What does this policy cover?

This policy describes how ThinkCX (also referred to as “ThinkCX “, “we” or “us”) will make use of your data when you visit our website and use the ThinkCX Solutions.

It also describes your data protection rights, including a right to object to some of the processing which ThinkCX carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

What information do we collect?

Our website, customer portal and relationship with you

If you accept our invitation to 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 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, where it can be retrieved by authorized users at our company. We will never share, exchange, loan, distribute, sell, or your data to any other party. 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

No information or data is collected about you by ThinkCX when you use the ThinkCX Solutions.

What information do we receive from third parties?

Our website, customer portal and relationship with you

We collect and process personal data 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 pages viewed, visitor source, and time spent on the site. The visitor IP address is collected to detect the company and geographic location. We only show company visits and automatically filter out all users visiting from residential IP addresses. If you have questions about the data use policies of these third parties, you are encouraged to review them yourself, and can find them here for Google and Pipedrive.

We use the data collected on our website 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. When we uninstall Google and/or Pipedrive, all website visitor data will be deleted.

ThinkCX Solutions

We receive information about you 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 only consumer data in the production of our Solutions, and do not share it with third parties except under the conditions detailed in this Privacy Policy.
Our Partners supply us with device and connection data that we analyze and model for our clients. This data may include:

• IP address
• User Agent
• Device Model
• Unique Device ID
• Geo Location
• Time Stamp/Time Zone
• Carrier
• Bidstream data attached to online advertising bids and auctions
• Mobile app usage data
• Cross Device Graphs
• Aggregated web traffic 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 data 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).
  • Where you give us consent:
    • we may send you direct marketing in relation to our relevant products and services, or other products and services provided by us;
    • we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used;
    • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
  • For purposes which are required by law:
    • In response to requests by government or law enforcement authorities conducting an investigation.

ThinkCX Solutions

We use the collected data to provide market information to our customers. ThinkCX is 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 anonymous data to provide the ThinkCX Solutions.

For the purposes of the ThinkCX Solutions, we generally rely on your consent to process personal data. 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?

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, 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 is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

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 is to a stakeholder or vendor in 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, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to The Chief Privacy Officer, ThinkCX Technologies, Inc., [email protected]

How long will you retain my data?

The data we process for the provision of the ThinkCX solutions is retained in our systems for up to 14 months.

If you ask us to stop processing your data, we may continue processing your data for a short period of time to allow us to implement your request. We also keep a record of the fact that you have asked us not to process your data so that we can respect your request in the future.

What rights do I have?

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.

Opting Out

We respect the choices that consumers have with regards to online privacy, and so we want to make you aware that there are industry resources that consumers can use to manage their visibility to online advertisers:

In Canada, go to http://youradchoices.ca/choices/
In the US, go to http://www.aboutads.info/choices/
In the EU/EEA, go to http://www.youronlinechoices.eu

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 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, or would like to opt out of direct marketing, you can get in touch at [email protected] or by writing to:

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

Version 2 (April 20,2022)