PRIVACY

Protecting the individuals privacy and Data Privacy procedures are important components of our strategy at Thinx!. We have created this Privacy Statement to outline how we handle information that can be used to directly or indirectly identify an individual ("Personal Data").

How thinx! Uses Information

In order to access some areas of thinx! Cloud, including Support, you will need to have an account with a username and password. As part of your account, you may choose to provide us with additional information, such as a photo and language preference.

Accessing thinx! Cloud will also assigns tokens that are aligned to your user session and are used to enforce security checks. These tokens are strictly used for security and are not retained after you logout from any of the thinx! Cloud solutions.

thinx! leverages Google Analytics which uses cookies, which are text files placed on your computer to help analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on site activity for site operators, and providing other services relating to site activity and Internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

Google has developed the Google Analytics Opt-out Browser Add-on. It provides website visitors more choice on how their data is collected by Google Analytics. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. It can be downloaded here: http://tools.google.com/

Data Uses

This section describes some of the ways in which thinx! uses the information we collect. Please note that there may be other uses, which we would describe to you at the point when we collect the information.

We use the information in our support system to determine what areas of the application you are experiencing issues and use your contact information (primarily email) to contact you if we are unable to reproduce the issue and/or need further information. Additionally we may use your information to diagnose technical problems, as well as to prevent, mitigate, and investigate potential security issues, as well as unauthorized access.

We use the information we collect to understand how our solutions are being used and to make improvements. For example, we may use the search queries entered into thinx! Cloud search bar to improve search capabilities or performance. As another example, we may use questions amount of times that certain functionality is accessed to enrich the content or help guide future enhancements to our products and services.

If you leverage our learning solutions, your enrollment and attendance information will be recorded to track your completion of courses and activities. For example, completion of specific thinx! courses and related pre-requisites will credit you with certification.

Disclosures

thinx! does not disclose any information about users and the use of our systems with other parties. No personal information, usage information or content contained in the solution is shared with other parties.

thinx! Cloud solutions require cookies and the use of tokens to maintain sessions and improve the usability of the application.

thinx! Cloud solutions do not recognize Do Not Track (DNT) signals. We will continue to monitor the standards for DNT and determine the best approach to implement within our solutions.

The thinx! Cloud platform can be used by external developers to build independent solutions. Please review all relevant privacy statements and terms when using external solutions on the platform. thinx! ensures that users know which modules/applications they are using.

thinx! will process all data based on agreements with customers and works closely with customers to ensure that a log of all data about users, employees and customers can be shared at any time. Please contact your security or privacy department in your company, should you have concerns about the use of your data and/or have not consented to your information being used in thinx! Cloud Solutions.

Security

thinx! employs reasonable and appropriate logical and physical security procedures to all information from loss, theft, misuse, unauthorized access, and unintentional disclosure, alteration, or destruction. You, as a user of the thinx! Cloud solutions, are responsible for ensuring that the security of your password when storing and using your password to access secured resources. thinx! may suspend your use of a solution without notice, pending an investigation, if any security breach is suspected.

Data Retention

We will retain your personal information and user profile only as long as needed to provide you with services or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Data entered into the thinx! Cloud is retained in accordance with the agreement between the thinx! Customers and thinx!.

EU-U.S. Privacy Shield Framework

thinx! Management, Inc. ("thinx!") 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. thinx! 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, thinx! 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 thinx! at:

By Email: info@thinxsoftware.com

By Telephone: +1 (832) 725 6391

By Mail:

thinx!
Legal Department
1544 Spring Hill Road
Suite 10506
McLean, VA, 22102, USA

thinx! has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.

thinx! also informs individuals about:

1. its participation in the Privacy Shield and provides a link to, or the web address for, the Privacy Shield List,
2. the types of personal data collected and, where applicable, the entities or subsidiaries of the organization also adhering to the Principles,
3. its commitment to subject to the Principles all personal data received from the EU and/or Switzerland in reliance on the Privacy Shield,
4. the purposes for which it collects and uses personal information about them,
5. how to contact the organization with any inquiries or complaints, including any relevant establishment in the EU and/or Switzerland that can respond to such inquiries or complaints,
6. the type or identity of third parties to which it discloses personal information, and the purposes for which it does so,
7. the right of individuals to access their personal data,
8. the choices and means the organization offers individuals for limiting the use and disclosure of their personal data,
9. [under the EU-U.S. Privacy Shield] the independent dispute resolution body designated to address complaints and provide appropriate recourse free of charge to the individual, and whether it is: (1) the panel established by DPAs, (2) an alternative dispute resolution provider based in the EU, or (3) an alternative dispute resolution provider based in the United States,
9. [under the Swiss-U.S. Privacy Shield] the independent dispute resolution body designated to address complaints and provide appropriate recourse free of charge to the individual, and whether it is: (1) the Commissioner, (2) an alternative dispute resolution provider based in Switzerland, or (3) an alternative dispute resolution provider based in the United States,
10. being subject to the investigatory and enforcement powers of the FTC, the Department of Transportation or any other U.S. authorized statutory body [currently, there is no other U.S. authorized statutory body recognized by the EU or Switzerland],
11. the possibility, under certain conditions, for the individual to invoke binding arbitration,
12. the requirement to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and
13. its liability in cases of onward transfers to third parties.

Changes to This Privacy Statement

thinx! reserves the right to change or update this Privacy Statement at any time. Changes to the Privacy Statement will be posted on the cloud.thinx!.com web site and links to the Privacy Statement will indicate that the statement has been changed or updated. We encourage you to periodically review this Privacy Statement for any changes. For new users, changes or updates are effective upon posting. For existing users, changes or updates are effective 30 days after posting.

Contacting thinx!

If you have any questions regarding our Privacy Statement, or if at any time after providing your personal information to thinx! you want to update, change, unsubscribe, or request removal or deletion of your information, or if you would like to assert any of the rights listed above, please direct your request to privacy@thinxsoftware.com or via postal mail at the contact information listed below. thinx! will respond to your request within a reasonable timeframe.

1544 Spring Hill Road
Suite 10506
McLean, VA, 22102, USA