Privacy Policy

Effective Date: Jan 8, 2018

Context


Your privacy is very important to us. Please read below to see how ThinkEE handles information. Before you get to the details, here are a few of our fundamental privacy principles:

  • Information, data you upload or post to ThinkEE may be seen by others depending on your permissions settings.
  • We give you several ways to control the privacy of your data and we are continuously working to enhance privacy options available to you.

ThinkEE respects your privacy and shares your concern about the security of information you may submit to ThinkEE’s websites and the related mobile applications and services (collectively, the “Services”). Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy settings and your rights in connection with the Services. ThinkEE is headquartered in Ecublens, Switzerland. If you are a resident of the European Union (“EU”), ThinkEE is the controller of your personal data for the purposes of EU data protection law. This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services. Questions or comments about this Privacy Policy may be submitted by mail to the address below:

ThinkEE
Chemin du Croset 9
Ecublens 1024, Vaud, Switzerland

contact@thinkee.ch

We Collect, Use, Share and Otherwise Process Information


ThinkEE relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • where you have consented to the processing, which you can revoke at any time. For example, you may consent to the processing of health-related information;
  • where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  • to protect your vital interests, or those of others, such as in the case of emergencies;
  • where you have made the information public;
  • where necessary in the public interest; and
  • where necessary for the purposes of ThinkEE’s or a third party’s legitimate interests, such as those of visitors, members or partners.

Our Legitimate Interests


We process your information in furtherance of our legitimate interests, including:

  • providing and improving the Services, including any personalized Services. We do so as it is necessary to pursue our legitimate interests of providing and developing innovative and tailored offerings to our members on a sustained basis; and
  • keeping the Services safe and secure. We do so as it is necessary to pursue the legitimate interests of ThinkEE and its members in ensuring the Services are secure, and to protect against fraud, spam and abuse, etc.

Information ThinkEE Collects


ThinkEE collects information about you, including information that directly or indirectly identifies you, if you to share it with ThinkEE. For example:

  • We collect basic account information such as your name, email address, date of birth, gender, username and password that helps secure and provide you with access to our Services.
  • Profile and use information is collected about you when you choose to upload a picture or data from devices.
  • ThinkEE collects information from devices and apps you connect to ThinkEE. For example, you may connect a temperature sensor or slack account to ThinkEE and information from these devices and apps will be passed along to ThinkEE.
  • ThinkEE may collect or infer health information which may include information such as heart rate or other biometric information, such as power, cadence, height and weight or other indicators. Before you can upload health information to ThinkEE or information from which ThinkEE can infer health information, you must give your explicit consent to the processing of that health information by ThinkEE. You can withdraw your consent to ThinkEE processing your health information at any time.
  • When you make a payment on ThinkEE, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry compliant third-party payment services and we do not store your credit card information.

When you visit the Services, a cookie will be stored on your computer. Generally, cookies and similar technologies work by assigning to your browser or device a unique number that has no meaning outside of ThinkEE. ThinkEE uses these technologies to personalize your experience and to assist in delivering content specific to your interests. Additionally, after you’ve entered your member ID and password during a session on the Services, ThinkEE saves that information so you don’t have to re-enter it repeatedly during that session.

Most browsers automatically accept cookies. To manage the collection of information through cookies or other equivalent technology you can use the settings on your browser or mobile device. ThinkEE is committed to providing you choices to manage your privacy and sharing. However, ThinkEE does not recognize or respond to browser-initiated Do Not Track signals, as the internet industry has not fully developed Do Not Track standards, implementations and solutions. To learn more about Do Not Track signals, you can visit https://allaboutdnt.com. Not accepting cookies may make certain features of the Services unavailable to you.


The Services use log files. Stored information includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc., may be linked to session IDs and device identifiers.

