Privacy Policy

PRIVACY POLICY

Effective: April 13,2017

Overview

Welcome to the website of Group Systems Corporation d/b/a ThinkTank (“ThinkTank,” “we,” “us” or “our”).  This Privacy Policy describes ThinkTank’s collection, use and disclosure of your information and content in connection with our website and service, including without limitation, the ThinkTank.net website and other websites that link to this Privacy Policy (the “Site(s)”), and the ThinkTank application and service (the “Service”).

This Privacy Policy describes how we collect, use and disclose personal data and other information that you provide when using our Site or Service. Through your use of our Site or Service, you consent to the collection, transfer, processing, storage, disclosure and other uses of your information as described in this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, do not use our Site or Service.

Remember, maintaining data privacy and security is a shared responsibility. Information you upload to the Service may be viewed, used and copied by certain other users, as described in detail below. It is your responsibility to know what information you disclose through the Site or Service, and any other legal or organizational obligations you may have regarding that information. Please read this policy carefully to understand how your information is shared and other choices you have regarding your information.

Other Agreements

This Privacy Policy is part of the Terms of Use for our Site and Service, and any enterprise agreement to which you are a party. This Privacy Policy may include certain words and phrases that are defined in those agreements.

Third Parties

This Privacy Policy applies only to ThinkTank. To the extent the Site or Service may link to websites, applications and services owned or operated by a third party (including, without limitation, those of your employer) this Privacy Policy does not apply. Please review any applicable privacy statements or policies before providing your Personal Data (defined below) to third parties.

If you are accessing the Site or Service through an account linked to, created or maintained by your employer or enterprise, that party may control aspects of your account, and may be able to monitor or access your Personal Data and information related to your use of the Site or Service. Your employer or enterprise reserves the right to terminate your access to and use of the enterprise portion of your account. We are not responsible for actions of your enterprise with respect to your account or your information. See our Terms of Use or your enterprise agreement for more information and any additional terms relating to the rights and obligations of employers and ThinkTank regarding your account.

DATA WE COLLECT & HOW WE USE IT

When you visit our Site, register, or otherwise use the Service, we may collect information that, either alone or in combination with other information, can be used to identify you individually (“Personal Data”). For example, you are likely to provide Personal Data when you register on our Service or complete a contact form on our Site.  Please note that any User Content (as defined in our Terms of Use) may contain Personal Data or confidential information. Please be mindful of any User Content you choose to upload.

We typically collect and use your data in the following ways:

When you join as a guest user. When you use our Service as a guest user, we may collect your email address and user name. As discussed in detail below, some of your registration information may be visible to other users.

When you register with our Service. When you register for a permanent account on our Service, we may collect your name, employer or enterprise account holder, and email address and ask you to create a password. You may also provide, if you choose, additional contact information, or other information available to you. This information may be visible to other users, depending on your account settings.

When you access our Site or Service. When you access our Site, or use our Service, we may collect your IP address, operating system information, web browser and version number, ISP or wireless internet provider, and other information about your connection to the internet. We may also collect aggregated user data regarding your use of the Site or Service, such as the number of visitors, and other frequency and patterns of use, tag usage, and usage trends (“Aggregated Data”). We may collect this type of information to analyze overall trends to help us improve the Site and Service, help us understand usage, and to track aggregate data about our user base.

Cookies and similar technologies. Our Site and Service may use cookies, web beacons and similar digital tracking technologies. Cookies are small data files that are transferred to your hard drive when your browser settings permit the acceptance of cookies. Similar technologies, such as web beacons or pixel tags function using small files, such as a GIF or PNG, which are opened on a page, ad, or in an email. The request for these files from a server reveals certain information, such as your browser type, IP address, and other information.

We generally use cookies and similar technologies for basic site operations, such as maintaining an active session, to provide security, and store your preferences. Our Site and Service may also use cookies or other technologies provided by analytics services such as Google Analytics to help us better understand how our Site and Service are used. To learn more about the cookies and similar tracking technologies we use on our Service, please read our Cookie Policy.

HOW WE SHARE USER DATA

We will share your Personal Data and User Content with other users only in accordance with the applicable account preferences set by you when you use the Site or Service, or as otherwise set forth below.

Information shared with your employer/enterprise. If you are an enterprise user, certain User Content or Personal Data may also be shared with your enterprise and/or users in your enterprise, regardless of your choices. For example, your enterprise and its enterprise users may have the ability to view your account usage, monitor the content you upload to the Service, and access or monitor your account and associated Personal Data.

Information shared with other users. The Service allows you to post, upload and share User Content with other users. In addition, certain Personal Data, such as your name, job title, company name, and/or email may be visible to other users during your use of the Service or in materials created through or by the Service. As described below, you may choose to make anonymous comments and posts, in which case your Personal Data may be obscured. Please be aware that any User Content you upload and share through the Service may contain confidential information or Personal Data. When you upload User Content, you consent to the disclosure of such information to the class of users you choose, and you represent and warrant that you have the right to do so.

Legal disclosures. We may release your Personal Data or User Content or other information you have posted or provided through the Site or Service when necessary or appropriate to comply with the law; cooperate with law enforcement or national security requirements; respond to lawful requests; protect the rights of ThinkTank, other ThinkTank users or enterprises, and third parties; or to enforce our Terms of Service. However, in doing so, we may: (i) dispute demands for release to the extent we believe, in our sole discretion, they are unwarranted, illegitimate or overbroad; and (ii) when appropriate and allowed, we will notify you of any requests for release.

