We do not store, transmit, or otherwise process any individually identifiable health information or PHI via the Site or Services, and we prohibit submission or collection of protected health information or individually identifiable health information (as those terms are defined by the Health Insurance Portability and Accountability Act of 1996) in connection with use of the Site or Services.
The Site and Services are not intended for use by children. Consistent with the requirements of the Children’s Online Privacy Protection Act, if we learn that we have received information directly from a child under the age of 13 without first receiving a parent or legal guardian’s verified consent, we will use any collected information solely to inform the child that use of the Site and Services is prohibited, and any collected information will be deleted.
The Site and Services are hosted in the United States and governed by applicable U.S. federal and state laws. When you provide information to us through the Site or Services, you consent to the processing of your data in the United States.
Table of Contents
- Why We Collect Information
- What Information We Collect
- How We Collect Information
- How We Use Information
- Information Disclosure
- Information Retention and Security
- Your Choices
- California Consumer Privacy Act
“You” or “Your” means the individual accessing or using the Site or, as the case may be, the individual authorized to access and use the Services as a User.
“User” means an individual associated with a Partner or Client, who is authorized to access and use the Services or a portion thereof.
“Client” means an entity subject to an agreement with Partner under which Partner agrees to provide access to and use of the Services or a portion thereof.
“Partner” means an entity subject to an agreement with Company under which Company authorizes Partner to provide access to and use of the Services or a portion thereof to its Client.
“Service Provider” means a third-party performing work for us or a portion of the Services on our behalf.
“Personal Information” means information associated with or used to identify you, such as: (a) your first and last name, email address, postal address, phone number, and some Usage Data under applicable law; (b) your job title or department; or (c) your employer’s name, phone number, postal address, payment information, type of company, company industry, and company size.
“Usage Data” means information about your activity on the Site or Services that, by itself, does not identify you, such as: (a) browser type, operating system, webpages visited, access times, links clicked, and the page visited before navigating to our Site or Services; (b) technical information about the computer or mobile device you use to access our Site or Services, including hardware model, operating system and version, unique device identifiers, location data, IP address, domain name, internet service provider, or network information; (c) information searched for, observed, or accessed while using the Services; or (d) metadata related to User Content, such as date, time, or location.
“User Content” means any content you submit through or in connection with the Services.
Why We Collect Information
In general, we collect information to perform our agreements with our Partners and related business purposes, such as product performance, product development, relationship management and marketing, compliance with legal obligations, and other similar business and legal purposes.
What Information We Collect
When you access the Site, we may collect your Personal Information or Usage Data. When you access or use the Services, we may collect your Personal Information, Usage Data, and User Content.
How We Collect Information
When you access the Site, we may collect Personal Information provided to us directly by you or Usage Data provided to us automatically by Data Collection Tools as described below. For example, you may complete a form on the Site used to contact us about our products and services, which may include Personal Information. When you access or use the Services, we may collect information from You, Clients, Partners, Service Providers, or Data Collection Tools as described below.
We may collect Personal Information and User Content provided to us directly by you when you access or use the Services. For example, we collect information when you create an account, fill out a form, make a purchase, subscribe to receive communications, request customer support, communicate with us, or submit information when you use the Services.
From Clients and Partners
We may collect information provided to us directly by a Client or Partner. For example, a Partner or Client may share information with us about the other so that we may provide particular products or services to either or both of them.
From Service Providers
When you access or use the Services, Service Providers may collect Personal Information, Usage Data, or User Content. For example, a Service Provider may collect information about unauthorized access to or use of the Services and share it with us, or a Service Provider may process Personal Information or User Content provided directly by you when you use the Services.
From Data Collection Tools
How We Use Information
In general, we use information to perform our agreements with our Partners and related business purposes, such as product performance, product development, relationship management and marketing, compliance with legal obligations, and other similar business and legal purposes, such as:
- To provide the Services;
- To operate, maintain, improve, or personalize the Services or other products and services we offer;
- To provide customer service or respond to your comments, questions and requests;
- To send technical notices, updates, security alerts, and support or administrative messages;
- To communicate with you about products, offers, promotions, rewards, and events we or others offer, or provide news and information we think will be of interest to you;
- To monitor and analyze trends, usage, and activities in connection with our Services;
- To provide advertisements about content or features more relevant to you;
- To assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Services;
- To process your transactions and send you related information, such as confirmations and invoices;
- To help us develop new products and services or improve our existing products and services;
- To enforce our Terms of Service and other applicable agreements or policies; and
- To carry out any other lawful purpose for which information was collected.
