Effective Date: June 11th, 2018
thankU.app cares deeply about the privacy of its visitors and users, and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.
We strongly urge you to read this policy and make sure you fully understand it, before you access or use any of our services.
Capitalized terms which are not defined herein shall have the meaning ascribed to them in our Terms and Conditions.
1. Please read carefully!
This policy describes our privacy practices – what information we collect on our visitors and users, how we collect it, what we do with it, how we protect it, and your rights regarding your information.
2. What information do we collect?
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users:
Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of Users’ contact details (e.g., e-mail address), Users’ mailing details (name, physical mailing address) if they request us to provide them with thankU contactless tags in order to benefit from using our Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists
We collect two types of information: Personal Information (which could be used to uniquely identify an individual) and Non-personal Information (which is non-identifying).
We collect such information regarding our users and visitors, job applicant and anyone else who may provide it to us.
2.2. thankU Jobs Applicant Information
We also collect information that is provided to us by thankU jobs candidates (“Applicants”), when they apply to any of the open positions published through our Website, by e-mail or otherwise (as further described in Section 6 below).
3. How do we collect such information?
There are two main methods we use:
We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website, register a User account, and/or download and use any thankU Apps, use our Services to give tips, and/or make other payments, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 7 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 8 below.
We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as Facebook or Google; when you submit or upload such Personal Information as you use in any of our Services; and/or when you contact us directly by any communication channel (e.g. emails).
We also collect information from third party sources as described in Section 7 below.
When you visit or use our services – you may also provide us with certain information (either automatically through the process of using the Service, or by manually submitting it).
4. Why do we collect such information?
We collect such Non-personal and Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed in Section 9 below);
To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;
To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
To enhance our data security and fraud prevention capabilities;
To consider Applicants’ candidacy for working with Appsanely Ltd. (as further detailed in Section 6 below); and
To comply with any applicable laws and regulations.
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support), or
our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of thankU campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
We collect and use information in order to provide our services and make them better and safer.
We also collect and use information in order to contact our visitors, users and job applicants, and in order to comply with the laws applicable to us.
5. Where do we store your information?
thankU Visitors’ and thankU Users’ Personal Information may be maintained, processed and stored by thankU and our authorized affiliates and service providers in the United States of America, in Europe (including in the United Kingdom), and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
thankU Jobs Applicants Information will be maintained, processed and stored in the United Kingdom, in the applied position’s location(s), and as necessary, in secured cloud storage provided by our Third Party Services.
thankU.app Ltd. is based in the United Kingdom.
thankU affiliates and service providers that store or process your Personal Information on thankU’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
We may store and process Personal Information in the USA, Europe, or other jurisdictions, whether by ourselves or with the help of our affiliates and service providers.ֿ
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Upon request thankU will provide you with information about whether we hold any of your Personal Information. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.
Please note that permanently deleting your thankU account erases all of your information from thankU's databases except data directly related with any transactions on your account. After completing this process, you can no longer use any of your thankU Services, your User account and all its data other than the aforementioned transaction data will be removed permanently, and thankU will not be able to restore your account or retrieve your data in the future. If you contact thankU Support in the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.
6. thankU jobs applications
thankU welcomes all qualified Applicants to apply to any of the open positions published at https://www.thanku.app, by sending us their contact details and CV (“Applicants Information”) through any means provided by us.
We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants Information private and use it solely for thankU’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Please note that thankU may retain Applicants Information submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we can re-consider Applicants for other positions and opportunities at thankU; so we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at thankU.
If you previously submitted your Applicants Information to thankU, and now wish to access it, update it or have it deleted from thankU’s systems, please contact us at firstname.lastname@example.org.
We welcome all qualified job seekers to apply to any of our open positions, by sending us their contact details and CV.
We will use such information solely for our internal recruitment, employment and business purposes.
7. Sharing personal information with third parties
thankU may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
7.1. Third Party Services:
thankU may in the future partner with a number of selected service providers, whose services and solutions will be intended to complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.
thankU is accountable for Personal Information that it receives under the Privacy Shield and subsequently transfers to a third party as described in the Privacy Shield Principles. In particular, thankU remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Information on its behalf do so in a manner inconsistent with the Principles, unless thankU proves that it is not responsible for the event giving rise to the damage.
We may share the information of our visitors, users and their users-of-users with various third parties, including certain service providers, law enforcement officials and application developers.
The information may be shared solely in accordance with this policy.
