Privacy and Cookie policy
Effective Date: September 5, 2018.

Think Revolution and its affiliates hereinafter are referred to as “TKR”.
We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person, collected via all websites or apps that post a link to this Privacy Policy (collectively, “the Sites”). This Privacy Policy describes how we handle and protect your personal data in connection with the Sites, in our capacity as data controllers. Please see our Terms of use for more information about our online terms and policies in general.

Information we collect
TKR collects personal data on certain areas of the Sites when you register for or apply for jobs through the TKR Recruitment Portal, register for TKR newsletters and alerts, participate in our alumni activities through our Alumni Center Website, sign up for conferences and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected varies across the Sites and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, and background information required to apply for a job. For instance, by registering for TKR newsletters or alerts, you agree to receive the correspondence to which you have subscribed at the e-mail address that you provided at registration. Only TKR or its agents will contact you using this e-mail address. We will send e-mails to this address related to your registration.

We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected will be associated with any personal data you have provided.

Use of information
The personal data we collect may be used where we have your specific consent to do so, or where TKR has a legitimate interest in or other legal basis for processing such information. In some situations, the collection of personal data may be required for the operation of the Sites or to provide certain services or products. TKR uses your personal data to fulfill your requests for information, process your requests to participate in conferences and events, personalize content that you view or receive on the Sites, evaluate and improve our services, distribute newsletters and alerts to you, recruit and evaluate job applicants, analyze the Sites’ performance and functioning, publish your letters to the editor or comments, prevent fraud, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce TKR’s agreements, and accomplish other purposes you may initiate or request. We may keep any of your personal data on file and use it to contact you.

TKR may use first and third party Cookies and Other Tracking Technologies to manage our Sites and our services and collect analytics about how you use them. The information provided throughout this Privacy Policy about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy for more details regarding our use of cookies.

Our Sites do not collect personal data about your online activities over time and across third party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.

Use of information collected via mobile devices
In connection with our mobile applications, TKR may use third party service providers to analyze non-personally identifiable user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, TKR receives reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, and other events occurring within our apps. TKR also receives reports on certain errors occurring within mobile applications. None of these third party service providers gathers information in a manner intended to identify any particular user personally.

In addition, our TKR Insights app offers a personalized list of recommendations (called “Insights for you”) directing you to TKR content that we think you will find interesting. Recommendations are based solely on what you have viewed in the Insights app. A unique user identifier that is generated by the app helps personalize your app experience and tracks the articles that you read in the app. We do not share your viewing history or trends with other users or any external third parties (i.e., persons or entities that are not affiliates or third party service providers of TKR).

Data recipients and international data transfers
Personal data collected on the Sites may be transferred from time to time to TKR subsidiaries and affiliates and their personnel across our global organization, as well as to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by TKR and our third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by TKR subsidiaries, affiliates and third- party service providers, including the transfer of your personal data to countries other than the one in which you reside. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address below. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.

TKR will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent, whether for such third parties’ own marketing purposes or otherwise, except as follows. TKR may provide access to your personal data to third party service providers engaged by TKR to provide services related to the Sites, provided that such third- party service providers will first agree to maintain the strict confidentiality of such information and provide the same level of data security as provided by TKR.

We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys or contests, or communicating with you. These third party service providers are not permitted to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal requirements.

In addition, we may disclose information about you:

If we are required to do so by law or legal process;
To law enforcement authorities or other government officials;
When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
If disclosure is necessary to protect the vital interests of a person;
To enforce our Terms of use;
To protect our property, services and legal rights;
To prevent fraud against TKR, our subsidiaries, affiliates and/or business partners;
To support auditing, compliance, and corporate governance functions; or
To comply with any and all applicable laws.
We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

User forums
You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. TKR is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.

Link to third-party sites
TKR may provide links to third-party websites or information as a service to our users. If you use these links, you will leave the Sites. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by TKR of the third party, the third- party website, or the information contained therein, and TKR shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

Social networking
The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with TKR. The Sites also may allow you to log in to a TKR account using certain social network account credentials.

By associating your social network account with TKR or logging in to a TKR account using your social network account credentials, you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. We use the information we receive from your social network account in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with TKR and other connected applications and to manage the data that is shared through your account, including information about your activities using our Sites.

If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.

Security
TKR has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized TKR personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, TKR cannot guarantee that unauthorized persons will not obtain access to your personal data.

Data retention policy
TKR retains personal data, as necessary, for the duration of the relevant business relationship. We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, TKR will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.

Children
The Sites are not designed for or directed at children 13 years of age or younger, and TKR does not intentionally collect or maintain personal data about anyone under this age.