We may derive information or draw inferences based on information collected when you access or use the Services. For example, we may make inferences about your interest in our products and services based on your location, browsing behavior, usage behavior, and past purchases.
To improve the Services, information collected may be used in an aggregated or deidentified manner. For example, information about a particular use of the Services may be used to suggest such use may be beneficial to others.
We may allow third parties or Service Providers to serve advertisements on our behalf across the internet and to provide analytics services. Such entities may use Data Collection Tools to collect information about your use of the Site, Services, and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests in our Services and other websites, and better understand your online activity.
- With your consent or at your direction, including if we notify you through our Site or Services that the information you provide will be shared in a particular manner and you provide such information;
- With Partners, so they understand their Clients’ use of the Services and related needs, or to perform functions initiated by Users;
- With Service Providers to perform functions for which we engage them, such as hosting, analytics, or a portion of the Services;
- With our affiliates or subsidiaries for the purpose of providing the Services to you;
- In aggregated or de-identified form, which cannot reasonably be used to identify you;
- For legal purposes, such as to enforce our rights, protect our property, or protect the rights, property, or safety of others; as needed to support external auditing, compliance, and corporate governance functions; to respond to a subpoena, regulation, binding order of a data protection agency, legal process, government request, or other legal or regulatory process; or as required to pursue available remedies or limit damages we may sustain; and
- In connection with a merger, sale, reorganization, financing, acquisition, or other change of ownership or control by or of Company or any affiliated company in whole or in part.
Information Retention and Security
In general, we retain information pursuant to our data retention policy unless otherwise permitted or prohibited by applicable law. We use commercially reasonable security measures designed to protect the security of information submitted to or through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for any change to or loss of data. Users are responsible for maintaining the security of any User ID, password, or other form of authentication involved in obtaining access to the Services. To protect your information, we may suspend your use of the Services, without notice, during an investigation if any breach of security is suspected. Access to and use of the Services is restricted to authorized Users only. Unauthorized access or use is prohibited and may lead to a civil action or criminal prosecution.
You may access and review information under your user profile and make corrections or deletions as necessary. You may also email us at [email protected]. If you wish to deactivate your account, please email us at [email protected] but note that we may retain information pursuant to our data retention policy unless otherwise permitted or prohibited by applicable law.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that removing or blocking cookies may affect the availability and functionality of our Site and Services. For more information about internet-based ads or to opt out of having your web browsing information used for behavioral advertising purposes, please visit: http://www.aboutads.info/choices.
You may opt out of receiving our promotional emails by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
California Consumer Privacy Act
THIS SECTION APPLIES SOLELY TO CALIFORNIA RESIDENTS. If you are a California resident, you may have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”). All phrases used in this section shall have the same meaning as those phrases are used under the CCPA.
Right of Non-Discrimination
You have a right to exercise your rights without suffering discrimination. We will not discriminate against you in any way if you choose to exercise your rights under the CCPA.
Right to Know
You have a right to request that we disclose the following information to you:
- The categories of personal information we have collected about you;
- The categories of sources from which personal information is collected;
- The business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom we share personal information; and
- The specific pieces of personal information we have collected about you.
The following paragraphs describe items listed above:
Categories of Personal Information: In the preceding 12 months, we have collected the following categories of personal information: Personal Information, Usage Data, and User Content, as those terms are defined in “Definitions”.
Categories of Sources: The categories of sources from which we have collected personal information are described in “How We Collect Information”.
Specific Pieces of Personal Information: You may submit a right to know request by visiting us at https://thinkhr.com/ccpa/, calling us at (844) 455-8706, or emailing us at [email protected]. This right is subject to certain exceptions available under the CCPA.
Right to Delete
You have a right to request that we delete personal information we have collected from you. You may submit a right to delete request by visiting us at https://thinkhr.com/ccpa/, calling us at (844) 455-8706, or emailing us at [email protected]. This right is subject to certain exceptions available under the CCPA.
Right to Opt Out
You have a right to direct a business that sells your personal information to third parties not to sell your personal information, but please note that we do not sell personal information to third parties.
We will verify your identity before responding to your requests. To verify your identity, we will generally match the identifying information provided in your request with the information we have on file about you.
If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf. To designate an authorized agent to exercise these rights on your behalf, please email us at [email protected].