Last updated: 11th December 2021
Threado Inc. and its affiliates (“Threado”, “we”, “us”, or “our”) provide a marketing platform available at https://www.threado.com/ for community-driven businesses to manage their online community wherever it exists (“Platform”). The provision of the Platform is referred to as the “Service”.
(a) About us:
Name: Pramod Rao
Designation: Data Protection Officer
Where we process your personal data strictly on our Clients’ instructions and on the basis of a contract between us and the Client, we will be considered data processors of the Client. To understand how your personal data is treated by the Client on whose behalf we process your personal data, please review their respective privacy notices and policies.
In cases where we act as a data controller (for example, when you visit our Platform in individual capacity to learn more about our business), we are directly responsible to you for the processing activities that we undertake in respect of your personal data.
(c) Third-Party Services:
The Service may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy policies.
(a) We collect different types of personal data about you in various ways, which we have grouped together as follows:
(i) Identity Data, such as your first name, last name and username.
(ii) Contact Data, such as your email address and telephone numbers.
(iii) Location Data, such as your address, city, state, province, ZIP/Postal code.
(iv) Transaction Data, such as your billing and payment information including billing and shipping addresses.
(v) Technical Data, which includes your IP address, device ID, device type or other identifier, browser information including browser type and version, browser language preference, time zone setting and location, browser plug-in types and versions, web browser application details, corresponding location details, date and time stamp, operating system, and diagnostic data on the devices you use to access the Service.
(vi) Usage Data, which includes information about how you use the Service and your activity within the Platform, the pages of the Platform that you visit, the time spent on those pages, the time and date of your visit, referring URL, page views, and links you click within our Clients’ sites.
(c) During your use of our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, details of documents on educational qualification, professional training, employment agreements, non-disclosure agreements, information on bonuses and compensation, information on marital status, family members, government identification number, office location and other data.
(d) We do not knowingly collect or process personal data of children. If you have any reason to believe that a child, without a parent or guardian’s consent has provided personal information, then please contact us at privacy@Threado.com, and we will use reasonable efforts to delete that information based on parent/guardian consent.
(e) We do not collect any data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data, or any information about criminal convictions and offences.
(f) What happens if I refuse to provide my personal data?
Where we need to collect personal data by law, or under the terms of a contract, and you fail to provide that data when requested, we may not be able to perform our obligations under the contract (for example, to provide you with the Service). In this case, we may have to cancel your access to the Service, but we will notify you accordingly.
We use different methods to collect data from and about you including through:
(a) Direct interactions. You provide us your personal data when you interact with us. This includes personal data you provide when you:
(i) create an account with us;
(ii) use our Service;
(iii) request marketing material to be sent to you;
(iv) enter a competition, promotion, or online surveys;
(v) register for demonstrations;
(vi) download case studies; or
(vii) give us feedback or contact us.
(b) Automated technologies or interactions. As you interact with the Service, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites that employ our cookies.
(c) Third parties or publicly available sources. We will receive personal data about you from various third parties:
(i) Technical Data from analytics providers such as Google; and
(ii) Identity Data and Contact Data from publicly available sources.
(a) Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you use your browser settings to block all cookies (including Essential Cookies), you may not be able to access all or parts of our Service.
(b) We use the following cookies:
(i) Essential Cookies. These cookies are sometimes called “strictly necessary” cookies, and are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform.
(ii) Analytical or Performance Cookies. These allow us to recognise and count the number of visitors on our Platform and to understand how visitors move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users find what they look for easily.
(iii) Preference Cookies. These are used to recognise you when you return to our Platform. This enables us to personalise our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
(iv) Targeting cookies. These cookies record your visit to our Platform, the pages you have visited and the links you have followed. We use this information to make our Platform and the advertisements displayed on it more relevant to your interests.
(d) Third-party Cookies. Additionally, you may encounter cookies or other similar devices that are placed by third parties on certain pages of the Platform. We do not control the use of these cookies, which are likely to be performance cookies or targeting cookies, by third parties. These third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Platform, we may collect such information within a file specific to you.
