Privacy Policy

Your privacy is important to us. This privacy statement explains what personal data ThinkRIT collects from you, through our interactions with you and through our software products and services (also referenced as “Services“), and how we use that data.

ThinkRIT (also referred as “Company”) offers a wide range of products and services under these Terms Of Use. References to Company Services in this statement include Company services, websites, applications and any other company software that you may use directly or not.  This Privacy Policy statement applies to all ThinkRIT ‘s Services interactions with you unless otherwise stated and covers:

• the information we collect about you when you use our Services and why we collect it;
• how we use and share that information;
• and some of the features that we’ve built into our Services to protect your privacy.

Last updated: Oct 1^st, 2017

Recent Changes

• Explanatory examples of applied policies related to the personal data collection added.

When this policy applies

Our Privacy Policy applies to all of the Services offered by ThinkRIT and its affiliates. It does not apply to services offered by other companies or individuals, including products or services that may be displayed to you in search results, through other bots that you interact or elsewhere.

Compliancy, Data Transfers & Storage

ThinkRIT makes a continuous effort to comply with the EU GDPR legislation, as well as with the U.S. Privacy Shield Framework regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

Unless otherwise stated, ThinkRIT is a data controller for personal data we collect through the Services subject to this statement.

If third-party agents process personal data on our behalf in a manner inconsistent with the principles of our Privacy Policy or EU GDPR we remain liable unless we prove we are not responsible for the event giving rise to the damage.

If there is any conflict between the terms in this privacy policy and the EU GDPR, the EU GDPR shall govern. To learn more about the EU GDPR, please visit http://www.eugdpr.org

For any complaints related to the privacy policy that cannot be resolved with Company directly, we have chosen to cooperate with the relevant Data Protection Authority, or a panel established by the European DPAs for resolving disputes. Please contact us to be directed to the relevant DPA contacts. Binding arbitration is available to address residual complaints not resolved by other means.

 

Data Process, Transfers & Storage

Personal data collected by ThinkRIT may be stored and processed anywhere in the globe where ThinkRIT or its affiliates, subsidiaries or service providers maintain facilities. Our servers and our service providers may be located in Europe, in the United States, Canada or other countries.  Because of this, your personal information may be available to the U.S., Canadian or other government or its agencies under a lawful order made in that country.  The laws of those countries may be less strict regarding your personal information than the laws where you live.

Typically, the primary storage location is in the customer’s region often with a backup to a data center in another region, but this depends on the Services global availability and allocated resources. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.

In case that we need to transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, we proceed using a variety of legal tools and mechanisms, including contracts, to help ensure your rights and protections travel with your data.

 

Data collection (information we collect)

ThinkRIT collects data to operate effectively and provide you the best experiences with our Services. You provide some of this data directly, such as when you create, administer or interact with our Services, e.g. submit a search query, register for a Company event, speak a voice command to a bot, upload some information through our Services or contact us for support. We get some of it by recording how you interact with our products by, for example, using technologies like cookies and receiving error reports or usage data from software running on your device.

More specifically, we collect:

Information you give us

We collect some content and other information you provide when you use our Services. It is important to understand that ThinkRIT Services collect information or data that is voluntarily supplied by you. The data we collect depends on the context of your interactions with ThinkRIT Services, the choices you make, including your privacy settings, and the products and features you use.

For example, when you sign up for an account or message or communicate with others, including our support team, you may give us your name, username, email address, phone number, address, birth date, contact preferences, photos and gender. In limited circumstances, we may ask you for government issued ID to validate your identity when you are requesting support or to confirm that you’re eligible to use our Services or as required by law. Users can also report violations of our Terms of Service to our support team and they may include the content of your chat in those reports.

You always have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a service, product or feature, you may not be able to use that service product or feature.

We also continuously try to make it easier to understand the types of information we collect from you when you use our services, how we use it and when we share it.

Information we get from your use of our Services.

The data we collect depends on the context of your interactions with Company, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include the following:

Personal information

Name and contact data. We may collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We may collect passwords, password hints, and similar security information used for authentication and account access.

Demographic data. We may collect data about you such as your age, gender, country, and preferred language.

