Privacy Policy

Effective May 25, 2018

This privacy policy describes how ThinkRight App (which are collectively referred to as the “Company”, “we”, “us” or “our”) collects and processes the information you provide in connection with your use of the ThinkRight App™ websites and services, including any ThinkRight® mobile applications (the “Mobile Software”), and the ThinkRight® website at www.ThinkRight.Me (the “Website” or “Site”, and together with the Mobile Software, the “Service” and collectively, our “Services”).

It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. You can find additional tools and information in the Settings.

What information does ThinkRight collect from me?

 

Collection and Use of Personal Information

In order to provide the [Services], we collect and process certain information about you.

The type of information that we collect depends on how you use our Products. You can learn how to access and delete information that we collect by visiting the Settings

We collect the following information from you:

  • Information and content, you provide.During your use of our Services, you provide us with various kinds of information as set out below. We use this information to enable us to provide the Services to you.
    • Whenever you create an account to use our Services, you provide us with some personal data to allow us to provide our services to you. This data includes user profile information like Name, Gender, Mobile no, Date of Birth, Email and profile picture provided by you.
    • When you use our Services, you provide us with certain information which we collect and process. This information includes information and content you share on our platforms such as status updates, photographs, and other data. In addition to the same we collect information related to the content that you provide such as the date of creation of the content, location of such content, device used to upload such content, version of the ThinkRight App used, and other metadata related to such content. We also record and collect information of the actions you perform while using our Services, such as [likes, shares, comments on information/content shared by others]. Similarly, any information about you, shared by other users, during their use of our Services is also received and collected by us.
    • Some information that you share is public in nature, including your profile information, account creation date, and your public updates. Similarly, certain information in relation to your public updates like the date, time, and application and version of ThinkRight App you used, and you may elect to disclose publicly your location and the location of your public updates. Similarly, the groups you are part of, the accounts you follow, or accounts that follow you] are also public. Information about you shared by other users who use our services may also be public. You are responsible for your public updates and other information you provide through our services, and you should think carefully about what you make public, especially if it is sensitive information.
    • To use our Services, you may instead of creating an account directly, you may connect and sign up with an account of yours with another service provider such Twitter, Google, or Facebook. You may also connect your account with us to these other services. In such cases we will receive information from those services such as your email address, friends, or contacts list.
    • If you email or contact us, the content of your message, your email address, and Your other contact information, would be stored by us to respond to your request.
    • Sensitive Data: If you provide us with sensitive data such as such as race, religion, politics, sex life, or health, you allow us to collect and process such information. Depending on the laws of your country, you will be entitled to any special protection afforded to such sensitive data.
  • Information about your use of our Services.We also receive and collect information about the manner in which you use our Services as set out below, and we use such information to operate or personalize our services and ensure their secure, reliable, and robust performance. Such information enables us to make inferences, understand the use of our Services and therefore allows us to improve our content, better design our services for you and make it more meaningful and relevant for you. It also allows us to make suggestions about people you would know, content you would like and features that you would be interested in.
    • Each time you use our Services, we collect certain information in about how you use our Service. This includes information about the type, nature and substance of content you view or engage with, the various features you use, the different action that you take, other users or accounts or that you engage and interact with. We also receive information about the frequency, the length of time and the periodicity of such viewing, actions, engagements, interactions, and use.
    • We receive information about the links (internal and third party) which you interact with across our Services, and we also receive information about how you interact with these links.
      In addition to the above, when you use our Services we also receive information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information.
  • Information about transactions made.We do not capture or store any kind of payment information including your credit or debit card number, card expiration date, CVV code, and billing address, in order to make in app purchases or purchase other offerings provided as part of our Services.
  • Information about and from your Device.We receive and collect information about and from each of the devices you use, to access and use our Services. We use this information either by itself or in combination with other information about you that we have received or collected, to personalize and improve our content, better design our services for you and make it more meaningful and relevant for you. Information that we obtain from these devices includes:
    • Device attributes:information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
    • Device operations:information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
    • Identifiers:unique identifiers, device IDs and other identifiers, such as from games, apps or accounts that you use.
    • Device signals:Bluetooth signals, information about nearby Wi-Fi access points, beacons and mobile phone masts.
    • Data from device settings:information that you allow us to receive through device settings that you turn on, such as access to your GPS location, camera or photos, other apps installed on your device.
    • Network and connections:information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.
    • Cookie data:data from cookies stored on your device, including cookie IDs and settings.
  • Information about you from partners.We work with various partners, such as advertisers, vendors, service providers, developers, third parties whose APIs are integrated with our Services. We receive information from these partners provide about your activities outside of the Services – such as information about your device, websites you visit, purchases you make, the adverts you see and how you use their services. They receive your data when you visit or use their services or through third parties that they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us

