The websites thethrivologycompany.com, thrivology.co, thrivology.co.uk, Thrivology Digital.academy, Thrivology Digital.com, Thrivology Digital.co.uk, and all other pages stemming from the above URLs (hereinafter collectively “Website” or “The Websites”) are owned and operated by Thrivology Limited, a United Kingdom Registered Company (Company number: 13215559) trading as The Thrivology Company and Thrivology Digital (hereinafter “we” “us” “our” “Thrivology” or “Thrivology Digital”). By visiting and using The Websites, you (hereinafter “visitor” “you” “your”) agree to the following Privacy Policy, and your use of The Websites constitutes your acceptance to be bound by the terms outlined herein. Your use of The Websites, and any information that you contribute or provide to us is subject to this Privacy Policy. The following Privacy Policy informs you of how we collect and process your personal data, including that which you provide by voluntarily “opting in” to receive a free resource, subscribing to our email list or newsletter, purchasing a product, service or membership (such as the Thrivology Digital membership program), or contacting us via The Websites. It also covers personal data that we may collect automatically from you based upon your activity on The Websites. For purposes of this Policy, personal data means any information that can be used to identify an individual, directly or indirectly. We may update these terms from time to time and will provide notice via email of any material changes made to this Privacy Policy. We will not provide notice of any minor updates, and you acknowledge it is your responsibility to read any updated version(s), and that you agree to be bound by the most updated versions of this Policy. Your first use of The Websites after the date of any non-material amendments or alterations will constitute your acceptance of such changes; therefore, we recommend reviewing this policy regularly to stay updated on any changes made. If you do not agree with or understand the contents of this Privacy Policy, please immediately stop use of The Websites and contact us at info@thethrivologycompany.com for assistance.

Registration and Access

Minimum Age: You must be at least 18 years old to use the Services on The Websites. If you are under 18, you may not register for or use our Services. Registration: You must provide accurate and complete information to register for an account to use our Services. You may not share your account credentials or make your account available to anyone else and are responsible for all activities that occur under your account. If you create an account or use the Services on behalf of another person or entity, you must have the authority to accept these Terms on their behalf.

LAWFUL GROUNDS FOR PROCESSING

In order to ensure compliance with the European Union’s General Data Protection Regulation (“GDPR”), we confirm we have lawful grounds for processing the information we collect from you. If you provide your personal information via the “contact us” page on The Websites or send us any other form of electronic communication, we will process your data based upon our legitimate interest to respond to visitor or customer inquiries. If you elect to receive communication from us by “opting in” and provide us with your name and email address in exchange for a free resource or training, or if you purchase a product, service or membership (such as the Thrivology Digital membership program) from us, we will process your data for the purpose it was collected based on your affirmative consent to do so, and may periodically send you additional email marketing based upon our legitimate interest in marketing to those that have shown an interest in our offerings. We may also give you the option to be added to our email list in order to receive our newsletter, information about our products, services, and memberships, and other information we believe may be of interest to you based upon your decision to opt-in to one or more of our free resources, and will obtain your consent to do so. You may withdraw consent at any time by contacting us and requesting your information be edited, updated, or deleted. We do not collect any sensitive data, including but not limited to data relating to your health, religious or political beliefs, trade union membership, genetics, sexual orientation, nor any information regarding criminal offenses or convictions. In accordance with the Privacy and Electronic Communications Regulations (PECR), if you are located within the UK, we may also send you relevant advertisements or marketing information if you (1) have ever purchased or inquired about our products, services or memberships, (2) at the time of your purchase or inquiry, you agreed to receive advertising or marketing information from us, and you have not elected to opt out of receiving that information.

HOW & WHY PERSONAL INFORMATION IS COLLECTED

We collect your personal information when you voluntarily, directly provide it to us to receive a free or paid resource, product, service, or membership (such as the Thrivology Digital membership program), or when you fill out a form or send an email to contact us through The Websites. We do so in order to provide you with the resource, product, service, or membership you have indicated you’d like to receive. We may also track your future interactions with our content and use your personal information to keep you informed about the offerings you have elected to receive, as well as any related or similar products, services, or memberships we think you may be interested in. Your personal information will be collected by us following your choice to manually enter it and click to opt-in to our list or make a purchase. No such information will be collected without your taking action to opt-in, make a purchase, or request a free resource. We may also receive data from third parties like Google Analytics, Facebook and other advertising platforms, providers of technical or payment services as needed, and other similar third parties. We do our best to only utilize third parties who have been deemed GDPR-compliant, and whom we have either completed a data processing agreement with, or have reviewed and confirmed their policies regarding data processing to ensure compliance.

