THOUGHTFUL PINCH PRIVACY POLICY
Last updated May 8, 2019
By using the Thoughtful Pinch, LLC (“Thoughtful Pinch”, “we”, “us” or “our”) website (thoughtfulpinch.com) (“Website”) or any other websites, products, services and/or mobile applications owned or operating by Thoughtful Pinch (collectively with the Website the “Platform”), you are agreeing to this Privacy Policy (“Privacy Policy”) and the Thoughtful Pinch Terms of Service (“Terms”) which we may update or amend from time to time as set forth herein. Capitalized words or phrases not defined herein have the meaning ascribed in the Terms.
Description of Users and Acceptance of Privacy Policy
This Privacy Policy applies to users who sign up for access to the Platform and its Services (“Users”), and to visitors who view only public content (“Visitors”). By visiting, using, signing up, or accessing the Platform you acknowledge that you have read, understand, and agree to be legally bound by this Privacy Policy and our Terms of Service. If you do not agree to any of the provisions of this Privacy Policy or any of the Terms of Service, you may not access or use the Platform or Services.
Information We May Collect
You may be asked to provide your personal information anytime you are in contact with Thoughtful Pinch, or the affiliates or subsidiaries of Thoughtful Pinch, or when using Thoughtful Pinch or any other Services or Platform provided by Thoughtful Pinch, or its subsidiaries, affiliates, or partners. Thoughtful Pinch and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy for purposes of providing the Services to you as well as providing customer service, conducting research, and improving the Services For more details on why we collect information and how it is used please see “Use of Information” below. Information may also be combined with other information to provide and improve our products, Services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or Services or respond to any inquiries you may have. By voluntarily providing information, including personal information, you are consenting to our use of it in accordance with this Privacy Policy. If you provide personal information to the Services, you acknowledge and agree that such personal information may be transferred from your current location to the offices and servers of Thoughtful Pinch and the authorized third parties referred to herein and our Terms of Service.
Here are some examples of the types of information Thoughtful Pinch may collect (collectively “Personal Information”):
Personal Data and Identifying Information for registration (e.g. name, email address, location);
The geographical area in which you use your computer or mobile device, as indicated by and IP address or similar identifier;
Payment processing information, including but not limited to account numbers, routing numbers, and other payment methods;
The Thoughtful Pinch products and Services that you use;
Access to information stored on your mobile device, including but not limited to access to your camera, files, photograph and any other digital content stored on you mobile device; and
Any content that you provide or 3rd party data which may be synced with your account.
Some information (which may be deemed personal information in some jurisdictions) may be automatically received and stored as non-identifiable personal information. Such information is collected passively using various technologies and cannot presently be used to specifically identify you. Example of this non-personal information includes the type of internet browser or mobile device you used, any Platform from which you have come to the Services, your operating system location data (which is anonymous), your IP address, cookie ID, pages accessed and clickstream, additional session information and timestamps. We may store such non-personal information ourselves or it may be included in databases owned and maintained by our affiliates, agents, or service providers. The Services may use such non-personal information to assist us in providing effective Services and to collect broad demographic information for aggregate use.
Cookies
When you utilize the Platform or our Services we strive to make that experience as efficient as possible, and our web server may send data collection and tracking tools such as web beacons, pixel tags, embedded links, cookies and other similar tracking techniques to your computer or mobile device. Cookies are small pieces of information which are issued to your computer or mobile device when you visit a Platform or access or use a mobile application, and which store and sometimes track information about your use of the Services and Platform. A number of cookies we use last only for the duration of you web or application session and expire when you close your browser or exit the application. Other cookies may be used to remember you when you return to the Platform and will last longer. Some cookies are set by us, and others by third parties who are delivering Services on our behalf. In all cases in which we use cookies, we will not collect Personal Information unless we obtain your permission.
Most web and mobile device browsers automatically accept cookies. You may change or adjust your settings to prevent this if you wish. Please note, however, that by blocking or deleting cookies you may not be able to take full advantage of the Services. If you have questions about how to change or adjust your settings please direct those inquiries to the maker of your device or service provider.
Use of Information
The information we collect allows us to provide the Services as described in the Terms of Service. We collect information from you so that we can provide the transfers to and from your User Account that you identify, and request using the Site and provide information that you request from us. We may send you newsletters or other communications, and we may contact you regarding Services we provide or that you request. We may provide information to third party service providers, subsidiaries, affiliates, or other partners, that will help us or allow us to process the Services that you request.
These service providers will have access to your personal information in order to provide these Services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the Services. We use demographic information to better understand our customers and improve our products and Services.
We also use personal information to help us create, develop, operate, deliver, and improve our products, Services, content, and advertising, and for loss prevention and anti-fraud purposes.
We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate Services. For example, we may use date of birth to verify the age of account holders to ensure they are of legal age to use the Services we provide.
From time to time, we may use your personal information to send important notices, such as communications about transaction or transfers, and about changes to our terms, conditions, and policies. Because this information is important to your interaction with Thoughtful Pinch, you may not opt out of receiving these communications.
We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Thoughtful Pinch’s products, Services, and customer communications.
We may also share or disclose your personal information with our affiliates and subsidiaries. We may share or disclose your personal information to protect our customers; to maintain the security of our Services; to detect, prevent, or report fraud, criminal activity, or violations of our terms of service/use; to protect the health and safety of our customers or the general public; and to protect our rights and property.
Some Platforms may belong to ad networks that use your browsing history across Platforms to choose which ads to display on their sites; the displayed ads may include advertising for Thoughtful Pinch. Platforms may also offer their own opt-out methods for interest-based advertising.
