SCHEDULE B – THINKON PRIVACY POLICY

SCHEDULE B – THINKON PRIVACY POLICY

Last Updated: June 1st, 2019

This Privacy Policy applies to individuals who are our prospects, employees of our Resellers, employees of our Subscribers or individuals representing our Subscribers, collectively (“Individuals”). ThinkOn is committed to protecting the privacy of Individuals while they interact with ThinkOn employees, services and on-line properties.

Because ThinkOn gathers certain types of information from Individuals, it is important that Individuals understand what information about them is collected, how it is collected, how that information is used, and how Individuals can control ThinkOn’s disclosure of that information.

A. INFORMATION COLLECTED
ThinkOn collects two types of information from Individuals: i) information that Individuals voluntarily provide to ThinkOn (e.g. through a voluntary registration process, sign-ups or emails); and ii) information that is derived through management logging mechanisms.

In order to fully access ThinkOn services, Individuals must first complete a registration process, during which ThinkOn will collect limited information about the Individuals. The information may include the Individual’s name, telephone numbers and email addresses.

ThinkOn does not collect personally identifiable information about an Individual except when the Individual provides such information to ThinkOn on a voluntary basis. By registering with ThinkOn, the Individual consents to the use and method of disclosure as described in this Privacy Policy. ThinkOn collects only the information necessary for the purpose of providing Services, in compliance with the law.

ThinkOn also collects personally identifiable information when the Individual interacts with ThinkOn Services to manage Subscriber resources, make inquiries, and consent to receive email or text messages containing relevant operational information.

B. COOKIES
ThinkOn on-line properties may use “cookies” and other tracking technologies. Cookies enable ThinkOn to serve secure pages to its authorized Individuals without asking them to sign in repeatedly. Most browsers allow the Individual to control cookies, including whether or not to accept them and how to remove them. If an Individual’s system is idle for a defined time, the cookie will expire, forcing the Individual to sign in again to continue their session. This prevents unauthorized access to the Individual’s information while they are away from their computer.

The Individual may set most browsers to notify the Individual if a cookie is received, or the Individual may choose to block cookies with his/her browser, but please note that if the Individual chooses to erase or block cookies, the Individual may need to re-enter his/her original login credentials to gain access to ThinkOn’s on-line properties.

C. REFERRALS
The Individual may choose to invite other people to access ThinkOn on-line properties inputting email addresses from other people via the new user invite feature. ThinkOn may store the email addresses the Individual provides so that the respondents may be added to the Subscriber’s on-line property’s account. ThinkOn does not sell these email addresses or use them to send any other communication besides invitations and invitation reminders. Recipients of invitations may contact ThinkOn to request removal of their information from ThinkOn’s database.

D. HOW THINKON USES INDIVIDUAL’S INFORMATION
ThinkOn only uses the personal information of Individuals for the original purposes it was given. An Individual’s personal information will not be sold or otherwise transferred to unaffiliated third parties. ThinkOn may share personally identifiable information with its subsidiaries or affiliates.

ThinkOn will not disclose, use, give or sell any personal information to third parties for any purposes other than to its suppliers who require this information in order to deliver services on behalf of ThinkOn. ThinkOn reserves the right to contact Individuals representing Subscribers regarding matters relevant to the underlying service provided and/or the information collected.

Personally identifiable information is used only to provide the Individual with a more convenient experience and to help ThinkOn provide relevant information regarding products or services that may be of interest to its Subscribers. ThinkOn uses personally identifiable information to support and enhance the use of on-line properties, including without limitation: fulfilling a Subscriber’s order; providing Subscriber service; tracking email invitations that Individuals send; and otherwise supporting the use of on-line properties.

ThinkOn may transfer personally identifiable information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of ThinkOn’s business or as part of a corporate reorganisation, stock sale or other change in control.

ThinkOn may disclose Information in special cases where ThinkOn has reason to believe that disclosing this information is necessary to identify, contact or bring legal action against a Subscriber or Individual who may be violating ThinkOn’s terms and conditions of use or may be causing injury or interference with ThinkOn’s rights, property, its Subscribers, Individuals or anyone who could be harmed by such activities.

ThinkOn uses non-identifying and aggregate information to better design its on-line properties and for business and administrative purposes. ThinkOn may also use or share with third parties for any purpose aggregated data that contains no personally identifiable information.

E. HOW THINKON PROTECTS SUBSCRIBER INFORMATION
ThinkOn is committed to protecting the information it receives from Individuals. ThinkOn takes appropriate security measures to protect Individual information against unauthorized access to or unauthorized alteration, disclosure or destruction of data. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, ThinkOn has implemented various security measures, including:

  • All permanent and temporary employees must sign a confidentiality agreement
  • Rules concerning the protection of the confidentiality of personal information has been added to our Code of ethics and professional conduct, and the violation of these rules can lead to disciplinary action, up to dismissal
  • All ThinkOn vendors providing goods and services with access to personal information must sign a confidentiality agreement
  • Security systems have been installed within our Service Delivery Infrastructure and appropriate safeguards have been installed in our computer systems to prevent unauthorized access

F. ACCESSING AND UPDATING PERSONAL INFORMATION AND PREFERENCES
Individuals can access the personal information relating to themselves contained in the on-line applications by sending a written request in that regard. This right of access and correction covers:

  • The right to consult the personal information in the on-line properties free of charge
  • The right to have incomplete, inaccurate or ambiguous information corrected in the on-line properties

ThinkOn may provide mechanisms for updating and correcting the Individual’s personal information, in which case the Individual may modify or remove any of their personal information by logging into their account.

If an Individual no longer wishes to receive updates or notifications, they may opt-out of receiving these communications by selecting the “opt out” link in the body of ThinkOn’s email communications.

G. CHILDREN’S PRIVACY AND PARENTAL CONTROLS
ThinkOn does not solicit any personal information from children. If the Individual is not 18 or older, the Individual is not authorized to use the on-line properties.

H. DISCLAIMER TO SECURITY
By consenting to the Terms and Conditions of the on-line properties and hence the Privacy Policy, the Individual consents that no data transmission over the Internet is completely secure. ThinkOn cannot guarantee or warrant the security of any information that the Individual provides to ThinkOn and that the Individual transmits such information to ThinkOn at his/her own risk.

I. NOTIFICATION OF CHANGES
ThinkOn reserves the right to change this Privacy Policy from time to time at its sole discretion. If at some point in the future, there is a change to our Privacy Policy, unless ThinkOn obtains the Individual’s express consent, such change will only apply to information collected after the revised Privacy Policy took effect. The Individual’s continued use of the Site indicates their acceptance.

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