Privacy Policy

Last Updated: February 25, 2021

Thine Solutions, Inc. (“Thine”) is committed to safeguarding your information. We understand the importance of privacy and want you to make an informed decision about sharing information with us when visiting our website and using our services. We value the trust our users place in us when they give us access to their personally-identifiable information (“Personal Information”).

This Privacy Policy (“Privacy Policy”) describes the services offered through the Thine website at thine.co (the “Services”), any subdomain thereof, any Thine mobile site, and any software provided by Thine in connection with providing our services to you (collectively, the “Site”) and how we collect, use, share, and protect personal information we obtain through the Site. 

If you are located within the European Union, European Economic Area, or the United Kingdom, you may have different or additional rights. Please read the Privacy Notice for EU Users.

If you are a resident of California, you may have different or additional rights. Please read the Privacy Notice for California Residents.

Please read the Privacy Policy carefully to understand our practices regarding your information and how we will treat it. By visiting the Site and/or using our services, you acknowledge that the collection, use, and sharing of your information will take place as described in this Privacy Policy. For the purposes of this Privacy Policy, any references to “we,” “our,” or “us” shall mean Thine. 

Please note that we reserve the right to review and update this Privacy Policy from time to time. Accordingly, each time you access or use the Site, you should check the Last Updated legend at the top of this Privacy Policy, and review any changes since you last accessed or used the Site. If you access or use the Site after an updated Privacy Policy is published, you will be deemed to have agreed to the amended Privacy Policy.

If you have questions regarding the Privacy Policy or about Thine, please contact us by email at privacy@thine.co.

BY ACCESSING AND USING THIS SITE, YOU REPRESENT AND WARRANT THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THE TERMS OF, THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THIS SITE.

1. INFORMATION THAT WE COLLECT ABOUT YOU

Information Provided by You Upon Creating an Account

When you create and register a user account (“Account”) on the Site, you may be asked to provide or confirm certain pieces of Personal Information, which may include one or more of the following:
1. First and last name
2. E-mail address
3. Educational history
4. Current occupation and title
5. Employment history
6. Demographic information (providing such information will always be voluntary)

We also collect data and Personal Information from you when you provide or upload it to the Site, such as when you fill out a form, submit a resume or other document, or respond to a survey or questionnaire. This can include resumes, personality and cognitive ability assessments, background information, location data, and GPAs.

We may supplement the Personal Information you provide with additional Personal Information we gather from public sources or from third-parties (e.g., consumer reporting agencies) that may lawfully provide such information to us.

You are under no obligation to provide your Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the Site’s features and services. Your information may also be required by a potential employer in order to identify your assessment results with your job application.

Information Provided By Our Customers

We may receive Personal Information about you from law firms or other legal employers with whom we contract to provide Services through our Site (each, a “Customer”) if you interact with, are associated with, and/or apply for a role with any of our Customers.

Information Provided When You Contact Us

We may collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Site. We generally collect one or more of the following types of Personal Information when you contact us with a question or comment, or request information from us about our products and services: 
1. Name
2. E-mail address
3. Phone Number

Passively Collected Information

‍When you access and use our Site, we may automatically collect and retain certain types of information, including your computer or device’s internet protocol (IP) address and other technical information about your computer or device and website usage, such as your browser type and version, time zone setting, and operating system and platform. 

When you take our online assessments (the “Assessments”) on the Site, we also collect and retain your “Assessment Data”, which is defined as information and data collected from your responses, including metadata about your real-time user interaction with the Assessments. After your completion of the Assessments, the Site will review your Assessment Data and generate your specific “Trait Profile”, which includes your development report and contains the Site’s assessment and description of your personality traits. If you record and submit videos on the Site, we may also collect and retain images, video, voice and audio information and a transcript of your audio information in such videos, however, we will not use your videos for marketing, publication, or any purpose other than to provide Assessment Data to employers as part of the Services, unless you give us permission to do so. 

We may collect application log information like the employers you submit a job application for through the Site, the role or roles you apply for, and the time and date of such applications.

We may collect certain additional information when you access our Site with a mobile device. This information may include location, device type, unique device identifier, operation system, and other related user data. This data is analyzed to help us create a more user-friendly mobile experience. You may restrict collection of certain data by changing the setting preferences on your mobile device. 

We also use cookies on our Sites. For more information, please see the section below on Cookies and Other Tracking Technologies That We Use.

2. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE

Cookies, Beacons and Embedded Scripts

We and our service providers use cookies, beacons and embedded scripts in connection with the Site.

  • Cookies are small text files that are stored on your computer or device when you visit our Site. Cookies allow a website to recognize a particular device or browser. The use of cookies is a standard practice among websites to collect information about visitors’ activities while using the website.

  • Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on our Site and typically work in conjunction with cookies to assist our site with the automated collection data on user behavior. We will not be able to personally identify you in connection with these practices.