In addition to the sharing described elsewhere in this Policy, we may share personal information with companies, organizations or individuals outside of the Company in a de-identified format when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information. Sensitive personal information is a particular category of personal information relating to racial or ethnic origins, political or religious beliefs or sexuality.
We will share personal information with third party companies, organizations, or individuals outside of the Company if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
Meet any applicable law, regulation, subpoena, legal process, or enforceable governmental request.
Enforce applicable Terms of Service, including investigation of potential violations.
Detect, prevent, or otherwise address fraud, security, or technical issues.
Protect against harm to the rights, property, or safety of Thoughtful Pinch, our users, customers or the public as required or permitted by law.
Use of Other Information
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it,
We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where Thoughtful Pinch accessed from so that we can better understand customer behavior and improve our products, Services, and advertising.
We may collect information regarding customer activities on our Platform and mobile application Services, and from our other products and Services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our Platform, products, content, and Services are of most interest. Aggregated data is considered nonpersonal information for the purposes of this Privacy Policy.
We may collect and store details of how you use our Services and/or Content, including search queries. This information may be used to improve the relevancy of results provided by our Services. Except in limited instances to ensure quality of our Services over the Internet, such information will not be associated with your IP address.
With your explicit consent, we may collect data about how you use your device, the applications and Platform in order to help our developers improve the apps and Platform.
If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
Disclosure to Third Parties
At times Thoughtful Pinch may make personal information available to strategic partners that work with Thoughtful Pinch to provide products, Services, or Content, or that help Thoughtful Pinch market to customers or Users. Personal information will only be shared by Thoughtful Pinch to provide or improve our products, Services, Content, and advertising; it will not be shared with third parties for their marketing purposes nor will it in any event be sold to any third party.
Thoughtful Pinch shares personal information with companies who provide Services such as information processing, payment processing, delivering products to you, managing and enhancing user data, providing user service, assessing your interest in our products and Services, and conducting User research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Thoughtful Pinch operates.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Thoughtful Pinch to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our Terms of Service or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Thoughtful Pinch is not in the business of selling or renting your information. Your information will only be shared when necessary to provide Services, enforce the Terms of Service, as otherwise required by law, or in cases where you have provided your explicit consent.
Retention of Personal Information
Thoughtful Pinch will keep your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and Terms of Service unless a longer retention period is required or permitted by law. If your personal information is incorrect or needs updating, please contact Thoughtful Pinch immediately at support@thoughtfulpinch.com and we will be happy to assist.
Protecting Your Information
Your security and the security of your information is important to us. When you enter sensitive information on our Platform, we encrypt the transmission of that information using HTTPS. We and our custodian also use third-party ID verification to ensure our users’ true identities are validated.
We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration or destruction. Unfortunately, however, no security system is impenetrable. We cannot guarantee the security of our databases or the security of the databases of our affiliates or third-parties which we may share information with, nor can guarantee that information stored with us will not be stolen while being transmitted over the internet. Specifically, email sent to us may not be secure, and you should be careful when determining what information, you wish to communicate via email. If you have questions about security on our Platform please contact support@thoughtfulpinch.com.
Third Party Services
Thoughtful Pinch Platforms, products, applications, and Services may contain links to third-party Platforms, products, and Services. Our products and Services may also use or offer products or Services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
Additionally, we may use third-party analytics services (for example, Google Analytics, Mixpanel, Braze, and others) to evaluate your use of the Platform, compile reports on activity, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
Use of Information by You
As part of the Services, we will provide you with information gathered from your Platform. It is solely your responsibility to make appropriate disclosures to visitors to your Platform about the type of information that may be collected and its use. You are solely responsible for implementing and ensuring your own privacy policy which complies with all federal, state and local laws. Thoughtful Pinch is not responsible for any act or omission by you with regard to such information. Thoughtful Pinch’s liability shall be limited pursuant our Terms of Service and you agree to indemnify, defend, and hold Thoughtful Pinch harmless from and against any and all claims, suits or otherwise relating in any way to your use of information provided to you by Thoughtful Pinch.
Choices and Exclusions
You may visit the Platform without providing any personal information. If you do not provide the required information, however, you will not be able to use certain Services.
This Privacy Policy does not apply to any Personal Data or other information collected by us other than personal information collected through our Services. It does not apply to any unsolicited information you voluntarily provide to us, post, or upload through the Services or through any other means (“Unsolicited Information”). This includes, but is not limited to, information posted to any public areas of the Services or Platform. You agree that Unsolicited Information becomes the intellectual property of Thoughtful Pinch to the fullest extent permitted by applicable law and agree to assign any and all residual rights or interest that you may have in such Unsolicited Information to Thoughtful Pinch. All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution to the fullest extent permitted by law.
Children
We do not knowingly collect personal information from children under the age of 13. If you are under the age of 13, please do not use the Services and/or submit any personal information through the Services. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information on any Platform without their permission.
Links to Other Sites
This Privacy Policy applies only to our Services. Our Services contain links to other web sites not operated or controlled by us, to which our Privacy Policy does not apply. The links from the Service do not imply that we have reviewed the third-party sites and we suggest contacting those sites directly for information regarding their respective privacy policies.
Changes
The Services and Platform may change from time to time. As a result, we may be required or deem it necessary or desirable to change this Privacy Policy or our Terms of Service. We therefore reserve the right to update or modify this Privacy Policy or our Terms of Service at any time, and from time to time, and with or without notice to you. Any material change will be preceded by a notice posted on the relevant Services. If you disagree with our revisions to the Privacy Policy you may de-activate your account and discontinue the use of our Services. Please review this Privacy Policy and our Terms of Service periodically, especially before providing and personal information. Your continued use of the Services after any changes or revisions individuate your agreement with such changes or revisions.