Device and Usage data

In order to improve the quality and efficiency of our Services, your experience (including by showing you relevant ads) and to develop new services, we may collect data about your device and how you and your device interact with Company and our products.  Device-specific information may include your hardware model, operating system version, unique device identifiers or advertising IDs, and mobile network information including phone number if applicable. In some cases, this information will be associated with your Service specific account. For example, we may collect:

• Product use data. We collect data about the features you use, the items you purchase, and the web pages you visit. This data includes your voice and text search queries or interactions (e.g. commands) with our Services, (e.g. our chat bots). This also includes the settings you select and the software configurations your use most.
• Device, connectivity and configuration data. We collect data about your device and the network you use to connect to our products. It includes data about the operating systems and other software installed on your device, including product keys. It also includes IP address, device identifiers (such as the IMEI number for phones), regional and language settings.
• Log information. When you use our Services, we may automatically collect and store certain information in our server logs including details of how you used our Services, such as the date and time a message was sent, the account you were messaging with, and your internet protocol address, as well as third party websites or services you used (your chats with bots as well as your use of GIFs or emojis).
• Error reports and performance data. We collect data about the performance of the products and any problems you experience with them. This data helps us to diagnose problems in the products you use, and to improve our products and provide solutions. Depending on your product and settings, error reports (sometimes called “crash dumps”) can include data such as the type or severity of the problem, details of the software or hardware related to an error, contents of files you were using when an error occurred, and data about other software on your device.
• Troubleshooting and Help Data. When you engage Company for troubleshooting and help, we collect data about you and your hardware, software, and other details related to the incident. Such data includes contact or authentication data, the content of your chats and other communications with Company, data about the condition of the machine and the application when the fault occurred and during diagnostics, and system and registry data about software installations and hardware configurations.

 

Interests and favorites.

We collect data about your interests and favorites, such as the type of products that you order through a trading app, or the favorite locations you add for delivery of goods, the communication languages you prefer, the traders that you have business with etc. In addition to those you explicitly provide, your interests and favorites may also be inferred or derived from other data we collect.

 

Contacts information.

We may use the information from your mobile device’s address book from time to time to connect you with other users of our Services and to allow those who have you in their address book to be able to find and get connected with you. We may collect data about your contacts and relationships if you use Company Services to manage contacts.

Content (e.g. Bot chats)

If you chat with bots made by ThinkRIT (such as TrfBot for example), we may collect the contents of your conversation to improve your experience and our Services or create new ones. If you are chatting with other bots through our Services, those bot developers may share your conversation with ThinkRIT to improve our Services or create new ones.

 

Location data.

We may collect information on where Services are used to ensure that we can deliver products or services to you or limit advertising or promotions to certain geographic areas. For products with location-enhanced features, we collect data about your location, which can be either precise or imprecise. Precise location data can be Global Navigation Satellite System (GNSS) data (e.g., GPS), as well as data identifying nearby cell towers and Wi-Fi hotspots, we collect when you enable location-based products or features. Imprecise location data includes, for example, a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level.

 

Cookies, Local storage & Similar Technologies

We or our service providers (such as analytics providers) may collect, store or recognize some information on your computer or mobile phone from technologies such as cookies and web beacons.

ThinkRIT uses cookies (small text files placed on your device) and similar technologies to provide our websites and online services and to help collect data. Cookies allow us, among other things, to store your preferences and settings; enable you to sign-in; provide interest-based advertising; combat fraud; and analyze how our websites and online services are performing. Company apps use other identifiers, such as the advertising ID in Windows described in the Windows section of this statement, for similar purposes.

We may collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

You have a variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. Your browser and other choices may impact your experiences with our products.

Company uses cookies (small text files placed on your device) and similar technologies to provide our websites and online services and to help collect data. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your computer, but it can contain other information as well. Company apps use additional identifiers for similar purposes, and our websites and applications may also contain web beacons or other similar technologies, as described below.

Our Use of Cookies and Similar Technologies

Company may use cookies and similar technologies for several purposes, depending on the product, including:

• Storing your Preferences and Settings. Settings that enable our products to operate correctly or that maintain your preferences over time may be stored on your device. For example, if you enter your city or postal code to get local news or weather information on a Company website, we may store that data in a cookie so that you will see the relevant local information when you return to the site. We also save preferences, such as language, browser and multimedia player settings, so those do not have to be reset each time you return to the site. If you opt out of interest-based advertising, we store your opt-out preference in a cookie on your device.
• Sign-in and Authentication. When you sign into a website using your personal account, we may store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.
• Security. We may use cookies to detect fraud and abuse of our websites and services.
• Storing Information you Provide to a Website. When you provide information, or add products to a shopping cart when shopping on Company websites, we may store data in a cookie to facilitate interaction, e.g. to remember the products and information you have added.
• Social Media. Some of our websites may include social media cookies, including those that enable users who are logged in to the social media service to share content via that service.
• Feedback. Company may use cookies to enable you to provide feedback on a website.
• Interest-Based Advertising. Company may use cookies to collect data about your online activity and identify your interests so that we can provide advertising that is most relevant to you. You can opt out of receiving interest-based advertising from Company as described in this privacy statement.
• Showing Advertising. Company may use cookies to record how many visitors have clicked on an advertisement and to record which advertisements you have seen so you don’t see the same one repeatedly.
• Analytics. In order to provide our products, we may use cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a web page or service and to develop other statistics about the operations of our products. This includes cookies from Company and from third-party analytics providers.
• Performance. Company may use cookies for load balancing to ensure that websites remain up and running.

Some of the cookies we commonly use are listed below. This list is not exhaustive, but it is intended to illustrate the main reasons we typically set cookies. If you visit one of our websites, the site may set some or all of the following cookies:

• MUID – Identifies unique web browsers visiting Company sites. It is used for advertising, site analytics and other operational purposes.
• ANON – Contains the ANID, a unique identifier derived from your Company account, which is used for advertising, personalization, and operational purposes. It is also used to preserve your choice to opt out of interest-based advertising from Company if you have chosen to associate the opt-out with your Company account.
• CC – Contains a country code as determined from your IP address.
• PPAuth, MSPAuth, MSNRPSAuth, KievRPSAuth – Helps to authenticate you when you sign in with your Company account.
• NAP – Contains an encrypted version of your country, postal code, age, gender, language and occupation, if known, based on your Company account profile.
• MH – Appears on co-branded sites where Company is partnering with an advertiser. This cookie identifies the advertiser, so the right ad is selected.
• MR – Used to collect information for analytics purposes.
• TOptOut – Records your decision not to receive interest-based advertising delivered by Company.

In addition to the cookies Company sets when you visit our websites, third parties may also set cookies when you visit Company sites. In some cases, that is because we have hired the third party to provide services on our behalf, such as site analytics. In other cases, it is because our web pages contain content or ads from third parties, such as videos, news content or ads delivered by other ad networks. Because your browser connects to those third parties’ web servers to retrieve that content, those third parties are able to set or read their own cookies on your device and may collect information about your online activities across websites or online services.

How to Control Cookies

Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. For example, in Company Edge, you can block or delete cookies by clicking Settings > Privacy > Cookies. Instructions for blocking or deleting cookies in other browsers may be available in each browser’s privacy or help documentation.

Most browsers allow to refuse to accept cookies; for example:

(a) in  Internet  Explorer  (version  11)  cookies  are  blocked  using  the  cookie handling  override  settings  available  by  clicking  “Tools”,  “Internet  Options”, “Privacy” and then “Advanced”;

(b) in  Firefox  (version  36)  the  user  can  block  all  cookies  by  clicking  “Tools”, “Options”,  “Privacy”,  selecting  “Use  custom  settings  for  history”  from  the drop down menu, and unticking “Accept cookies from sites”; and

(c) in Chrome (version 41) cookies can be blocked by accessing the “Customise and  control”  menu,  and  clicking  “Settings”,  “Show  advanced  settings”  and “Content  settings”,  and  then  selecting  “Block  sites  from  setting  any  data” under the “Cookies” heading.

Cookies that have already been saved can also be deleted, for example:

(a) in Internet  Explorer  (version  11),  cookie  files  must  be  deleted  manually (instructions under http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);

(b)  in Firefox (version 36), click “Tools”, “Options” and “Privacy”, then select “Use custom  settings  for  history”  from  the  drop-down  menu,  clicking  “Show Cookies”, and then clicking “Remove All Cookies”; and

(c) in  Chrome  (version  41),  access  the  “Customize  and  control”  menu,  and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.

Certain features of Company products depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.

Additional privacy controls that can impact cookies, including the Tracking Protection feature of Company browsers, are described in this privacy statement.

Our Use of Web Beacons and Analytics Services

We also use web beacons to help deliver cookies and gather usage and performance data. Our websites may include web beacons and cookies from third-party service providers.

