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Privacy Policy

Revised: January 1, 2020

Our most important asset is our relationship with you. We would never jeopardize our trust with you under any circumstances.

ThriveTracker, (" ThriveTracker," "we," "us") is committed to maintaining the confidentiality, integrity and security of any personal information about our users and provides this Privacy Policy to inform users of our policies and procedures regarding the collection, use and disclosure of personally identifiable information received from (i) users of this website located at www.thrivetracker.com ("Site"), (ii) users of our online advertising management software platforms and all other software applications available on the Site (collectively, "Subscription Services", "Services"), and (iii) visitors to websites of our customers on which we place Tags (defined below) (collectively, "Customer Sites"). Please note that this Privacy Policy applies to the information that we collect through (i) this Site, (ii) Subscription Services, and (iii) Customer Sites. This Privacy Policy may be updated from time to time for any reason. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on the Site. You are advised to consult this Privacy Policy regularly for any changes.

By using our Site, the Subscription Services and Customer Sites, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing" means using cookies or Tags (defined below) on a computer or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the U.S. your personally identifiable information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. By visiting our Site or otherwise providing information to us, you consent to such transfer to, and processing in, the U.S. If you have any questions or comments about this Privacy Policy or our use of your personally identifiable information, please contact us at info@thrivetracker.com.

But enough about us - let's talk about you. Whether you own a business or manage campaigns for clients, you need a tracking platform that takes care of the tedious stuff so you can focus on growth.

YOUR PRIVACY AND INFORMATION ARE NEVER FOR SALE

Our primary goals in collecting personally identifiable information are to provide you with the products and services made available through the Site, including, but not limited, to the Subscription Services, to communicate with you, and to manage your registered user account, if you have one.

Simply put, we do not and will not sell or rent your personal information to anyone, for any reason, at any time. We are especially sensitive to login credentials to external sites that you may provide on our software platforms as a requirement to fully utilize the software capabilities. These private user information will only be used to internally troubleshoot problems, detecting and protecting against errors, preventing fraudulent and criminal activity, to analyze and improve our services to you, to enforce our Terms of Use, to fulfill your requests for certain products and services, and otherwise set forth in this Privacy Policy.

If you desire to have access to certain restricted sections of the Site, you may be required to become a registered user, and to submit certain personally identifiable information to ThriveTracker. This may happen in a number of instances, such as when you sign up for a free trial of the Subscription Services or you download materials from the Site, if you desire to receive our newsletter or other marketing materials and information, or if you wish to enter into a contests, sweepstakes or promotions (collectively, "Promotions") we provide via the Site. Personally identifiable information that we may collect in such instances may include your user name, password, company title (if applicable), email address, physical address and telephone number. If you decide to become a paying customer for the Subscription Services, we may collect additional information from you, such as your credit card number or other billing information. If you contact us by email through the Site, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, including any information you may provide about your advertising spending, to respond to you. In addition, we may use your contact information to market to you, and provide you with information about, our products and services, including but not limited to our Subscription Services. If you decide at any time that you no longer wish to receive such information or communications from us, please follow the unsubscribe instructions provided in any of the communications or contact us at info@thrivetracker.com.

When you visit the Site, our servers automatically record information that your browser sends whenever you visit a web site ("Log Data"). This Log Data may include information such as your internet protocol ("IP") address, browser type or the domain from which you are visiting, the web-pages you visit, the search terms you use, and any advertisements on which you click. For most users accessing the Internet from an Internet service provider the IP address will be different every time you log on. Except in the instances described herein, we do not use this information to identify you personally. We use it to monitor the use of the Site and of any services or Promotions we provide via the Site including our Subscription Services, and for the Site's technical administration. But the same pieces of information are considered non-identifying information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). For users of the Subscription Services only, we may combine your personally identifiable information with non-identifying information and aggregate it with information collected from Site users to attempt to provide you with a better experience, to improve the quality and value of the services and Promotions we provide via the Site and to analyze and understand how our Site, services and Promotions are used.

COOKIES

Like many web sites, we also use "cookie" technology to collect additional website usage data and to improve the Site and any services or Promotions we provide via the Site including our Subscription Services. A cookie is a small data file that we transfer to your computer's hard disk. We do not use cookies to collect personally identifiable information. ThriveTracker may use both session cookies and persistent cookies to better understand how you interact with the Site and with and any services or Promotions we provide via the Site including our Subscription Services, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve usability and performance of the Site. A session cookie enables certain features of the Site and our service and is deleted from your computer when you disconnect from or leave the Site. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the web sites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site.