  • An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

The above technologies are used in analyzing trends; administering the Site and its features and services; tracking users’ movements around the Site; and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies on an individual as well as aggregated basis.

We use cookies to remember users’ settings, market products and services to users, and for authentication purposes. To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept, or delete cookies from our Site at any time. The “Help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies; how to have the browser notify you when you receive a new cookie; or how to disable cookies altogether. Please note that if cookies are disabled or removed, not all features of our Site will operate as intended.

Third-Party Analytics

We may also use service providers, such as Google Analytics, that may use cookies or other technologies to collect information about your online activities across this and other sites over time for non-advertising purposes such as those described above. To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, you may visit:  http://www.google.com/intl/en/policies/privacy/partners/.

3. WHAT WE DO WITH THE INFORMATION WE COLLECT

  • General Uses. We use the information we collect to manage, analyze, develop, customize, and improve our Site as well as our products and services, including our Assessments, Trait Profile, and success models. We sometimes use automated decision making in processing your information, such as to create your Trait Profile, which is used to help inform employers’ decisions by determining your "fit" by comparing your individual results against a benchmark profile of current employees.

  • Information Provided When You Register an Account and Take Our Assessments. We may use this information to authorize and administer your access to the Site, verify your identity, authenticate your visits, and provide our products and services to you. We may also use your information to improve and personalize your experience with us, including by showing you relevant information such as your job matches and, with your consent where necessary, notify you regarding new roles on the Site, remind you to complete the Assessment or job applications, send you information about us, and keep you informed of our products and services that may be of interest to you. We may also combine such Personal Information with other Personal Information lawfully collected from third parties in order to better market and provide our products and services.

  • Information Provided When You Contact Us. We may use this information to understand and respond to your question or comment, and/or reach out to you regarding your inquiry or request regarding our products and services.

  • Passively-Collected Information. We use passively collected information to monitor and maintain the performance of our Sites; analyze trends, usage, and activities in connection with our services; validate users and ensure the Site’s technological compatibility with users; optimize our marketing efforts; and to provide our products and services to you, including analyzing your Assessment Data and developing your Trait Profile.

  • Aggregate or De-Identified Data. We may use our users’ Personal Information and passively-collected information to create aggregate or de-identified data which cannot be used to identify you (“Aggregate Data”). For example, Aggregate Data may include data that describes the general demographics, usage, Assessment Data, or other characteristics of a Site’s users. We reserve the right to use, transfer, and/or sell Aggregate Data about the Site’s users for any lawful purposes. We also reserve the right to use such aggregate information in collaboration with outside researchers to measure, quantify and audit the effectiveness, validity and fairness of our products and services.

  • Incumbent Employees. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and take the Assessment by your current employer, then we may use your information to create a talent assessment model for a specific role at your current employer. In such a scenario, you would be deemed an “Incumbent Employee”.

  • Job Candidates. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and take the Assessment at the suggestion of your law school or as part of the job application process for a specific employer, or if you visited the Site, created an Account (or signed into your existing Account), and took the Assessment as part of a more generalized recruiting process, then we may use your information to assess your fit to a specific role(s) at the specific employer or across our network of employers, as applicable. In such a scenario, you would be deemed a “Job Candidate”.

  • Other Purpose. We may use your information for any additional purpose which you separately authorize in the course of accessing and using our Site.

4. WITH WHOM WE SHARE THE INFORMATION WE COLLECT

Personal Information of our users is an integral part of our business. We reserve the right to share your Personal Information with third parties as described below. We also reserve the right to transfer and/or sell other types of data, including Aggregate Data derived from Personal Information, for lawful purposes in our discretion. Note that we do not share Personal Information with third parties for their direct marketing or revenue-generating purposes.

  • Service Providers. We, like many businesses, sometimes hire other companies (“Service Providers”) to perform certain business-related functions. Examples include customer service, maintaining databases, data storage, cloud services, and hosting services. When we employ a Service Provider to perform a function of this nature, we provide it with the information that it needs to perform its specific function, which may include Personal Information and other information that you provide to us via the Site. These Service Providers are authorized to use your information only as necessary to provide these services to us.

  • Legal Requirements. We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena or similar legal obligation; (b) protect and defend our rights or property; (c) act in urgent circumstances to protect the personal safety of users of the Site or the public; (d) protect against legal liability; or (e) or as otherwise required or permitted by law.

  • Job Candidates. If you are a Job Candidate, then we share your Personal Information and Trait Profile with employers in our network and any third party that is pertinent to their employment application process for the role for which you are applying to through our Site.

  • Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, total or partial sale of assets in bankruptcy or similar event, your Personal Information and other information may be part of the transferred assets.

  • Other Third Parties. We may disclose your information to other third parties with your prior express consent.

