Privacy Policy, effective July 2, 2024

 

ThinkLP, Inc. (“ThinkLP”, the “Company”, “we”) is committed to protecting the privacy of individuals who visit the Company’s Websites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to attend the Company’s corporate events (“Attendees”) (collectively, “you” or “your”). This Privacy Statement describes ThinkLP’s privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by ThinkLP (the “Services”).

This Privacy Policy applies to specific ThinkLP Services for which ThinkLP acts as a business or controller, meaning that, for the information collected for those Services, ThinkLP controls or determines how your personal information is used, processed, shared, and retained. ThinkLP does this in a manner that is consistent with this Privacy Policy, your expectations, and your privacy rights. 

This Privacy Policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to, be accessible from, or present in the Services (collectively, “Third Party Services”) where ThinkLP acts as a service provider. In those cases, the relevant ThinkLP Customer or the Third Party Services acts as the business or controller. If you have any questions about how Customers or Third Party Services collect, use, process, or disclose your personal information, please review their respective privacy policies.

1. Websites covered

In addition to the Services described above, this Privacy Policy covers the information practices of the http://www.thinklp.com and http://thinklp.cloudforce.com websites (collectively referred to as “ThinkLP’s Websites” or “the Company’s Websites”).

ThinkLP’s Websites may contain links to other websites. The information practices or the content of such other websites are governed by the privacy statements of such other websites. The Company encourages you to review the privacy statements of other websites to understand their information practices.

2. Information collected

When expressing an interest in obtaining additional information about the Services or registering to use the Services, ThinkLP requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services, ThinkLP may require you to provide the Company with financial qualification and billing information, such as billing name and address, invoicing instructions, and the number of employees within the organization that will be using the Services (“Billing Information”). ThinkLP may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information about Customers are referred to collectively as “Data About ThinkLP Customers”, or in the case of Attendees, “Data About ThinkLP Attendees”.

We also collect information automatically when you download content from us or open emails or click on links in emails from us.

As you navigate the Company’s Websites, ThinkLP may also collect information through the use of commonly-used information-gathering and tracking technology tools, such as cookies, pixels, and Web beacons (collectively, “Website Navigational Information”).  Website Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, device identifications, and may collect analytical and performance information concerning the actions you take on the Company’s Websites (such as the web pages viewed and the links clicked).

ThinkLP may derive information or draw inferences based on the information it collects. For example, ThinkLP may make inferences about a Visitor’s interests or personalize their user experience based on their industry, company, or how they interact with the Company’s Websites.

3. Use of information collected

The Company uses Data About ThinkLP Customers to perform the Services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Services.

The Company also uses Data About ThinkLP Attendees to plan and host corporate events, host online forums and social networks in which event attendees may participate, and to populate online profiles for Attendees on the Company’s Websites.  Additional information on the Company’s privacy practices with respect to Data About ThinkLP Attendees may be found in additional privacy statements on the event Websites, as the case may be.

The Company may also use Data About ThinkLP Customers and Data About ThinkLP Attendees for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events.

The Company may also use Data About ThinkLP Customers and Data About ThinkLP Attendees to:

• To process transactions and send you related information, including confirmations, receipts, invoices, and customer experience surveys;
• To personalize and improve your experience on our Services;
• To send you technical notices, security alerts, and support and administrative messages; 
• To respond to your comments and questions and provide customer service;
• To communicate with you about products, services, and events offered by us and others that we think will interest you;
• To monitor and analyze trends, usage, and activities in connection with our Services; 
• To market and promote our Services to you;
• To detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and security threats and to protect the rights and property of Company and others;
• To debug to identify and repair errors in our Services; 
• To pursue the legitimate interests listed below in Additional Disclosures for Individuals in Europe; and
• To comply with our legal and financial obligations.

ThinkLP uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information alone or in combination with Data About ThinkLP Customers and Data About ThinkLP Attendees to provide personalized information about the Company.

4. Web Site Navigational Information

This section describes the types of Website Navigational Information used on the Company’s Websites and how this information may be used.

Cookies

ThinkLP uses cookies to make interactions with the Company’s Websites easy and meaningful. When you visit one of the Company’s Websites, ThinkLP’s servers send cookie to your computer or browser. 

