This Privacy Statement describes the personal data we collect and/or process (which may include collecting, organizing, structuring, storing, using, or disclosing) to provide products and services offered directly by Thrive Talent (“Thrive”), including Thrive’s websites, workshops, programs, content, and messaging platform.
What Personal Data Do We Receive?
Personal data is any information from or about an identified or identifiable person, including information that Thrive can associate with an individual person. We may collect, or process on behalf of our customers, the following categories of personal data when you use or interact with Thrive Products:
- Account Information: Information associated with an account that licenses Thrive Products, which may include administrator name, contact information, account ID, billing information, and account plan information.
- Profile and Participant Information: Information associated with the Thrive profile of a user who uses Thrive Products under a licensed account or that is provided by an unlicensed participant, which may include name, display name, picture, email address, phone number, job information, stated locale, user ID, or other information provided by the user or their account owner.
- Contacts and Calendar Integrations: Contact information added by accounts or their users to create contact lists on Thrive Products, which may include contact information a user integrates from a third-party app. Users can also integrate their calendars from other services with their Thrive profile or account.
- Settings: Information associated with the preferences and settings on a Thrive account or user profile, which may include audio and video settings, recording file location, screen sharing settings, and other settings and configuration information.
- Registration Information: Information people provide when registering for a Thrive workshop, program or course, which may include name and contact information, responses to registration questions, and other registration information requested by Thrive.
- Device Information: Information about the computers, phones, and other devices people use when interacting with Thrive Products, which may include information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
- Workshop, Program, and Course Content and Context: Content generated in workshops, programs or courses that are hosted on Thrive Products, which may include audio, video, in-session messages, chat messaging content, transcriptions, written feedback, responses to polls and Q&A, and files, as well as related context, such as invitation details, meeting or chat name. Content may contain your voice and image, depending on the account owner’s settings, what you choose to share, your settings, and what you do on Thrive Products.
- Product and Website Usage: Information about how people and their devices interact with Thrive Products, such as: when participants join and leave; whether participants sent messages and who they message with; performance data; mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off), and other user inputs that help Thrive to understand feature usage, improve product design, and suggest features; which third-party apps users add to a meeting or other Product and what information and actions the app is authorized to access and perform; use of third-party apps; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with Thrive’s websites, including what pages they accessed, their interaction with the website features, and whether or not they signed up for a Thrive Product.
- Communications with Thrive: Information about your communications with Thrive, including relating to support questions, your account, and other inquiries.
- Information from Partners: Thrive obtains information about account owners and their users from third-party companies, such as market data enrichment services, including information about an account owner’s company size or industry, contact information, or activity of certain enterprise domains. Thrive may also obtain information from third-party advertising partners who deliver ads displayed on Thrive Products, such as whether you clicked on an ad they showed you.
How Do We Use Personal Data?
Thrive uses personal data to conduct the following activities:
- Provide Thrive Products and Services: To provide Products, features, and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, including to customize Thrive Product features and recommendations for accounts or their users. Thrive also uses personal data, including contact information, to route invitations and messages to recipients when people send invitations and messages using Thrive Products. This may also include using personal data for customer support, which may include accessing files and messages, at the direction of the account owner or their users. We also use personal data to manage our relationship and contracts with account owners, including billing, compliance with contractual obligations, and related administration.
- Product Research and Development: To develop, test, and improve Thrive Products, including, for example, content-related features (such as background filters), and to troubleshoot products and features.
- Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, detect, investigate, and prevent malicious conduct or unsafe experiences, address security threats, protect public safety, and secure Thrive Products.
- Communicate with You: We use personal data (including contact information) to communicate with you about Thrive Products, features, and services, including product updates, your account, and changes to our policies and terms. We also use your information to respond to you when you contact us.
- Legal Reasons: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Terms of Service or policies.
Thrive uses advanced tools to automatically scan content for the purpose of detecting and preventing violations of our terms or policies and illegal or other harmful activity, and its employees may investigate such content where required for legal, safety, or security reasons.
How Do We Share Personal Data?
Thrive provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):
- Resellers: If an account owner licensed or purchased Thrive Products from a third-party reseller of Thrive Products, the reseller may be able to access personal data and content for users, including meetings, webinars, and messages hosted by the account owner.