Company web pages may contain electronic images known as web beacons (also called single-pixel gifs) that we use to help deliver cookies on our websites, count users who have visited those websites and deliver co-branded products. We also include web beacons in our promotional email messages or newsletters to determine whether you open and act on them.

In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us develop statistics on how often clicking on an advertisement on a Company website results in a purchase or other action on the advertiser’s website.

Finally, Company products often contain web beacons or similar technologies from third-party analytics providers, which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites or other products. However, we prohibit these analytics providers from using web beacons on our sites to collect or access information that directly identifies you (such as your name or email address). You can opt out of data collection or use by some of these analytics providers by clicking the following links:

• AppsFlyer
• Flurry Analytics
• Google Analytics (requires you to install a browser add-on)
• Kissmetrics
• Mixpanel
• Nielsen
• Omniture (Adobe)
• Visible Measures:
• WebTrends

Other Similar Technologies

In addition to standard cookies and web beacons, our products can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. But, like standard cookies, these technologies can also be used to store a unique identifier for your computer, which can then be used to track behavior. These technologies include Local Shared Objects (or “Flash cookies”) and Silverlight Application Storage.

Local Shared Objects or “Flash cookies.” Web sites that use Adobe Flash technologies can use Local Shared Objects or “Flash cookies” to store data on your computer. To manage or block Flash cookies, go to Flash Player Settings

Silverlight Application Storage. Web sites or applications that use Company Silverlight technology also have the ability to store data by using Silverlight Application Storage. To learn how to manage or block such storage, see the Silverlight section of this statement.

 

Information shared by others

We may use third-party analytics companies (such as Google Analytics and Nielsen). The information collected by these third-parties may be used for purposes disclosed in their privacy policies, and by us to develop and deliver advertising and promotional content within our Services.

We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time, but have included:

• Data brokers from which we purchase demographic data to supplement the data we collect.
• Social networks when you grant permission to a Company product to access your data on one or more networks.
• Service providers that help us determine a location based on your IP address in order to customize certain products to your location.
• Partners with which we offer co-branded services or engage in joint marketing activities, and
• Publicly-available sources such as open government databases or other data in the public domain.

We may also combine the information described above with other information we collect about you.

Content

We collect content of your files and communications when necessary to provide you with the Services you use and according to your interaction channel. For example, if you upload transmit a file using Skype to one of our chat bots, we may need to collect the content of that file to display it to you, enable you to reply to it, and store it for you until you choose to delete it. Other data we collect to provide communication services to you include the:

• subject line and body of an email,
• text or other content of an instant message,
• audio and video recording of a video message, and
• audio recording and transcript of a voice message you receive or a text message you dictate.

If you enable the use of cookies or similar technologies, ThinkRIT collects Customer Data (including content), Support Data, and Administrator Data, defined below in the relevant section.

We also collect information you provide to us and the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded. If you enter our retail stores or other facilities, your image may be captured by our security cameras.

Product-specific sections below may specialize further the Privacy Policy and Terms of Use and describe data collection practices applicable to use of those products.

We collect information to provide you with the Services, to improve your experience using the Services and develop new services.

Payment data

We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.

You may also be given the opportunity to complete payments in ThinkRIT through a third party payment processor. In such cases, your credit card information, if you choose to enter it, is held by this third party and not by ThinkRIT.

 

Data Use (How we use information)

Your data is stored in our secured servers. Some of your data may be sent to vetted third parties to assist with providing you with ThinkRIT services. Separately, we retain the right to share data with government agencies to satisfy applicable law, regulation, legal process or enforceable governmental request.

ThinkRIT does NOT sell your data individually or in aggregated form.

Your data help us to customize our Services to your needs

Access to your data allows ThinkRIT to learn your preferences which helps your automated assistant provide you with the best experience.

• Provide, improve and develop our Services.We use information we have to deliver and enhance our Services, personalize content, and make suggestions to you. For example, we use some registration information to: (a) set up a profile page for you; and (b) help connect you with friends or partners (unless you change this in your settings).
• Communicate with you.The information we collect lets us keep you posted on ThinkRIT latest product announcements, software updates, upcoming events and any messages you have waiting on ThinkRIT if you haven’t been active for a while. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences.
• Show and measure ads and Services.We use information to improve our advertising and measurement systems so that we can show you relevant ads on our Services and measure the effectiveness and reach of the ads and services. Learn more about how to control information about you that is used to personalize the ads here.
• Promote Safety and Security.We may use your information, including date of birth, to verify identity, to determine eligibility to use the Services, and to recommend appropriate Services. We also use information for loss prevention and anti-fraud purposes and to enforce our Terms of Service.

