THRIVE CONSULTING LLC
WEBSITE PRIVACY POLICY
Effective date: [DATE]
THRIVE Consulting LLC (“THRIVE,” “we,” “us” or “our”) operates the website at www.thrive-co.com (the “Site”). This policy explains what personal information we collect through the Site, why we collect it, who we share it with, how long we keep it, and the choices and rights available to you.
This policy applies only to personal information collected through the Site. It does not apply to personal information we collect or handle in the course of providing consulting services to our clients, or through any other channel.
Contact details are in Section 13.
Contact form. Your name, your email address, and the content of your message, together with anything else you choose to include in it.
Newsletter signup. Your email address.
Please do not submit sensitive personal information, such as government identification numbers, financial-account information, health information, or information about another person, through the Site contact form unless THRIVE specifically requests it through an appropriate channel.
The Site does not offer ecommerce or online-purchasing functionality, does not use advertising or ad-targeting pixels, and does not accept job or candidate applications. We do not sell your personal information.
The Site does not set cookies and does not use similar tracking technologies. We do not use advertising or ad-targeting pixels, social-media tracking tools, or third-party tracking scripts. Site analytics are provided through Cloudflare’s cookie-free, aggregate analytics, which measure Site usage without storing cookies or other identifiers on your device.
If we introduce cookies or other technologies that require consent in the future, we will update this policy and, where required by applicable law, request your consent at that time.
Because the Site does not collect personally identifiable information about your online activities over time and across third-party websites or online services, and does not allow third parties to do so, the Site does not respond to browser “Do Not Track” signals.
We do not permit third parties to collect personally identifiable information about your online activities over time and across different websites or online services when you use the Site.
We use the information described above for the purposes set out in the table below. The third column applies to visitors in the EEA and the UK and identifies the legal basis on which we rely.
| Purpose | Information used | Legal basis (EEA and UK visitors) |
|---|---|---|
| Responding to an inquiry you submit through our contact form | Name, email address, message content | Our legitimate interests in responding to business inquiries about our services (Art. 6(1)(f)) |
| Business development follow-up relating to your inquiry | Name, email address, message content | Our legitimate interests in following up on inquiries and developing our consulting business (Art. 6(1)(f)), subject to applicable direct-marketing rules; your consent where consent is required (Art. 6(1)(a)) |
| Sending our newsletter | Email address | Your consent (Art. 6(1)(a)) |
| Understanding how the Site is used so that we can maintain and improve it | Aggregate, cookie-free analytics that do not identify you | Our legitimate interests in operating and improving the Site (Art. 6(1)(f)) |
| Operating, securing and troubleshooting the Site | Technical and usage information described in Section 2.2 | Our legitimate interests in keeping the Site secure, available and working correctly (Art. 6(1)(f)) |
| Complying with legal obligations, and establishing, exercising or defending legal claims | Any of the above, as relevant | Compliance with a legal obligation (Art. 6(1)(c)); or our legitimate interests in protecting our legal position (Art. 6(1)(f)) |
Providing information through the Site is voluntary. If you do not complete the contact form, we may not be able to respond to your inquiry; if you do not provide an email address, we cannot send you the newsletter.
Newsletter. We send the newsletter only to people who have signed up for it. Every newsletter email contains an unsubscribe link, and you can also unsubscribe at any time by emailing privacy@thrive-co.com. We act on unsubscribe requests promptly.
Business development follow-up. If you contact us through the contact form, we may follow up with you about our consulting services in connection with your inquiry. You can ask us to stop at any time by replying to any message or emailing privacy@thrive-co.com. Where applicable law requires consent before sending marketing emails, we will send them only with your consent or where we are otherwise permitted to do so.
Suppression records. If you opt out, we keep a record of your request so that we can continue to honor it.
Opting out of marketing does not stop us from replying to an inquiry you have sent us, or from sending you administrative messages about the Site.
We do not sell your personal information. We may share personal information with the following categories of recipients, as appropriate:
Website hosting and platform providers, which host the Site and deliver it to you.
Cloudflare, which hosts the Site and provides cookie-free, aggregate analytics.
HubSpot, which processes contact form submissions and newsletter sign-ups on our behalf.
Email and newsletter service providers, which store our correspondence and send the newsletter on our behalf.
IT, security and professional service providers, including our legal and accounting advisers.
Courts, regulators, law enforcement and other government authorities, where we are required to do so by law or where it is necessary to establish, exercise or defend legal claims.
A buyer or successor, in connection with a merger, acquisition, financing or sale of all or part of our business, subject to appropriate confidentiality protections.
THRIVE is based in the United States. Personal information collected through the Site may be stored and processed in the United States and in other countries where THRIVE or its service providers operate. Data-protection laws in those countries may differ from those in your country.
