Privacy policy

Thriving Springs Inc ( “we,” “us,” or “our”) is committed to protecting the privacy of our customers and users. This Privacy Policy explains who we are, how we collect, use and share Employee information about you and how you can exercise your privacy rights. 

This Privacy Policy describes (unless a different privacy notice is displayed) our privacy practices regarding the employee information we collect from individuals in the usual course of business, including when you register to or otherwise use any of the Thriving Springs Services as an application, team member or employee of one of our Customers (collectively “Users”) when we act as a controller of your Employee Information.

For purposes of this Privacy Policy, “Employee Information” means any information relating to an identified or identifiable individual (e.g., name, address, email address, or phone number).

Thriving Springs customers are organizations that use our services to help them manage and engage with their employee and user learning.  Thriving Springs processes employee information in these services only according to our Customer’s and their User’s instructions (as defined in our Customer agreements). If you have questions about employee information you have entered into the Thriving Springs Services used by one of our Customers.

Thriving Springs follows these principles in order to protect your privacy:

• Employee information collected is restricted to the data shared by our customers via product integration with their HR and other systems. This is completely governed by customers and their use cases that they wish to achieve with Thriving Springs learning platform.
• Personalization: To tailor your experience, understand your preferences, and recommend relevant content and features.
• We only use your Employee Information for the purposes (eg: providing customer support to you) we specify in this Privacy Policy, unless you are notified otherwise;
• We do not keep your employee information after it is no longer needed.

The information we collect depends on the ways you interact with Thriving Springs and the choices you make (including your privacy settings), the products and features you use, your location and applicable law.

(i) Information You Provide to Us

If you are a Customer of Thriving Springs, you (or your administrator) may provide certain Employee Information to us through the Thriving Springs Services – for example, when user registers for a Thriving Springs account to access and use our Services, when user consults with customer support or send us an email or communicate with us in any way (for example, to make a support request).

The Employee Information we collect may include:

• Business information (such as name, job title, phone number, email address and country) as provided by your organization (our customer);
• Employee information that you provide to us or that is collected on behalf of our customer as it relates to your employment (such as address);
• Marketing information (such as your contact preferences);
• Account log-in credentials (such as your email or username and password when you sign up for an account with us and the unique User ID assigned to you in our systems);
• Troubleshooting and support data (which is data you provide or we otherwise access in connection with support queries we receive from you. This may include, for example, contact or authentication data, the content of your chats and other communications with Thriving Springs, and the product or service you are using related to your help inquiry); and
• If you ever communicate directly with us, we will maintain a record of those communications and responses.

(ii) Information We Collect During Use

When user interacts with the Thriving Springs Services, we collect or receive certain information through our Services (for example in log files) and through other technologies (such as cookies) about device and usage of the Thriving Springs Services.The information we collect includes:

• Log and usage data, which is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use the Thriving Springs Services and which we record in log files. This log data may include the Internet Protocol (IP) address, device information, browser type and settings and information about your activity in the Services (such as the date/ time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you use)), device event information (such as system activity, error reports and hardware settings)
• Device data, such as information about your computer, phone, tablet or other device you use to access the Thriving Springs Services. This device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information. If you are using our mobile app, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our mobile app you accessed.
• Location data, such as information about your device’s location, which can be either precise or imprecise. How much of this information we collect depends on the type and settings of the device you use to access our Services.  For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).  You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of our Services.

This information is used to:

• Maintain the security of the Thriving Springs Services;
• Provide necessary functionality
• Improve performance of the Thriving Springs Services
• Assess and improve your experience of the Thriving Springs Services;
• Review compliance with applicable usage terms
• Identify feature requirements for development of the Thriving Springs Services;
• Assess capacity requirements
• Enhance security of Thriving Springs generally (in addition to the security of the Thriving Springs Services)
• analyze overall trends, to help us provide and improve the Thriving Springs Services, and to improve their security and proper functioning.