You hereby consent to our sharing of your Personal Information and other information for the above purposes.

5. YOUR CHOICES REGARDING YOUR INFORMATION

Choice

You are not required to create an Account to gain access to some services and features of the Site. If you use the Site’s personalized services and features (e.g., the Assessments and Trait Profile), you will need to create an Account and enter Personal Information, which we will treat as described in this Privacy Policy.

Our Opt-out Policy

We may send you notifications and communications using the email address you provided to us when you registered your Account. To stop receiving some or all email communications from us, you can use your Account settings to edit your email preferences. Alternatively, you can use the “unsubscribe” mechanism provided in the email communication.

We will also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature. If you do not wish to receive these announcements, you have the option to deactivate your Account.

We may also send you information for marketing purposes if you have signed up for such communications or otherwise indicated an interest in receiving such communications. If you no longer wish to receive these communications, you may opt-out by contacting us directly or by clicking the opt-out link in our email marketing communications.

Accessing, Correcting and Updating Your Information

You may access, correct, and update most of your Personal Information by changing the settings in your Account profile. You may also email us at support@thine.co with information necessary for us to process your request. We may need to verify your identity before granting access to Personal Information in our custody or control.

Updating Assessment Data

Our Assessment and Trait Profiles are designed to measure traits and motivators at a particular point in time, and suggest avenues for improvement and growth. Because these traits and motivators take some period of time to change, and because taking multiple Assessments for the same role in a short period of time decreases the reliability of the Trait Profile, Assessments cannot be retaken, and Assessment Data will not be updated, for a period of two years from the date of completion.

Deactivating Your Account

You may deactivate your Account by sending a deactivation request through your Account profile. You may also deactivate your Account by emailing us at privacy@thine.co with information necessary for us to process your request. 

When you deactivate your Account, you will no longer be able to log into the Account. You will also no longer be able to create any new Accounts with the email address associated with the deactivated Account. If you wish to reactivate your deactivated Account, please email us at privacy@thine.co with the email address.

A deactivated Account does not mean that all of the information associated with your Account is expunged from our systems, although such information will no longer be readily available to you.

Deleting Your Information

You may request that we delete your Personal Information by sending a deletion request through your Account profile. You may also request deletion of your Personal Information by emailing us at privacy@thine.co with information necessary for us to process your request. Note that any deletion request will be subject to our Retention Policy below.

6. OUR RETENTION POLICY

As part of our Services for our Customers, we regularly build and update predictive models which are used by Customers to evaluate the employment candidacy for a Job Candidate. We use aggregated and anonymized data to build such predictive models and otherwise improve the performance of the Site and the Services. Every time a model is built or updated, we must re-evaluate the employment candidacy of a Job Candidate using the new model and the information Job Candidates have provided through the site. We also rely on information collected from Incumbent Employees to build and update these predictive models. Therefore, we retain aggregated and anonymized data for these purposes.

We retain Personal Information (1) for as long as you have an active account with Thine, (2) for as long as necessary to provide you with our services, comply with our legal obligations, preserve and protect our rights as allowed by law, resolve disputes, maintain security, prevent fraud and abuse, and enforce our agreements (including our Terms of Service), (3) with your consent, or (4) as required by law.

Upon your request to delete information associated with your Account, our retention policy differs depending whether you last took the Assessment as a Job Candidate:

  • If you took the Assessment as a Job Candidate: If you were directed to visit the Site, create an Account (or sign into your existing Account), and take the Assessment as part of the job application process for a specific employer, then, in accordance with our obligations and requirements under local law, we must retain your information for a period of two years following the end of the hiring cycle for the role of which you took part. As a result, if you request deletion of any information prior to this 2-year anniversary, we must wait until the two-year period has passed, after which we will process your deletion request. If you request deletion of any of information after this two-year anniversary, then we will process your request upon 10 business days of receipt

  • If you took the Assessment as an Incumbent Employee: If you were directed to visit the Site, create an Account (or sign into your existing Account), and take the Assessment as directed by your current employer, then, in accordance with our obligations and requirements under local law, we must retain your information for a period of two years following the end of the hiring cycle for the role of which you took part. As a result, if you request deletion of any information prior to this two-year anniversary, we must wait until the two-year period has passed, after which we will process your deletion request. If you request deletion of any of information after this two-year anniversary, then we will process your request upon 10 business days of receipt.

Even if we are obligated to retain certain information, once you deactivate your Account or request to deletion of your Personal Information, your Personal Information will cease being visible to third parties through our Site. 

As discussed above, we may aggregate or de-identify our user’s Personal Information and other information to create Aggregate Data which cannot be used to identify you. We will retain such Aggregate Data even after any Personal Information deletion requests have been processed.