ThinkLP uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web sites, but certain functional or performance tools may not work, and you will not be able to successfully use the Services.

The following sets out how ThinkLP uses different categories of cookies and your options for managing cookies’ settings:

Type of Cookies	Description	Managing Settings
Required, Necessary, or Essential cookies	Required, necessary, or essential cookies enable you to navigate the Company’s Websites and use their features, such as accessing secure areas of the Websites and using ThinkLP Services.    If you have chosen to identify yourself to ThinkLP, the Company uses cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Services, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow the Company to uniquely identify you when you are logged into the Services and to process your online transactions and requests.	Because required cookies are essential to operate the Company’s Websites and the Services, there is no option to opt out of these cookies.
Performance, Analytics,  or Statistics cookies	These cookies collect information about how Visitors use our Web site, including which pages visitors go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies a Visitor. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Company’s Websites function and perform.   From time-to-time, ThinkLP engages third parties to track and analyze usage and volume statistical information from individuals who visit the Company’s Websites. ThinkLP may also utilize Flash cookies for these purposes.	To learn how to opt out of performance cookies using your browser settings click here.   To learn how to manage privacy and storage settings for Flash cookies click here.
Functionality or Preferences cookies	Functionality or preference cookies allow the Company’s Websites to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of ThinkLP’s Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.   ThinkLP uses local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Web sites to personalize your visit.	To learn how to opt out of functionality cookies using your browser settings click here. Note that opting out may impact the functionality you receive when visiting ThinkLP.   To learn how to manage privacy and storage settings for Flash cookies click here.
Targeting or Advertising cookies	From time-to-time, ThinkLP engages third parties or uses cookies delivered by third parties to track the performance of Company advertisements. For example, these cookies remember which browsers have visited the Company’s Websites.    ThinkLP also contracts with third-party advertising networks that collect IP addresses and other information from Web beacons (see below) on the Company’s Websites, from emails, and on third- party Websites. Ad networks follow your online activities over time by collecting Web Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements about ThinkLP or our Services on other websites. These cookies help us deliver advertisements we believe would be of interest to you and to manage and track the effectiveness of our marketing efforts.   Third parties, with whom the Company partners to provide certain features on our Websites or to display advertising based upon your Web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored	To learn more about these and other advertising networks and their opt out instructions, click here and here.   To learn how to manage privacy and storage settings for Flash cookies click here.

 

Web Beacons

ThinkLP uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Websites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Website tied to the Web beacon, and a description of a Website tied to the Web beacon. For example, ThinkLP may place Web beacons in marketing emails that notify the Company when you open an email or click on a link in the email that directs you to one of the Company’s Web sites. ThinkLP uses Web beacons to operate and improve the Company’s Web sites and email communications.

IP Addresses

When you visit ThinkLP’s Websites, the Company collects your Internet Protocol (“IP”) addresses. ThinkLP uses IP addresses for various reasons, including to monitor the regions from which Customers and Visitors navigate the Company’s Web sites. ThinkLP also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.

Do Not Track

Currently, various browsers – including Internet Explorer, Firefox, and Safari – offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user’s browser DNT preference setting. ThinkLP does not currently commit to responding to browsers’ DNT signals with respect to the Company’s Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. ThinkLP takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5. Public forums, refer a friend, and customer testimonials

ThinkLP may provide bulletin boards, blogs, or chat rooms on the Company’s Websites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. ThinkLP is not responsible for the personal information you choose to submit in these forums.

Customers and Visitors may elect to use the Company’s referral program to inform friends about the Company’s Websites. When using the referral program, the Company requests the friend’s name and email address. ThinkLP will send the friend an email inviting him or her to visit the Company’s Web sites.

ThinkLP may post a list of Customers and testimonials on the Company’s Websites that contain information such as Customer names and titles. ThinkLP obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

6. Disclosure of information collected

ThinkLP may disclose personal information to fulfill the purposes for which it was provided. ThinkLP may also disclose aggregated or de-identified information that cannot be reasonably used to identify the subject. ThinkLP may use de-identified data in some instances. ThinkLP either maintains such data without attempting to re-identify it or treats such data as personal data.