 

Cookies and Other Tracking Technologies

As applies to most Web sites, we automatically gather information about your computer and device such as your IP address, browser type, referring/exit pages, operating system, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We may use cookies, or other technologies in combination with your information to enhance and personalize your experience, for example, to keep track of your preferences and profile information. Cookies are also used to collect general usage and volume statistical information that does not include personal information. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, it’s important to remember that many of our Services may not function properly if your cookies are disabled.

How does ThinkRight use my personal information?

Provide, personalize and improve our Services.

The primary purpose for which we use the information that we receive about you and your device if for providing you our Services, and this includes, personalizing our Services and the content and the ads for you. We use such information to operate or personalize our services and ensure their secure, reliable, and robust performance. Such information enables us to make inferences, understand the use of our Services and therefore allows us to improve our content, better design our services for you and make it more meaningful and relevant for you. It also allows us to make suggestions about people you would know, content including ads you would like and features that you would be interested in. We also make use of the information for the purposes of developing, testing and improving our Services, including by way of conducting surveys and research, and testing and troubleshooting new products and features.

We may use your personal information to:

  • so that we can reimburse you with loyalty points for app usage in exchange for such information
  • to personalize your experience as per your preferences
  • to save some manual typing efforts by auto-populating some information
  • so that we can verify your unique user account within our system.

We may also use your personal information to:

  • Send you requested product or service information;
  • Administer your account;
  • Send you a newsletter;
  • Send you marketing communications;
  • Administer contests and sweepstakes you entered, and notify you if you win;
  • Respond to your questions and concerns;
  • Improve our Services and marketing efforts;
  • Conduct research and analysis;
  • Display content based upon your interests and personalize the content and advertising you receive;
  • Offer other products, features, or services that may be of interest to you.

 

Advertising

Advertising is our key and primary source of revenue and allows us to provide you the Services and most of its features for free. We may use ad networks to customize and display advertising on our Services. However, we do not share any information about you as a user with any ad network and service providers. We may from time to time work with other companies for certain services such as analytics or advertising, and you may be subject to their privacy policies as well.

Measurement, analytics and other business services

We use the information and the inferences we draw from processing such information to help advertisers and other partners measure the effectiveness and distribution of their ads and services and understand the types of people who use their services and how people interact with their websites, apps and services. We conduct data analytics to provide analytics and measurement reports.

Safety, integrity and security.

We use the information for verification of accounts and your activity to prevent any misuse of our Services, or any harmful conduct either towards you or towards the general community and therefore provide safety and maintain integrity and Security of our Services.

In communications sent to you.

We use the information to send you communications related to our Services, marketing content, sponsored content, related to our terms and conditions and to reply to you when you contact us.

Information Sharing

For the purposes mentioned here, we do disclose certain personal information we collect or receive, however we do so subject to your control, or because it’s necessary to operate our services, or because it’s required by law.

With your consent or at your direction or on your instructions, we share or disclose personal information, like when you authorize a third-party web client or application to access your account. If you’ve shared with another user on the ThinkRight App, who accesses our Services through a third-party service, keep in mind that the information may be shared with the third-party service.

Subject to the settings controls you have provided us with, we also disclose your personal information with certain third parties for allowing us offer or operate our Services. For instance, we disclose to the advertiser’s certain specific information when you see or engage with their ads, which enables them to measure the productivity and effectiveness of their adverts and our advertising proposition.

We also share device identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, interest-based advertising, or similar activities.

The information we share with these partners does not include your name, email address, phone number, or ThinkRight username, but some of these partnerships allow the information we share to be linked to other personal information if the partner gets your consent first.

