Privacy

Last updated: August 23, 2023

Communication Labs Ltd (“us”, “we”, or “our”) operates the Thrive Matters’ website and Thrive Matters web and mobile application(s), including the Thrive Matters platform, content and functionality relating to the application(s) (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service. You can also find the version of this document at https://www.thrivematters.com/privacy.  

Communication Labs assumes by accessing the Service and answering questions provided while using the Service, that you understand your responses will be used to derive outputs to you, and potentially to the organization or individual that ordered an account for you, and/or provided Communication Labs with your personal details to prepare an account for you, for the purpose of using the Service.

You can read our Terms and Conditions at https://www.thrivematters.com/terms.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Communication Labs Ltd of Albuquerque NM, USA.

Information Collection and Use

Communication Labs collects two types of information: Personal information, which means information that can be used to uniquely identify and contact you; and non-personal information, which does not provide direct association with you.

When you use the Service or are sent an invitation following an order for you to use the Service, we collect the following:

  • Your sign-in information which includes: your name, organization (if provided), email address and password. We use this information to identify you so you have access to the Service

  • In some instances, we may request your demographic information, which we use for our research. Your demographic information is non-personal. Your age (if asked) and gender (if asked) is used for anonymized analytics.

  • Your answers to questions are linked to your account and used for your profile and customized development advice and analysis. Answers associated with your profile may also be included in collective/group advise and analysis if you accessed the Service using an account prepared by an educational institution, organization, or a person in an advisory role to you or a group of collective users such as those that are part of an educational institution or coaching initiative.

  • If further questions (such as a survey) are provided to you, and you have accessed the Service via an account prepared by an educational institution, organization or group, or person in an advisory role to you or the educational institution, organization or group, then your responses may be provided to the educational institution, organization, advisor or group you are associated with.

  • Any data which is used for research will be anonymized.

  • Device information. We may collect information about the device or any computer you may use to download or stream a copy of the Thrive Matters application on your device, including, where available, the device’s or computer’s unique device identifiers, operating system, browser type and mobile network information as well as the device’s telephone number, for system administration. We may associate device information with your sign-in data and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

  • Log information. When you use Thrive Matters, we may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, internet service provider (ISP), clickstream data, browser type and language, viewed and exit pages and date or time stamps.

  • If you connect using our mobile application, we may request to send you push notifications regarding your account or Services. If you wish to opt-out from receiving these types of communications, you may turn them off using your device’s settings.

If you contact us for customer service, we may also collect any information you give us. We use this information to identify you as a customer and help improve our service.

Disclosing Information

We will not sell, rent or give any of your personal information to third parties, with the following exceptions:

  • If we need to in order to provide the Service ordered.

  • If you have explicitly given us permission to do so.

  • If an account has been prepared or ordered for you to access the Service by an educational institution, organization, or a person in an advisory role to you, the educational institution or organization, that has prepared or ordered an account for you.

And except from the following circumstances:

  • If we are responding to a subpoena, court order, or legal process, or to establish or exercise our legal rights or to defend ourselves against legal claims.

  • If we have to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or as otherwise required by law.

  • If we are acquired by or merged with another company.

  • If with an affiliate who has agreed to honor this privacy policy. Affiliates include any parent company and any subsidiaries, joint venture or application partners, or other companies that we control or under common control with us.

Communication Labs may allow you to share your profile. If you do this, or if you share your information publicly in any other way, the information becomes publicly accessible and is no longer covered by this Privacy Policy. Remember that putting personal information online where it is publicly accessible means third parties can collect it and use it to send you unsolicited messages or for any other purposes.  Please share your information carefully.

Access, Correction, Deletion

If you wish to access or amend any personal data we hold about you, or to request that we delete any information about you that we have obtained, you may contact us in the “Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.

If you wish to limit your personal information being disclosed to an organization that has prepared an account for you to access Thrive Matters, we recommend you first contact the organization and request that your personal information to be no longer associated with the organization. Alternatively, you may contact us in the ‘Contact Us’ section. At your request, we will seek to have your profile removed from being connected to the organization that prepared the account.

You may update or correct your account information and preferences at any time by accessing your account settings page on the Service. Please note that while changes you make will be reflected in active databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we reasonably believe that we have a legitimate reason to do so.

Data Transfers

Personal information that you submit through the Services may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information, for example, to our data processors with servers in the U.S. Your consent to this Privacy Policy by your submission of such information represents your agreement to that transfer.

 We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR.  These include:

  • Standard data protection clauses. We transfer, in accordance with Article 46 of the GDPR, personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area. 

  • Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding, enforceable commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules. 

  • Communication Labs will remain liable under the Data Privacy Framework Principles (DFP Principles) if a third-party processes personal data in a manner inconsistent with the DFP Principles, unless Communication Labs proves that it is not responsible for the event giving rise to the damage.

Data Privacy Framework

Communication Labs complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce.  Communication Labs has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Communication Labs commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact Communication Labs at privacy@communicationlabs.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Communication Labs commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

Communication Labs has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the ICO (https://ico.org.uk) for the UK, with regard to unresolved complaints concerning data transferred from the EU and UK. Communication Labs will comply with information and advice the relevant supervisory authority may provide in relation to unresolved complaints.

The Federal Trade Commission has jurisdiction over Communication Labs’ compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

Under certain conditions an individual can invoke binding arbitration for complaints regarding DPF compliance that is not resolved by any of the other DPF mechanisms. Refer to Annex 1 for additional information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2

Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Only persons age 18 or older have permission to access our Service. Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Controls for Do-Not-Track features

Most browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your browsing activities monitored and collected. No standard technology for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or other mechanism that automatically communicates your choice not to be tracked.

Changes to This Privacy Policy

This Privacy Policy is effective as of August 23, 2023 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. You waive any right to receive specific notice of each change or modification.

Contact Us

If you have any questions about this Privacy Policy, please contact us at: privacy@thrivematters.com