Privacy policy

This ThoughtFocus Privacy Policy (hereinafter called “Policy”) provides information to the user on the procedures followed by ThoughtFocus and its Affiliates (“ThoughtFocus”, “we”, “us”, “Company”, “our”) to collect/process/utilize/handle/store/disclose/ protect the personal information and sensitive personal information of ThoughtFocus employees, visitors, users of the ThoughtFocus sites, users of ThoughtFocus services or any data of customer/prospective customers including their representatives, the subscribers of ThoughtFocus newsletters, third party suppliers and business partners (“user”, “you”, “your”). This Policy also applies to our services offered through any third-party site or service provider. This Policy applies to all employees of ThoughtFocus and is designed to comply with Applicable Data Protection Laws under the applicable jurisdiction.

ThoughtFocus reserves the right to make necessary changes to this Policy from time to time as it deems appropriate to continue to be compliant with the governmental/regulatory changes, changing requirements of business, or otherwise.

The key terms used in the Policy are defined below and the terms which are not defined below shall have general meaning attributed to it.

1. “Affiliate” shall mean the company or any other entity that, whether directly or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with us.
2. “Applicable Data Protection Laws” for the purpose of this Policy shall mean and include General Data Processing Regulation (EU 2016/679) (GDPR), California Consumer Privacy Act (CCPA) of USA, Health Insurance Portability and Accountability Act of 1996 (HIPAA) of USA, Graham-Leach-Bailey Act (GLBA) of USA, Information Technology Act 2000 of India, Digital Personal Data Protection Act 2023 of India, the Privacy Act (Canada), the Personal Information Protection and Electronic Documents Act (Canada) and any other data protection law which may be applicable (including any amendments, additional guidelines, regulations) from time to time.
3. “GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and means used.
4. “Data”, “Personal Information”, “Personal Data” shall mean any information that relates to an identified or identifiable natural person, an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

This Policy will outline the nature of the Data collected and processed by ThoughtFocus. It will also explain the means of processing and the purpose of processing the Data.

 

I. What kinds of Personal Information/Data do we collect?

ThoughtFocus gathers various forms of Personal Data from our users to optimize the delivery of our services and functionalities. The specific information we collect is contingent upon user interactions with our sites and services, the content of communications, and engagements with third-party entities.

• Direct Identifiers, including but not limited to your unique online identifier, name, alias, social media handle, IP address, username and password, postal and/or e-mail address, phone number.
• Related Identifiers, including but not limited to your date of birth, bank, financial information, insurance policy number.
• Physical Characteristics, including protected characteristics under federal and state law, such as age, sex, race, and ethnicity.
• Commercial Information, including records of products or services purchased, obtained, or considered, and other purchasing and consuming histories and tendencies.
• Biometric Information, such as fingerprints is collected only from ThoughtFocus employees to secure access to ThoughtFocus’ office space.
• Internet or other Electronic Network Activity Information, including browser type and version, browser settings, operating systems and platform, device type, operating information, mobile carrier, page response time, and download errors, with our sites and in communications.
• Geolocation Data, such as your zip code and time zone.
• Communications, Audio, Electronic, and Visual Information, including telephone recordings, electronic communication records, security camera footage from applicable ThoughtFocus properties.
• Professional or Employment-Related Information, such as your work history, salary history, and education history.
• Other details, any other information the user might provide to us voluntarily or as needed to render the services you opted for.

 

II. How we collect Personal Information/Data?

We collect Data through your interactions on our website and through your use of our products/services. While some Data is provided directly to us, some Data is collected by us through the use of a website, interaction therein, and choices and preferences you make. Your privacy setting in the device and the preferences you make while using our website or any product or service, determines the kind of Data shared with us.

We collect Data that you voluntarily provide to us through a website or email, account creation, or any physically filled form, or you voluntarily consent to us collecting the Data from you.