Service Providers:

We engage vendors and service providers to perform functions and provide services to us, to help operate our services, such as by providing technical infrastructure services, analyzing how our Services are used, providing analytics and measurement reports (which reports we may share with our partners) providing customer service, facilitating payments or conducting surveys. We may share your private personal data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

Law, Harm, and the Public Interest:

Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer to you, we may preserve, use, or disclose your personal data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to protect the safety or integrity of our platform, including to help prevent spam, abuse, or malicious actors on our services, or to explain why we have removed content or accounts from our services; to address fraud, security, or technical issues;

or to protect our rights or property or the rights or property of those who use our services.

Affiliates and Change of Ownership:

In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity. We may also disclose personal data about you to our corporate affiliates in order to help operate our services and our affiliates’ services, including the delivery of ads.

We may also share aggregated, non-personally identifiable information, publicly and with our partners like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services, the number of people who clicked on a particular link, or reports to advertisers about how many people saw or clicked on their ads.

Links to Other Web Sites

Our Service includes links to other apps or Web sites whose privacy practices may differ from those of the Company. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

Security

The security of your personal information is important to us. When you enter sensitive information, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, we cannot guarantee absolute security.

If you have any questions about security on our Website, you can contact us at dpo@jetsynthesys.com

Additional Policy Information

Many of our services let you post or share information with others. Remember that when you share information publicly, others besides us have access to it, and it may be indexable by search engines, or copied, forwarded or archived by others even after we have deleted or deactivated your account. We are not responsible for the content you post. See our Terms of Use for more information.

Managing your Personal Information

Correcting and Updating Your Personal Information

To review and update your personal information to ensure it is accurate, contact us at dpo@jetsynthesys.com. If you believe your information is wrong, we strive to give you ways to update it quickly or to delete it unless we have to keep that information for legitimate business or legal purposes. When updating your personal data, we may ask you to verify your identity before we can act on your request. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

For EU residents

You are in control of your personal information which we have received or collected.

Accessing or Rectifying Your Personal Data:
We provide you with tools and account settings to access, correct, delete, or modify the personal data you provided to us and associated with your account. You are also able to download certain account information, including your public updates, by following the instructions here. You can request correction, deletion, or modification of your personal data, and download your account information, by following the instructions here. You can learn more about the interests we have inferred about you and request access to additional information here.

Deletion:
Personal Information provided by you which we use to provide you Services is retained by us until it is no longer necessary to provide our services or until your account is deleted – whichever comes first. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. We keep information collected at ThinkRight for a maximum of 180 days. To deactivate or delete your account follow the instructions here. Upon deactivation, your ThinkRight account, including your display name, username, and public profile, will no longer be viewable on ThinkRight. Thereafter for up to 30 days, you will be entitled to restore your account and for that period we will retain your personal information. Information that others have shared about you isn’t part of your account and won’t be deleted.

If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via dpo@jetsyntheys.com. If you reside or are located in the EEA, you have the right to request that we:

  • provide access to any Personal Information we hold about you;
  • prevent the processing of your Personal Information for direct-marketing purposes;
  • update any Personal Information which is out of date or incorrect;
  • delete any Personal Information which we are holding about you;
  • restrict the way that we process your Personal Information;
  • provide your Personal Information to a third-party provider of services; or
  • provide you with a copy of any Personal Information which we hold about you.

We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personally Information. Please also note that certain Personal Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation.

When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.

Object, Restrict, or Withdraw Consent:
You can manage your privacy settings and other account features here at any time.

Portability:
We provide you with a means to download the information you have shared at the time of using our Service and you can find more information on the same here.

Children and Our Services
We do not direct our Services to children and to use our Services you must be at least 13 years of age and if you are a resident of EU then you must be at least 16 years of age. You must also be old enough to provide a legal and binding consent (as determined by the laws of your country) to the processing of your personal data (in some countries we may allow your parent or guardian to do so on your behalf).

Operation and Transfer of Information
For providing you our Services, we operate globally and are required to transfer your information to countries where we operate for processing of such information, and by agreeing to use our Services, you authorise us to make such transfers. The laws governing privacy and data protection in such countries may differ from the laws in your country however we attempt to ensure an adequate level of protection for your information in compliance with receiving country’s data protection laws, and by placing contractual obligations on the recipient of the data (in case of third parties).

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The most current version of the Privacy Policy will govern our processing of your personal data and will always be at www.ThinkRight.Meapp.com If we make any amends, which we determine in our sole discretion to be material, we will notify you via a ThinkRight App update or email to the email address associated with your account. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

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