7. MISCELLANEOUS

Other Websites. Our Site may contain links to websites or mobile applications owned and/or operated by third parties. We do not own nor control these third-party websites or mobile applications, and accordingly assume no responsibility for the information practices of those sites or apps. We suggest that you review their privacy, security, and data collection and distribution policies, if any, prior to providing such websites or apps with any information.

Content, Blogs and Public Features of the Sites. Our Site may contain features (e.g., content, blogs, chat rooms, community forums, sharing functions, etc.) that permit you to upload, post, transmit, display, perform, or distribute content and information, including your Personal Information. Any information that you choose to disclose by means of such features becomes public information over which we are unable to exercise control. You should exercise caution when deciding to disclose information by means of such features, and you agree to assume all responsibility for doing so.

Security. The security of your Personal Information is important to us. We take commercially reasonable steps to help protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. For example, we use one or more of secure socket layer (SSL) encryption, firewalls, and self-updating anti-virus software. Your Personal Information will be stored in the United States and will be subject to laws applicable in that country. We take all steps we consider appropriate to protect your data, including technical and organization measures to ensure that your Personal Information is handled securely in accordance with this Privacy Policy. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. Please create a unique password for your Account and do not share your password with anyone else.

Minors. Visitors under 18 years of age are not permitted to use and/or submit their Personal Information at the Site. We do not knowingly solicit or collect information from visitors under 18 years of age.

Contacting Us. If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us directly at privacy@thine.co or at Thine, 1330 Avenue of the Americas, Floor 23, New York, NY 10019.

PRIVACY NOTICE FOR EU USERS

This Privacy Notice for EU Users is part of the Thine Privacy Policy and applies solely to visitors, users, and others who reside in the European Union, European Economic Area, or the United Kingdom in compliance with the General Data Protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR). PLEASE READ THE PRIVACY POLICY IN ADDITION TO THIS PRIVACY NOTICE FOR EU USERS. Terms defined in the GDPR have the same meaning when used in this Notice.

Under certain circumstances, EU residents have rights under data protection laws in relation to their personal data. If you are an EU resident, you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

‍Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

‍Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

‍Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

‍Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

‍Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

‍Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us directly at privacy@thine.co or at Thine, 1330 Avenue of the Americas, Floor 23, New York, NY 10019.

‍NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights unless your request is clearly unfounded, repetitive or excessive, in which case we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.

‍WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

‍TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

‍INTERNATIONAL TRANSFERS
Whenever we transfer personal data out of the European Economic Area, we ensure that a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them using Standard Contractual Clauses and if they provide adequate protection of personal data shared between the Europe and the US.

PRIVACY NOTICE FOR CALIFORNIA USERS

This Privacy Notice for California Residents is part of the Thine Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) in compliance with the California Consumer Privacy Act of 2018 (CCPA). PLEASE READ THE PRIVACY POLICY IN ADDITION TO THIS PRIVACY NOTICE FOR CALIFORNIA RESIDENTS. Terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Our Site collects Personal Information, further defined in Section 1 of the Privacy Policy. For purposes of this Notice, “Personal Information” also includes information that identifies or could reasonably be linked, directly or indirectly, with a particular consumer or device.

Our Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

A. Identifiers.
First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (reviews, photos) submitted, stored, sent, or received by the Data Subjects.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (reviews, photos) submitted, stored, sent, or received by the consumers.Note: Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law.
None.

D. Commercial information.
Purchased product/service.

E. Biometric information.
None

F. Internet or other similar network activity.
IP Address, system usage data, aggregated data.

G. Geolocation data.
None.

H. Sensory data.
None

I. Professional or employment-related information.
None.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
None.

K. Inferences drawn from other personal information.
None.

For purposes of this Notice, “Personal Information” does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, such as:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the Personal Information listed above from directly from you when you submit it to us and indirectly from you (for example, through cookies or other tracking mechanisms.) For more information about how we collect your Personal Information, see Sections 1 and 2 of the Privacy Policy.

Use of Personal Information


We may use or disclose the Personal Information we collect for the business purposes set forth in Section 3 of the Privacy Policy.


Sharing Personal Information


Thine does not sell or disclose your Personal Information to third parties for commercial purposes or otherwise except as set forth in Section 4 of our Privacy Policy.

California Residents’ Individual Rights 

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we collected about you.

  • The categories of sources for the Personal Information we collected about you.

  • Our business or commercial purpose for collecting or selling that Personal Information.

  • The categories of third parties with whom we share that Personal Information.

  • The specific pieces of Personal Information we collected about you (also called a data portability request).

  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that Thine delete your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity (including fraudulent user generated content such as product reviews), or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise a right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our Site. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at privacy@thine.co or at Thine, 1330 Avenue of the Americas, Floor 23, New York, NY 10019.

We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. However, note that many features of our Site, our products, or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our Site or write us at our address listed on our webpage.