Thrive Global Privacy Policy

Last Updated: February 3, 2020

Welcome to Thrive Global Holdings Inc. (“Thrive”, “we”, “us” and/or “our”). Our mobile application (“App”) helps users (“Users,” “you,” or “your”) achieve behavior change through “too small to fail” microsteps, personal assessments, video micro-learning and inspiring stories. Our website (“Site”) also allows you to easily access and use content, including features, resources and other information intended to help you change the way you live and work. Collectively, the services we provide through the Site and the App are defined as the “Service(s)”.

This Privacy Policy explains what personal data we collect through the App and the Site, 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 are available at https://www.thriveglobal.com/thrive/terms.

By providing us with your personal data when using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services.

Thrive complies with the EU-U.S. and Swiss-U.S. Privacy Shield frameworks (“Frameworks”) as set forth by the U.S. Department of Commerce regarding the processing of personal data transferred from the EU and Switzerland to the U.S. (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway). Thrive has certified that it adheres to the Privacy Shield Principles (described below). If there is any conflict between the policies in this Privacy Policy and the EU or Swiss Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Frameworks and to view our certification page, please visit https://www.privacyshield.gov/.

INFORMATION WE COLLECT

When you interact with our Site or App, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”), described below.

I. App Users

Personal Data You Provide Us. We collect the information that you choose to provide when you use the Services, such as your name, email address contact details, and password. You may also choose to provide other information to make public on the Services, such as a profile photo, biography, country information, demographic information (such as your racial and ethnic origin, as well as gender and age). We may also collect information on your interests and behaviors (such as the content you are most interested in), including through the use of cookies and other technologies as described below.

Automatically Collected Data. When you download and use our App we will automatically collect certain information, described under the Automatically Collected Data section below.

Location Information. When enabled by you, we collect location information provided by your device. We may also obtain location information you provide in your profile or from your Internet Protocol (IP) address. With your consent where required by the applicable law, we may also determine location by using other data from your device, such as precise location information from GPS, information about wireless networks or cell towers near your mobile device.

II. Site Users

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.

Automatically Collected Data. We automatically collect certain information relating to your use of our Site, described under the Automatically Collected Data section below.

Location Information. When enabled by you, we collect location information provided by your device. We may also obtain location information you provide in your profile or from your Internet Protocol (IP) address. With your consent where required by the applicable law, we may also determine location by using other data from your device, such as precise location information from GPS, information about wireless networks or cell towers near your device.

III. Automatically Collected Data

When you use the Site or the App, the following information is created and automatically logged in our systems:

• Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site, or that the App automatically sends when you use the Services. Log data includes your IP address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Services.
• Cookies: Information from cookies and other technologies. Please see the “Cookies” section below to learn more about how we use cookies and other technologies.
• Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
• Usage Information: Information about how you use our Site and the App, such as the types of content that you view or engage with, the features you use, the actions you take, the other Users you interact with and the time, frequency and duration of your activities. 

IV. Service Data. Where we provide the Services under contract with Thrive’s enterprise customers (“Customers”) (for example, your employer), that Customer controls whether the Customer provides Personal Data or other information to or in connection with the Services. In this Privacy Policy we refer to the all of the data we process that is provided to us directly by our Customers as “Service Data”. 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). 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.

HOW WE USE INFORMATION

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:

• To respond to your inquiries and fulfill your requests for products and services;
• To customize our Services for you. For example, we use information on your use of Services features, including information that we obtain through cookies and other technologies, to better understand your needs and interests in order to personalize your experience with our Services by presenting content or functionalities tailored to your interests;
• To send administrative information to you, for example, information regarding the Site or the App, and changes to our terms, conditions, and policies;
• To provide, maintain and improve the content and functionality of the Services. For example, we regularly fix bugs or user experience issues that may be tied to particular user accounts. We use cookies and other technologies to analyze how Users interact with our Services. And that analysis can help us build better Services;
• To conduct research, and provide aggregate and anonymized information on your use of our Services to third parties (such as device manufacturers);
• If you ask us to delete your data and we are required to fulfill your request, to keep basic data to identify you and prevent further unwanted processing;
• To prevent fraud or criminal activity, misuse of our products or services, and ensure the security of our IT systems, architecture and networks; and
• To (a) comply with legal obligations and legal process; (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our Terms and Conditions Agreement; (d) protect our operations or those of any of our affiliates; (e) protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain, as required or permitted by the law.

For individuals in the European Union (“EU”) and Switzerland, please see the “European Union (EU) Users” section below for information on what we mean by legitimate 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, please contact us at [email protected] 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.

SHARING AND DISCLOSURE OF INFORMATION

We may share or disclose your information at your direction, such as when you authorize a third-party service to access your account or when you voluntarily share information or content via the Services.