How ThinkEE Uses Information


ThinkEE uses the information we collect and receive to administer and operate the Services and as otherwise described in this Privacy Policy. For example, we use your uploaded data to provide you with statistics and visualizations. Subject to your privacy settings, your information, including your profile, username, photos, devices and comments you publish will be shared on ThinkEE to participate in the Services, for example to show an activity on ThinkEE.

We use your information to communicate with you about the Services and let you know about new features or updates to our Terms of Service. We also use your information to respond to you when you contact us. ThinkEE will use your information to communicate with you, for example by sending you notifications.

How Information is Shared


We may share your information with third parties who provide services to ThinkEE such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf so that we or they may promote ThinkEE or display information that may be relevant to your interests on the Services or other websites or services.


Subject to your privacy settings, your information and content may be publicly accessible.


When you choose to use third party apps, plug-ins, or websites that integrate with the Services, they may receive your information and content, including your personal information, photos, and your data. Information collected by these third parties is subject to their terms and policies. ThinkEE is not responsible for the terms or policies of third parties.


We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If ThinkEE becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction.


We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that disclosure is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of ThinkEE or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

How We Protect Information


We take several measures to safeguard the collection, transmission and storage of the data we collect. Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure. The Services uses industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. The Services are registered with site identification authorities so that your browser can confirm ThinkEE’s identity before any personally identifiable information is sent.

To help ensure that these measures are effective in preventing unauthorized access to your private information, you should be aware of the security features available to you through your browser. You should use a security-enabled browser to submit your credit card information and other personal information at the Services. Please note that if you do not use a SSL-capable browser, you are at risk for having data intercepted.

Most browsers have the ability to notify you if you change between secure and insecure communications, receive invalid services identification information for the Services you are communicating with, or send information over an unsecured connection. ThinkEE recommends that you enable these browser functions to help ensure that your communications are secure. You can also monitor the URL of the services you are visiting (secure URLs begin with https:// rather than http://), along with the security symbol of your browser to help identify when you are communicating with a secure server. You can also view the details of the security certificate of the services to which you are connected. Please check the validity of any Services you connect to using secure communications.


While ThinkEE continues to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and ThinkEE cannot ensure or warrant the security of any information you transmit to ThinkEE. Transmitting personal information is done at your own risk.

Managing Your Settings


ThinkEE offers several features and settings to help you manage your privacy and how you share your activities.


ThinkEE offers various ways to manage the notifications you receive. You can choose to stop receiving certain emails and notifications. You may also unsubscribe by following the instructions contained at the bottom of each type of email. Any administrative or service-related emails (to confirm a purchase, or an update to this Privacy Policy or the Terms of Service, etc.) generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested.


You may correct, amend or update profile or account information that is inaccurate at any time by adjusting that information in your account settings. If you need further assistance, please contact ThinkEE. ThinkEE will generally respond to your request within 7-10 business days.


You may request that your account is deleted by contacting ThinkEE Once deleted, your data, including your account and data cannot be reinstated.

Note that content you have shared with others or that others have copied may also remain visible after you have deleted your account or deleted the information from your own profile.

EU Members’ Rights


If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

  • Access and Porting

    You can access much of your information by logging into your account. If you require additional access or if you are not a ThinkEE member, contact ThinkEE. To download a copy of your data contact ThinkEE.

  • Rectify, Restrict, Limit, Delete

    You can also rectify, restrict, limit or delete much of your information by logging into your account. If you are unable to do this, please contact ThinkEE. ThinkEE will generally respond to your request within 10-14 business days.

  • Object

    Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

  • Where you have previously provided your consent, such as to permit us to process health-related data about you, you have the right to withdraw your consent to the processing of your information at any time. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

  • Complain

    Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

Transfers


The Services are operated from Switzerland. If you are located outside of the Switzerland and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in Switzerland, as it is necessary to provide the Services and perform the Terms of Service. Switzerland privacy laws may not be as protective as those in your jurisdiction.

Retention of Information


We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted whichever comes first. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Privacy Policy Information


ThinkEE reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If ThinkEE makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.