In addition, ThinkLP may disclose information for the following purposes:

Service Providers

ThinkLP may disclose Data About ThinkLP Customers and Data About ThinkLP Attendees with the Company’s contracted service providers so that these service providers can provide services on our behalf. Without limiting the foregoing, ThinkLP may also disclose Data About ThinkLP Customers and Data About ThinkLP Attendees with the Company’s service providers to ensure the quality of information provided, and with third- party social networking and media Web sites, such as Facebook, for marketing and advertising on those websites. 

ThinkLP uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.

ThinkLP Affiliates

The Company may disclose Data About ThinkLP Customers and Data About ThinkLP Attendees with our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership. For example, the Company may need to disclose Data About ThinkLP Customers for recovery integration purposes.

We may disclose information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, acquisition, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business.

Business Partners

From time to time, ThinkLP may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from ThinkLP, the Company may disclose Data About ThinkLP Customers collected in connection with your purchase or expression of interest with our joint promotion partner(s) at your direction. ThinkLP does not control our business partners’ use of the Data About ThinkLP Customers we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be disclosed in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.

ThinkLP does not disclose Data About ThinkLP Attendees with business partners unless: (1) you specifically opt in to such disclosure via an event registration form; or (2) you attend a Company event and allow ThinkLP or any of its designees to scan your attendee badge. If you do not wish for your information to be disclosed in this manner, you may choose not to opt in via event registration forms and elect not to have your badge scanned at Company events. If you choose to disclose your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements.

Compelled Disclosure

ThinkLP reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.  We may disclose information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

7. De-Identified Data

ThinkLP may use de-identified data in some instances. ThinkLP either maintains such data without attempting to re-identify it or treats such data as personal data subject to applicable state privacy laws.

8. Data use preferences

ThinkLP offers Visitors, Customers, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request to [email protected].

In the U.S., most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. For more information about cookies and how to disable them, see our Section 4 of this Privacy Policy (Web Site Navigational Information). In Europe, you must opt into cookies.

9. Customer Data

ThinkLP Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). ThinkLP will not review, share, distribute, or reference any such Customer Data except as provided in the ThinkLP Master Subscription Agreement, or as may be required by law. 

ThinkLP does not classify Customer Data, and all information that has been electronically submitted by Customers to the Services is considered Customer Data and is protected with the highest level of security. Customers are responsible for using the features of the Services to define adequate security access controls and data retention schedules according to their own security risk posture and internal policies and procedures. In accordance with the ThinkLP Master Subscription Agreement, ThinkLP may access Customer Data only for the purpose of providing the Services or preventing or addressing service or technical problems, or as may be required by law.

10. Retention and Security

ThinkLP may store personal data for as long as necessary to carry out the purposes for which it was originally collected and for other legitimate business purposes, including to meet the Company’s legal, regulatory, or other compliance regulations.

ThinkLP uses commercially reasonable security measures to protect Data About ThinkLP Customers and Data About ThinkLP Attendees. Because the Company uses the Services to maintain Data About ThinkLP Customers and Data About ThinkLP Attendees, this information, which is stored in the Services, is secured in the same manner as described in the Trust and Compliance documentation.

11. Mobile applications

Without limiting the generality of this Privacy Statement, in addition to information gathered through its Websites or submitted to its Services, ThinkLP may obtain information through applications (“Mobile Applications”) that Customers or their authorized individuals (“Users”) download to, and run on, their mobile devices (“Devices”). Mobile Applications provided by ThinkLP may obtain information from, or access data stored on, Users’ Devices to provide services related to the relevant Mobile Application. For example, a Mobile Application may: access a camera on a User’s Device to enable the User to upload photographs to the Services; access the call history on a User’s Device to enable the User to upload that information to the Services; access calendar information on a User’s Device to enable the User to match meeting attendees with contacts submitted by the User to the Services; or access the geographic location of a User’s Device to enable the User to identify contacts submitted by the User to the Services who are nearby. Information obtained to provide Mobile Application services may include information obtained in preparation for anticipated updates to those services. Mobile Applications may transmit information to and from Devices to provide the Mobile Application services.

