Thank you for visiting our website. At Think TRUE, we strive to make our website a rewarding experience for our guests.
This policy was implemented as of January 1st, 2019 and applies to information collected on this website and those of our affiliates (together, “our website” or “the website”) and covers the following areas:
- What personally identifiable information is collected by Think TRUE or by any third party through our website;
- How Think TRUE uses this information;
- With whom Think TRUE may share this information;
- What choices are available to you as a user of our website with respect to collection, use and distribution of the information; and
- What types of security procedures are in place to protect the loss, misuse or alteration of information under our control.
- Information Collection and Use
Think TRUE collects two different types of information through our website: anonymous information and personally identifiable information.
Anonymous Information. We may collect and store anonymous, aggregate information (such as internet protocol (IP) addresses, browser types, search engines, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) from all visitors to our website. You may search our website for general information provided through our website without ever submitting your name, email address or any other personally identifiable information. The anonymous information that we do collect from your visit is never linked to any of your personally identifiable information until you voluntarily submit that personal information, in which case some otherwise anonymous information may be connected to your website activity and personal account. Otherwise, the anonymous information is only used in the aggregate to analyze trends, administer the website, diagnose any problems, track a visitor’s movement in the aggregate, and gather broad demographic information for aggregate use. We may provide this anonymous information in aggregate form to other parties or use it for our own insight or marketing purposes. Our ability to use this information is not restricted in any way.
We also use “cookies” and “image tags” to collect certain usage information from all visitors to our website. A “cookie” is a small text file that a website can place on your computer’s hard drive or on your mobile device’s memory in order to collect information about your activities on our website. An “image tag,” also known as a clear GIF or web beacon, works together with cookies and is a small image file that may be located in various areas of our website. Most browsers automatically accept cookies, but you have the option to change your browser setting to decline them.
Accepting cookies in no way gives us access to your computer or any personal information about you, since cookies are not used to identify anonymous website visitors. Our cookies enable you to proceed smoothly through our website and know whether you’ve used it before, so as to eliminate some steps that apply to new visitors. Cookies also give us usage data like how often you visit, where you go on our website, and what you do while here.
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.
- Our Use Restrictions on Your Personally Identifiable Information
Think TRUE does not sell, rent, or share personally identifiable information to or with any third party not affiliated with or owned by Think TRUE, except service providers who may assist us in such areas as our promotions and data storage (See “Agents and Vendors,” below). Think TRUE will never give or sell your personally identifiable information to unaffiliated third parties to be used for the purposes of sending you unsolicited commercial offers, such as spam. We may, however, use your personal information to send you information in e-mails from Think TRUE. You may altogether avoid or opt out of these campaigns (See “Opting Out,” below).
- Third Party Information About You
- Our Agents and Vendors
- Disclosure of Personal Information as Required By Law or Otherwise
We will disclose personal information when required by law, or if we have a good-faith belief that such action is necessary to (a) comply with a current judicial proceeding, a court order or legal process served on us or to comply with the request of a law enforcement agency, (b) protect and defend our rights, (c) protect the rights, property, and other interests of our users or others, or (d) operate our systems properly.
Think TRUE takes commercially reasonable precautions to protect your personally identifiable information. However, given the nature of the Internet and the fact that network security measures are not perfect, we cannot guarantee the absolute security of your information. If we are required to provide notice to you of a data security breach, the notice will be provided in electronic form.
- Your Consent and Notification of Changes
- California Privacy Rights
If you are a California resident, you may request that we provide to you:
- a list of the categories of personal information about you that Think TRUE has disclosed to third parties for the third parties’ direct marketing purposes during the calendar year preceding your request;
- the names and addresses of such third parties; and
- if the nature of the third parties’ business cannot reasonably be determined from their names, examples of the products or services marketed, if known to Think TRUE, sufficient to give you a reasonable indication of the nature of the third parties’ business.
To submit your request, please email email@example.com.
- Personal Data of EU and Swiss Residents
Our website is controlled and operated from the United States, and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. We do not represent or warrant that the website or any part thereof is appropriate or available for use in any particular jurisdiction other than the United States. In choosing to access our website, you do so on your own initiative and at your own risk, and you are responsible for complying with all local laws, rules and regulations. We may limit our website’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
Nevertheless, for users who are located in the European Union and Switzerland, all processing of such users’ personal data by us will be performed in good faith accordance with privacy rights and regulations following the GDPR.
Under the GDPR, GDPR data subjects have a number of important rights. In summary, those include rights to:
- Fair processing of information and transparency over how we use your use personal information;
- Require the correction of any mistake in the personal information that we hold about you;
- Require the erasure of personal information concerning you in certain situations;
- Receive the personal information concerning you that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third-party in certain situations;
- Object at any time to the processing of your personal information for direct marketing;
- Object to decisions being taken by automated means that produce legal effects concerning you or similarly significantly affect you;
- Object in certain other situations to our continued processing of your personal information; and
- Otherwise restrict our processing of your personal information in certain circumstances.
For further information on each of those rights, including the circumstances in which they apply, guidance is available from applicable data protection authorities. For example, the UK Information Commissioner’s Office (the “ICO”) has issued guidance on individuals’ rights under the GDPR: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you are a GDPR data subject and would like to exercise any of these rights, please:
- Email us at firstname.lastname@example.org;
- Provide enough information to identify you (e.g., name, email address);
- Provide proof of your identity and address (a copy of your driver’s license or passport and a recent utility or credit card bill); and
- Provide the information to which your request relates.
You have the right, at any time, to lodge a complaint about the processing activities of your personal information by us with the ICO, or other competent supervisory authority.
- Opting Out
If for any reason you would like to be removed from our customer list, simply send an email to [email address] or mail to [address].