Privacy Policy

Introduction

ThinkCX (“ThinkCX”, “us”, “we”, “our”) is a data analytics company that provides commercial marketing solutions (“Solution”, “Solutions”) to our B2B clients.  We contract with Data Supply Partners (“Partners”) to supply us with raw data that we in turn analyze and model for our clients. The purpose of this Privacy Policy is to provide you with information about the data ingestion, collection, and use policies that pertain to the ThinkCX Solutions and ThinkCX websites (“Website”, “Websites”) located at www.thinkcx.com and www.telcochurndata.com.

Website

Our Websites are directed to a B2B audience. We use Google Analytics to provide us with traffic data and insights pertaining to the browsing behaviours of our visitors. Google Analytics uses cookies to derive standard browsing and visitor information.

We may also collect name, company name, email address, and phone number from site visitors, but only when they voluntarily submit that information in order to receive information or request contact from us.  This visitor information is used only for our own internal business operations, and is never sold, rented, distributed, or shared with any other party.

Our Websites may also collect a username and password when a user utilizes the client log-in function. This data is collected in order to verify a user as an authorized user and provide them with access to the Solution.

Through your continued use of the Website and Solutions, you consent to the use and disclosure of your information as described in this Privacy Policy.

The remainder of the information contained in this Privacy Policy pertains to the ThinkCX commercial Solutions.

Solution

The ThinkCX commercial Solutions use consumer data collected by and provided to us by our Partners in the advertising and marketing technology industry. We collect and ingest anonymized data regarding consumers’ online activities over time across non-affiliated websites, mobile applications, or online services for the purpose of using such data to predict consumer behaviour and improve the relevance of advertising messages. 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.

ThinkCX’s business operations are located in Canada, and our data servers are located in Canada and the United States. In using the Solutions, which could potentially be delivered to or accessed from anywhere in the world, information may be transferred across international borders. Be aware that the regulations and laws governing data use in your jurisdiction may be different than in ours.

Business User Data

When a client purchases one or more of our Solutions, we may request their billing address, contact name, and email address in order to be able to invoice correctly. We may use a third party payment provider to collect payments to be made for our fees. The only Information we share with the payment provider is e-mail address, postal address, phone number, and name. Any additional information, such as credit card details, will be requested from the client directly by the payment provider and provided by the client directly to the payment provider. We have no access to such data and do not store credit card details. Client payment records and history will be stored by us, and only accessible to authorized personnel in our organization.

We may also receive from our client the name, email address, user name, and password of each person designated as an authorized user of the Solution. This information will only be used internally to grant access to the Solution, provide technical support, and perform other services directly for the client.

Consumer Data

Our Partners supply us with consumer data that we analyze and model for our clients. The data provided to us is anonymous, non-personally identifiable information (“Non-PII”) and cannot be linked to a person. Our Partner agreements prohibit us from linking data provided to us with Personally Identifiable Information (“PII”) data, or persons directly. In turn, our commercial agreements prohibit our clients or any third party using our Solutions to use our product or service to link the data back to PII or directly to individuals.  We do not use and are not interested in using PII.

The data we use is primarily technical information about the network devices that consumers use, such as a mobile phone, tablet, or computer. We may use operating system, timestamps, device identifier, iOS® Identifier for Advertising, Android™ Advertiser ID, model, manufacturer and OS version of device, session start/stop time, mobile network code/mobile country code, time zone, network status (WiFi, etc.).  We may use IP Address, but in such a way that it cannot be linked or associated with any person, and we do not have access to any databases or tools, either our own or supplied by some third party, that would enable us to form such a linkage or association.

We may also use demographic information, such as the geographic location of the device.

We may use anonymous behavioural data such as interactions with digital advertising (impressions and clicks), and sites visited.

If you choose to connect with a social networking service, we may share information with that service, and that service may share information with us. We may use the information in order to improve the effectiveness and scope of the Solutions we provide to our clients.

We and our Partners may use cookies (a small text file that is stored on a user’s computer or mobile device for record-keeping purposes) and web beacons or pixels (electronic images that deliver cookies and help to count visits) to collect some of the information listed above. Most web browsers (including mobile web browsers) are set to accept first party cookies by default. However, some web browsers (including mobile web browsers) are set to not accept third party cookies by default. You can typically remove or reject cookies by following directions provided in your Internet browser’s help file or in the “Settings” of your mobile device. However, removing cookies may not allow you to take full advantage of all features on publishers’ websites.

We do not collect or use any Personally Identifiable Information, including IMEI, MSISDN, name, email address, phone number, etc.

We never collect or use sensitive data (“Sensitive Information”) such as medical conditions, financial data, religious affiliation, etc…about the users of the devices we track.

Children

Our Websites and Solution are not directed at or developed for persons under the age of 18. We do not knowingly accept information about anyone under the age of 13. If we are made aware that we have received information about someone under 13, we will use reasonable efforts to remove that information from our records.

Data Retention

Raw data supplied by our Partners and used in the production of our Solutions is deleted from our systems within 14 months of receipt. Processed data that is part of the output of our Solutions is retained for as long as is necessary to provide the Solution to our clients.

Partner Data Policies

We may receive additional information about you and/or your device that is publicly or commercially available from our Partners, and combine it with other information we have collected or received. Our Partners have been carefully selected in part because their own privacy policies and practices clearly indicate that they uphold and abide by their regulatory obligations and adequately inform their users about the data they collect, their collection methods, and how they use the data.

However, even though we perform our diligence on our Partners’ use of data, we don’t control the privacy practices of our Partners or any other third-party services. So we encourage you to read the privacy policies of the services before connecting to or using them. If you wish to receive more information on specific Partner data policies, please contact us at the email address provided below.

Data Security

ThinkCX has security measures in place to protect the loss, misuse, and alteration of the information under our control. All the data we hold is protected by multiple layers of physical, electronic and administrative safeguards, to secure it against accidental, unauthorized or unlawful access, use, modification, disclosure, loss, or destruction. However, no method of transmission over the internet or method of electronic storage is 100% secure; therefore, while ThinkCX uses commercially acceptable means to protect your information, we cannot guarantee absolute security.

Disclosure In Certain Cases

In situations where we are obligated by law, we may disclose information in order to investigate, prevent or take action regarding suspected or actual prohibited or criminal activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.

ThinkCX may also transfer information to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via a prominent notice on our Website of any change in ownership or data disclosure.

Opting Out

We respect that 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/

Notice

This privacy policy is subject to change. If we make any substantive changes in the way we use the information under our control, we will post a clear and conspicuous notice on our Websites and in this Privacy Policy.

Last updated: June 2017

If you have any questions about this Privacy Policy or our privacy practices, please email or mail us:

Email: info@thinkcx.com

Address: ThinkCX Technologies, Inc.  #200 – 8661 201 Street, Langley, BC  V2Y 0G9