Privacy Policy

1. ThriveDX SaaS Ltd. And its affiliates (defined below), including but not limited to ThriveDX SaaS Inc., ThriveDX SaaS Pte. Ltd., and Lucy Security AG (“we,” “us,” “our”, or “ThriveDX”) works hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) on which this Privacy Policy is linked (collectively, “Sites”), such as www.thrivedx.com, and any transactions, interactions, or other engagements you might have with us.

Definitions. For purposes of this Agreement, the following terms have the following meanings:

“Affiliates” shall mean an entity controlled by, under common control with, or controlling such party, where control is denoted by having fifty percent (50%) or more of the voting power (or equivalent) of the applicable entity.

“Updates” means any updates, bug fixes, patches, or other error corrections to the Sites ThriveDX makes available.

2. This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.

3. Please carefully read this Privacy Policy, which is part of our End User License Agreement (“EULA”), before using our Sites. If you do not agree with our EULA or this Privacy Policy, you must refrain from using our Sites. By accessing or using our Sites, you agree to our use of your information consistent with our EULA  and this Privacy Policy.

4. This Privacy Policy does not apply to our collection, use, or disclosure of Personal Information (as defined below) in performing services on behalf of our educational institution partners and other clients (collectively, “Clients”).

This Privacy Policy also does not apply to our collection, use, or disclosure of Personal Information related to job applicants, employees, or their dependents and beneficiaries, or the collection, use, or disclosure of Personal Information by third parties.

5. This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. If we make any material changes to this Privacy Policy, the revised policy will be posted on the Sites with the date of revision. Changes will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide notice, such as by a posting on the Sites or an email to your last known email address, before using your Personal Information in the new way.

6. Conflict Between this Policy and Laws and Regulations

When federal, state, or local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. The specific requirements of this Privacy Policy apply unless disallowed by applicable laws or regulations. Please be aware that the Sites are subject to the laws of the country in which they operate, or are registered, and your Personal Information may be processed in the United States and other jurisdictions.

INFORMATION WE COLLECT

7. Personal Information

You agree that ThriveDX may collect and use the content, technical data, and related information, that is gathered periodically to facilitate the provision of software updates, product support and improving our website and content. ThriveDX may also collect data related or generated from your use of the Sites for statistical analysis and usage patterns analysis, to make the sites more intuitive. ThriveDX may use or share this information, as long as it is in a form that does not personally identify You, to improve its products or to provide Platforms or technologies that better suit Your preference. We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

a. Unique Identifiers such as name, social media identifiers;

b. Contact Information such as mailing address, billing address, email address, phone number;

c. Characteristics of Protected Classifications such as age, gender, race, ethnicity, national origin, military or veteran status;

d. Commercial Information such as inquiries about or purchases of our products and services, use of our products and services (e.g., course completion status, program completion status), participation in promotional events, participation in surveys;

e. Internet and Network Information such as IP address, device ID, browsing/search history, browser type, device type and settings;

f. Audio/Visual Information such as images, call recordings, video or audio testimonials;

g. Educational Information such as educational institutions attended, dates of attendance, degrees earned, grades, instructor reviews/feedback, transcripts;

h. Professional Information such as past and current employers, job title, salary earned, professional association membership, professional credentials and certifications;

Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., consumer response models, propensity to purchase models).

The specific Personal Information we collect about you may vary based on how you use the Sites and your relationship with us.

8. Usage Data and Sites Activity

We automatically collect information in connection with the actions you take on the Sites (“Usage Data”). For example, each time you visit our website, we automatically collect the type of web browser you use, the type of device you use, the type of your operating system, the name of your internet service provider, the pages you view on our Sites, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites. If this information is reasonably capable of being associated with you, we treat it as Personal Information under the category “Internet and Network Information”. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.

9. Communication Recordings

We may record calls and retain the content of written/electronic communications between you and us (such as emails, or web-forms). By communicating with us, you explicitly consent to our recording and retention of communications.

HOW WE COLLECT INFORMATION

10. Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us, use the Sites, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or we may not be able to fulfill your requested interaction.

11. Social Media

If you engage with us via social media, use your social media credentials to access the Sites, or interact with social media buttons or widgets embedded in our Sites, we may collect Personal Information available on your social media profile and Usage Data. For information about privacy controls available through your social media provider, please visit their website.

12. Cookies and Other Automated Tools

We use cookies (a small text file placed on your computer) and other automated tools such as tracking pixels to improve the experience of the Sites, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can change your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. However, certain features of the Sites may not work properly if you delete or disable cookies.

We use the following types of cookies:

a. Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Sites and are typically deleted once you close your browser.

b. Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Sites. For example, persistent cookies may allow us to remember your preferences and provide you with personalized content.

c. Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.

d. Analytics Cookies: Analytics cookies help us understand how our Sites work and who is visiting our Sites. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Policy.

e. Functional Cookies: Functional cookies allow our Sites to work as intended such as by allowing us to recognize and honor your login and take other actions for authentication and security.

We also employ web beacons, local shared objects (sometimes referred to as “flash cookies”), and other technologies that enable us to track certain aspects of a user’s visit to the Sites. For example, web beacons generally consist of an object embedded on a webpage or in an email that is invisible to the user but allows us to understand whether a user has viewed a particular webpage or email and to deliver certain services. Web bacons typically help us collect Usage Data such as the time and date of a page or email view and a description of the page or email viewed.

If you arrive at the Sites by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching that led you to our Sites, may be transmitted to us and we may use it. You should review the privacy policy of any website from which you reached the Sites to determine what information was collected by that website and for what purposes you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

13. Interest-Based Advertising

We work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you our ads or other of our content that we believe would be relevant to you. Advertisers may also show you third-party ads or content when you engage with our Sites. Advertisers may collect and use information about your use of the Sites as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information, including across time, devices, and websites. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Sites, on third-party websites, or on social media properties. Using a tool created by the Network Advertising Initiated, you can opt out of several Advertisers’ activities. For more information, please visit the Network Advertising Initiative or the Digital Advertising Alliance (“DAA”) Consumer Choice Page. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Please note that opt-outs only apply to interest-based advertising and not all advertising networks participate. You may still receive other types of online advertising.

14. Information from Advertisements

If you arrive at the Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date, and time).

Certain third parties, including but not limited to those identified below, collect Personal Information and/or Usage Data from users of our Sites using automatic information collection tools such as APIs, cookies, and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their respective privacy policies.