Company uses the data we collect for three basic purposes, described in more detail below: (1) to operate our business and provide (including improving and personalizing) the products we offer, (2) to send communications, including promotional communications, and (3) to show advertising, whether in our own products supported by advertising like MSN and Bing, or in products offered by third parties.

In carrying out these purposes, we combine data we collect to give you a more seamless, consistent and personalized experience. For example, cookies can use your favorite location of requesting a delivery using our Services, and we may use information about the apps and services you use not only to provide information relevant to your interests, but to optimize the whole procedure to your benefit. However, to enhance privacy, we have built in technological and procedural safeguards designed to prevent certain data combinations. For example, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address or phone number.

Providing and improving our products

We use data to provide and improve the products we offer and perform essential business operations. This includes operating the products, maintaining and improving the performance of the products, developing new features, conducting research, and providing customer support. Examples of such uses include the following:

• Providing the Products. We use data to carry out your transactions with us and to provide our products to you. Often, those products include personalized features and recommendations that enhance your productivity and enjoyment, and automatically tailor your product experiences based on the data we have about your activities, interests and location.
• Customer support. We use data to diagnose product problems, repair customers’ devices, and provide other customer care and support services.
• Product activation. We use data—such as device and application type, location, and unique device, application, network and subscription identifiers—to activate software and devices that require activation.
• Product Improvement. We use data to continually improve our products, including adding new features or capabilities. For example, we use error reports to improve security features, search queries to improve the relevancy of the search results, usage data to determine what new features to prioritize.
• Security, Safety and Dispute Resolution. We use data to protect the security and safety of our products and our customers, to detect and prevent fraud, to confirm the validity of software licenses, to resolve disputes and enforce our agreements. Our security features and products can disrupt the operation of malicious software and notify users if malicious software is found on their devices. For example, we may scan content in an automated manner to identify suspected spam, viruses, abusive actions, or URLs that have been flagged as fraud, phishing or malware links; and we may block delivery of a communication or remove content if it violates our terms.
• Business Operations. We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.

Communications

We use data we collect to communicate with you and personalize our communications with you. For example, we may contact you by phone or email or other means to inform you when a subscription is ending, discuss your licensing account, let you know when security updates are available, remind you about items left in your online shopping cart, update you or inquire about a service or repair request, invite you to participate in a survey, or tell you that you need to take action to keep your account active. Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from Company by email, SMS, physical mail, and telephone. For information about managing your contact data, email subscriptions and promotional communications, please visit the “Cookies & similar technologies” section of this privacy statement.

Advertising

Company does not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files to target ads to you.

We use data we collect through our interactions with you, through some of our products and on third-party web properties, to show advertising. For example:

• Company may use your data to select and deliver some of the ads you see on Company web properties
• When the advertising ID is enabled in Windows 10 as part of your privacy settings, Company apps can access and use the advertising ID (much the same way that websites can access and use a unique identifier stored in a cookie) to select and deliver ads in such apps.
• We may share data we collect with third parties, such as Oath, AppNexus, or Facebook (see below), so that they can select and deliver some of the ads you see in our products, their products, or other sites and apps serviced by these partners.
• Advertisers may choose to place our “Cookies & similar technologies” on their sites in order to allow Company to collect information on their sites such as activities, purchases and visits; we use this data on behalf of our advertising customers to help target their ads. We also share data directly with service providers, such as Oath, AppNexus, or Facebook, to permit them to provide services on our behalf or to partner with us in selecting and serving ads for our advertising partners.

The ads that you see may be selected based on data we process about you, such as your interests and favorites, your location, your transactions, how you use our products, your search queries, or the content you view. For example, if you search for a particular Make Code using our Services automobiles, we may show advertisements about cars of that particular manufacturer.

The ads that you see may also be selected based on other information learned about you over time using demographic data, location data, search queries, interests and favorites, usage data from our products and sites, as well as the sites and apps of our advertisers and partners. We refer to these ads as “interest-based advertising” in this statement. To provide interest-based advertising, we combine cookies placed on your device using information that we collect (such as IP address) when your browser interacts with our websites. If you opt out of receiving interest-based advertising, data associated with these cookies will not be used.