TAGS

We also use ""web beacons," "pixel tags," "clear GIFs" or similar means (individually or collectively "Tags") on our Site and on Customer Sites. A Tag is an electronic image, often a single pixel, embedded on web pages. Tags are ordinarily not visible to users. Tags allow us to count the number of users who have visited certain pages of the Site or Customer Sites, to deliver branded services and to generate statistics about how our Site and Customer Sites are used.

We use the services of third party companies to help us carry out and measure the effectiveness of our own and Customer advertising campaigns. For example, these third party companies may ensure that you are shown ads at appropriate frequencies, so that you do not see the same ad repeatedly. As part of these services, one or more Tags may be placed on the Site and on Customer Sites. These Tags do not enable third parties to collect your name, e-mail address, phone number or other similar information that directly identifies you. Rather, when you visit the Site or Customer Sites, these Tags will direct your web browser to contact these third party companies, at which time they may set or read a cookie on your device and collect information about your visit - such as your IP address, cookie ID, which parts of the websites are viewed or clicked, and date/time information.

Currently, we use our own Tags on the Site and on Customer Sites to enable collection of information about visitors to our Site and such Customer Sites.

We use information collected from Tags to gather non-personally identifiable information, including, but not limited to, your computer's IP address, browser type or the webpage you were visiting before you came to our Site or the applicable Customer Site, pages of our Site or the applicable Customer Site that you visit, the time spent on those pages, information you search for on our Site or on the applicable Customer Site, access times and dates, and other statistics.

THIRD PARTY INFORMATION COLLECTION/"DO NOT TRACK"

With respect to Ad Servers: To try and bring you offers that are of interest to you, we have relationships with other companies that we allow to place ads on our Site. As a result of your visit to our Site, ad server companies may collect information such as your domain type, your IP address and clickstream information. For further information, consult the privacy policies of the companies representing the ads or http://www.google.com/privacy_ads.html.

Third parties with whom we partner to provide certain features on the Site or to display advertising based upon your web browsing or application activity use Flash cookies and HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

"Do-Not-Track" is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to Do- Not-Track signals.

If you wish to limit the collection of information by us or third party partners to provide you with advertising based upon your website browsing activities and interests, you may click [http://preferences-mgr.truste.com] to opt out. To opt out of targeted advertising on your mobile device, iOS users can click here: https://support.apple.com/en-us/HT205223 to learn how to limit ad tracking and Android users can click here: https://support.google.com/ads/answer/2662922?hl=en to learn how to opt out of interest-based ads. Please note that opting out of interest-based/targeted advertising does not limit all advertising. You will continue to receive generic advertisements.

OPTING-OUT

If you supply us with your e-mail address, you may receive periodic e-mails from us with information on new products and services or upcoming events. If you do not want to receive e- mails from us in the future, please let us know by sending us e-mail to: info@thrivetracker.com. However, we may still contact you concerning administrative or transactional matters.

If you supply us with your postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by calling us at the number provided below, writing to us at the below address, or e-mailing us at info@thrivetracker.com.

Persons who supply us with their telephone numbers may receive telephone contact from us with information regarding new products and services or upcoming events. If you do not wish to receive such telephone calls, please let us know by calling us at the number provided below, writing to us at the below address, or e-mailing us at info@thrivetracker.com.

HOW WE SHARE THE INFORMATION WE COLLECT

Except as set forth in this Privacy Policy, ThriveTracker will not share your personally identifiable information with third parties. We may share generic aggregated demographic information not linked to any personal information regarding visitors and users with our business partners, or any other party for any purposes including the purposes outlined above. In addition, we may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys.

If you decide to use the Subscription Services either on a trial basis or otherwise, we may use and share the information that you will provide to us with third parties, including with companies providing paid search advertising services to you, pursuant to the Subscription Services Terms of Use. If you decide to enter into one of our Promotions, we may share your personally identifiable information with third parties who work with us to sponsor and promote such Promotions. In addition, we may share personal information:

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of ThriveTracker's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by ThriveTracker is among the assets transferred
  • To fulfill any purpose or effect the action for which you provide the information
  • To any third party with your consent
  • To comply with any court order, law, legal process, including to respond to any government or regulatory request
  • To enforce or apply our terms of use and other agreements, including for collections purposes and disbursements or
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ThriveTracker, our customers or others. This includes exchanging information with other organizations for the purposes of fraud protection.