(a) We will only use your personal data when the law allows us to. We will use your personal data where we need to perform the contract we are about to enter into or have entered into with you or a Client (as the case may be), where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override such interests, or where we need to comply with a legal obligation. We use your personal data for the following purposes:
(i) to provide and maintain the Service;
(ii) to notify you about changes to our Service;
(iii) to allow you to participate in interactive features of our Service when you choose to do so;
(iv) to personalize your experience and better respond to your individual needs;
(v) to detect, prevent and address technical issues and to improve our Service offerings;
(vi) to improve customer service and effectively respond to your service requests and support needs;
(vii) to send you notices about your account and/or subscription (as the case may be), and periodic emails with marketing material, information and updates related to us or the Service;
(viii) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
(ix) to comply with legal obligations; and
(x) to fulfil any other purpose for which you provide it.
(b) Where applicable laws permit us to, we rely on your consent as a ground to process your personal data.
(c) If you are based in the EU (or where applicable law does not permit us to rely on your consent to process personal data), and provided that you are not using the Service as an end user of a Client, we rely on the following legal bases for processing your personal data:
(i) Legitimate interests, which means our interest in conducting and managing our business to enable us to provide you with the best Service, and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
(ii) Performance of a contract, which means we process your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
(iii) To comply with a legal obligation, which means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
(d) Additionally, if you are based in the EU:
(i) we will get your consent before sending third-party direct marketing communications to you through email or text messages. You have the right to withdraw consent to marketing material at any time by contacting us; and
(ii) we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
(e) We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
(f) Please note that we may process your personal data without your knowledge or consent, in compliance with the rules above where this is required or permitted by law.
(a) We do not share, sell, trade, or otherwise transfer to any third parties or allow third-party to access your personally identifiable information. However, we may share your personal data with the following third parties for the purposes set out in Clause 5:
(i) Internal third parties, which are other companies within the Threado group of companies.
(ii) External third parties such as:
• trusted third parties who assist us in operating our Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential;
• payment service providers to confirm payment for the Service purchased on our Clients’ solutions over a secured transfer protocol and under PCI-DSS compliance standards;
• regulators and other authorities, as required by law or regulation.
(b) We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
(a) The personal data that we process may be transferred to countries other than where you are based. For example, we transfer your personal data to the United States, where our servers are located. Where applicable law permits such transfer, we rely on consent to transfer such data. If you are based in the EU, we rely on standard data protection clauses that are approved by the European Commission for the transfer of personal data outside the European Economic Area.
(b) You can find out more about these transfer mechanisms by contacting us.
(a) We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed without authorisation, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
(b) We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database and is only accessible by those authorised with special access rights to such systems and are required to keep the information confidential.
(c) After a transaction, your private information such as credit card details and financials will not be stored on our servers.
(a) We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of such personal data breach where we are legally required to do so.
(a) We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. In case your information is no longer required for any purpose of lawful processing, then we will ensure it is disposed of in a manner that is consistent with Applicable Law.
(b) We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or where we are legally obligated to retain this data for longer time periods.
(c) In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
(a) Depending on the data protection laws applicable to you, you may have certain rights in relation to the processing of your personal data.
(b) Subject to the data protection laws that apply to you, you may have the right to:
(i) Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(ii) Request confirmation as to whether or not your personal data is being processed.
(iii) Request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(iv) Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(v) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(vi) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
(vii) Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, and machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(viii) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Service to you. We will advise you if this is the case at the time you withdraw your consent.
(c) If you wish to exercise any of the rights set out above, please contact us at the details provided in Clause 1(a).
(d) We will acknowledge your request within 24 (Twenty-four) hours and try to respond suitably to all legitimate requests within 72 (Seventy-two) hours. Occasionally, it could take us longer than 72 (Seventy-two) hours if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
(e) We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Please be aware that personal identifiable information that you voluntarily disclose and that is accessible to other users (for example, on social media, forums, bulletin boards, or in chat areas) may be collected and disclosed by others. We will not be responsible for such collection and disclosure.