TKR Recruitment portal/TKR Recruiting Program/Alumni Center website
Through the TKR Recruitment portal, you can apply for positions with TKR or sign up for a TKR Recruiting Program where you can be notified of any potential job openings or other similar opportunities that might be of interest. The Recruitment Privacy Notice describes more in detail how TKR and our subsidiaries and affiliates handle and protect the personal data that we collect in connection with the recruitment process.

If you are a former TKR employee, you may be eligible to join our Alumni program and have access to the Alumni Center website. The Alumni Center website is accessible only to current and former TKR colleagues and the relevant conditions are set forth in the Alumni Center website.

Your rights
Where granted by local law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.

If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at [email protected] To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.

In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.

You may also unsubscribe from mailing lists or any registrations on any of the Sites. To do so, please either follow instructions on the page of the Site on which you have provided such information, subscribed or registered or contact us at the address provide at the bottom of this Privacy Policy.

Your California privacy rights
Pursuant to California Civil Code Section 1798.83(c)(2), TKR does not share your personal data with third parties for those third parties’ direct marketing use.

If you are a California resident under the age of 18, and a registered user of any of the Sites where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected] Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Consent; changes to Privacy Policy
By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.

Cookie policy
This Cookie Policy explains how and why cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) may be stored on and accessed from your device when you use or visit any website or app that posts a link to this Policy (collectively, “the Sites”). This Cookie Policy should be read together with our Privacy Policy and our Terms of use.

By continuing to browse or use our Sites, you agree that we can store and access Cookies and Other Tracking Technologies as described in this Cookie Policy.

What are Cookies and Other Tracking Technologies?
A cookie is a small text file that can be stored on and accessed from your device when you visit one of our Sites, to the extent you agree. The other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our Sites. This allows our Sites to recognize your device from those of other users of the Sites. The information provided below about cookies also applies to these other tracking technologies. You can find more information at www.allaboutcookies.org and www.youronlinechoices.eu.

How do our Sites use Cookies and Other Tracking Technologies?
TKR uses Cookies and Other Tracking Technologies to identify you and your interests, to remember your preferences, and to track your use of our Sites. We also use Cookies and Other Tracking Technologies to control access to certain content on our Sites, protect the Sites, and to process any requests that you make of us.

To administer our Sites and for research purposes, TKR also has contracted with third-party service providers to track and analyze statistical usage and volume information from our Site users. These third-party service providers use persistent Cookies to help us to improve the user experience, manage our Site content, and analyze how users navigate and utilize the Sites.

First and Third-party Cookies
“First party Cookies” are cookies that belong to TKR and that TKR places on your device. “Third-party Cookies” are cookies that another party places on your device through our Site. TKR may contract with third-party service providers to send e-mails to users who have provided us with their contact information. To help measure and improve the effectiveness of our e-mail communications, and/or to determine whether messages have been opened and links clicked on, the third-party service providers may place Cookies on the devices of these users.

For more information on how these companies collect and use information on our behalf, please refer to their privacy policies as indicated below.

We use the following types of cookies:

Persistent Cookies. We use persistent Cookies to improve your experience of using the Sites. This includes recording your acceptance of our Cookie Policy to remove the cookie message which first appears when you use the Sites.

Session Cookies. Session Cookies are temporary and deleted from your machine when your web browser closes. We use session Cookies to help us track internet usage as described above.

You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Sites. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you direct your browser to our Sites.

The data collected by the Sites and/or through Cookies that may be placed on your computer will not be kept for longer than is necessary to fulfil the purposes mentioned above. In any event, such information will not be kept for longer than one year.

Third-Party Advertising These Cookies collect information about your activities on these and other sites to provide you targeted advertising. We may also allow our third-party service providers to use Cookies on the Sites for the same purposes identified above, including collecting information about your online activities over time and across different websites. The third-party service providers that generate these Cookies, such as Adobe, Google, LinkedIn, and Facebook, have their own privacy policies, and may use their Cookies to target advertising to you on other websites, based on your visit to our Sites.
How do I refuse or withdraw my consent to the use of Cookies?
If you do not want Cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject the setting of all or some Cookies and to alert you when a Cookie is placed on your device. For further information about how to do so, please refer to your browser ‘help’ / ‘tool’ or ‘edit’ section or see www.allaboutcookies.org . Please note that if you use your browser settings to block all Cookies (including strictly necessary Cookies) you may not be able to access or use all or parts or functionalities of our Sites.

If you want to remove previously-stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless and until you adjust your Internet browser setting as described above.

For more information on the development of user-profiles and the use of targeting/advertising Cookies, please see www.youronlinechoices.eu if you are located in Europe or www.aboutads.info/choices if in the United States.

Contact us
If you have any questions about our policies, please contact us at [email protected]

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