We may collect and receive information about users of our Services ("users", "you", "your") from various sources, including: (i) information you provide through your user account on the Services (your "Account") if you register for the Services; (ii) your use of the Services; and (iii) from third-party websites, services, and partners.
What information do we collect
Information, that you provide:
Account registration. When you register an Account, we may ask your contact information, including items such as name, company name, address, email address, and telephone number. If you choose to refer a friend to our Services, we may also collect your friend’s email address so that we may send them a referral or promotional code to sign up for our Services.
Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Information, that we collect when you use our Services:
Cookies and other tracking data. As is true of most websites, we gather certain information automatically from your device. This information may include IP address, geo-location, browser type, operating system, date/time stamp and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area ("EEA"), the information referenced above in this paragraph may be considered personal information under applicable data protection laws.
Search data. In order to provide the Services we collect and process strictly on behalf of our users some information about their searches on the platform.
Information, that we receive from third parties:
Third-party accounts. If you choose to link our Services to a third-party account, we will receive information about that account, such as your authentication token from the third-party account, to authorise linking. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.
Third-party partners. We may also receive publicly available information about you from our third-party partners and combine it with data that we have about you.
How do we use information?
We use the information we collect in various ways, including:
- To provide, operate, and maintain our Services;
- To improve, personalise, and expand our Services;
- To understand and analyse how you use our Services;
- To develop new products, services, features, and functionality;
- To communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes;
- For compliance purposes, including enforcing our Terms and Conditions, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
How do we share information?
We may share the information we collect in various ways, including the following:
Vendors and service providers. We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Services, for promotional and/or marketing purposes, and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information.
Aggregate information. Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can’t reasonably be used to identify you.
Referral sign up. If you sign up for our Services through a referral from a friend, we may share information with your referrer to let them know that you used their referral to sign up for our Services.
Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
With Your Consent. We may share information with your consent.
How do we protect information?
Personal data. ThePureTech is committed to protecting your personal data. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorised access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please bear in mind that the Internet cannot be guaranteed to be 100% secure.
Credit cards. We never ask for your credit card details. We don't store nor process them either. All billing operations are performed by a PCI DSS compliant third-party service of our choice on behalf of ThePureTech.
How long do we store information for?
We retain personal information we collect from you while we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
How do you access your information?
If you are a registered user, you may access certain information associated with your Account by logging into our Services or contact us.
To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit ThePureTech's ability to comply with a legal obligation; inhibit ThePureTech's ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to ThePureTech or a third party.
You may access other third-party services through the Services, for example by clicking on links to those third-party services from within the Services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.
COPPA (Children Online Privacy Protection Act)
GDPR (General Data Protection Regulation)
If you are a resident of the EEA, you have the following data protection rights:
Rights to access, erasure and rectification. If you wish to access, correct, update, or request deletion of your personal information, you can contact us at any time.
Rights to object, restrict processing and data portability. In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by contacting us;
Opt-out of marketing communications. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.
Consent withdrawal. Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: we will notify you via email within 7 business days.
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions
Process orders and to send information and updates pertaining to orders.
Send you additional information related to your product and/or service
Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CAN SPAM, we agree to the following:
Not use false or misleading subjects or email addresses.
Identify the message as an advertisement in some reasonable way.
Include the physical address of our business or site headquarters.
Monitor third-party email marketing services for compliance, if one is used.
Honour opt-out/unsubscribe requests quickly.
Allow users to unsubscribe from our marketing mailing lists by using the link at the bottom of each email.
Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.
Last updated: 2019-08-27