HOW WE USE YOUR PERSONAL INFORMATION

You have the right to know and understand how your personal information is used. We will use the personally identifiable information you voluntarily provide to us through The Websites in order to carry out the service, product, or membership (such as the Thrivology Digital membership program) you requested. This includes providing free resources, trainings, newsletters, periodic promotional emails, and notifying you about any changes to our policies or offerings. We may also use your personal information to create “look-a-like” audiences in our digital marketing campaigns, which includes uploading your information into our social media advertising platforms. If you make a purchase from us, we will use your billing address and payment information solely to complete your desired purchase or purchases, and will not store or share any such information beyond what is necessary to facilitate the transaction. By providing this information to us, you understand and agree that we may use and temporarily store such information to send order confirmations, process payments, or utilize comments for marketing purposes related to the product, service or membership you purchased. If you purchase from us, we may also use your personal information to send necessary updates, resources or materials related to the product, service or membership you have purchased, or to keep you informed of any necessary information directly pertaining to your purchase. Non-Personally Identifiable Information: Additional non-identifying information that is collected may be used to provide an overview of how people are accessing and using The Websites; it is not used for any additional purposes, and we do not use any such data to make automated decisions. We may also record some or all information to help create a better user experience. We may use information such as your IP address to help diagnose technical problems with our servers or websites, and to determine which portions receive the most traffic, in order to understand which content is most useful to our visitors. Your IP address will not personally identify you, and may be used in such limited purposes as outlined above, solely to improve the user experience on The Websites.

HOW PERSONAL INFORMATION IS STORED & SHARED

You have the right to know what personal information is stored (and not stored) and how it is processed. Your information is stored through a secure data management system, and it is important to us to take appropriate measures to ensure your personal information is kept confidential. You understand that there are limited purposes where we will share your confidential information, including with those who are providing technical support for The Websites, or those who are members of our team, such as legal and accounting personnel. Any parties who will have access to your personal information will keep such information confidential and will never share it with any unrelated parties to the best of our abilities. Personal information provided by you will never be sold to any other company or person without your consent, other than what is required to complete a purchase, service or membership you have requested, unless required to do so by law or any governmental regulations. For purchases, email opt-ins, and other resources we offer in partnership with another company, Thrivology Limited will share your name and email address only with the partnered company. No additional billing or purchase information will be shared, and we recommend reviewing the partnered company’s privacy policy for their policies regarding data retention. You will be notified of any such data sharing on the relevant landing or purchase page, and we will not share with anyone other than the partnered company without requesting additional consent. We require all such third parties to treat your personal information in accordance with the law, and only allow them to process your personal data for specific, necessary purposes. Where we have outsourced a function or activity to an external service provider, we will only disclose personal data that the service provider needs to undertake that function or activity, and we require external service providers to agree to keep your personal data secure in accordance with relevant laws. We will not share your personal data with any third party for that third party’s marketing purposes unless we have obtained your consent to do so. Please be aware we may disclose information you provide if we are required to do so by law, or if there is an honest, good faith belief that such disclosure is necessary to protect the rights of The Websites or of Thrivology Limited, if any portion of our policies are being violated, to prevent or mitigate a belief that a crime may be committed, or to protect the safety or rights of our other users. This information may also be shared as a result of the sale of Thrivology Limited or any branch of the company, as well as with any joint venture partners or affiliate marketers, should we deem it necessary to share such information. We will always take all reasonable measures to protect and safeguard your personal information. The Websites, and the servers and parties which made these websites available on a global scale, are located within and operate within the United Kingdom. The internet laws of the United Kingdom and the principles of the General Data Protection Regulation (GDPR) govern any and all matters relating to The Websites, including content. Any personal information you choose to provide through The Websites, including subscribing to a newsletter, opting-in to receive a free resource, purchasing a product, service or membership, or contacting us will be processed within the United Kingdom. Depending on the type of information and how it is stored by us, that information may then be transferred within the United Kingdom or to other countries, some of which may not have data protection laws that are as comprehensive or protective as those in your country of residence; however, our collection, storage, and use of your Personal Information will at all times be governed by this Privacy Policy. By visiting The Websites, you acknowledge this information, and by submitting any personal information onto The Websites, you hereby authorize this transfer and processing of information. By collecting and using your personal data, Thrivology Limited is acting as a data controller, meaning we determine what personal information is collected, how long it is stored, and what the Personal Information will be used for. We utilize third-party companies to act as data processors, which may store information such as names and email addresses that make up our email lists and customer databases. To the best of our ability, we have researched and concluded that all third-party data processors we use have advised us they are compliant with the General Data Protection Regulations as well.