Further details regarding our advertising-related uses of data include:

• Advertising Industry Best Practices and Commitments. ThinkRIT adheres to the following self-regulatory programs:
  • In the US: Digital Advertising Alliance (DAA)
  • In Europe: European Interactive Digital Advertising Alliance (EDAA)
  • In Canada: Ad Choices: Digital Advertising Alliance of Canada (DAAC) / Choix de Pub: l’Alliance de la publicité numérique du Canada (DAAC)
• Health-Related Ad Targeting. In the United States, we provide interest-based advertising based on a limited number of standard, non-sensitive health-related interest categories, including allergies, arthritis, cholesterol, cold and flu, diabetes, gastrointestinal health, headache / migraine, healthy eating, healthy heart, men’s health, oral health, osteoporosis, skin health, sleep, and vision / eye care. We will also target ads based on custom, non-sensitive health-related interest categories as requested by advertisers.
• Children and Advertising. We do not deliver interest-based advertising to children whose birthdate in their Company account identifies them as under 18 years of age.
• Data Retention. For interest-based advertising, we retain data for no more than 13 months, unless we obtain your consent to retain the data longer.
• Data Sharing. In some cases, we share with advertisers reports about the data we have collected on their sites or ads.
• Data Collected by Other Advertising Companies. Advertisers sometimes include their own privacy statements and terms of Use, (or those of their other advertising partners) within their advertisements that we display, enabling them to set and read their own policies. Additionally, Company partners with third-party ad companies to help provide some of our advertising services, and we also allow other third-party ad companies to display advertisements on our sites. These third parties may place cookies on your computer and collect data about your online activities across websites or online services.
• You may find more information on each company’s practices, including the choices it offers, in their corresponding web sites. Many of them are also members of the

NAI or DAA, which each provide a simple way to opt out of ad targeting from participating companies.

Retention Policy of Personal Data

ThinkRIT may retain personal data for as long as necessary to provide the products and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The criteria used to determine the retention periods include:

• How long is the personal data needed to provide the products and operate our business? This includes such things as maintaining and improving the performance of those products, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods.
• Do customers provide, create, or maintain the data with the expectation we will retain it until they affirmatively remove it? Examples include a purchase request, or a message you sent us in a conversation. In such cases, we maintain the data until you actively delete it.
• Is there an automated control, such as in the Company privacy dashboard, that enables the customer to access and delete the personal data at any time? If there is not, a shortened data retention time will generally be adopted.
• Is the personal data of a sensitive type? If so, a shortened retention time would generally be appropriate.
• Has Company adopted and announced a specific retention period for a certain data type?
• Has the user provided consent for a longer retention period? If so, we will retain data in accordance with your consent.
• Is Company subject to a legal, contractual, or similar obligation to retain the data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.

Information we share

We may share your information if you ask us to. For example, if you post content on social networking sites using our Services, we will provide your content as you’ve requested. The information you choose to share on social networking sites is not covered by this privacy policy, and you agree that you are solely responsible for your use of those sites.

We may share your non-personal, aggregated information with third party advertisers.

We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. For example, we share your content with third parties when you tell us to do so, such as when you send a purchase request to a partner through our Services. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.

In addition, we share personal data among Company-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

We do not share, sell or transfer your personal information without your consent, except as described below:

• Third Party products and services.Bots, gifs, emojis, smileys and web pages may be operated by third-party advertisers.  When you deal with these third-parties through ThinkRIT, they and other users of these bots or web pages may be able to see your user profile and the content of messages you are sharing on bots or web pages, and sometimes, your approximate location. They may use this information as described in their privacy policies, which can include advertising.

Also, we may share limited information with advertisers who are interested in presenting you with a tailored offer based on the content of your interactions with our Services. For example, we may provide the approximate location associated with your IP address (i.e. country and state/province), your age or age range and your gender so that you’ll receive more relevant offers. We do not share your username or email address with advertisers without your consent.

• Our service providers.We use third-party service providers to help operate our business. Examples include suppliers that host our data or provide customer service.  Use of your personal information by our service providers is limited to the information they need to provide services on our behalf. For more information about how these service providers treat your personal information, contact us at the address shown on the “Privacy Questions – How to contact us” paragraph below.

 

§  Our related companies. We may share some or all of your information with our related companies, including our affiliates, subsidiaries, or joint ventures who are also required to honor this privacy policy.

