Privacy Policy

ThinkWise, LLC. (“ThinkWise”) takes privacy seriously. In our modern technological world we work to balance the importance of the free flow of information against the importance of an individual’s privacy rights. This Internet Privacy Policy (“Policy”) describes the privacy policies applicable to personally identifiable information collected by ThinkWise, including personally identifiable information collected online via the ThinkWiseInc.com and related domains (the “Site”). 

ThinkWise complies with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield  Frameworks, 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.  ThinkWise 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/.  For Swiss individuals, the dispute resolution provider is the Swiss Federal Data Protection and Information Commissioner (FDPIC), https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/auftrag.html

Personal Information Received from the European Union:
We anticipate receiving personal information from European Union citizens, such as name, email address, and personality type for each visitor to our Web sites, our Web server automatically recognizes the visitor’s domain name, browser type, operating system, entry page, exit page, resources accessed and average time on the Web site. This information is used to (1) authenticate the user to the site and to help us improve our Web site and to better understand our customer’s needs. All personal data is processed according to the six data processing principles of the GDPR.
ThinkWise agrees to cooperate with the EU Data Protection Authorities, and to participate in the dispute resolution program provided by the European Data Protection Authorities Panel.

ThinkWise is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)

Onward transfers to third parties:
 a. To transfer personal information to a third party acting as a controller, ThinkWise must comply with the Notice and Choice Principles.   ThinkWise must also enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify ThinkWise if it makes a determination that it can no longer meet this obligation.  The contract shall provide that when such a determination is made the third party controller ceases processing or takes other reasonable and appropriate steps to remediate.

 b.    To transfer personal data to a third party acting as an agent, ThinkWise must: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with ThinkWise’s obligations under the Principles; (iv) require the agent to notify ThinkWise if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department upon request.

 ThinkWise assumes liability for onward transfer of data as defined within the Privacy Shield Principles. Under certain conditions, individuals may request to invoke binding arbitration.

ThinkWise adheres to the Privacy Shield Principles.  

If you have questions or concerns regarding this statement, you should first contact the Legal Department of ThinkWise, by e-mail at Privacy@thinkwiseinc.com 

Collection of Information on the Internet
Our Web site may log a user’s IP address, browser type and version, domain, and computer operating system when customers visit the site. IP addresses may in some cases be linked to personally identifiable information. We use the tracked information to help diagnose problems with our server and to administer our Web site. IP addresses also may be used to gather broad demographic information (i.e., information that is not associated with any individual and is anonymous). The data is used for research, product development, and statistical analysis only in the aggregate and never discloses any individual’s identity. Our Web site may use an order form for customers to purchase products and services. ThinkWise collects the name and e-mail address of the end user (the system user) for the sole purpose of providing customers with access to our software. We may collect customers’ contact information (such as their mailing and e-mail addresses). We verify our customer-provided credit card information with a third party prior to order processing. ThinkWise may send users mailings and other marketing collateral regarding product information and releases. Users may opt out of receiving any mailings by contacting ThinkWise by e-mail, mail, or phone. We reserve the right to aggregate or compile and use data obtained from the scoring or other processing of products listed on this site or otherwise sold or licensed by ThinkWise, and to utilize this data for research, product development, and statistical analysis. Be assured that such data is used in aggregate only and an individual’s identity is never disclosed.
Our Web site may contain links to other Web sites. We have no control over the privacy practices of such other Web sites, nor should the link be considered an endorsement of such other Web sites’ privacy practices. We recommend that you read the privacy policies of such other Web sites.

