English | Español | Français | हिंदी | Polski
Welcome to Thrive Global Holdings, Inc. (“Thrive Global”, “Thrive”, “we”, “us” and/or “our”). Our website (“Site”) also allows you (“Users,” “you,” or “your”) to easily access and use content, including features, resources and other information intended to help you change the way you live and work. Our mobile application and services (“App”) helps Users achieve behavior change through “too small to fail” incremental microsteps, personal assessments, video micro-learning, inspiring stories and other content and resources. Collectively, the services we provide through the Site and the App from time to time are defined as the “Service(s)”.
This Privacy Policy explains what personal data we collect through the Services, how we use and share that data, and your choices concerning our data practices. This Privacy Policy forms part of our Terms and Conditions Agreement, which is available at https://www.thriveglobal.com/terms.
Users in different regions might be subject to different data protection standards and based on their employer DPA (Data Protection Agreement) with Thrive Global (For App Users Only). This document has a section dedicated to European Economic Area (EEA), United Kingdom (UK), and Switzerland consumers and their privacy rights, as well as a section dedicated to California consumers and their privacy rights.
This Privacy Policy applies to all Services we provide, except for the Thrive Walmart Challenge, which are covered by a different privacy policy https://thriveglobal.com/walmart/privacy and different terms and conditions https://thriveglobal.com/walmart/terms.
When you interact with us through the Services, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”), described below.
Personal Data You Provide Us. We collect information that visitors to the Site enter when you sign up on the Site (e.g., email and password) or send to us electronically, for example when completing any “free text” boxes in our forms (such as on our “Contact Us” page, support request or survey submission), requesting information, registering for an event, or subscribing to email lists. While the type of data we collect depends on the nature of the inquiry, it typically includes name and contact details, company information, and phone number.
When you use the Site or the App, the following information is created and automatically logged in our systems:
Where we provide the Services under contract with Thrive Global’s enterprise customers (“Customers”) (for example, your employer), we may process some Personal Data on behalf of the Customer, such as data identifying which employees are eligible to use our Services (“Service Data”). This Privacy Policy does not apply to Service Data. Our use of Service Data is governed by our contract with the specific Customer and may be subject to the Customer’s own privacy policies. We are not responsible for the privacy policies or privacy practices of Customers or other third parties. Service Data does not include any Personal Data or other data provided to us or to the Services by a User (including a User who has access to the Services in connection with an enterprise relationship between a Customer and Thrive Global).
We use your Personal Data collected for the following purposes:
To authenticate Users and provide the Services. This processing is necessary to provide you with access to and use of the Services.
As necessary for certain legitimate business interests, which include the following:
For individuals in the European Economic Area (the EEA), United Kingdom and Switzerland, please see the “General Data Protection Regulation (GDPR) ,UK General Data Protection Regulation Users, and Swiss Data Protection Users” section below for information on what we mean by legitimate business interests and your rights.
Marketing. We may contact you to tell you about content, services or products we believe will be of interest to you. If we do, where required by law, for example if you are a User in the EU, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you or by updating your user settings. In addition, if at any time you do not wish to receive future marketing communications, you can unsubscribe here or email privacy@thriveglobal.com. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.
Usage Data. We glean valuable insights from your use of and interactions with the Services, including the aggregated and/or anonymized data that is derived from your and others’ use of the Services. We may create such aggregated and/or anonymized data from or using your interactions and contributions to the Services (including your content) and other metrics related to your usage of the Services. We use such aggregated and/or anonymized data in connection with our internal operations and functions, including, but not limited to, operational analytics and reporting, internal financial reporting and analysis, audit functions and archival purposes, as well as in connection with our other business purposes.
