Privacy Policy

Thinaer Privacy Policy
Last Updated: 1/19/2018

Thank you for using Thinaer. We are committed to protecting your privacy and, for that reason, we have adopted this Privacy Policy to memorialize our data collection and disclosure practices for the Thinaer mobile app and website, and their related tools and services (collectively, the “Services”). The Services are owned and operated by The Leadership Analytics Group LLC, a Pennsylvania limited liability company (“we”, “us” or “our”). This Privacy Policy applies to information collected through the Services, as well as other information provided to us online or offline by customers or users; however, it does not apply to information collected from our employees, contractors or vendors.

This Privacy Policy describes, among other things:

• Personal and other information we collect about you
• How we use your information
• How we may share your information with third parties
• Your choices regarding the personal information we collect about you

1. CONSENT

By using the Services, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services or Thinaer. Information gathered through the Services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the Services, you agree to the transfer, use and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or Thinaer are deemed to occur in the United States, where our servers are located.

2. COLLECTION OF YOUR PERSONAL AND OTHER INFORMATION

When you use our Services, we collect Personal Information. By “Personal Information” we mean information that can identify an individual, such as:

• Names
• Email addresses
• Information contained in any profile information associated with your position, such as your department or position (e.g., Sales Team, West Region, Supervisor).

Additionally, we create Unique Identifiers, meaning arbitrary codes or series of characters that we create to identify unique users. These Unique Identifiers may be associated with feedback you provide and/or Personal Information, such as your name.

You may always choose not to provide Personal Information, but this may prevent you from receiving certain Services.

We also collect non-Personal Information, that is, information that does not personally identify an individual. The non-Personal Information we collect includes how you interact with the Services, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the Services.

Examples of the non-Personal Information we collect are:

• Your Internet Protocol (IP address),
• Information about your operating system and browser, such as its maker or version
• The pages of our website that you viewed during a visit or the features of the app you use
• What information or content you view, hover over or click on
• The referring web page
• Language preferences, and The city and state in which you are located (but not your precise geographic location).

We will not use non-Personal Information to try to identify you, and if we associate any non-Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather non-Personal Information.

Information collected by the Services may be collected by us or one of our service providers, but in either case, this Privacy Policy will govern the collection, use and sharing of the information.

3. USE OF YOUR INFORMATION

We use the information we collect to:

• Assist us in providing the Services, including disclosing the feedback you provide and receive to your employer
• Set up accounts
• Improve online operations
• Provide customer service
• Provide you with newsletters, RSS feeds, and/or other communications or services which you have signed up for or otherwise agreed to receive
• Send account- or transaction-related communications, such as welcome letters or notifications
• Perform research and analysis aimed at improving our products and services, and
• Manage our systems

We will only use your Personal Information in the way we specified when it was collected (including as described in this Privacy Policy).

4. DISCLOSURE OF YOUR INFORMATION

We will not disclose your Personal Information to third parties except as described below. We also will not sell or disclose your Personal Information to third parties for their own marketing purposes unless you have explicitly and affirmatively granted us permission to do so.

We will disclose Personal Information to provide the Services, which will be apparent when you use or access Thinaer or when you authorize or instruct us to do so, for example when you choose to use the Services to post or transmit messages that are viewable by other users of the Services, including your employer. We may also disclose Personal Information to companies, agents, contractors, service providers or others engaged to perform functions on our behalf (such as provision of data storage, hosting of our website, marketing of our products and services, conducting audits, and performing web analytics).

We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues.

Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to Thinaer, or in the unlikely event of a bankruptcy, liquidation or receivership of our business. You will be notified via email or prominent notice on our website for 30 days of any such change in ownership or control of your Personal Information.

Lastly, we may also disclose non-Personal Information, anonymously aggregated with information about our other users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

5. COOKIES & AUTOMATIC INFORMATION GATHERING TECHNOLOGIES; AUTOMATING GATHERING OF NON-PERSONAL INFORMATION

Every time you access our Services, or one of its web pages, we collect Non-Personal Information (discussed above in Section 2). To assist the Services in collecting and storing Non-Personal Information, we may use a variety of technologies, including “Cookies,” local browser storage and “Web Beacons.” A “Cookie” is a small amount of data a website may store in your web browser that it can access when you visit it. A cookie also refers to web-browser-based storage provided by Adobe’s Flash plugin (a “Flash Cookie”). Cookies may contain user preferences, unique identifiers and other non-Personal Information. A “Web Beacon” is a small, usually-transparent image placed on a web page that allows us or our partners to collect non-Personal Information.

