Last updated: 10 March 2020
Thrive Academy (” Thrive Academy“, ” we“, ” our“, ” us“) are committed to protecting and respecting your privacy. We are a limited liability company established in the US with a registered office at 630 Water St, Santa Cruz, CA 95060.
(the ” Websites“), our mobile app, Thrive Academy (the ” App“) and your use of our training courses, certifications and related services and content (” Thrive Academy Content“) (collectively ” the Services“).
Individual Customers: If you are using our Services for your own personal purposes as opposed to in connection with your employment, your data controller for the purpose of the EU General Data Protection Regulation (the ” GDPR“) is Thrive Academy.
Corporate Customers: If you are using our Services in connection with your employment, your employer is your data controller for the purposes of the GDPR, and we are data processor collecting and use that data only to provide the services to your employer. Your employer may have their own privacy notices that will apply to your use of our Services. Your employer will have access to your usage information, such as courses taken and results.
- Collection and Use of Information
We collect certain information or data about you when you use our Services:
- when you create an account with us, or submit questions, queries or feedback via our Websites, App, email or social media, including your email address if you send an email to us, as it is in our legitimate interests to provide our Services, communicate with you and provide customer support per your request;
- your country and IP address, as it is necessary for our compliance with legal obligations to identify where our users are located in connection with US laws;
- where you have provided your consent, you email address so you can receive our newsletters;
- where you post information on our Websites chat forum, as it is in our legitimate interests to provide our Services;
- when you provide evidence of purchases of “Thrive Academy” courses on third-party platforms via our Websites, as it is in our legitimate interest to provide our Services and validate your purchase per your request;
- when you inquire about our product via our Websites, App, email or social media, including your email address if you send an email to us, as it is in our legitimate interests to provide our services, communicate with you and contact you about our product as per our request;
Information we automatically collect from your computer, mobile phone, or other access device on how you use the Websites, including your IP address; device information including, but not limited to, identifier, name, and type of operating system; and standard web information, such as your browser type and the pages you access on our Websites (” Technical Usage Information“).
We collect Technical Usage Information as it is in our legitimate interests to provide effective services and useful content to you, in order to:
- personalize our Websites to ensure content from the Websites is presented in the most effective manner for you and your device;
- monitor and analyze trends, usage and activity in connection with our Websites and Services to improve the Websites;
- administer the Website, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
- keep the Websites safe and secure; and
- measure and understand the effectiveness of the content we serve to you and others.
In addition to cookies that are strictly necessary to operate the Websites, we use the following cookies:
- Functional cookies, which are set by us and the following third parties to enhance your experience on our Websites.
- Performance Cookies provided by the following third parties including: ClickFunnels and Google Analytics, which enable us to provide a better user experience based on how our you use our Websites.
- Targeting or Advertising Cookies which are set by us and the following third parties, including: Google AdWords, ClickFunnels, WooCommerce, and Infusionsoft to tell us and those third parties about your browsing habits, so you can be provided with advertising that is more relevant to you.
- Social Media Cookies which are set by the following third parties including: Facebook, and allow you to share what you’ve been doing on the Websites on social media.
If you do not accept the use of these cookies, please disable them by changing your browser settings so that cookies from the Websites cannot be placed on your computer or mobile device. These browser settings will typically be found in the “options” or “preferences” menu of your browser; otherwise you should use the “Help” option in your browser for more details. If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links:
- Network Advertising Initiative ( http://www.networkadvertising.org/)
- Digital Advertising Alliance ( http://www.aboutads.info/consumers)
- Disclosure to Third Parties
- cloud storage and server providers including AWS and Linode located in the United States to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
- service providers for analytics services to help understand your usage of our Services. In particular, we use Google Analytics and ClickFunnels, and provide a limited amount of your information (such as your email address and signup date) to Google and ClickFunnels to collect data for analytics purposes when you visit our Websites. Google Analytics and ClickFunnels analyze your use of our Services websites and/or products and tracks our relationship so that we can improve our service to you. We may also use Infusionsoft as a medium for communications, either through email, or through messages within our Services.
- service providers for authentication services to authenticate, identify and grant access to our Services; and
- service providers for payment services including Infusionsoft to handle receipt of payment for products and services at our Websites.
We will also disclose your information to third parties:
- if you are an employee of one of our corporate customers, we will share data generated from your use of the Services with your employer;
- in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; and
- if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
We do not knowingly collect personal information from children under age 16 for any purpose. If we learn that we have collected personal information of a child under age 16, we will attempt to delete that personal information as soon as possible and take any other measures required under applicable law.
- Keeping Your Data Secure
Transmitting information over the internet is generally not completely secure, and we can’t guarantee the security of your data.
Any data you transmit is at your own risk.
We have procedures and security features in place to try and keep your data secure once we receive it.
We won’t share your information with any other organizations for marketing or market research, and we don’t pass on your details to other websites.
Payment transactions are always encrypted.
- Your Rights
Where you sign up for our Services as an individual, you have certain rights including to find out what information we hold about you and review, update, and correct the personal information you provide us by logging into your account.
Corporate Customers: If you are an employee of one of our corporate customers, please contact your employer to exercise your rights.
Individual Customers: You have certain rights in regard to your personal information. You have the right to ask us to access the personal information we hold about you and be provided with certain information about how we use your information and who we share it with. You also have the right to ask us to correct your personal data where it is inaccurate or incomplete and we will endeavor to do so without undue delay.
In certain circumstances, you have the right to ask us to delete the personal information we hold about you:
- where you believe that it is no longer necessary for us to hold your personal information;
- where we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
- where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal data; or
- where you believe the personal information we hold about you is being unlawfully processed by us.
In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal information:
- where you believe the personal information we hold about you is inaccurate and while we verify accuracy;
- where we want to erase your personal information as the processing is unlawful but you want us to continue to store it;
- where we no longer need your personal information for the purposes of our processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
- where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.
In addition, you can object to our processing of your personal information based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.
At any time you have the right to object to our processing of information about you in order to send you marketing, including where we build profiles for such purposes, and we will stop processing the data for that purpose.
To exercise any of these rights above, please contact [email protected] . In addition, you have the right to complain to the Information Commissioner’s Office or other applicable data protection supervisory authority.
Please note that these rights above are limited, for example, where fulfilling your request would adversely affect other individuals, our trade secrets or intellectual property, where there are overriding public interest reasons, or where we are required by law to retain your personal data.
- International Transfers
If you are located in the EU, your personal information will be transferred to and processed by:
- Thrive Academy personnel located in the United States under the terms of the EU Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2010/87/EU. Please contact [email protected], if you would like to see a copy of the model contracts; and
- our third party suppliers (as described above) located outside the EEA where such transfers will either be: (i) to a recipient certified to the US Department of Commerce’s EU-US Privacy Shield; or (ii) subject to the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses). For more information about the EU-US Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website. Please contact [email protected], if you would like to see a copy of the model contracts.
Thrive Academy, Inc.
630 Water St, Santa Cruz, CA 95062
© 2008–2020 Thrive Academy, Inc.