• To protect our Services and their users

We may disclose your information to protect our customers, for example to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone;

if we believe that disclosure is needed to protect your safety or the safety of others, including when there is an emergency involving potential harm, loss of security or serious injury to people or threats of such emergencies.

 

• , or for legal purposes. 

We may disclose your information to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies:

(a) if we think it’s needed to detect, prevent or address illegal activity on our Services, or identify, contact or bring legal action against someone who appears to be causing injury to or interfering with our rights or property or other users;

(b) as part of a legal matter or investigation, including an investigation related to a suspected breach of our Terms of Service;

(c) when we believe that disclosure is required or permitted by law, including when responding to subpoenas, warrants, production orders, or similar instruments; or

• Merger, financing or sale.We may share or sell your information in connection with a merger, financing, acquisition, dissolution transaction, bankruptcy or proceeding involving sale, transfer, divestiture of all or a portion of our business or assets. If another company acquires our business or assets, that company will have your information collected by us and will assume the rights and obligations regarding your information as allowed by this privacy policy.

Finally, we will access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to:

1. operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks; or
2. protect the rights or property of Company, including enforcing the terms governing the use of the services – however, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of Company, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.

Please note that some of our products may include links to products of third parties whose privacy practices differ from Company’s. If you provide personal data to any of those products, your data is governed by their privacy statements.

 

Access Control (Safety & security)

ThinkRIT is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the Internet, we protect it through the use of encryption.

Access of your personal information is restricted to certain ThinkRIT employees, contractors, and agents who need to know that information in order to process it for us. All of these individuals are subjected to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

We also store, use, and maintain your personal information using procedures designed to limit its loss, theft, or unauthorized access, use, modification, copying or disclosure. When you enter your login information (such as username and password) on ThinkRIT Services, we encrypt the transmission of that information between the app and the server. As well, when applicable, we have contracts in place with our third party suppliers that obligate such suppliers to protect the confidentiality of your personal information. Despite these efforts, you should know that we cannot fully eliminate security risks associated with information. You are also responsible for helping to protect the security of your information and having a strong password that you’ve not used in other places is important.

User Access to information

You can access and update your information by going to the “Your Account” section on services with such a functionality. You can also request access, updating and corrections of inaccuracies in other personal information we have by emailing or writing to us at privacy@thinkrit.gr.  We may ask you for certain information in order to verify your identity.

 

Children

Generally, ThinkRIT Services are meant to be used only by adults. Children under 18 are not permitted to use ThinkRIT Services or even to create accounts.

 

Notices to End Users

Company accounts

Many Company products are intended for use by organizations and are administered to you by your organization. Your use of Company products may be subject to your organization’s policies, if any. If your organization is administering your use of the Company products, please direct your privacy inquiries to your administrator. When you use social features of such products, other users in your network may see some of your activity. To learn more about the social features and other functionality, please review documentation or help content specific to the Company product. Company is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.

If you use an email address provided by an organization you are affiliated with, such as an employer or school, to access Company online services, the owner of the domain (e.g., your employer) associated with your email address may: (i) control and administer your Company online services account and (ii) access and process your data, including the contents of your communications and files.

Changes to This Privacy Statement

We will update this privacy statement when necessary to reflect customer feedback and changes in our products. When we post changes to this statement, we will revise the “last updated” date at the top of the statement and describe the changes in the Recent Changes sections. If there are material changes to the statement or in how Company will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how Company is protecting your information.

How to contact us

Our address is

Think RIT Ltd

Persefonis 1,

15344 Gerakas

Greece

Email: privacy@thinkrit.gr

If you have any questions, comments, complaints or suggestions, regarding this privacy policy please contact us; we will respond to questions or concerns within 30 days from the reception of your communication.

Be sure to check back often for the latest information on our privacy practices. When we update this Privacy Policy we will change the “Last Updated” date above.

If you have a technical or support question, please visit our relevant web page.

Privacy Questions

Any user who has provided personal data to any form of interaction with ThinkRIT and as such has established a business relationship may request information about whether ThinkRIT has disclosed personal information to any third parties and for what purpose. In general, if ThinkRIT has made such a disclosure of personal data, upon receipt of a request by the user, ThinkRIT will provide a list of all third parties to whom personal data was disclosed, as well as a list of the categories of personal data that were disclosed.

Any questions related to our Privacy Policy may be addressed to ThinkRIT by email at privacy@thinkrit.gr