Privacy Policy

• ThrivePass, Inc. ("We"), respect your privacy and are committed to protecting it through our compliance with this policy.
• This policy describes the personal information that we collect from you, or that you provide on this website, thrivepass.com (our "Website") and how that information may be used or disclosed by us.
• This policy does not apply to information we collect through any other means, or to information collected on any affiliate or third-party site [or by any third-party application] that may link to or be accessible from the Website.
• Please read the following carefully to understand our policies and practices regarding your personal information and how we will treat it. By using or accessing our website, you agree to this privacy policy. This policy may change from time to time and your continued use of the Website is deemed to be acceptance of such changes, so please check the policy periodically for updates.

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

• Information you provide to us.
• Information we collect as you navigate through the site, such as, usage details, IP addresses, cookies, and web beacons.
• Information we receive from third parties, for example, participating experience providers with our Website.

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

• Information that you provide by filling in forms on our Website. This includes information provided at the time of user registration to our Website, subscribing to any service, placing and order or reimbursement request, posting material, filling out surveys, answering questions, suggesting changes to our website, and requesting further services. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes, although you do not have to respond to them.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

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:

• Basic information
• Contact information
• Demographic information

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.

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
  
• Speed up your searches.
  
• Recognise you when you return to our Website.
  
• Other uses of cookies that assist in optimizing our Website and products. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  
• Web Beacons. Pages of the Website may contain electronic images known as web beacons (also referred to as single-pixel gifs) that permit the Company to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Web beacons are not used to access your personal information on the Website and are only used to compile aggregated statistics concerning use of the Website.

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:

• To present our Website and its contents in a suitable and effective manner for you and for your computer.
  
• To provide you with information, products or services that you request from us.
  
• To make recommendations or provide information to you about our products or services.
  
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us or only where there is a lawful basis for such processing.
  
• To notify you about changes to our service.
  
• To allow you to participate in interactive features of our service, when you choose to do so.
  
• To provide feedback to third-party vendors and other users on the quality of the services provided by the vendor, when you choose to provide us with feedback.

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:

• Our subsidiaries and affiliates.
  
• Contractors and service providers we use to support our business.
  
• In the event of merger, acquisition, or any form of sale of some or all of ThrivePass, Inc.'s assets, in which case personal information held by ThrivePass, Inc. about its customers will be among the assets transferred to the buyer.
  
• Third-party vendors when feedback is given about the vendor.
  
• We may also disclose your personal information to third parties to:
  

• Comply with any court order or other legal obligation.
  
• Enforce or apply our Terms and Conditions and other agreements.
  
• Protect the rights, property, or safety of ThrivePass, Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  
• Respond to lawful request by public authorities.
  Ensure compliance with enforcement authorities that have jurisdiction over the organization’s compliance. ThrivePass ensures compliance with HIPAA and IRS Code Section (105, 125, 132 or 223).
• Ensure compliance with enforcement authorities that have jurisdiction over the organization’s compliance. ThrivePass ensures compliance with HIPAA and IRS Code Section (105, 125, 132 or 223).

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:

• Cookies. If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of this site may then be inaccessible or not function properly. Please note that our Website or services may not recognize or take action in response to Do Not Track or similar signals from browsers.
  
• Promotional Offers from the Company. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
  

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:

• Protecting against security threats, abuse, and illegal activity. We use and may disclose information to detect, prevent and respond to security incidents, and for protecting against other malicious, deceptive, fraudulent, or illegal activity. For example, to protect our services, we may receive or disclose information about IP addresses that malicious actors have compromised.
  
• Auditing and measurement. We use information for analytics and measurement to understand how our services are used, as well as to fulfill obligations to our partners like publishers, developers, or rights holders. We may disclose non-personally identifiable information publicly and with these partners, including for auditing purposes.
  
• Maintaining our services. We use information to ensure our services are working as intended, such as tracking outages or troubleshooting bugs and other issues that you report to us.
  
• Research and development. We use information to improve our services and to develop new products, features and technologies that benefit our users and the public.
  
• Use of service providers. We share information with service providers to perform services on our behalf, in compliance with our Privacy Policy and other appropriate confidentiality and security measures. For example, we may rely on service providers to help provide customer support.
  

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 access the ThrivePass site from countries within the EU and UK. ThrivePass, Inc. is committed to protecting the rights of individuals through its compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

ThrivePass, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPFas 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 and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to 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 and the UK Extension to the EU-U.S. DPF, ThrivePass, Inc. commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact ThrivePass, Inc. via email at privacy@thrivepass.com. ThrivePass, Inc. is committed to review and response on issues raised by the individual within 45 days (including the 45^th day) upon receiving the request to privacy@thrivepass.com

In compliance with the EU-U.S. DPF and the UK Extension to 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) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.

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 and the UK Extension to the EU-U.S. 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.

If personal data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Policy, ThrivePass, Inc. will provide you with an opportunity to choose whether to have your personal data so used or disclosed.Requests to opt out of such uses or disclosures of Personal Data should be sent to us at privacy@thrivepass.com.

Certain personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered "Sensitive Information." Such information is not routinely collected or stored by ThrivePass, Inc.. Data in any form will be used strictly for the purposes which it was originally collected or subsequently authorized by the individual unless Thrivepass, Inc. has received your affirmative and explicit consent (opt-in).

If you are an EU, UK, or Swiss Individual, where we transfer your personal data to third party service providers (see above) who perform services for us or on our behalf, we are responsible for the processing of that data by them and shall remain liable if they process your personal data in a manner inconsistent with the DPF Principles referred to above, unless we prove that we are not responsible for the event giving rise to the damage.

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

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