7.2. Law Enforcement, Legal Requests and Duties:
Where permitted by local data protection laws, thankU may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
7.3. Protecting Rights and Safety:
thankU may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of thankU, any of our Users, or any member of the general public, with or without notice to you.
7.4. Social Media Features and Framed Pages:
Our Services include certain Social Media features and widgets, single sign on features, such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”).These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
thankU, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by thankU, and we therefore cannot ensure its accuracy, completeness or availability). Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however are not stored on your device, but instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.
(Please note that this website is not provided by thankU, and we therefore cannot ensure its accuracy, completeness or availability).
Behavioral Targeting/Re-Targeting: Certain Third Party Services and ad networks may display advertising on our Website, on thankU Apps, or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party Services to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by clicking here (or if you are located in the European Union click here (provided by YourChoicesOnline.eu). Please note this does not opt you out of receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will continue to receive advertising for which you have not opted out.
User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and Services that may be of interest to you. Where we obtain your Personal Information from these third parties, we ensure that such parties are contractually committed to inform you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
These technologies are used mostly for stability, security, functionality, performance and advertising purposes.
You may block, opt-out of or otherwise manage such tracking technologies by yourself, through your browser settings or other sources – but please note that this may adversely affect the way you experience our services.
9. Communications from thankU
9.1. Promotional Messages:
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from thankU or our partners (acting on thankU’s behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify thankU at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.
We may send you promotional messages and content.
You can easily opt-out of receiving promotional messages by contacting us or unsubscribing.
9.2. Service and Billing Messages:
thankU may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not able to opt-out of receiving such Service and Billing Messages unless you are no longer a thankU Visitor or User (which can be done by deactivating your account).
We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.
10. Your rights in relation to your personal information
It is imperative that you have control over your Personal Information. That’s why thankU is taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a thankU Visitor or User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us, or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please mail your request to thankU.app, 15 Bolton Gardens, London SW5 0AL.
We will make all reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations. You may also correct, update or remove certain parts of such Personal Information by yourself, through your User account or User Website settings.
Please note that permanently deleting your thankU account erases all of your information from thankU's databases except data directly related with any transactions on your account. After completing this process, you can no longer use any of your thankU services, your account and all its data other than the aforementioned transaction data will be removed permanently, and thankU will not be able to restore your account or retrieve your data in the future. If you contact thankU Support in the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.
You may request to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information you have stored with us. Just send us an e-mail or fill out our dedicated GDPR form. You may also correct and/or update your information through your account or website settings.
You can delete your Personal Information, other than information directly related you’re your historic transactions, by deleting your entire account.
We will respond to your requests within a reasonable timeframe.
11. Data Retention
We may continue to retain such Personal Information even after you deactivate your User account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.
We may keep your information for as long as your account is active, and longer as needed (for example, if we are legally obligated to keep it longer, or need it to protect our interests).
thankU has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and your payment-related information (e.g. credit card details) are not handled by us or visible to us – when you enter your credit card details in the ThankU app these are processed directly by PayPal, Apple / Stripe, and other trusted payment processing services as presented to you. The only payment-related information we store is that related to your being paid through the use of our Services, which at the current time is only if you have selected to be paid to a UK bank account, in which case we store your account name, account number, and sort code.
Regardless of the measures and efforts taken by thankU, we cannot and do not guarantee the absolute protection and security of your Personal Information you upload, publish or otherwise share with thankU or anyone else.
We therefore encourage you to set strong passwords for your User account, and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas on our Services are less secure than others, and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at email@example.com.
We are committed to securing your personal information, and use various security measures to better protect it.
However, as we can’t guarantee absolute protection – we encourage you to be careful, set a strong password for your account, and avoid submitting any sensitive information which, if exposed, could cause you major harm.
13. Public forums and user content
Our Services may in the future offer publicly accessible blogs, communities and support forums. Please be aware that any information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us at: firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any information (or use any posting means to post information) you don’t wish to publicize on these platforms.
Avoid posting any information to any of the public areas on our Services if you don’t want it to become publicly available.
14. Updates and interpretation
Any heading, caption or section title contained herein is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.
We may change this policy at any time. We will notify you of any material changes.
Translated (non-English) versions of these terms are provided for convenience only.
15. Contacting us
You may also contact us by mail at: Appsanely Ltd., 15 Bolton Gardens, London SW5 0AL, United Kingdom.