We collect several types of information from and about users of our Website, including:

We may collect and use the following information that you provide to us:

When you use our services, we collect and use personal information which is necessary for the performance of those services. The majority of the personal information we collect and use to provide our services is supplied voluntarily by you, your employer, and/or our customers. These can be different data points depending on the product you are utilizing. This information falls into the following categories:

Usage Details and IP Addresses. As you navigate through the Website, we may also collect details of your visits to our Website, including, but not limited to, traffic data, location data, logs and other communication data, and the resources that you access, as well as information about your computer and internet connection, including your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' equipment, browsing actions and patterns and does not identify any individual.

Cookies. For the same reason, we may obtain information about your general internet usage by using cookies. A cookie is a small file stored on the hard drive of your computer. Use of cookies help us to improve our Website and to deliver a better and more personalized service by enabling us to:

We do not collect personally identifiable information automatically, but we may tie this information to your previously submitted personally identifiable information.

You are responsible for any content, including personal information, that you contribute to be published or displayed (hereinafter, "posted") on the Website, or transmit to other users of the Website (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to other users of the Website at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. You understand and acknowledge that, even after removal, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms and Conditions and known or suspected violations should be reported to support@thrivepass.com.

We use information that we collect about you or that you provide to us, including any personal information, in the following ways:

We do not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual. To the extent necessary for those purposes, we take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current. We adhere to the principles for as long as the information is retained by our organization.

We use information that we collect about you or that you provide to us, including any personal information, in the following ways:

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

You should review this privacy policy carefully, because if you do not agree with our practices, your ultimate choice is not to use the Website. Remember, by using any part of the Website, you accept and agree to our privacy practices. If we update this privacy policy, your continued use of the Website (following the posting of the revised privacy policy) means that you accept and agree to the terms of the revised privacy policy.

You can review and update your personal information by logging into the Website and visiting your account profile page and making changes to your personal information. If you have forgotten your password, once you have tried to register and failed, you can click on the "Forgot your password?" link to reach a page on which you can submit your e-mail address. You will then be allowed to create a new password. Also, pursuant to relevant laws, we will respond to any requests for access to personal data within a commercially reasonable time. Any access request will be subject to the relevant fee to meet our costs in providing you with details of the information we hold about you. We will comply with your request as soon as reasonably practicable and in accordance with applicable law. We may need to retain certain information for record keeping purposes, as required under applicable legal obligations, and/or to complete any transactions that you began prior to requesting such change or deletion. Further details can be obtained by using the contact details shown below. Also please use the below contact information in case you would like your information to be deleted.

WE MAY WITHHOLD INFORMATION WHERE THE SEARCH FOR THAT INFORMATION WOULD REQUIRE DISPROPORTIONATE EFFORT OR HAVE A DISPROPORTIONATE EFFECT DUE TO, FOR EXAMPLE, THE COST OF PROVIDING THE DATA, THE TIME IT WOULD TAKE TO RETRIEVE THE DATA, OR HOW DIFFICULT IT MAY BE TO OBTAIN THE DATA REQUESTED.

If the California Consumer Privacy Act (CCPA) applies to your information, we provide these disclosures and the tools described in this policy so you can exercise your rights to receive information about our data practices, as well as to request access to and deletion of your information. These tools allow you to review, update and delete your information, as well as export and download a copy of it. You can also read more about our data retention periods, and the process we follow to delete your information.

We do not sell your personal information. We only share your information as described in this policy. We process your information for the purposes described in this policy, which include “business purposes” under the CCPA. These purposes include:

We also use information to satisfy applicable laws or regulations, and disclose information in response to legal process or enforceable government requests, including to law enforcement. If you have additional questions or requests related to your rights under the CCPA, you can contact us at privacy@thrivepass.com.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on secure servers behind firewalls and encrypted using SSL technology. Any payment transactions will be processed by a third-party (Paypal) encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. Any user of the Website may view the information you share in public areas.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.

The terms included within this section apply exclusively to employees accessing the ThrivePass site from EU countries.

ThrivePass, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. ThrivePass, Inc. 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 in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-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/.

In compliance with the EU-U.S. DPF, ThrivePass, Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF in the context of the employment relationship. EU individuals with inquiries or complaints regarding our privacy policy should first contact ThrivePass, Inc. at privacy@thrivepass.com. ThrivePass, Inc. is committed to issued raised by the individual within 45 days (including the 45^th day) upon receiving the request to privacy@thrivepass.com.

ThrivePass, Inc. reserves the right to disclose personal data to your employer for purposes of program administration and usage information. Individuals will retain the right to access this personal data through the employer. ThrivePass, Inc. will accommodate requests by the employer to provide the employee’s information to the employer for employee’s access. Outside of employer provided data, individuals will have the right to limit the use of their personal data by simply not engaging with our service. All actions on the site are entirely voluntary.

Additionally,

ThrivePass, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). An individual has the opportunity, under certain conditions, to invoke binding arbitration for complaints regarding data privacy compliance not resolved by any of the other DPF mechanisms. Please utilize the following link for additional information: https://www.dataprivacyframework.gov/s/

ThrivePass, Inc. will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
ThrivePass, Inc. will remain liable in cases of onward transfers to third parties.

Our EU Representative: Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:

Instant EU GDPR Representative Ltd.

Adam Brogden

contact@gdprlocal.com

Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD Office 2, 12A Lower Main Street, Lucan Co. Dublin K78 X5P8, Ireland

EU Repoting Link

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to this privacy policy, we will notify you by e-mail or through a notice on our home page. The date the privacy policy was last revised is identified at the top of the page.

To ask questions or comment about this privacy policy and our privacy practices, contact us at:
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ThrivePass, Inc.
3801 Franklin St.
Denver, CO 80205