Cookies
We use session cookies as part of our login process. Session cookies are identifiers that can be sent from a Web site via your browser to be placed on your computer’s hard drive. Our session cookie stores the user’s account information and personality type, but is destroyed when the user logs out, when the user leaves the related .thinkwiseinc.com site, or when the browser window is closed. You may elect not to accept cookies by changing the designated settings on your Web browser. However, not utilizing cookies may prevent you from using certain functions and features of Web sites. The information collected from the use of cookies is used to personalize the experience of our customers, provide support to customers, record visitor preferences, provide personalized and specialized content, record session information, throughout the Web site, and customize site content based on your browser type, operating system, and preferences. By gathering such information to supplement our records, we learn things like what pages are most attractive to our visitors, and which of our products most interest our customers. If you disable cookies, you may still use our Web site; however, you may not be able to access certain areas within it. ThinkWise does not have access to or control over cookies used by third parties accessed through links on ThinkWise sites. This privacy statement does not cover the use of cookies by any of those third parties.

Security
We use security measures to protect against the loss, misuse, and alteration of the information under our control which is gathered from our Web site. We have licensed the industry-standard Secure Sockets Layer (SSL) technology for the encryption of personally identifiable information such as your name and email. This will make your information unusable in the event of unauthorized third-party interception. Additionally, we have appropriate security measures in place at our physical facilities to protect against the loss, misuse or alteration of your personal information. We store this information in a secure environment at one or more of our service providers.

Disclosure of Information
We do not share, sell, trade, or rent or otherwise give to any other entity or organization the individual information our customers submit on our sites except as noted in this privacy policy. From time to time, ThinkWise will provide its approved distributors in international markets with a list of customers, including name and contact information, residing in that distributor’s ThinkWise-approved area of distribution. ThinkWise will do so only when it reasonably believes that providing such information will permit improved service to ThinkWise customers in that distributor’s area, and only when the distributor’s use of such information is in accordance with ThinkWise’s privacy policies in general. We may share Your Information with agents, contractors or partners of ThinkWise in connection with services that these individuals or entities perform for, or with, ThinkWise. These agents, contractors or partners are restricted from using this data in any way other than to provide services for ThinkWise, or services for the collaboration in which they and ThinkWise are engaged (for example, some of our products are developed and marketed through joint agreements with other companies). We may also provide Your Information to a third party in connection with the sale, assignment, or other transfer of the business of this website to which the information relates, in which case we will require any such buyer to agree to treat Your Information in accordance with this Privacy Policy. Other than as stated above, if ThinkWise provides a third party with client information, it will be in the form of aggregate data and used for the purposes of product development, research, or statistical analysis. The information will remain anonymous, stripped of all personally identifiable data, and compiled among all of our visitors’ answers to survey questions and instrument responses as well as grouped on-site behavior. Again, all identifiable individual information will be removed.
We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web sites. ThinkWise may release account information when it believes, in good faith, that such release is reasonably necessary to (i) comply with law; (ii) enforce or apply the terms of any of its user agreements; or (iii) protect the rights, property, or safety of ThinkWise, its users, or others. If you need to delete, update, or correct the personal information that you have provided to ThinkWise, please send an e-mail to customerservice@ThinkWiseinc.com. You can expect a response to your request within 30 days.

Choices/Opt-Out and Updating Information
If you receive marketing or similar e-mail messages from us and wish to opt out of receiving such messages, you may simply follow the opt-out procedure specified in such e-mail.

Individuals may choose to limit the use and disclosure of their personal data. To opt out of the use and disclosure of your personal data provided to ThinkWise, please send an e-mail to customerservice@ThinkWiseinc.com. 

Summary
ThinkWise is committed to protecting its customers’ privacy. We use the information collected on our sites to improve our products, your experience, and scientific study. By using our Web sites, you consent to the collection and use of information by ThinkWise. We may from time to time change our privacy policy, but we will always post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Because of the changing legal landscape and the evolving nature of technologies, we may amend and reserve the right to amend this privacy policy from time to time. If we make material changes to this policy, we will notify you here, by e-mail, or by means of a notice on our homepage. You can determine when this privacy policy was last updated by looking at the “Last Updated” statement at the bottom of this Web page.

Dispute Resolution
ThinkWise agrees to cooperate with the EU Data Protection Authorities.
Contact Us
ThinkWise, LLC.
12471 168th Ave.
Grand Haven, MI 49417
PRIVACY@thinkwiseinc.com

Last Updated: MARCH 2022