In addition to the Services, we may offer certain programs for Thrive Users to participate in, such as webinars, events, stories, promotional contests, etc. (each a “Thrive Program”). By participating in a Thrive Program and submitting to Thrive Global any requested Personal Data or other information, you expressly agree that (i) Thrive Global may, for the duration of the Thrive Program and thereafter, copy, modify, display, distribute, or otherwise use, for any legitimate business purpose, any audio, pictures, video, information of or disclosed by you (including any health or personal information of yourself or your family whom you have valid authorization to do so), and/or other materials you submit to Thrive Global or otherwise are recorded by Thrive Global during the applicable Thrive Program, and (ii) you release and hold harmless Thrive Global from any liability or damages that may arise from such use. IF YOU DO NOT AGREE, PLEASE DO NOT PARTICIPATE IN ANY THRIVE GLOBAL PROGRAMS.
How we share information pursuant to our lawful business purposes: There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, unless required by the law, as set forth below:
How we share information at your direction: We may share or disclose your information at your direction, such as when you authorize a third-party service to access your account. Additionally, we may provide you the option to share reports on your engagement with the Services, including statistics such as the frequency and duration of your use of the App, with Customers.
How you share information on the App: You may choose to voluntarily share information with other Users on the Services, such as when you post public information on the App or chat or otherwise engage with the User community on the App.
We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us as described in the “Contact Us” section below. We will address your request as required by applicable law.
If you would like to exercise your Data Privacy Rights, as applicable to your location of residence, please visit https://preferences.thriveglobal.com/privacy. For general inquiries regarding privacy requests and other concerns, please email privacy@thriveglobal.com.
Scope. This section applies if you are a User in the EEA, UK and, to the extent applicable, Switzerland.
Thrive Global is based in the United States. If you are accessing our Services from the European Union or other regions with laws governing data collection and use, please note that your Personal Data will be transmitted to our servers in the United States as necessary to provide you with the Services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). Although the United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located, we safeguard your personal information by treating it in accordance with this Privacy Policy. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your personal information in storage. We use secure transmission methods to collect personal data through our Site and Apps.
“Legitimate business interest” means our interest in conducting our business, managing and delivering the best Services to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.
Thrive Global Holdings, Inc. is the data processor for processing Personal Data provided to us through the Services.
EU, UK, and Swiss Users may contact DataRep, who has been appointed as Thrive’s Data Protection Representative in the EU and UK pursuant to Article 27 of the General Data Protection Regulation and Switzerland pursuant to Article 14 of Swiss Data Protection Law on matters related to the processing of your Personal Data. If you want to raise a question to Thrive, or otherwise exercise your rights in respect of your personal data (described below), you can::
Your Rights. Subject to applicable EU, UK, and Swiss regulations, you have the following rights in relation to your Personal Data that we hold about you:
Thrive Global voluntarily participates and complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (and together the respective “Principles”) as set forth by the U.S. Department of Commerce to facilitate cross-border transfers of personal data in compliance with EU law. Thrive Global has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Thrive Global has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. Note, Thrive Global is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). In the context of an onward transfer, Thrive Global has responsibility for the processing of Personal Data it receives under the DPF and subsequently transfers to vendors or service providers. We remain liable under the DPF if our vendor or service provider processes such Personal Data in a manner inconsistent with the DPF, unless we can prove that we are not responsible for the event giving rise to the damage.
For inquiries or complaints:
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Thrive Global commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Thrive Global at: privacy@thriveglobal.com.
Alternative Dispute Resolution provider:
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Thrive Global commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States and United Kingdom (please reference globalteam@jamsadr.com for non-US sessions). Thrive Global is committed to arbitrated claims and follows the terms as set forth in Annex I of the DPF Principles. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/ for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Sub-processors are regularly updated. You can join a mailing list to be notified of these changes here.
Name and Address of Sub-Processor
*May not be applicable to all Users
Do Not Track Signals: The Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
Thrive Global does not sell your personal information for payment or other monetary consideration. However, because California law broadly defines a “sale” of your personal information to include the act of making cookies and other similar data available to third party advertising and analytics providers when you visit our website, we are required to disclose the “sale” of Site User Data.
