TM Thrive is committed to protecting your privacy and ensuring that you have a positive experience on our website and in using our products and services (collectively, “Products”). This policy covers the TM Thrive website, web applications, mobile applications, and desktop clients and is applicable worldwide.
Collection of your Personal Data
We may collect the following categories of Personal Data about you when you use or otherwise interact with our Products:
- Email address
- SSO profile information (when you use 3rd party services to log-in to our Products or to create an account for our Products)
- IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
We collect and/or process your Personal Data in connection with the below activities related to our Products:
- Account registration
- Participating in discussion groups or forums
- Generating reports based on information collected from use of our Products
- Requesting service and support for our Products and providing such support
Processing of your Personal Data
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the Products) and our “legitimate interests” or the legitimate interest of others (e.g. our users) such as:
- Complying with our legal obligations, resolving disputes with users, enforcing our agreements
- Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
We process Personal Data for purposes such as:
- To provide reports based on information collected from use of our Products
- To provide support and assistance for our Products
- To provide the ability to create personal profile areas and view protected content
- To the extent you choose to participate, to conduct questionnaires and surveys as part of the Active Mental Health Leadership program
- To meet contract or legal obligations
You can choose whether to provide Personal Data to TM Thrive, in order to access our services. If you would like to discontinue the services, you can update your preferences by contacting us using the information in the “Contact Us” section of this policy.
Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
- Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the 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. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- 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 Products.
- Right to File Complaint: You have the right to lodge a complaint about TM Thrive’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.
TM Thrive and our third party service providers automatically collect some information about you when you use our Products, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or Products.
Sharing your Personal Data
We do not sell or rent your Personal Data to third parties for marketing purposes.
We share Personal Data within TM Thrive, and with third party service providers for purposes of data processing or storage.
We also share Personal Data with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested services and providing customer support. We provide these third parties with Personal Data to complete the requested service offering.
In some cases, we may choose to buy or sell assets. In these types of transactions, 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 NOT be transferred or acquired by a third party. TM Thrive would first seek consent to transfer your data and proceed with deletion/destruction of data whose owners have not consented to the transfer. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of TM Thrive’s terms of service, or as otherwise required by law.
Security of your Personal Data
TM Thrive is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology.
We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us by using the information in the “Contact Us” section of this policy.
Transfer and Storage of Personal Data
Our website and related services are hosted and operated in Australia through TM Thrive and its service providers. We will NOT transfer your Personal Data to any TM Thrive affiliate or to third parties acting on our behalf for the purposes of processing or storage outside of Australia.