Privacy Statement, effective as of October 1st, 2014
ThinkSmart Solutions, Inc. (“ThinkSmart” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”). This Privacy Statement describes ThinkSmart’s privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by www.thinksmartone.com (the “Services”).
1. Web sites covered
This Privacy Statement covers the information practices of Web sites that link to this Privacy Statement, including: http://www.thinksmartone.com; (collectively referred to as “ThinkSmart’s Web sites” or “the Company’s Web sites”).
Thinksmart’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites 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, ThinkSmart 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, ThinkSmart may require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). ThinkSmart 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 ThinkSmart Customers”.
As you navigate the Company’s Web sites, ThinkSmart may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked). For additional information about the collection of Web Site Navigational Information by ThinkSmart and others, please see “4. Web Site Navigational Information.”
3. Use of information collected
The Company uses Data About ThinkSmart 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 may also use Data About ThinkSmart Customers 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.
ThinkSmart uses credit card information solely to check the financial qualifications and collect payment from prospective Customers.
ThinkSmart 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 ThinkSmart Customers to provide personalized information about the Company. For additional information about the use of Web Site Navigational Information, please see “4. Web Site Navigational Information.”
4. Web Site Navigational Information
Cookies, Web Beacons and IP Addresses
ThinkSmartuses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information used on the Company’s Web sites and how this information may be used.
The following sets out how ThinkSmart uses different categories of cookies and your options for managing cookies’ settings:
|Type of Cookies||Description||Managing Settings|
|Required cookies||Required cookies enable you to navigate the Company’s Web sites and use its features, such as accessing secure areas of the Web sites and using ThinkSmart Services.
|Because required cookies are essential to operate the Company’s Web sites and the Services, there is no option to opt out of these cookies.|
|Performance 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 Web site functions and performs.
From time-to-time, ThinkSmart engages third parties to track and analyze usage and volume statistical information from individuals who visit the Company’s Web sites. ThinkSmart may also utilize Flash cookies for these purposes.
|Functionality cookies||Functionality cookies allow the Company’s Web sites 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 ThinkSmart’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.
ThinkSmart 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.
Third parties, with whom the Company partners to provide certain features on our Web sites 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.
ThinkSmart uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites 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 Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, ThinkSmart may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. ThinkSmart uses Web beacons to operate and improve the Company’s Web sites and email communications.
When you visit ThinkSmart’s Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, thinksmartone.com uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.
ThinkSmart also collects IP addresses from Customers when they 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. ThinkSmart 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. ThinkSmart 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
ThinkSmart may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. 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. ThinkSmart 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 Web sites. When using the referral program, the Company requests the friend’s name and email address. ThinkSmart will automatically send the friend a one-time email inviting him or her to visit the Company’s Web sites. ThinkSmart does not store this information.
ThinkSmart posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. ThinkSmart obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.
6. Sharing of information collected
ThinkSmart may share Data About ThinkSmart Customers with the Company’s contracted service providers so that these service providers can provide services on our behalf. Without limiting the foregoing, ThinkSmart may also share Data About ThinkSmart Customers 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 Web sites. Unless described in this Privacy Statement, ThinkSmart does not share, sell, rent, or trade any information with third parties for their promotional purposes.
The Company may share Data About ThinkSmart Customers with other companies in order to work with them, including affiliates of the ThinkSmart corporate group. For example, the Company may need to share Data About ThinkSmart Customers for customer relationship management purposes.
From time to time, ThinkSmart 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 ThinkSmart, the Company may share Data About ThinkSmart Customers collected in connection with your purchase or expression of interest with our joint promotion partner(s). ThinkSmart does not control our business partners’ use of the Data About ThinkSmart 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 shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.
This Privacy Statement sets forth the information ThinkSmart collects on the Company’s Web sites and the information we share with third parties. ThinkSmart does not authorize the collection of personal information by third parties through advertising technologies deployed on the Company’s Web sites, nor do we share personal information with any third parties collected from the Company’s Web sites, except as provided in this Privacy Statement. Section 4 of this Privacy Statement, Web Site Navigational Information, specifically addresses the information we collect through cookies and web beacons, and how you can control cookies through your Web browsers.
ThinkSmart 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.
ThinkSmart 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.
7. International transfer of information collected
The Company primarily stores Data About ThinkSmart Customers in the United States.
To facilitate ThinkSmart’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. A list of the Company’s global offices is available here. This Privacy Statement shall apply even if ThinkSmart transfers Data About ThinkSmart Customers to other countries.
8. Communications preferences
ThinkSmart offers Visitors and Customers 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@example.com.
9. Correcting and updating your information
Customers may update or change their registration information by editing their user or organization record. To update a user profile, please login to http://www.thinksmartone.com with your username and password and click “Setup.” To discontinue your account please email firstname.lastname@example.org. Requests to access, change, or delete your information will be handled within 30 days.
10. Customer Data
ThinkSmart Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). ThinkSmart will not review, share, distribute, or reference any such Customer Data except as provided in the ThinkSmart Terms and Conditions, or as may be required by law. In accordance with the ThinkSmart Terms and Conditions, ThinkSmart 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.
ThinkSmart uses robust security measures to protect Data About ThinkSmart Customers.
12. Changes to this Privacy Statement
ThinkSmart reserves the right to change this Privacy Statement. ThinkSmart will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.
13. Contacting us
Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to ThinkSmart Privacy by clicking here or by mailing ThinkSmart Privacy, 475 Gate 5 Road, Suite 216, Sausalito, CA 94965.