Other disclosures. In the event, some or all of our assets are acquired by or merged with a third-party entity, we may transfer or assign Personal Data and User Content in connection with such transaction. Your Personal Data and User Content will still be subject to the terms of the then-current Privacy Policy. We may also share Personal Data and User Content and other information with entities under our control or under common control with ThinkTank (our affiliates), and with vendors providing services to us (such as vendors storing or serving information and content or creating or maintaining our equipment or software). Finally, we may also provide Personal Data and Aggregated Data to certain third-party companies and individuals we work with to help us provide, analyze, and improve the Site or Service.

YOUR CHOICES

It is possible for you to visit our Site without providing Personal Data, but you may not be able to access certain features and content. Through your account settings menu or choices provided to you when you post User Content, you may change certain preferences with respect to your Personal Data and User Content. In some cases, you may be able to post User Content without disclosing your identity, however, please note that your participation on the Service will still be identifiable, even if your User Content is submitted anonymously.  We strive to respect your choices with regard to sharing of User Data with other users, however, we cannot guarantee that all Personal Data you share will remain anonymous. Note that we or certain administrators may be able to determine which users make comments or post certain User Content, and we reserve the right to disclose any personal information we have linked to content that we believe, in our sole discretion, violates this Policy or our Terms.

To the extent required by law, you may choose to opt out of sharing with any other parties with whom we may share your Personal Data; however, you may be unable to use the service or certain features if you wish to limit such sharing. Further, you may, to the extent you expressly consent to our sharing of your Personal Data with others, opt out of having your information provided to third parties for marketing or other commercial purposes, and opt out of additional communications from us. To do so, simply unsubscribe from the email newsletters or similar communications by clicking on the unsubscribe link in the email.

ACCESSING, CORRECTING AND DELETING YOUR INFORMATION

You have the ability to access, update, change, and delete your Personal Data as set forth in this section. In some cases, you may be able to modify User Content, depending on the settings of the administrator. In some cases, we may retain copies of the original information, to the extent required by law, to protect ThinkTank’s rights, or if it is not reasonably feasible to remove it. To access or update your user profile or manage your User Content, please login to your account and visit your account settings page.

Accounts will be deactivated upon your request (or in some cases, deactivated or suspended by us or your enterprise, as described in our Terms of Use). Please note, following the termination or closure of your account, we may retain information for a reasonable amount of time should you wish to reactivate your account, and we may retain certain information indefinitely if we believe that it is necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

SECURITY

We have implemented reasonable security measures to safeguard the Personal Data you provide us. However, please keep in mind that we cannot be liable for the actions of third parties to whom we may transfer your Personal Data in accordance with this Policy, or third parties to whom you directly provide your Personal Data. Furthermore, please remember that “perfect security” does not exist on the Internet, and accordingly we cannot provide any guarantee that your Personal Data or any other information you provide us will remain secure.

INTERNATIONAL TRANSFERS OF USER DATA

If you are accessing our Site or Service from outside of the United States, any information provided will be transferred to us or our service providers in the United States. Regardless of where your information is collected or transferred, the information will be treated in accordance with this Privacy Policy. You consent to such transfer through your continued use of our Site or Service.

U.S.-SWISS AND U.S.-EU PRIVACY SHIELD

We comply with the U.S.-Swiss and the U.S.-EU Privacy Shield Frameworks (collectively “Privacy Shield”). The Privacy Shield frameworks are set forth by the U.S. Department of Commerce and relate to the collection, use, and retention of personal data collected from users in Switzerland and the European Union. We adhere to the Privacy Shield principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse/enforcement/liability, and to the extent applicable, the supplemental principles, all of which are available at https://www.privacyshield.gov/article?id=Requirements-of-Participation. In the event we transfer data to a third party, we are responsible for ensuring that third party’s compliance with the Privacy Shield principles. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the Privacy Shield, ThinkTank is potentially liable.

We encourage EU (and U.S.) users to contact us if you have any concerns about our compliance with this Privacy Policy and the Privacy Shield Framework. Any questions or concerns may be sent to the address or email below. We will respond to complaints from EU and Swiss/ citizens within 45 days. If any complaints by EU/Swiss residents against ThinkTank cannot be resolved informally, we have agreed to participate in the JAMS dispute resolution procedures pursuant to EU-U.S. Privacy Shield principles. EU and Switzerland residents with unresolved complaints may refer them to JAMS as described at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim/. If required by law, we will work with the appropriate panel of DPAs or individual DPA in the EU to resolve disputes. Under certain circumstances, these dispute resolution processes may result in your ability to invoke binding arbitration. As a U.S. company, we are also subject to the investigatory and enforcement power of the FTC regarding our compliance with the Privacy Shield Framework and this Privacy Policy, and users may direct complaints to the FTC in the event the dispute resolution processes described above is unsatisfactory.

If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov. You may view the list of Privacy Shield companies here: https://www.privacyshield.gov/list

LIMITATION OF LIABILITY

By providing us with any Personal Data you expressly and unconditionally release and hold harmless ThinkTank, its parents, subsidiaries, affiliates, related companies and their respective shareholders, owners, members, directors, officers, employees and agents (collectively, the “Releases”) from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected Personal Data. In addition, we cannot be held liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your Personal Data by any third parties who receive your Personal Data. We make no representations or warranty regarding any third party’s use, collection or disclosure of your Personal Data.

CONTACT US

ThinkTank, 1433 17th St. Suite 200, Denver, CO, 80202, attn: Legal, or at support@thinktank.net.

CHANGES TO THIS PRIVACY STATEMENT

We may revise this Privacy Policy from time to time. We will post the current policy on our Sites, so please check back regularly to ensure you are aware of the most current policy. By continuing to access or use the Site or Service after those changes become effective, you agree to be bound by any revised Privacy Policy.