 

III. Purposes for which we process Personal Information/Data:

We use the personal information outlined in a variety of business and commercial purposes, including but not limited to:

• Provide the services you have requested.
• Conduct business dealings with you.
• Fulfil a transaction you requested or service you opted for. Create and manage your account between ThoughtFocus and you or any other Third Party.
• To improve our business operations, systems and process such as to operate the sites, including access management, site administration, internal operations, troubleshooting, data analysis, testing, debugging, research, and statistical purposes.
• Respond to your requests, feedback, or inquiries.
• Employment-related matters like hiring, training, performance management, benefits administration, and payroll management. This includes business purposes such as internal reporting, analysis, and planning.
• Process invoices for our services and manage our accounts (including usage and licensing compliance).
• To perform our duties and establish our rights, as per the commercial contracts executed between you and ThoughtFocus such as Terms of Use or any other agreements for activities not limited to detecting fraudulent and unauthorised usage of this website.
• Comply with laws, regulations, and other legal requirements.
• Comply with relevant industry standards and our policies.
• Operate, evaluate, and improve our business.
• Provide you with information and advertisements about our products, services, services updates and promotions from us or affiliates that may interest you.
• Deliver content tailored to your interests and the way you use the Sites.
• Marketing related activities to promote our services/products.
• Present content in a manner that is optimized for your device.
• Measure and analyze the effectiveness of the sites and services we provide to you. We may conduct surveys or gather feedback from you from time to time to understand the user experience further. We use the data provided by you or collected from you to enhance your usage of this Website or of our services.

 

IV. Who do we share Personal Information/Data with, and why?

We do not sell or rent your Personal Information or share your Personal Information for cross-context behavioral advertising. We may, however, disclose Personal Information for purposes such as:

• With your consent. We may disclose your Personal Information with your consent. We may obtain your consent in writing, email, online, or through “click-through” agreements when you accept the terms of use on our sites, orally, either in person or on the phone, or by other means.
• In a business transfer. We may disclose your Personal Information as part of a potential or actual corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets.
• To non-affiliated third parties, such as service providers and contractors. We may disclose your Personal Information with other parties, such as service providers and contractors, to facilitate your access and use of our sites and services, including but not limited to internet service providers, advertising networks, data analytics providers, governmental entities, operating systems, and platforms, and service providers who provide us a service (e.g., billing, shipping, repair, customer service, auditing, marketing, event organisers, debugging to identify and repair errors that impair existing intended functionality on our sites or services, and/or protecting against malicious, deceptive, fraudulent, or illegal activity).
• To subsidiaries and Affiliates. We may disclose your Personal Information with our subsidiaries and affiliates to further facilitate your use of our sites and services and to ensure the smooth and consistent operations of ThoughtFocus, not limited to identifying and repairing errors that impede intended functionality and to protect against malicious, deceptive, fraudulent, or illegal activity.
• For legal process and protection. We may disclose your Personal Information to satisfy any law, regulation, legal process, or governmental request or where we have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to:
  • Protect our rights or interests, property or safety, or that of others.
  • In connection with claims, disputes, or litigation – in court or elsewhere.
  • Protect us or users of our sites and services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; and
  • Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government.

 

V. How we store your Personal Information/Data?

We take reasonable steps to protect the personal information we collect from being used, lost, or accessed in an unauthorized manner. Access to your data is limited to those employees, contractors, and other third parties who have business and need to know. Associates with access to such data, are subject to the nondisclosure agreements, and only to the extent required to process for the business requirements. The data collected are primarily stored on servers in the US. A secondary data backup may be maintained on computer systems outside the US at ThoughtFocus subsidiaries. ThoughtFocus complies with all Applicable Data Protection Laws of jurisdiction where the Data is stored. We assess privacy risks periodically and take measures to ensure that your personal information is protected and kept confidential. Data collected and stored employ robust encryption methods and hashing techniques that are standard and current in the industry.

 

VI. How long do we retain your Personal Information/Data?

We will only retain your Data for as long as it is necessary to satisfy the purpose for which it was provided by you or collected by us (for example, for the time necessary for us to answer queries or resolve problems or for providing Services or for employment-related matters).

We may retain your Data for a reasonable period after your last interaction with us. When the Data that we collect is no longer required in this way, we destroy or delete it in a secure manner. We may, instead of destroying or erasing your Data, make it anonymous so that it cannot be associated with or tracked back to you. In certain cases, we may have legal or regulatory obligations that require us to retain specific records for a set period of time.