(iii) Information We Collect from Third Parties

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about the user from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information may include your:  mailing address, job title, functional role, business email, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, social media URLs and custom profile.  We process this data for the purposes of: updating our records; targeted advertising; event promotion; optimizing our sites and the Thriving Springs Services; for our sales and marketing activities, including sending marketing emails.

Thriving Springs uses a technology called “cookies” to store session information. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive.

If you would like to change your choices about what cookies Thriving Springs uses, in your browser settings you can elect to delete all cookies, or just cookies placed by specific websites. Many browsers provide directions for managing cookies in their “help” or other user support directories (for example, this information provided by Google for managing cookies in Chrome).

We also partner with third-party ad networks to manage our advertising on other sites and with third-party analytics companies to assist us with analyzing the use of our own website. These third-party companies use cookies, web beacons, pixel tags, and related technologies to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests and to provide measurement and analytic services.

Specifically, we use the following third-party services: Google Ads and Analytics, Microsoft’s Bing Ads, Quora Ads, LinkedIn Ads, Twitter Ads, Facebook Ads, Instagram Ads, and Mixpanel Analytics. To learn more about third-party advertising, and to opt out of certain ad-targeting activities, please visit: preferences-mgr.truste.com, aboutads.info/choices, and youronlinechoices.com.

• To learn more about Microsoft’s privacy practices, see: privacy.microsoft.com/en-us/privacystatement; to opt-out of interest based advertising with Microsoft, see https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads.
• To learn more about Google’s advertising policies, see: policies.google.com/technologies/ads; your ad settings with Google, see: adssettings.google.com; and Google’s ad personalization, see: policies.google.com/technologies/partner-sites.
• To learn more about Quora’s privacy practices, see quora.com/about/privacy; to opt-out of interest based advertising with Quora, see: http://www.aboutads.info/choices and https://www.youronlinechoices.com/.
• To learn more about LinkedIn’s privacy practices, see linkedin.com/legal/privacy-policy; to opt-out of interest based advertising from LinkedIn, see www.aboutads.info/choices and www.youronlinechoices.eu and www.youradchoices.ca/choices.
• To learn more about Twitter’s privacy practices, see twitter.com/en/privacy; to opt-out of interest based advertising from Twitter, see https://optout.aboutads.info.
• To learn more about Facebook’s privacy practices, see facebook.com/policy.php; to opt-out of interest based advertising with Facebook, see http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.
• To learn more about Mixpanel’s analytics services and privacy practices, see the ‘https://mixpanel.com/legal/privacy-policy/;

“DO NOT TRACK” SETTING Currently, various browsers offer a “do not track” or “DNT” option which sends a signal to websites’ visited by a user about the user’s browser DNT preference setting. Thriving Springs does not currently respond to browsers’ DNT signals with respect to the website, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Thriving Springs takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

Thriving Springs processes employee or personal information for the following business and commercial purposes, and if you are a resident in the EEA or UK, on the legal basis identified below:

• Providing our websites and Thriving Springs Services: In reliance on our legitimate interest, we process your personal information to operate and administer our websites, and to provide, operate, and maintain the Thriving Springs Services;
• Communicating with you about the Thriving Springs Services: We may send you service, technical and other administrative or technical email, messages and other types of notifications(such as distribution and product updates and product patches and fixes) in reliance on our legitimate interests in administering the Thriving Springs Services and providing certain features. These communications are considered part of the Thriving Springs Services and in most cases you cannot opt-out of them.  If an opt-out is available, you will find that option within the communication itself;
• Providing necessary functionality: We process your employee information in reliance on our legitimate interest to provide you with the necessary functionality required during your use of our websites and Thriving Springs Services.
• Transactional considerations: We process your employee information to complete transactions, and send you related information, including purchase confirmations and invoices, to perform our contract with you and to the extent necessary in reliance on our legitimate interest;
• Handling contact and support requests: If you fill out a “Contact Us” web form or request support as a User, or if you contact us by other means including via a phone call, we process your Employee Information to perform our contract with you and/or (if we have not entered into a contract with you) to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
• Administering Events: We process your employee information to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, billing, registration and to connect you with other event attendees, to perform of our contract with you, or to the extent necessary for our legitimate interests in fulfilling your requests to attend any such events;
• Developing and improving our websites and services:  We process your Employee Information to analyze trends and to track your usage of and interactions with our websites. marketing activities and Thriving Springs Services to the extent it is necessary for our legitimate interest in developing, improving and troubleshooting our websites, marketing activities and the Thriving Springs Services and providing you with more relevant content and service offerings, or where necessary, in reliance on your consent;
• Sending marketing communications: We will process your Employee Information for marketing purposes in accordance with your preferences, such as to communicate with you via email, SMS or telephone about services, features, surveys, newsletters, promotions or events we think may be of interest to you and/or to provide other news or information about Thriving Springs and/or our select partners, in each case in reliance on our legitimate interest in conducting direct marketing or where necessary with your consent. 
• Displaying personalized advertisements and content: We process your Employee Information to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in supporting our marketing activities or advertising the Thriving Springs Services;
• To the extent necessary for our legitimate interests in promoting the safety and security of our websites and services, we may use collected data to investigate and prevent fraudulent transactions, unauthorized access to the websites, Thriving Springs Services, and other illegal activities;
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products and features, enhancing, improving or modifying our products and services, identifying usage trends and expanding our business activities in reliance on our legitimate interests; and
• Complying with legal obligations: We process your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, the Thriving Springs Services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
• Reviewing compliance with applicable usage terms: We process your Personal Information to review compliance with our contract with you or your organization (where applicable) to the extent that it is in our legitimate interest to ensure adherence to the relevant terms; and
• Other purposes: We will process your Employee Information for other purposes about which we notify you in advance, or for which we receive your consent.

Thriving Springs will not share Personal or Employee Information, or otherwise make your Employee Information available to any other parties except as provided in this Privacy Policy. Parties with whom we may share your Employee Information, pursuant to any applicable agreements, include:

Legal or regulatory bodies and agencies: Thriving Springs may share information, in order to respond to investigations, court orders, legal processes, or to investigate prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, violations of Thriving Spring’s Terms of Service, or as otherwise required by law. If Thriving Springs is required by law or an order of a court of competent jurisdiction to disclose your information, Thriving Springs will promptly notify you of this requirement, if permitted by the court or applicable law, so that you may seek a protective order or other appropriate relief.

Our website includes links to other websites whose privacy practices may differ from those of Thriving Springs. If you submit information to any of those sites, your information is governed by the privacy policies that apply to those sites. We encourage you to carefully read the privacy policy of any website you visit.

All of your Employee Information remains private and confidential. The security of your Employee Information is important to us. All data is secured with highest security standards.

Thriving Springs maintains a comprehensive written information security program that complies with applicable law and generally accepted industry standards. Our program includes appropriate administrative, technical and physical safeguards, procedures and practices to protect Employee Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, the Thriving Spring’s web application owned and operated by Thriving Springs, or the Thriving Springs Services, please contact us using the contact information below.

Thriving Springs and its representatives will never request your account credentials. You should never share your Thriving Springs account information, including your username and password, with anyone else. We recommend that you use a unique password for your Thriving Springs account that is not associated with other websites. You should check your Thriving Springs account regularly to ensure that your Employee Information has not been tampered with or altered. Any suspicious activity regarding your account, including automated messages or calls from parties you cannot identify, should be reported to your site administrator and Thriving Springs using the contact information below.

If your Employee or Personal Information has been submitted to us by or on behalf of our Customer (your employer) and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Customer directly. For more information on how your employer uses your Personal Information, please see your employer’s privacy policy.

When Thriving Springs is acting as a controller, depending on your location, your jurisdiction, and applicable law, you may have the rights below with regard to the Personal Information we control about you. We will respond to your requests within the appropriate timeline under applicable law. Please note, however, that the rights described below are not absolute and, depending on applicable law or in certain cases, may be subject to conditions or limitations. In responding to any request to disclose/delete, Thriving Springs shall maintain a record of the requests as required under applicable law.