Mobile Applications may provide ThinkLP with information related to Users’ use of the Mobile Application services, information regarding Users’ computer systems, and information regarding Users’ interaction with Mobile Applications, which ThinkLP may use to provide and improve the Mobile Application services. For example, all actions taken in a Mobile Application may be logged, along with associated information (such as the time of day when each action was taken). ThinkLP may also share anonymous data about these actions with third party providers of analytics services. In addition, if a User downloads a ThinkLP Mobile Application after clicking on a third-party mobile advertisement for the Mobile Application or for ThinkLP, the third-party advertiser may provide ThinkLP with certain information, such as the User’s Device identification information, which ThinkLP may use to track the performance of its advertising campaigns.

Customers may configure ThinkLP Mobile Application services, and the information accessed or obtained by the Mobile Application on a User’s Device may be affected by the Customer’s configuration. In addition, if a Customer purchases more than one Service from ThinkLP and its affiliates, a Mobile Application may be designed to interoperate with those Services; for instance, to provide a User with access to information from any or all of those Services or to provide information from a User’s Device to any or all of those Services.

Information accessed or obtained by the Mobile Application on a User’s Device may be accessible to the Customer and its organization, depending on the intended functionality of the Mobile Application.

Notices and contractual terms related to a particular Mobile Application may be found in the End User License Agreement or relevant terms of service for that application. The Company encourages you to review the End User License Agreement or relevant terms of service related to any Mobile Applications you download, install, use, or otherwise interact with to understand that Mobile Application’s information practices. The Mobile Application’s access to information through a User’s Device does not cause that information to be “Customer Data” under ThinkLP’s Master Subscription Agreement with the Customer or under this Privacy Statement, except as follows: To the extent that a User uses a Mobile Application to submit electronic data and information to a Customer account on our Services pursuant to the Customer’s Master Subscription Agreement with ThinkLP (or a similar agreement that governs the Customer’s subscription(s) to ThinkLP’s Services), that information constitutes “Customer Data” as defined in such agreement, and the provisions of that agreement with respect to privacy and security of such data will apply.

12. International transfer of information collected and Additional Disclosures for Individuals in Europe

The Company primarily stores Data About ThinkLP Customers and Data About ThinkLP Attendees in the United States. To facilitate ThinkLP’s global operations, the Company may transfer and access such information from around the world, including from other countries in which the Company has operations. This Privacy Statement shall apply even if ThinkLP transfers Data About ThinkLP Customers or Data About ThinkLP Attendees to other countries. ThinkLP will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including putting appropriate safeguards in place such as standard contractual clauses approved under applicable data protection laws.

Additional Disclosures for Individuals in Europe

If you are located in the EU, UK, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal information or data.

When we process your personal information, we will do so in reliance on one or more of the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
• To pursue our “legitimate interests” in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you and our customers (e.g., to provide, maintain, personalize, enhance and improve our Services, to monitor and analyze trends, usage, and activities in connection with our Services, to enforce our policies and comply with legal obligations, to comply with marketing opt-outs and unsubscribes, to defect, monitor, and prevent fraud or other unlawful acts, or to communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents, track those who have opted out of marketing communications, and comply with other regulatory obligations).
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Where we are processing personal data on behalf of our Customers, the Customer is the Controller and ThinkLP is a Processor, as those terms are defined under the applicable privacy laws. You are encouraged to review the Customer’s privacy policy directly for information concerning the collection, use, and processing of your personal data.

Subject to certain limitations, you have the following privacy rights:

• Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information.  This enables you to receive a copy of the personal information we hold about you and certain other information about it.
• Correction: you are entitled to request that any incomplete or inaccurate information we hold about you is corrected.
• Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
• Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Portability: you may ask us to help you transfer certain of your personal information to another party.
• Objection: where we are processing your personal data based on a legitimate interest (or those of a third party), you may challenge this. However, we may be entitled to continue processing your information in case there are compelling legitimate grounds to do so. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
• Consent: where we are processing personal data with consent, you can withdraw your consent.

If you would like to exercise any of these rights, please contact us at [email protected].

Supervisory Authorities & Right to Lodge a Complaint

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. 

Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

13. Changes to this Privacy Statement

ThinkLP reserves the right to change this Privacy Statement. 

14. Contacting us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to ThinkLP Privacy at [email protected]