Last updated May 25th, 2018.
“Personal Data” as defined means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Keeping your personal data is one of our most important responsibilities. We will safeguard, according to established standards of security and confidentiality, any information our users share with us.
2. HOW WE COLLECT AND USE YOUR PERSONAL DATA
a. In this section we set out:
i. The categories of personal data that we may process
ii. The reason why we may process personal data
iii. The legal basis for processing this data;
In some circumstances, THINKFOODGROUP, LLC may request personal information from you, like your name, email, company name or telephone number. We may also ask you to select a username and password or identification number to gain access to certain portions of our site. We may also ask you to provide optional demographic information such as your zip code, your age range, or your product preferences. When a visitor requests pages on the THINKFOODGROUP, LLC Site, our servers automatically recognize the browser’s domain name IP address. Our servers also record email address for reasonable business purposes.
In general, you can visit THINKFOODGROUP, LLC sites without divulging any personal information. However, there are areas of THINKFOODGROUP, LLC’ sites that require this information to complete their customization functions. These sites areas may not be available to those choosing not to reveal the information requested.
1. ANALYTICS DATA: We may collect and process data about your use of our website (‘analytics data’). The analytics data may include any of the following: your IP address; approximate location, internet browser type and version, the source of referral, length of your visit, and website navigation paths, as well as information about the frequency, and pattern of your visits. We gather this data through the Google Analytics service. The legal basis for procession this data is our legitimate interests in improving our website and service.
2. CUSTOMER DATA: We collect and process data relating to customer profiles (‘customer data’). This data includes: your full name, email address, phone number & billing address. You may be required to provide this information during the process of booking our service. The legal basis for processing this data is for the performance of the contract, in particular, for us to be able to reliably communicate with you regarding your bookings or purchases, and to provide the service you requested. All of our data is passed on to a third-party service/vendor as part of Transaction information. For more information see section 4.
3. TRANSACTION DATA: We may collect and process data relating to the payment of services through our website or customer service agents (‘Transaction Data’). Transaction data includes: card number, card expiration date and card security code, as well as some customer data: billing address and card holder’s name, we may also process some additional data to run background checks in order to reduce fraudulent activity, this data may include: your email address & telephone number. Transaction data is handled and stored by a third-party service. The transaction data may be processed for supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.
4. CORRESPONDENCE DATA: We may process information contained in or relating to any communication that you send to or have with us (‘correspondence data’). The correspondence data may include: email content, online chat transcripts, call recordings and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you. Where possible we avoid collecting transaction data in correspondence data, this is done via warning notices on emails and pausing call recordings during the payment. The legal basis for this processing is in the performance of a contract, namely to organize and supply the purchased services. Correspondence data is handled and stored by a third-party vendor.
5. We may process any of your personal data where necessary, for use in the defense of legal claims in court or another legal proceeding. The legal basis for this is to protect and assert our legal rights, the rights of our customers’ or the rights of others.
6. We may process any of your personal data where such processing is necessary to comply with a legal obligation to which we are subject, or to protect your interests or the interests of another person.
3. THE STEPS WE TAKE TO PROTECT YOUR PERSONAL DATA
We have a security team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.
4. THIRD PARTY SERVICE/VENDOR
1. We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide the Services to you. Unless we tell you differently, such third parties do not have any
right to use the Personal information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Services, including the provision of maintenance services, database management, web analytics and general improvement of the Services. In particular, as part of our provision of the Services to you, we provide a limited amount of your End User Customer Information to our third-party vendors so that our third-party vendors can collect and compile publicly available contact and social media information related to your End User Customers, such as email addresses, gender, company, job titles, photos, website URLs, social network handles and physical addresses.
2. Transactional Information: Financial transactions relating to our website and services are OR may be handled by our payment services providers, In-store, handled by our third-party payment service providers. THINKFOODGROUP, LLC has the right to choose its third-party vendors and those details can be made available by contacting email@example.com. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices on their websites.
4. We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of 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. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
5. RETAINING AND DELETING PERSONAL DATA
This section sets out our data retention policies, these are designed to ensure that we comply with our legal obligation in relation to the retention and deletion of personal data and are designed so that we maintain the lowest possible level of risk to our customers.
Personal data that we process for any purposes shall not be kept for longer than is necessary to fulfill the purchased service and our third-parties legal obligations.
We will retain and delete your personal data as follows:
1. Analytics Data:
a. Google Analytics retains data relating to a visit to our website indefinitely. The data collected is non-identifiable. We collect some identifiable analytics data, this is stored for at least five years following a visit to our website, at the end of which period it will be deleted from our system.
2. Customer Data will be retained for the standard and legal time allowed, unless customer request to have personal information deleted.
6. YOUR RIGHTS
If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us using the mechanisms provided below. We will try to comply with your request as soon as reasonably practicable.
You may opt out of having your personal information used or disclosed for certain purposes:
1. If you no longer want to receive marketing-related emails from us on a going-forward-basis, you may opt-out of receiving these emails by clicking “unsubscribe” or “update my preferences at the bottom of any marketing email you receive.
2. If you would prefer that we do not share your personal information on a going-forward basis with business partners for their direct marketing
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority:
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
We do not collect personal information from any person we actually know is under the age of 17 without the consent of the parent or legal guardian of that minor. A parent or guardian may consent to the use of THINKFOODGROUP,LLC, by a minor, which parent or guardian is solely responsible for providing supervision of the minor’s use of THINKFOODGROUP, LLC and assumes full responsibility for the interpretation and use of any information or suggestions provided through THINKFOODGROUP, LLC . If you believe we might have any information from or about a child under 17, please contact us at firstname.lastname@example.org. If we learn and have confirmation we have collected or received personal information from a child under 17 without verification of parental consent, we will delete that information.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. MOBILE DEVICES
When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
10. CALIFORNIA LAW RIGHTS
Web Pages and HTML emails may contain a small snippet of code called a web beacon. In their simplest form, web beacons allow a website to transfer or collect information through a graphic image request. Websites may use web beacons and cookies for many purposes, including site usage analytics, advertising auditing and reporting, and content and advertising personalization.
THINKFOODGROUP, LLC may collect information through web beacons about how you interact with our html email marketing campaigns. This may include your IP address and the date / time that you opened or interacted with an html email. We may use the information we collect through web beacons:
• To determine which email messages sent by THINKFOODGROUP, LLC were opened and to note whether a message was acted upon.
• To understand how you use and interact with THINKFOODGROUP, LLC products and services.
• To improve THINKFOODGROUP, LLC products and services.
• To optimize your html email experience.
• To provide you relevant content.
12. OUR DETAILS
THINKFOODGROUP, LLC is registered in Delaware and our principal place of business is Washington D.C. You can contact us via email at email@example.com or phone 202.638.1910.
14. CONTACT THINK FOOD GROUP