Service Providers. We may engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage and management, and direct marketing campaigns. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

ACCESSING AND CORRECTING YOUR INFORMATION

You may send us an email at info@thrivetracker.com to correct or delete any information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect or misleading.

YOU CAN TRANSPORT OR DELETE YOUR DATA AT ANY TIME

Your data is yours. You can remove it anytime you want. When you request us to delete your account for the Service, your data will be permanently expunged from our primary production servers and further access to your account will not be possible. We will also promptly disconnect any connection we had established to your Account Information and delete all account credentials. However, portions of your data, consisting of aggregate data derived from your Account Information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media. We keep these backups to ensure our continued ability to provide the Service to you in the event of malfunction or damage to our primary production servers. We also reserve the right to use any aggregated or anonymous data derived from or incorporating your personal information. Such information and use will never be personally identifiable to you, and we will never access your data stored externally from our site.

SECURITY

ThriveTracker is very concerned about safeguarding the confidentiality of your personally identifiable information. We employ advanced administrative, physical and electronic measures designed to protect your information from unauthorized access.

We will disclose any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

YOU ARE RESPONSIBLE FOR MAINTAINING CONFIDENTIALITY OF PASSWORD

We maintain strict rules to help prevent others from guessing your password. We also recommend that you change your password periodically. You are responsible for maintaining the security of your Login Email and Password. You may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at info@thrivetracker.com, but in any event you should change your password immediately via the Service. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy Policy or the Terms of Use.

If you have a security related concern, please contact us at info@thrivetracker.com. We will work closely with you to ensure a rapid and personal response to your concerns.

INTERNATIONAL TRANSFER

Your information may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Entity transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

LINKS TO OTHER WEBSITES

From time-to-time, our Site may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other web sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. This Privacy Policy addresses the use and disclosure of information that we collect from you through the Site. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

OUR POLICY TOWARDS CHILDREN

The Site is not directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at info@thrivetracker.com. If we become aware that a child under 13 has provided us with personally identifiable information, we will remove such information from our files.

ACCOUNTABILITY FOR ONWARD TRANSFERS

To effectively serve the needs of our clients, Thrive may need to share that data with certain third parties or sub-processors. In such instances, Thrive will execute any needed contracts, clauses or addendums to ensure that any third-party agents that it engages to process personal data does so in a manner that is consistent with the Privacy Shield Principles. Thrive is potentially liable for onward transfers to third parties of personal data of EU individuals received pursuant to Privacy Shield.

EU-U.S. PRIVACY SHIELD FRAMEWORK

ThriveTracker complies with the EU-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 to the United States. ThriveTracker 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 www.privacyshield.gov.

In compliance with the Privacy Shield Principles, ThriveTracker commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact ThriveTracker at:

info@thrivetracker.com

ThriveTracker has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

JURISDICTION

ThriveTracker has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. ThriveTracker states that if there is any conflict between the terms of our privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. ThriveTracker is also subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). To learn more about the Privacy Shield program, and to view ThriveTracker's Privacy Shield certification, please visitwww.privacyshield.gov.

RECOURSE & ENFORCEMENT

In instances where other redress possibilities have been exhausted under EU law, or where the complaint has not been resolved by any other means, ThriveTracker will provide EU end users a binding arbitration option before the Privacy Shield Panel. ThriveTracker acknowledges that any final decision by the Privacy Shield Panel is a legally binding decision, enforceable in US courts.

THRIVE'S PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents supplements the information contained in Thrivetracker's above PRIVACY NOTICE and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
  • In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:
Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. NO
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

Our Website obtains the categories of personal information listed above from the following categories of sources:

  • Tracking information received indirectly from forms you complete or products and services you purchase.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Website, products, and services.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.

Sales of Personal Information
In the preceding twelve (12) months, Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
  • Full name, email address, date & time of transaction
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically in a csv document.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights
We do not sell the personal information of consumers.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@thrivetracker.com or write us at: 401 N. Cattlemen Rd. Suite 200 Sarasota, FL 34232.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which ThriveTracker, LLC collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: https://thrivetracker.com/contact/
Email: info@thrivetracker.com
Postal Address:
ThriveTracker
Attn: Privacy Department
401 N. Cattlemen Rd.
Suite 200
Sarasota, FL 34232