Thoughtswin Systems Inc. and its affiliates (collectively, “Thoughtswin”, “we”, “our” or “us”) recognize the importance of privacy. The purpose of this Privacy Statement is to inform you about our privacy practices, including how we collect, use, and disclose your personal information. This privacy statement relates to all of our activities, unless we have provided you with a separate privacy statement for a particular product, service or activity.
This Privacy Statement covers the following topics:
“Personal information” means information about an identifiable individual. This information may include, but is not limited to, your name, mailing address, e-mail address, telephone number and country of residence.
Personal information does not include information where there is no serious possibility that it can be used to identify an individual, whether on its own or in combination with other information, or personal information that has been anonymized or aggregated such as to be considered anonymized information or no longer personal information under applicable laws.
We may collect, use, and disclose different types of personal information, depending on our relationship with you. Generally, we collect the following types of personal information (not all of which may apply to you):
We also collect, use, and share aggregated and anonymized data for any purpose. Aggregated and anonymized data is not considered personal information because it cannot be used to identify you.
We generally use your personal information for the following purposes:
We generally identify to whom, and for what purposes, we will disclose your personal information (and we obtain your consent to such disclosure) at the time we collect your personal information.
We rely on service providers to perform a variety of services on our behalf, such as payment card processors, technical support providers, and data storage and processing service providers. If we transfer your personal information to a service provider, we require that they maintain the confidentiality of your personal information and keep it secure. We also require that our service providers comply with applicable privacy laws and only use your personal information for the limited purposes for which it is provided.
Additionally, we may disclose your information when we believe such disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.
If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure and obtain your consent.
A “cookie” is a small text file that contains information and is stored on your computer. We use cookies and similar tracking technologies, such as web beacons and pixels, to automatically collect information about your use of our website and your interaction with our emails. Information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, internet service provider and/or mobile carrier, pages and files viewed, searches, operating system and system configuration information, and date/time stamps associated with your usage.
We use this information to facilitate the use of our website, for our business or analytical purposes (including to assess website traffic and track search criteria), and to personalize web pages according to your choices and interests.
We may also use this information to engage in interest-based advertising (also known as targeted or behavioral advertising) in connection with your use of our website, and across third-party websites or service offerings when you leave our website. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with advertising and marketing materials that are relevant to you, based on those preferences and interests.
If you do not wish to accept cookies, you can adjust your web browser settings so that you automatically deny the storage of cookies or are informed each time a website requests to store a cookie. Previously stored cookies can also be deleted through your web browser. Please refer to your web browser’s help pages for more information. Some areas or features of our website rely on cookies and may not work if you delete or decline cookies. For more information about cookies generally please visit www.allaboutcookies.org.
If you no longer want to receive marketing-related e-mails from us, you may opt out of receiving marketing-related e-mails by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by contacting us directly using the contact information in the “How to Contact Us” section below.
Please note that if you opt out from receiving marketing-related e-mails, we may still need to send you communications about your use of our products or services, or other matters.
We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, and as permitted or required by law.
Personal information may be processed in any country where we have facilities or in which we engage third party service providers to fulfil the purpose for which we collected the personal information. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
Our practices regarding your personal information will at all times continue to be governed by this privacy statement and we will continue to comply with all applicable legal requirements. For more information about our policies and practices regarding transfers to other countries, contact us using the contact information in the “How to Contact Us” section below.
We have implemented commercially reasonable physical, organizational, contractual and technological security measures with a view to protecting your personal information from accidental or unlawful destruction, loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. In the case of a breach of security safeguards, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.
You are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of our website and/or services. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through our website or services. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through our website or services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information on our website.
Individuals have a number of rights concerning their personal information under global privacy laws. You may make a written request to access, correct or delete any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.
Where applicable, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing; (ii) the right to object to unlawful data processing, under certain conditions; (iii) the right to erasure of personal information about you, under certain conditions; (iv) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (v) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vi) the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions.
Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
When you exercise your right to deletion of your personal information, we will delete your personal information, subject to some instances where your personal information will be maintained for us to fulfill our obligations under contract or as required by law.
You also have the right to lodge a complaint with the relevant data protection or privacy authority, such as the Office of the Privacy Commissioner.
We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products or services from third parties with different privacy practices. Those other websites, products, or services are governed by the privacy statements and policies of the respective third party. This Privacy Statement does not extend to any websites, products, or services provided by third parties. We do not assume responsibility for the privacy practices of third parties and we encourage you to review all third-party privacy statements prior to using third-party websites, products, or services.
The Privacy Statement was last revised as of the date that appears at the top of this page.
From time to time, we may make changes to this Privacy Statement. When changes are made, they will become immediately effective when published in a revised Privacy Statement posted on our website, unless otherwise noted. We may also communicate the changes to this Privacy Statement by other means.
All comments, questions, concerns, or requests regarding your personal information or our privacy practices should be forwarded to our Privacy Officer as follows:
