ThinkCX Privacy Notice

Effective Date: May 26, 2025

What does this policy cover?

This privacy policy describes how ThinkCX (also referred to as “we” or “us”) will collect and make use of your data when you visit our website at https://thinkcx.com and how we collect and use consumer data to provide and the ThinkCX Solutions. It also describes data protection rights that may be available to you, including a right to object to some of the processing which ThinkCX carries out.

What information do we collect?

Our website, customer portal and relationship with you

If you submit your personal information to us by using the Contact Us form on our website, we may collect and use your name, company name, email address and phone number, and any other information that you may choose to include in your submission. We also collect information you provide through interacting with us for other purposes, like through our customer portal. We use this data to gain a better understanding of your specific interest in our company and commercial products, and to communicate directly with you. We may record your information and store it to a database, which could be hosted locally or on a secure 3rd party cloud server. We retain this data for a limited period of time, which is as long as we need it to fulfil the purposes for which we have initially collected it.

ThinkCX Solutions

ThinkCX does not collect information or data directly from consumers for the ThinkCX Solutions. Our data collection for the ThinkCX Solutions is described below.

What information do we receive from third parties?

Our website, customer portal and relationship with you

We collect and process personal information about you when you interact with us and our website. We use selected third-party vendors to collect this data on our behalf, such as Google Analytics and Pipedrive. We collect the behavioural data of website visitors, which includes the pages viewed, visitor source (referring website), and time spent on the website. Your IP address, browser type, and device type may also be collected, and IP address may be used to detect the company and general geographic location.. If you have questions about the privacy policies of these third parties, you are encouraged to review them yourself, and can find them here for Google and Pipedrive.

We use this data to measure and optimize traffic to our website, determine the popularity of certain website content, and to gain a better understanding of the online activity of visitors to our website. We retain this data for a limited period of time, which is as long as we need it to fulfil the purposes for which we have initially collected it. You can also see the “What are ThinkCX’s digital advertising practices?” section of this privacy policy to learn more about the use of this information and the choices available to you.

ThinkCX Solutions

To provide the ThinkCX Solutions, we collect data about consumers from third parties. These third parties are our data supply partners (“Partners”). In particular, the ThinkCX Solutions use data provided to us by our Partners in the internet traffic control, and programmatic advertising and marketing technology industries.

Our Partners supply various types of data to us, including cross-device data, which we may use to connect or associate the various devices used by a consumer. We use the data our Partners supply us with to analyze and model for our clients. This data may include

  • Mobile phone number
  • IP address
  • User agent
  • Device model
  • Unique device ID
  • Geo location
  • Time stamp / time zone
  • BSSID/MAC
  • SSID
  • Carrier
  • Bidstream data attached to online advertising bids and auctions
  • Mobile app usage data
  • Cross device graphs
  • Aggregated web traffic data
  • Where permitted by law, demographic data

How do we use this information, and what is the legal basis for this use?

Our website, customer portal and relationship with you

We process this personal information for the following purposes:

  • To respond directly to you when you submit a “Contact Us” request on our website.
  • As required by ThinkCX to conduct our business and pursue our legitimate interests, in particular:
    • we will use your information to provide products and services you have requested, and respond to any comments or complaints you may send us;
    • we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
    • we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
    • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation)
    • we may send you marketing in relation to our relevant products and services, or other products and services provided by us or that we think may be of interest to you; or
    • we may use, or allow third parties to use, information collected through cookies and use similar technologies for digital advertising purposes;
  • Where you give us consent, including where consent is required by law:
    • ,we will use the data for the purposes which we explain at that time.
  • For purposes which are required by law:
    • In response to requests by government or law enforcement authorities; or
    • To comply with our legal requirements.

ThinkCX Solutions

To offer the ThinkCX Solutions, we use the data we collect from our Partners to provide information to our clients. ThinkCX Solutions are focused on the telecommunications sector with a commercial interest in providing internet service providers, mobile carriers and handset manufacturers with actionable insights to help grow their business through our solutions mentioned above. Where possible, we rely on aggregated or identified data to provide the ThinkCX Solutions.

For the purposes of the ThinkCX Solutions, we generally rely on our legitimate interests or consent to process personal information. This consent may not be collected by us and may have been collected by one of our Partners.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent (even if the consent was not obtained by us), although we may have other legal grounds for processing your data for other purposes, such as those set out above.

In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

Who will we share this data with, where and when?

We share personal information we collect with other parties, including the following as permitted by law:

  • With third-party service providers who process information on our behalf, such as data hosting services, email service providers, or with our legal or business advisors.
  • With any affiliates or joint venture partners that we may have in the future.
  • With government authorities, law enforcement officials, or other third parties if required for the purposes described in this privacy policy , if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws.
  • In the event that the business, in part or in whole, is sold or integrated with another business, information will be disclosed to our advisers and any prospective purchaser’s adviser and with the new owners of the business or asset(s) sold.
  • With your consent or as otherwise disclosed at the time of data collection or sharing.

We may use and share deidentified information to the extent permitted by applicable law. When we use deidentified information, we maintain and use the information in deidentified form and do not attempt to reidentify it, except to check whether our deidentification processes satisfy the requirements of applicable law. We share aggregated or deidentified information with our clients to provide the ThinkCX Solutions.

Where does ThickCX process information?

ThinkCX’s business operations are located in Canada and the UK, and our data servers are located in Canada, Sweden, and the United States.

Where information is transferred outside the EEA, and where this transfer occurs to a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses or another adequate legal mechanism. A copy of the relevant mechanism can be provided for your review on request to ThinkCX Technologies, Inc., privacy@thinkcx.com

What are ThinkCX’s digital advertising practices?

On our website, we may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the website and other websites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

You may visit the DAA Webchoices tool at www.aboutads.info in the US or at http://youradchoices.ca/choices/ in Canada or at http://youronlinechoices.eu in Europe to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. You can also exercise choices regarding interest-based advertising on your mobile device by downloading the appropriate version of the DAA’s AppChoices tool at https://youradchoices.com/appchoices.

If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.

We may also work with third parties that collect data about your use of the website and other websites or apps over time for non-advertising purposes. ThinkCX uses Google Analytics and other third-party services to improve the performance of the website and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our site, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our website may not function as intended.

How long will you retain my data?

The data we process is retained in our systems as necessary to operate our business and provide the ThinkCX Solutions, comply with our legal obligations, and enforce our agreements.

What rights are available for individuals outside of the United States?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

What rights are available for United States consumers?

Some U.S. states grant individuals certain rights under state privacy laws with respect to personal data we collect. If you are a resident of such states, this section of the privacy policy contains disclosures required by law and explains rights that may be available to you.

This section of the privacy policy applies to personal information we collect to provide the ThinkCX Solutions. If you interact with ThinkCX in a business capacity and are a California resident, please see the “What rights are available to California business contacts?” section of this privacy policy.

Personal Information We Collect and Disclose. In the preceding 12 months, ThinkCX collected and disclosed for our business purposes the following categories of personal information:

  • Personal and online identifiers (such as first and last name, email address, or unique online identifiers);
  • Characteristics of legally protected classifications (such as gender);
  • Commercial information (such as records of our products you considered or purchased);
  • Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement);
  • Geolocation data;
  • Inferences drawn from the above information about your predicted characteristics and preferences; and
  • Other information about you that is linked to the personal information above.

Some of the categories of personal information listed above are considered “sensitive” under state privacy laws.

Categories of Sources. We collect personal information from the following categories of sources: our Partners and our service providers.

Our Purposes for Processing Personal Information. We process the personal information we collect for our commercial and business purposes, namely to provide our clients with actionable insights to help grow their businesses. However, we do not sell or use personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Recipients of Personal Information. We disclose the categories of personal information designated above to our service providers for our business purposes. When providing the ThinkCX Solutions, we provide our clients with aggregated or deidentified information, and we do not sell personal information or share personal information for targeted advertising to provide the ThinkCX Solutions. We also do not knowingly sell or share personal information about minors under 16 years old.

Your Rights. Depending on your state, you may be able exercise the following rights regarding personal information processed by ThinkCX, subject to certain exceptions and limitations:

  • The right to confirm whether we are processing personal information about you and, in some states, to obtain the categories of personal information we process.
  • In some states, the right to obtain the categories of third parties to which we disclosed your personal information. In other states, the right to obtain a list of the third parties (other than our service providers) to which we disclosed personal information.
  • The right to access a copy of the specific pieces of personal information we maintain about you.
  • For California residents, the right to know the categories of personal information that we have collected about you in the past 12 months, the categories of sources of such information, information about how we used your personal information, the categories of information we disclosed, shared, or sold and the categories of third parties to which we disclosed, shared, or sold it.
  • The right to request that we delete personal information.
  • The right to request that we correct inaccurate personal information.
  • The right to opt out or limit our processing of sensitive personal information
  • The right not to receive discriminatory treatment for the exercise of the above privacy rights.