EEA and UK. Where applicable EU or UK data-protection law requires safeguards for a transfer or disclosure of personal information by THRIVE to a recipient outside the EEA or United Kingdom, THRIVE will use a transfer mechanism or safeguard recognized under applicable law. [SPECIFY THE MECHANISM ACTUALLY RELIED ON ONCE VENDORS AND DATA FLOWS ARE CONFIRMED. Article 13(1)(f) GDPR and the corresponding UK transparency law require the final notice to identify the relevant safeguards and the means to obtain a copy, so this bracket must be resolved before publication.] You may request information about applicable safeguards by emailing privacy@thrive-co.com.
Singapore. Where the transfer requirements of the Personal Data Protection Act 2012 apply to a transfer of personal data out of Singapore, we take the steps required to ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection comparable to that under the Act.
We keep personal information only for as long as we need it for the purposes described in this policy.
Contact form submissions and related business-development correspondence: up to [24 months] after our last substantive contact with you, unless we need to keep it longer because you become a client or because of a legal claim.
Newsletter signup information: until you unsubscribe or we stop sending the newsletter. If you unsubscribe, we keep a minimal suppression record for as long as necessary to honor your request.
Analytics data: our Site analytics are aggregate and do not contain personal information, so no personal-data retention period applies.
Newsletter subscription data: for as long as you remain subscribed; if you unsubscribe, we keep your email address on a suppression list only as needed to honor your choice.
We may keep information for longer where we are required to do so by law, or where it is needed to establish, exercise or defend legal claims.
You may unsubscribe from the newsletter as described in Section 5. You may also contact us at privacy@thrive-co.com with a request concerning personal information submitted through the Site. We may need to verify your identity, and we will respond to requests as required by applicable law.
Subject to the conditions and exceptions in applicable law, you have the right to:
request access to the personal data we hold about you, and a copy of it;
have inaccurate personal data corrected and incomplete data completed;
have your personal data erased in certain circumstances;
restrict our processing of your personal data in certain circumstances;
receive certain personal data in a structured, commonly used, machine-readable format, and have it transmitted to another controller;
object to processing based on our legitimate interests, and to object to direct marketing at any time; and
withdraw your consent at any time where we rely on consent, without affecting the lawfulness of processing carried out before you withdrew it.
To exercise any of these rights, email privacy@thrive-co.com. You also have the right to lodge a complaint with your local data protection supervisory authority. In the UK, that is the Information Commissioner’s Office (ico.org.uk). We would appreciate the chance to address your concerns first.
This section is provided under the California Online Privacy Protection Act. The categories of personally identifiable information we collect through the Site, and the categories of third parties with whom we may share it, are described in Sections 2 and 6. THRIVE does not currently maintain a dedicated process through which Site visitors can review or request changes to personally identifiable information submitted through the Site. You may contact privacy@thrive-co.com with privacy questions concerning personal information you submitted through the Site. Our disclosures about Do Not Track signals and third-party collection across sites are in Sections 3.1 and 3.2.
Subject to applicable conditions and exceptions under the Singapore Personal Data Protection Act 2012, you may:
request access to personal data about you that is in our possession or under our control, and information about the ways in which it has been used or disclosed in the year before your request;
request correction of an error or omission in that personal data; and
withdraw your consent to our collection, use or disclosure of your personal data for any purpose, on giving reasonable notice. We will tell you the likely consequences of withdrawing consent.
Requests may be sent to our Data Protection Officer at [SINGAPORE DPO NAME OR JOB TITLE AND CONTACT DETAILS]. If you are not satisfied with our response, you may contact the Personal Data Protection Commission (pdpc.gov.sg).
The Site is intended for a business audience and is not directed to children. We do not knowingly collect personal information from children through the Site. If you believe a child has provided us with personal information through the Site, please contact us at privacy@thrive-co.com, and we will take appropriate steps to address it.
The Site may contain links to websites operated by other organizations. We are not responsible for the privacy practices of those websites. We encourage you to read their privacy policies before providing information to them.
We may update this policy from time to time. When we do, we will post the revised policy on the Site and update the effective date at the top. Where required by applicable law, we will provide additional notice of material changes. We encourage you to review this policy periodically.
For any question or request about this policy or your personal information:
THRIVE Consulting LLC
privacy@thrive-co.com
Representative in the European Union: [EU ART. 27 REPRESENTATIVE NAME, ADDRESS AND CONTACT INFORMATION]
Representative in the United Kingdom: [UK REPRESENTATIVE NAME, ADDRESS AND CONTACT INFORMATION]
Data Protection Officer (Singapore): [SINGAPORE DPO NAME OR JOB TITLE AND CONTACT DETAILS]
Effective date: [****DATE****]