 

VII. How we ensure the security of your Personal Information/Data?

We maintain a variety of physical, technical, and administrative security standards, technologies, and procedures to help protect your Data from loss, misuse, alteration, destruction, or damage to an appropriate level depending on the sensitivity of the information. All Data is secured safely in our database.

ThoughtFocus obtains an ISO 27001:2022 certification, which indicates that we adhere to the highest global information security standards. This certification is the only auditable international standard that defines the requirements for a sound Information Security Management System (“ISMS”) and this certification confirms that ThoughtFocus’ security controls provide an effective framework for protecting your information.

Wherever we collect personal sensitive information online, the Data is encrypted and transmitted to us securely. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the web page.

While we use encryption to protect personal sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to Data. The computers/servers in which we store Data are kept in a secure environment.

Following measures are employed to protect your Data:

• Physical security measures such as restricted access facilities and locked filing cabinets.
• Organizational processes such as limiting access to your personal information to a selected group of individuals.
• Technological measures include electronic security measures for computerized personal information, such as password protection, database encryption, and personal identification numbers.
• Requiring third parties with access to your personal information to protect, secure, and appropriately dispose it off.
• Shredding of documents containing personal information when no longer required as per this Policy.

 

VIII. What are your rights over the Data?

We provide you the ability to exercise specific controls and choices regarding our collection, use, storage, and disclosure of your personal information.

• • Right of correction. You may submit a request that we correct or update the information we have about you.
  • Right to obtain a copy of your Data together with information about how and on what basis that Data is processed.
  • Right to change preferences. You may change your choices for subscriptions, newsletters, and alerts.
  • Right to unsubscribe from ThoughtFocus marketing and advertising. You may choose whether you want to receive marketing and advertising contents from us.
  • Right to restrict processing. In the event you want us to stop using any Data about you due to it being inaccurate, then you may notify us to stop using the Data.
  • Right to anonymize your Data so that it cannot be associated with or tracked back to you.
  • Right to erasure: You may write to us to request that we delete all the data in our database.
  • Right of non-discrimination. You have a right to exercise your rights under this section free of discrimination. ThoughtFocus will not discriminate against you in any way if you choose to exercise your rights under this section.

How to use your rights: You can exercise the aforementioned rights by contacting our Data Privacy Officer. For this purpose, we may request certain information from you for ascertaining your identity and confirming that you are entitled to exercise such rights.

 

IX. How can you opt out of the process?

Unless you ask us not to, we may contact you via email in the future to tell you about new products or services, or changes to this Policy or otherwise for any promotional activity. You may opt-out from receiving such emails in the future as per the instructions in the email.

You may opt out of future contacts from us at any time by contacting us via the email address specified in this Policy, including to get information about your rights over the Data.

We may be required to retain certain Data for compliance, audit, or regulatory purposes, to the extent permitted by the Applicable Data Protection Laws.

 

X. Use of Cookies

ThoughtFocus uses cookies and other similar technologies which are small text files used to store data for the web server to remember you and your device and your preferences and settings. This is done with the sole intention of providing better service, remembering user preference, enabling account login, preference-based marketing, performance analysis of ThoughtFocus and for any other lawful purpose as may be required by the business.

If you do not wish to receive cookies from us, you have access to what information the cookies collect and thus can be edited by you through the settings of the internet browser, limiting the access granted to our cookies. This enables you to withdraw your consent as well by clearing the cookie or blocking cookie. Disabling cookies may impact how you see or use our website.

 

XI. How do we collect, use, and disclose Non-Personal Information?

Non-personal information is data that does not identify you or directly relate to you as an individual. This may include de-identified or aggregated personal information that no longer identifies a specific individual.

We may anonymize any personal information (i.e., render it so that it irreversibly no longer allows the person to be identified directly or indirectly). Such information may be used for a variety of purposes, such as performing services, developing and improving our products and services, and sharing it with third parties and/or business partners for any lawful purposes.

We will obtain your consent if we ever combine non-personal information with any personal information, and such information will be treated as personal information under the Policy.

 

XII. How to Contact Us

Contact our Data Privacy Officer if;

• You have a general question about how ThoughtFocus protects your personal data
• You wish to make a complaint about ThoughtFocus’ use of your data