) locally on your device by various means..

  2. How We Use the Information We Collect. We use the information we gather through the Site or your registration, downloading and/or use of the ThinkRite Software in the following ways:

    If you provide your email address to us, we may email you with information and updates about the Company and its products and services that we believe may be of interest to you.


  3. How We Share Your Information with Third Parties. We do not sell or rent user information we collect through the Site or your registration as a user of, or use of, the ThinkRite Software to any unaffiliated third parties for their own marketing purposes. In the event the Company wants to sell or rent your information to unaffiliated third parties for their own marketing purposes in the future, we will notify you and you will have an opportunity to affirmatively opt-in to receiving these third party marketing communications. The Company does share your information with third parties in some circumstances as follows:

    1. A. Employees and Third-Party Service Providers.We will disclose your information to our employees, contractors, vendors and suppliers ("Service Providers") who provide products and services to us or on our behalf, such as operating and supporting the Site and/or the ThinkRite Software, analyzing data, or performing marketing or consulting services, or in connection with your purchase of products or services provided by such Service Providers. These Service Providers will only have access to the information needed to perform these functions.

    2. Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies. To the extent permitted by law, we will disclose your information to government authorities or third parties if: (i) required to do so by law, or in response to a subpoena or court order; (ii) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (iii) we believe that you have abused the Site or the ThinkRite Software by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws or in other violation of our User Terms or improper conduct . You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

    3. Business Transfers; Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users of the Site to third parties. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Standard Privacy Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

    4. Aggregate Information. We may share information relating to users of the Site and/or the ThinkRite Software with affiliated or unaffiliated third parties on an anonymous, aggregate basis.

  4. Children Under Age 13. The Site and the ThinkRite Software is not intended for children under age 13, or for anyone under age 18 or the applicable age of majority without involvement of a parent or guardian. We do not knowingly collect or distribute personal information from or about children under the age of 13.

  5. Security. We implement industry standard security measures intended to protect against the loss, misuse and alteration of the information under our control. Please be aware that no data transmission over the Internet or telephone can be guaranteed to be 100% secure. As a result, the Company cannot guarantee or warrant the security of any information you transmit on or through the Site and/or the ThinkRite Software and you do so at your own risk.

  6. Amendments to this Standard Privacy Policy. We will notify you of changes to this Standard Privacy Policy by posting the amended terms on the Site and/or the ThinkRite Software. If you do not agree to the changes, you should discontinue your use of the Site and the ThinkRite Software. If you continue using the Site and/or the ThinkRite Software after the modified privacy policy takes effect, you will be bound by the modified privacy policy.

  7. Use of Information Outside the United States. The Site and the ThinkRite Software are directed to users located in the United States. If you are located outside of the United States and you choose to use the Site or the ThinkRite Software or provide your information to us, your information may be transferred to, processed and maintained on servers or databases located in the United States. Your use of the Site or the ThinkRite Software constitutes your consent and agreement to these practices and such transfer of your data. If you do not want your information transferred to or processed or maintained in the United States, you should not use the Site or the ThinkRite Software. The European Commission and/or other geopolitical regions have determined the United States may not subscribe the same legislative standards for data protection that may be applicable in other countries or geopolitical regions. By providing us with your personal information, you are consenting to our use of it in accordance with our privacy practices, including the transfer of your information across international boundaries to jurisdictions anywhere in the world as permitted by local law.

  8. Accessing, Changing and Managing Your Information. If you have provided your name and email address to us, you may request that we remove your name and email address from our database by contacting us at support@ThinkRite.com. Following receipt of a request from you, we will take reasonable steps to delete your information as requested. You may be unable to use the ThinkRite Software if your name and email address is removed. ThinkRite also honors requests from users for corrections or revisions to account information. The authorizations given by you hereunder remain in effect until you provide written notice of revocation to ThinkRite.

  9. Opting Out; Revocation of Authorization. If you wish to opt-out of receiving marketing emails from us, please follow the instructions contained in each such email you receive from us, which will allow you to opt-out of receiving further marketing emails from us. Please note, however, that any such opt-out only applies to ThinkRite and will not apply to any third parties to which we have supplied your information. Additionally, you acknowledge and agree that opt-out notification processing may not be immediate, and you agree that should you receive additional communications, your rights and remedies are limited to contacting us to reiterate your request to opt-out. You can revoke your authorizations regarding use of your information at any time by providing written notice to ThinkRite. A revocation of authorization is effective after you submit it to ThinkRite, but it does not have any effect on ThinkRite’s prior actions taken in reliance on the authorization before revoked, and does not affect ThinkRite’s use of information that does not constitute user identifiable information. You may not opt out of non-marketing emails, such as emails sent by ThinkRite or other users as part of the normal operation and use of the ThinkRite Software and its functionalities and features. If you do not wish to receive such emails, you must cease using the ThinkRite Software, remove the ThinkRite Software from your Device and request deactivation and deletion of your user account. Any third parties using the ThinkRite Software that are not registered users may continue to receive emails regardless of whether they have opted out of receiving marketing emails.

  10. Other Web Sites. Our Standard Privacy Policy only applies to our Site and ThinkRite Software.Our Site and/or the ThinkRite Software may link from several points throughout our Site or the ThinkRite Software to third party information and service providers who may collect personal information from our users in order to provide our users with information, products and/or services. Our Site content may also be featured on other websites with differing or non-existent privacy policies. These websites may collect personal information from their users that may or may not be used in conjunction with our Site information. ThinkRite has no control over the privacy policy of any third party. Please examine the privacy policies of such third parties prior to submitting any personal information, as they may differ from ours.

  11. Advertisements. Advertisements may appear on pages throughout our Site. Some advertisements may request information directly from our users or take our users to websites that may request personal information. ThinkRite has no control over its advertisers' privacy policies, so please examine the privacy policy of any third party advertising on our Site prior to submitting any personal information.

  12. Surveys. Occasionally, we may conduct surveys on our Site. Surveys are conducted at random and are completely voluntary to our Site users. The survey may require a user to provide personal information in exchange for the information or services provided by the survey. We may use this information in an aggregate manner to better tailor the type of services, information, and advertising that are provided on our Site.

  13. California Privacy Rights. Under California law, Users who are California residents may request certain information regarding the types of information shared by us with third parties for marketing purposes and the identities of those third parties. If you are a California resident, you may make such a request by sending an email to support@ThinkRite.com with “California Privacy Information Request” on the subject line and in the body of your message.

  14. Questions? How to Contact Us. Please also feel free to contact us at +1-954-653-2600 if you have any questions about this Standard Privacy Policy.



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