- Vendors: Thrive works with third-party service providers to provide, support, and improve Thrive Products and technical infrastructure, and for business services such as payment processing. Thrive may also work with third-party service providers to provide advertisements and business analytics regarding Thrive Products. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Thrive or as required by law.
- For Legal Reasons: Thrive may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers’ rights and property; and (6) resolve disputes and enforce agreements.
- Marketing, Advertising, and Analytics Partners: Thrive uses third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using Thrive Products and our website; to provide advertising and marketing for Thrive Products, including targeted advertising based on your use of our website; and to show you third-party advertising within Thrive Products. These third-party partners may receive information about your activities on Thrive’s website through third-party cookies placed on Thrive’s website. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool, available Cookies Settings. Where required by law, Thrive will first obtain your consent before engaging in the marketing or advertising activities described.
- Corporate Affiliates: Thrive shares personal information with corporate affiliates, such as SDI Consluting, Inc., to provide integrated and consistent experiences across Thrive Products (such as enabling a user to access custom content) to detect, investigate, and prevent fraud, abuse, and threats to public safety.
- Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Thrive’s business or assets, including in connection with bankruptcy or similar proceedings.
Who Can See and Share My Personal Data When I Use Thrive?
When you send messages or join workshops and programs on Thrive, other people and organizations, including third parties outside the workshops, programs, or messages, may be able to see content and information that you share:
- Account Owner: An account owner is the organization or individual that signs up for a Thrive account. Typically, an account owner designates one or more people (called an “administrator”) to manage their account and can grant privileges to users on the account. Depending on their license with Thrive, the account owner can authorize additional users on their account, and the account owner can create and/or access the profile information for all users on their account. The account owner and their users can invite others (including guests not on their account) to workshops or programs hosted on their account.
Thrive gives account owners controls and features that they can use to determine whether certain types of content can be used, for workshops and programs hosted on their account. Depending on their settings, account owners and the people they designate can access personal data for people who join workshops and programs on their account or send messages to users on their account. Specifically, account owners may have access to:
- Account Usage:
- Product Usage: Information about how people and their devices interact with their account, which may include who sent messages to their users in chat, email addresses, IP addresses, device information, and other information about who joined workshops, programs, courses, or messaging on their account, whether users viewed or downloaded content, how long people participated in their content, the time a message was sent, and other usage information and feedback metrics.
- Participant List: Information about the participants in a Thrive workshop, program, course or chat, which may include name, display name, email address, phone number, and participant or user ID.
- Registration Information: Information provided during registration for a workshop, program, or course hosted by the account.
- Thrive Chat Out-of-Session Messages: If enabled on their account, account owners can see information about who sent and received out-of-session messages to users on their account along with information about the message (for example, date and time, and number of participants). Depending on their settings, account owners also can see sender and receiver information, and other messaging data, along with the content of messages sent to and from users on their account.
- In-Session Messages: Account owners can see sender and receiver information, along with the content of messages sent to and from users on their account, in the following circumstances:Messages sent to Everyone in a workshop that is recorded
- Messages sent to panelists in a program that is recorded
- Direct messages if the account owner has enabled archiving
- Polling, Q&A, and Feedback: Account owners can see information about who provided responses to their polls, Q&A, or post workshop or program feedback requests, including name and contact information, together with the responses or feedback, unless responses are submitted anonymously.
- Facilitators and Participants: Facilitators and other participants may be able to see your email, display name, and profile picture. Facilitators and participants can also see content or messages sent to Everyone or to them directly, and files, whiteboards, or other information shared during a session. Facilitators may also be able to see responses to Q&A and polls generated during the session.
- Third-Party Apps and Integrations:
- Account owners can choose to add third-party apps to their account and the Thrive Products they use, including via use of the Thrive App Marketplace, and they can also control whether their users can add and use specific third-party apps. Account owners and their users and guests can share your personal data and content with third-party apps and integrations they approve, which may include all of the personal data available to account owners, hosts, and participants listed above, such as account information, profile and contact information, registration information, participants list, settings, content, product usage, and device information.
- Personal information shared by account owners and users with third-party apps and integrations is collected and processed in accordance with the app developers’ terms and privacy policies, not Thrive’s.
- Account Usage:
How to Contact Us
We retain personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.
The criteria used to determine our retention periods include the following:
- The length of time we have an ongoing relationship with you and provide Thrive Products to you (for example, for as long as you have an account with us or keep using our Products);
- Whether account owners modify or their users delete information through their accounts;
- Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).