INFORMATION PROTECTION & SECURITY

We use commercially reasonable methods to safeguard your personal data, including that which you provide to us, and that which we collect automatically, by using reasonable online security measures, and sharing your data with reputable third-party vendors that are compliant with generally accepted security and safety measures. We utilize a Secure Sockets Layer (SSL) on The Websites in order to assist in the secure transfer of information; however, it can never be guaranteed. Should we become aware that a data breach has occurred, we will timely notify the necessary parties with as much information as we have available. While our team does our best to protect the information we collect and prevent any misuse, unauthorized access, or disclosure, you understand that we cannot be responsible should an unauthorized third party obtain access to our information without our consent. Should The Websites be tampered with, you understand that your personal information may be accessed by these unauthorized parties. You agree that we are not responsible for any such actions, and acknowledge you will hold us harmless should your information become intercepted in this way without our knowledge, permission, or consent, including a release of any and all claims related to use of such information by such an unauthorized party.

DATA RETENTION

We will retain the minimum amount of Personal Information required of yours, including name, email address, and behavior tracking data, as long as you elect to remain on our mailing list or are a customer with an active product, service or membership purchase. We will also retain any additional Personal Information as long as it is needed in order to fulfill the purpose for which it was initially collected, such as completing other purchases. We will retain and use collected Personal Information as necessary in order to comply with any legal obligations, resolve any disputes, or as otherwise reasonably determined. If at any point you elect to be removed from our database, your Personal Information will be deleted and no longer retained.

YOUR RIGHTS TO CONTROL YOUR PERSONAL INFORMATION

You have the right to access, update, edit, or delete your Personal Information from our database. You may “unsubscribe” from our email list at any time by clicking the “unsubscribe” link at the bottom of any email we send you. Should you wish to request access to the Personal Information that Thrivology Limited has about you, correct or edit any information, or unsubscribe from our email list and remove your Personal Information from our database, you also have the option to do so at any time, free of charge, by reaching out to us by e-mail at info@thethrivologycompany.com

RIGHT OF ACCESS, RIGHT TO RECTIFICATION, RIGHT TO RESTRICTION OF PROCESSING, RIGHT TO DATA PORTABILITY

You have the right to request information about how your Personal Data is being processed, request a copy of the data we have, correct or edit data you initially provided to us, restrict how we process your data in certain circumstances, and receive your personal data in order to use it elsewhere. Please contact us at info@thethrivologycompany.com for more information.

RIGHT TO BE FORGOTTEN

You have the right to withdraw your consent to allow us to process your Personal Information by clicking the “unsubscribe” link at the bottom of any email we send you. Once unsubscribed, we will remove you from our mailing list, and you should not receive any further emails from us, barring any technical errors.

THIRD PARTY LINKS – NOT INCLUDED UNDER THIS POLICY

We may provide links to other websites on The Websites from time to time. Unless otherwise stated, this Privacy Policy only covers Personal Information that we collect from you on The Websites, which is expressly controlled by us. You understand that should you click on a link and be taken to another website, this Privacy Policy does not apply, and we have no control, responsibility, or liability for the content, activities, or policies of any other company, website, or individual. You acknowledge and agree that we are not responsible for the privacy policies or practices of third parties, and that you understand you will need to review the privacy policy of each individual website to confirm their specific policies.

AGE REQUIREMENTS

Our Websites and services are intended solely for individuals aged 18 and over. We do not knowingly collect or process any personal data from anyone under the age of 18. If you are under 18 years of age, please do not attempt to use our Websites or provide any personal information to us. If we become aware that we have unintentionally collected personal data from someone under 18, we will delete this information promptly. Parents and guardians should monitor their children’s online activities and prevent them from submitting any personal data to our Websites. If you have reason to believe we may have unintentionally collected personal data from someone under 18, please contact us immediately at info@thethrivologycompany.com so we can delete it. By using our Websites and services, you affirm that you are at least 18 years old. If we learn later that you are under 18, we reserve the right to delete any personal data you may have provided. Please read and review this Privacy Policy carefully. If you have any questions regarding this policy, your rights herein, or would like to access, update or remove your Personal Information from our database, please contact us at info@thethrivologycompany.com