Notices to California Residents
Your California Privacy Rights – California Consumer Privacy Act (“CCPA”)
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), beginning January 2020 you have certain rights with respect to that information. In particular, you have a right to request that we provide you with the following information:
You also have a right to:
If you would like to exercise your rights under CCPA, please visit https://preferences.thriveglobal.com/privacy. For general inquiries regarding privacy requests and other concerns, please email privacy@thriveglobal.com
A California resident who has provided Personal Data, as defined under California Civil Code section 1798.83, to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personal Data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Data was disclosed in the preceding calendar year, as well as a list of the categories of Personal Data that were disclosed. California Customers may request further information about our compliance with this law by emailing privacy@thriveglobal.com Please note that we are required to respond to one request per California Customer each year, and we are not required to respond to requests made by means other than through this email address.
The Services are not directed to children who are under the age of 16. Thrive does not knowingly collect Personal Data from children who are under 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Thrive through the Services please contact us and we will endeavor to delete that information from our databases.
The Site and the App may contain links to other websites not operated or controlled by us (“Third Party Sites”), including social media services such as Facebook or Twitter (“Social Media Services”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact those sites directly for information on their privacy practices and policies.
We use cookies and other technologies to operate and administer our Services, make it easier for you to use the Services during future visits and gather usage data on our Site or App.
What Are Cookies? A “cookie” is a piece of information sent to your browser by a website you visit. By choosing to use our Site after having been notified of our use of cookies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.
Some cookies expire after a certain amount of time, or upon logging out (session cookies); others remain on your computer or terminal device for a longer period (persistent cookies). Our Site uses first party cookies (cookies set directly by Thrive) as well as third party cookies, as described below.
Type of Cookies Used. The Site uses the technologies described below.
Necessary
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.
Functionality
We use a set of cookies that are optional for the website to function. They are usually only set in response to information provided to the website to personalize and optimize your experience.
Analytics Cookies
These cookies help us to understand how visitors engage with the website. We may use a set of cookies to collect information and report site usage statistics. In addition to reporting site usage statistics, data collected may also be used, together with some of the advertising cookies described, to help show more relevant ads across the web and to measure interactions with the ads we show.
Advertisement
We use cookies to make our ads more engaging and valuable to site visitors. Some common applications of cookies are to select advertising based on what’s relevant to a user; to improve reporting on ad campaign performance; and to avoid showing ads the user has already seen.
Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
You use Services at your own risk. Thrive Global takes steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should keep this in mind when disclosing Personal Data to us and take special care in deciding what information you disclose to us over the Internet or send to us via email. We cannot control the actions of other Users with whom you may choose to share information. Therefore, we cannot, and do not, guarantee that information or content posted by a User on or through the Services will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
Your access to and use of the Services is subject to any additional terms applicable to such Services that may be posted on the Services from time to time, including without limitation, Thrive Global’s Terms of Service at https://www.thriveglobal.com/terms.
The Services and our business may change from time to time. As a result, we may change this Privacy Policy at any time and when we do we will post an updated version on this page and change the Last Updated date above, unless another type of notice is required by the applicable law. You should consult this Privacy Policy regularly for any changes. By continuing to use the Services or providing us with information after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.
You may contact the Data Protection Officer at dpo@thriveglobal.com.
Please feel free to contact our privacy team if you have any questions about Thrive Global’s Privacy Policy or the information practices of the Services. You may contact us as follows: You may send an email to privacy@thriveglobal.com or send mail to:
Thrive Global Holdings, Inc.
Customer Support
599 Broadway
6th Floor
New York, NY 10012
Tel: 1-888-700-8474
If you would like to exercise your Data Privacy Rights, as applicable to your location of residence, please visit https://preferences.thriveglobal.com/privacy. For general inquiries regarding privacy requests and other concerns, please email privacy@thriveglobal.com.