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Privacy Policy

 

We at Thread Magic, Inc., fka ChatGenie, ("Thread", "ChatGenie", “Company”, “we”, “us”, “our”) know that our users (“you,” “your”) care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By visiting or using the www.getthread.com website (the “Website”) or any other features, content, or applications offered from time to time by Company in connection therewith (collectively, the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

If you have any questions or concerns please contact us.

 

1. What Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for our Services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any Personal Information to us or on the Services. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.

We gather various types of Personal Information from our users, as explained more fully below. We may use this Personal Information to personalize and improve our services, to contact users, to fulfill your requests for certain products and services, to analyze how users utilize the Services, and as otherwise set forth in this Privacy Policy. We may share certain types of Personal Information with third parties, as described below.

2. What Information Does Company Collect?

  1. Information You Provide to Us

    We receive and store any information you knowingly provide to us. For example, we collect Personal Information, including but not limited to, your name, title, company, email address, phone number, address, location and browser information. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features. We may anonymize your Personal Information so that you cannot be individually identified, and provide that information to our partners.

    If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses or communicate with you about your use of the Services. Also, we may receive a confirmation when you open a message from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference and contact us. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

  2. Information Collected Automatically

    Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

    When we collect usage information (such as the numbers and frequency of visitors to the Website), we only use this data in aggregate form, and not in a manner that would identify you personally. For example, this aggregate data tells us how often users use parts of the Services, so that we can make the Services appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal experience. We never disclose aggregate information to a partner in a manner that would identify you personally.

3. Will Company Share Any of the Personal Information It Receives?

We neither rent nor sell your Personal Information in personally identifiable form to anyone. However, we do share your Personal Information with third parties as described in Section II and in this Section:

  1. Affiliated Businesses and Third Party Websites We Do Not Control

    In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Services (either alone or jointly with us). Also, entities that we collaborate with in an effort to conduct business events & marketing fall under affiliated businesses.  You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

  2. Agents

    We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

  3. Business Transfers

    We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

  4. Protection of Company and Others

    We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

  5. With Your Consent

    Except as set forth above, you will be notified when your Personal Information may be shared with third parties in personally identifiable form, and will be able to prevent the sharing of this information.

4. Is Personal Information About Me Secure?

We endeavor to protect the privacy of your Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

The Services may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

5. What Personal Information Can I Access?

Our Services give you access to a broad range of information (including Personal Information) about your account and your interactions with the Service for the purpose of viewing and, in certain cases, updating or deleting that information. The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us.

6. What Choices Do I Have?

You can always opt not to disclose information to use, but keep in mind some information may be needed to register with us or to take advantage of some of our special features.

You may request deletion of your information by using the form on the contact us page. Please note that some information may remain in our records, for example in our archives, after your request of deletion of such information. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Please also note that comments you post publicly on our Website, such as comments on our blog posts, will remain visible to the public.

If you have any questions about viewing or updating information we have on file about you, please contact us. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please contact us.

 

7. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you a message. You are bound by any changes to the Privacy Policy when you use the Services after such changes have been first posted.

 

8. General Data Protection Regulation (GDPR)

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us.

What Personal Data Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

  • First and last name

  • Company name,

  • Email address

  • Telephone number

  • Address

  • IP Address

  • Username

  • Account Code (can include email addresses)

  • Browser information

  • Credit card and credit card CVV

  • Billing Address

  • Transaction and Billing Data

Information we receive from third party sources: Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following: 1

  • Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect or Twitter OAuth), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.

Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:

  • IP address

  • Device identifiers

  • Web browser information

  • Page view statistics

  • Browsing history

  • Usage information

  • Transaction information (e.g. transaction amount, date and time such transaction occurred)

  • Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) — For more information, please review our Cookie Policy (create hyperlink).

  • Location information (e.g. IP address, zip code)

  • Log data (e.g. access times, hardware and software information)

How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

  • Create and manage user profiles

  • Communicate with you about the Services

  • Process orders

  • Contact you about Service announcements, updates or offers

  • Provide support and assistance for the Services

  • Personalize website content and communications based on your preferences

  • Meet contract or legal obligations

  • Respond to user inquiries

  • Fulfill user requests

  • Comply with our legal or contractual obligations

  • Resolve disputes

  • Protect against or deter fraudulent, illegal or harmful actions

  • Enforce our Terms of Service

We will only process your Personal Data if we have a lawful basis for doing so. Lawful basis for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

    • First and last name

    • Email address

    • Mailing address

    • IP Address

    • Credit card and credit card CVV

    • Transaction and Billing Data

  • Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

    • First and last name

    • Email address

    • Mailing address

  • Examples of these legitimate interests include:

    • Operation and improvement of our business, products and services

    • Marketing of our products and services

    • Provision of customer support

    • Protection from fraud or security threats

    • Compliance with legal obligations

    • Completion of corporate transactions

  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

  • Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

  • Payment processors

  • Fraud prevention service providers

  • Ad networks

  • Analytics service providers

  • Staff augmentation and contract personnel

  • Hosting service providers

  • Co-location service providers

  • Telecommunications service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

  • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)

  • Social media services (if you interact with them through your use of the Services)

  • Third party business partners who you access through the Services

  • Other authorized parties

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).

We also share Personal Data when we believe it is necessary to:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies

  • Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud

  • Maintain the security of our products and services

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy

How Long Do We Retain Your Personal Data? We retain Personal Data about you in accordance with legal and additional compliance requirements. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, we use encryption and tokenization to keep your Personal data secure.

What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please contact us. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.

  • Erasure: You can request that we erase some or all of your Personal Data from our systems.

  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.

  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

  • Right to File Complaint: You have the right to lodge a complaint about Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data: The Services are hosted and operated in the United States (“U.S.”) through Company and its service providers, and laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the locale of your data being U.S. 

What If You Have Questions Regarding Your Personal Data? If you have any questions about this section or our data practices generally, please contact us using the following information:

Name:

Thread Compliance

Physical address:

244 Madison Ave

New York, NY 10016, USA

Email address for contact:

help@getthread.com

1 If applicable, indicate whether it came from publicly accessible sources. Art. 14(2)(f); where the personal data are not collected from the data subject, any available information as to their source.

2 The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form (Art. 15(3)). The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedom of others (Art. 15(4))

3 Controllers outside EU must establish a designate EU representative as an alternative contact available to EU data subjects. (Art. 27). The identity and contact information of the representative should be published here. (Art. 13(1)(a)).

4 The GDPR requires a company to retain a DPO only when its “core activities” involve “large-scale,” “regular and systematic monitoring” of EU subjects (Art. 37). Although this definition is unclear, it has been interpreted to apply to companies with “loyalty” and similar programs. In any case, because Member States may independently require a DPO for other circumstances (Art. 37(4)), companies with a broad EU presence may want to retain a DPO to ensure compliance across the board. If a DPO is required, its contact information should be disclosed here. (Art. 13(1)(b)).

List of Sub-Processors

Last Updated: February 2023