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:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions: providers of hosting, caching and other IT services, email communication and automation platforms, customer support services, analytics, marketing, advertising (for more details on the third parties that use cookies and other technologies through the Site and the App, please see the “Cookies” section below). For example, we use Google Analytics to collect certain demographic data and to understand how our Site and the App are used, and Google Cloud, Heroku and Amazon Web Services for hosting. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of Users of the Site or the App, or the public, or (iv) protect against legal liability.

DATA RETENTION

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.

UPDATE YOUR INFORMATION

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.

CALIFORNIA PRIVACY DISCLOSURE

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.

EUROPEAN UNION (EU) USERS

Scope. This section applies if you are a User in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).

Data Controller. Thrive Global Holdings Inc. is the data controller for processing Personal Data provided to us through the Services. To find out our contact details, please see the “Contact Us” section below.

You can also contact DPR Group, who has been appointed as Thrive’s Data Protection Representative in the EU pursuant to Article 27 of the General Data Protection Regulation 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), please contact DPR Group as follows:

• send an email to [email protected];
• fill in the online form at www.dpr.eu.com/thriveglobal, or
• mail your inquiry to DPR Group at the most convenient of the addresses in the table below. Please ensure post is addressed to ‘DPR Group’ and not to ‘Thrive Global Holdings, Inc.’ directly, to ensure that your communications are received by DPR Group. Please refer clearly to Thrive in your correspondence.

Country	Address
Austria	DPR Group, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Belgium	DPR Group, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium
Bulgaria	DPR Group, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria
Croatia	DPR Group, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia
Cyprus	DPR Group, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus
Czech Republic	DPR Group, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic
Denmark	DPR Group, Lautruphøj 1-3, Ballerup, 2750, Denmark
Estonia	DPR Group, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia
Finland	DPR Group, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland
France	DPR Group, 72 rue de Lessard, Rouen, 76100, France
Germany	DPR Group, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
Greece	DPR Group, 24 Lagoumitzi str, Athens, 17671, Greece
Hungary	DPR Group, EMKE Building, Rákóczi Út 42, Budapest, 1072, Hungary
Ireland	DPR Group, Phoenix House, Monahan Road, Cork, T12 H1XY, Republic of Ireland
Italy	DPR Group, BPM 335368, Via Roma 12, 10073 , Turin, Italy
Latvia	DPR Group, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia
Lithuania	DPR Group, Vilniaus g.31, Vilnius, LT- 01402, Lithuania
Luxembourg	DPR Group, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg
Malta	DPR Group, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
Netherlands	DPR Group, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands
Poland	DPR Group, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland
Portugal	DPR Group, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal
Romania	DPR Group, World Trade Centre, Piata Montreal no 10, Entrance F, 1st Floor, Sector 1, Bucharest, 11469, Romania
Slovakia	DPR Group, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia
Slovenia	DPR Group, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia
Spain	DPR Group, Puerta de las Naciones, Ribera del Loira 46, Madrid, 28042, Spain
Sweden	DPR Group, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden
United Kingdom	DPR Group, BPM 335368, 372 Old Street, EC1V 9AU, London, United Kingdom

Your Rights. Subject to applicable EU law, you have the following rights in relation to your Personal Data that we hold about you:

• Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of all Personal Data you are lawfully entitled to receive along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent, where applicable. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by us by automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
  • If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or
  • If we are processing your Personal Data for direct marketing.
• Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
• Rights in relation to automated decision-making: You have the right to be free from decisions based solely on automated processing of your Personal Data (including profiling) which produce a significant legal effect on you, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

Legitimate Interest. “Legitimate 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 to by law.

Children. The Services are not directed to EU data subjects who are 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.

PUBLICLY POSTED INFORMATION

This Privacy Policy shall not apply to any information you post to the public areas of the Services. Comments posted to public areas may be viewed, accessed, and used by third parties subject to those parties’ privacy practices and policies.

CHILDREN

The Services are not directed to children who are under the age of 13. Thrive does not knowingly collect Personal Data from children who are under 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Thrive through the Services please contact us and we will endeavor to delete that information from our databases.

LINKS TO OTHER WEBSITES

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.

COOKIES

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 the 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. For more details on cookies please visit All About Cookies.

Type of Cookies Used. The Site uses the technologies described below.

CATEGORY	DESCRIPTION	WHO SERVES THE TECHNOLOGY	PRIVACY POLICY	OPT OUT
Strictly necessary	We use cookies that are strictly necessary to provide Users with the Services and to use some of their features, such as the ability to log-in and access to secure areas. These cookies are essential for using and navigating the Site. Without these cookies, basic functions of our Site would not work. We also use a cookie to record when a User has agreed to the cookie consent banner.	Thrive	Thrive	Because these cookies are strictly necessary to deliver the Site and the Services, Users cannot refuse them.
Analytics/performance	We use “analytics” cookies that allow us to recognize and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our Site works, for example by making sure users are finding what they need easily. The collected data provides us only with anonymous traffic statistics (like number of page views, number of visitors, and time spent on each page). These cookies also may allow us to track how often posts on third party websites, such as social media sites, are clicked on.	FacebookGoogle AnalyticsKeyweeParselyQuantcastQuora	Facebook Work PrivacyGoogle AnalyticsGA Cookie ExpirationKeyweeParselyQuantcastQuoraFacebook	Google Analytics: Opt-out Browser Add-onKeywee: Users can opt out by disabling cookies for keywee.co.Parsely: Auto Opt-outQuantcast: Opt outQuora: Opt out
Functionality	We use cookies to enhance the performance and functionality of the Site and our services (such as collecting performance and error data). These cookies are not essential for using and navigating the Site. However, without these cookies, certain functionality may become unavailable.	New Relic	New Relic	New Relic: Users can opt out by disabling cookies for newrelic.com and nr-data.net.