Exercising Rights. To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

Depending on your state, if you have submitted a request you think we have not fulfilled, you may contact us to appeal our decision by sending an email with the subject line “Appeal” to privacy@thinkcx.com.

Note that we may need to request additional information from you to verify your identity or understand the scope of your request. We will require you to provide, at a minimum, your name and phone number.

Depending on your state, you may also designate an authorized agent to make requests on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent. We may still contact you to verify your identity or to confirm that you authorized the agent to make the request.

What rights are available to California business contacts?

This section of the privacy policy explains rights that may be available to our California business contacts under the California Consumer Privacy Act (“CCPA”) and provides disclosures required by the CCPA.

Personal Information We Collect and Disclose. In the preceding 12 months, ThinkCX collected and disclosed for our business purposes the following categories of personal information:

  • Personal and online identifiers (such as first and last name, email address, or unique online identifiers);
  • Recordkeeping information (such as financial information for payment purposes);
  • Commercial information (such as records of our products you considered or purchased);
  • Internet or other electronic network activity information (such as interactions with the ThinkCX websites and ThinkCX emails);
  • Audio or visual information (such as video or call recordings);
  • Professional or employment-related information;
  • Sensitive personal information (such as your account credentials); and
  • Other information about you that is linked to the personal information above.

Categories of Sources. We collect personal information from the following categories of sources: you, our clients, and our service providers.

Recipients of Personal Information. We disclose the categories of personal information we collect to the categories of third parties listed above in the “Who will we share this information with and when?” section of this privacy policy for our commercial and business purposes.

While we do not sell the personal information we may collect, we may “share” personal information for interest-based advertising purposes (also known as “cross-context behavioral advertising”) by allowing third-party advertising providers to collect data about our website visitors as described above under the “What are ThinkCX’s digital advertising practices?” section of this privacy policy. We do not knowingly sell or share personal information about minors under 16 years old.

Our Purposes for Processing Personal Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described above in the “How do we use this information, and what is the legal basis for this use?” and the “Who will we share this information with and when?” sections of this privacy policy.

Your Rights. California residents have certain rights with respect to the personal information collected by businesses like ThinkCX. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and share about you, the categories of sources from which we collected your personal information, our purposes for collecting or sharing your personal information, the categories of your personal information that we have either shared or disclosed for a business purpose, and the categories of third parties with which we have shared or disclosed for a business purpose personal information;
  • The right to request that we delete personal information we have collected from you.
  • The right to request that we correct personal information we maintain about you.
  • The right to opt out of our sharing of your personal information for interest-based advertising purposes (also known as “cross-context behavioral advertising”).
  • The right not to receive discriminatory treatment for exercising privacy rights conferred by the CCPA.

While the CCPA provides an opt-out opportunity for certain uses or disclosures of “sensitive personal information” (as defined under the CCPA), ThinkCX uses and discloses such information only for purposes that do not require an opt-out opportunity under the CCPA.

Exercising Rights. To exercise any of the above rights, other than the “right to opt out,” please contact us using the following information and submit the required verifying information, as further described below:

Note that we may need to request additional information from you to verify your identity or understand the scope of your request. We will require you to provide, at a minimum, your name, business email address, and phone number.

You may also designate an authorized agent to make requests on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent. We may still contact you to verify your identity or to confirm that you authorized the agent to make the request. To opt out of sharing for interest-based advertising purposes, our website recognizes Global Privacy Control (“GPC”) signals as a way to opt out when you visit our website with GPC enabled. You can activate GPC by implementing a browser or extension that offers this control. GPC is a third-party tool. More information and instructions on implementing this tool are available here. The opt out tools described would be specific to the browser you use when visiting our website.

How do I get in touch with you?

To exercise any of these rights, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you may have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, you can get in touch at privacy@thinkcx.com or by writing to:

ThinkCX Technologies, Inc.
#200 8661 201 Street
Langley, BC V2Y 0G9 Canada