You can erase information stored in cookies, flash cookies, and local browser storage at any time, but you may be forced to login to the website again and you may lose some preferences or settings. You can also set your browser to refuse all website storage or to indicate when it is permitted, but some features of our Services may not function properly without it. We do not use Cookies, Web Beacons or similar technologies to store Personal Information.

Additionally, every time you open or use our mobile app, we collect non-Personal Information. For example, using the Services may trigger the transmission of information between the app and our servers, and each time that occurs, our servers collect non-Personal Information.

Thinaer also automatically collects information about how people use the app. For example, to improve our Services, we collect how, when, and which parts of the app or its features you use.

To help us collect this information, we may use third-party software and services. Also, we may use your device’s unique identifier (UDID), media access control address (MAC Address), or other unique identifiers to assist us in collecting and analyzing this data.

6. TRANSPARENCY AND CHOICE

When you use our Services, we make good faith efforts to provide you with access to your Personal Information and either to correct this data if it is inaccurate or to delete such data at your request, in either case if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please e-mail us at info@thinaer.io with any questions, if you need assistance accessing or changing your Personal Information, or if you would like to have your Personal Information deleted. Please be aware that your employer may not authorize us to delete your Personal Information, in which case we will follow their instructions unless contrary to applicable law. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

Thinaer has features that permit users to set specific privacy preferences to control how certain information is shared or used. If you choose to limit how we can share or use your information through these features, then we will honor your settings. Naturally, we still may need to use your information to provide the Services or communicate with you.

We do not use, or allow third party advertising networks to use, information about web browsing activity collected through the Services for targeted or behavioral advertising. Thinaer supports the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized “do not track” feature is released, we intend to adhere to the browser settings accordingly.

You can opt out of receiving certain e-mails from us by clicking on the “unsubscribe” link in the e-mails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Also, even if you opt out of certain e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.

7. CHILDREN

We do not knowingly collect Personal Information from users under 18 years of age. We do not authorize users under 18 years of age to use the Services or Thinaer. If we learn that we have collected Personal Information from a person under the age of 18, we will delete that data from our systems.

8. INFORMATION SECURITY

We utilize reasonable information security measures to safeguard your Personal Information. For example, we utilize Secure Socket Layer (SSL) encryption technology when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network. Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security.

We restrict access to Personal Information to our employees, contractors, service providers and agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

9. THIRD PARTY WEBSITES

Please note that the Services may link or integrate with third party sites, services or apps. We are not responsible for the privacy or security policies or practices or the content of such third parties. Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites collect, use, share and protect your information.

10. EU-U.S. PRIVACY SHIELD FRAMEWORK

The Leadership Analytics Group, LLC (d/b/a Thinaer) complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. The Leadership Analytics Group, LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

The Leadership Analytics Group, LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission.

In compliance with the Privacy Shield Principles, The Leadership Analytics Group, LLC commits to resolve complaints about your privacy and our collection or use of your personal information. Our organization commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact The Leadership Analytics Group, LLC at: info@thinaer.io

The Leadership Analytics Group, LLC has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to International Centre for Dispute Resolution-American Arbitration Association (ICDR-AAA). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by The Leadership Analytics Group, LLC, please visit https://www.adr.org/Support for more information and to file a complaint. The services of ICDR-AAA are provided at no cost to you.

If these processes do not result in a resolution, you may also contact your local data protection authority, the US Department of Commerce, and/or the Federal Trade Commission for assistance.

If your complaint still remains unresolved, then you have the right to invoke binding arbitration by the Privacy Shield Panel upon written notice to The Leadership Analytics Group, LLC at: contact@develapme.com.

The Leadership Analytics Group, LLC is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield organization shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

11. CHANGES TO THIS POLICY

We may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed. If we make any material changes to this Privacy Policy, we will notify you by e-mail or post a notice of the changes on our website or through our mobile app prior to the changes becoming effective. We encourage you to check this Privacy Policy from time to time. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING Thinaer AND SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE “LAST UPDATED” DATE).

12. CONTACT US

For more information or to ask questions, please contact us at:

The Leadership Analytics Group, LLC.

E-Mail: info@thinaer.io