• The right of access, or the right to know, means that you have the right to request that we disclose what Employee Information we have collected, used and disclosed about you. You can do so at any time by contacting us using the contact details provided under the “How to Contact Us” heading below. If you are located in California, under the CCPA you have the right to request to know:
  
  The specific pieces of personal information we have collected about you;
  
  The categories of personal information we have collected, used, and/or disclosed about you;
  
  The categories of sources from which we have collected personal information about you;
  
  Business and/or commercial purposes for collecting and disclosing your personal information; and
  
  The categories of third parties with whom your personal information has been disclosed or shared.
• The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. As mentioned above, you can do so at any time by contacting us using the contact details provided under the ”How to Contact Us ” heading below.
• The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights, and Thriving Springs will not discriminate against an individual for exercising any rights under the CCPA or other applicable privacy law, including, but not limited to, (a) denying goods or its professional services, (b) charging different prices or rates (including discounts/penalties) not directly related to the value provided to Thriving Springs for personal information, or (c) suggesting an individual will receive a different rate/price or level of quality of goods/professional services.
• The right to opt-out, if you are located in California under the CCPA, means you can opt-out of the sale or certain sharing of your personal information by contacting us. Note that Thriving Springs does not sell personal information, though in certain instances Thriving Springs does share personal information as described in this Privacy Policy.
• You can also ask us to correct or update your Personal Information; object to the processing of your personal information; ask us to restrict processing of your Personal Information or request the portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to Contact Us” heading below
• While you cannot opt out of service-related emails if you are an account holder, as this is an essential part of the Thriving Springs Services, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, or you can contact us using the contact information below.
• Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent
• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
• Thriving Springs does not engage in any automated decision making with User Personal Information.

As mentioned above, Thriving Springs may provide third parties with certain personal information to provide or improve our products and services, for example to deliver products or services at your request. In such cases, we require those third parties to handle the information in accordance with applicable laws and regulations.

Thriving Springs does not sell personal information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018) – Thriving Springs is not a data broker and does not offer or disclose personal information on the open market, nor does Thriving Springs share personal information with third parties for their direct marketing purposes (pursuant to California Civil Code Sec.1798.83). In some instances, Thriving Springs may disclose limited personal information with some of its advertising partners for our advertising purposes as described in Section 7, above. If you elect to opt-out, Thriving Springs will stop sharing personal information with those advertising partners. As a result, you may no longer receive personalized offers from Thriving Springs on some sites or services. We will use the data collected when you opt-out solely to process your request and for record-keeping as required under the CCPA.  

We will retain your Employee Information for as long as is necessary to fulfill the services that you have requested, comply with any laws or regulations, resolve disputes, and enforce our agreements, unless we receive a verified request under an applicable privacy law for earlier deletion of such Employee Information. Where permitted under applicable law, Thriving Springs may retain your data longer for a legitimate business interest where business benefit is not outweighed by your personal rights and freedoms. Data entered into the Thriving Springs Services and processed on behalf of our Customers as a service provider or processor is retained in accordance with any applicable agreement between Thriving Springs and its Customer.

We follow applicable data protection laws when transferring employee data. 

You can exercise your rights yourself or depending on your country or state, you may be able to designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. For example, this could include sending an e-mail to an account on record, or asking you to identify a recent transaction or communication. We may also request that your authorized agent sign a declaration under the penalty of perjury attesting to their designation as your authorized agent, and that they have written permission from you to make requests on your behalf. We may also need to verify your authorized agent’s identity to protect your personal information.

Please contact us at support@thrivingsprings.com, if you would like to access this policy in an alternative format; exercise your rights; learn more about your rights or our privacy practices or designate an authorized agent to make a request on your behalf. 

Thriving Springs may update this Privacy Policy from time to time and will notify account holders of significant changes in the way we treat any Employee Information, by sending a notice to the primary email address specified in your Thriving Springs account. We may also place a prominent notice on our website. We encourage you to periodically review this page for the latest information on our privacy practices.