Technologies used on the App. We use Mixpanel on the App to track how Users interact with our App to make better informed product decisions. The information collected includes event-based data to determine the value of individual features and demographic information on Users, which may include a User’s locations and device configurations, age and gender. For more information on Mixpanel’s privacy practices, visit https://mixpanel.com/legal/privacy-policy/. We also use Google Analytics, a web analytics service provided by Google Inc., to gather statistics on your use of the App. For more information on Google Analytics privacy practices, read here.

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:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

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.

SECURITY

You use Services at your own risk. Thrive 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 e-mail transmission is ever fully secure or error free. In particular, e-mail 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 e-mail. 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.

OTHER TERMS AND CONDITIONS

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’s Terms and Conditions Agreement at https://www.thriveglobal.com/thrive/terms.

CHANGES TO THE PRIVACY POLICY

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 Site and the App 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.

Data Transfers. We rely on the EU-U.S. and Swiss-U.S. Privacy Shield certification to transfer Personal Data that we receive from the EU and Switzerland to Thrive in the U.S. (for more information, please read the “Privacy Shield” section below).

PRIVACY SHIELD

General. We rely on our Privacy Shield certification to transfer Personal Data that we receive from the EU and Switzerland to Thrive in the U.S. and we process such in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (“Privacy Shield Principles”), as described below.

Notice And Choice. This Privacy Policy provides notice of the Personal Data collected and transferred under the Privacy Shield and the choice that you have with respect to such data. It also provides information about other Privacy Shield Principles that are set forth below.

Accountability for Onward Transfers. We may be accountable for the Personal Data we receive under the Privacy Shield that we may transfer to third-party service providers (as described in the “Sharing and Disclosure of Information” section above) if they process Personal Data in a manner inconsistent with the Privacy Shield Principles and we are responsible if they do so and for the harm caused.

Security. We maintain security measures to protect Personal Data as described in the “Security” section of this Privacy Policy.

Data Integrity and Purpose Limitation. We take reasonable steps to ensure that Personal Data is reliable for its intended use, and that it is accurate, complete and current for as long as we retain it. Our data retention practices are described in the Data Retention section of this Privacy Policy.

Access. You have certain rights to access, correct, amend, or delete Personal Data where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. Please see the “European Union (EU) Users” section above for more information on the rights of Users in the EU (and, to the extent applicable, Users in Switzerland). When we process Personal Data on behalf of our Customers, we will process such requests pursuant to our contract with the applicable Customer.

Recourse, Enforcement, Liability. In compliance with the Privacy Shield Principles, Thrive commits to resolve complaints about our processing of your Personal Data. European Union and Swiss individuals with inquiries or complaints regarding this Private Shield Policy should first contact Thrive as follows:

• Email: [email protected]
• Attention: Customer Support
• Postal Mail: 599 Broadway, 6th Floor, New York, NY 10012, United States of America
• Tel: 1-888-700-8474

We have further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider JAMS (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield. Thrive will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at www.jamsadr.com/international-mediation-rules.

If your complaint is not resolved through these channels, under certain conditions a binding arbitration option may be available before a Privacy Shield Panel. For additional information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Personal Data received or transferred pursuant to the Frameworks.

INTERNATIONAL USERS

Thrive 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). 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. Some of our service providers (such as Google Inc. and Amazon Web Services) are certified to the Privacy Shield framework operated by the US Department of Commerce for transfer of Personal Data from the EU and Switzerland, as applicable, to the United States. Where we transfer your Personal Data out of the EU we will take steps to ensure that your Personal Data receives an adequate level of protection where it is processed and your rights continue to be protected.

CONTACT US

Please feel free to contact us if you have any questions about Thrive’s Privacy Policy or the information practices of the Services. You may contact us as follows: You may send an email to [email protected] send mail to:

Thrive Global Holdings, Inc.
Customer Support
599 Broadway
6th Floor
New York, NY 10012
Tel: 1-888-700-8474

If you are an individual in the EU, you can also contact DPR Group, who has been appointed as Thrive’s Data Protection Representative in the EU pursuant to Article 27 of the General Data Protection Regulation. Please read the European Union (EU) Users section above to learn how to contact DPR Group.