PRIVACY POLICY

Last revised on May 24, 2018.

This Privacy Policy (“Policy”) describes Thrive TRM LLC’s (“THRIVE”) practices for collecting, using, sharing, and protecting information relating to identifiable people.

Collection and Processing of Your Personal Data

Personal data means information that identifies you as an individual or from which you may be identified.  Non-personal information means information that does not directly identify you. We collect both types of information about you.  The following provides some examples of the type of information that we collect and what we use that information for:

Context Types of Data, Purpose for Collection, and Use of Data
Business Contact Information We collect business contact information, and billing information, from our clients and our potential clients for a legitimate business purpose.  We use this information in order to provide products, services, or information about our products and services.
Client Data Clients can use the THRIVE platform to organize information that relates to candidates or prospective candidates.  Information that is uploaded by our clients, or is collected by our clients, is used only by THRIVE to provide service to our clients.  Our clients control how that information is collected, used, shared, and processed.
Email Interconnectivity If you receive email from us, we use certain tools to capture data related to when you open our message or click on any links or banners it contains. We may also take the information in your emails and add it to our contacts.
Employment If you apply for a Thrive job posting, or become an employee at Thrive, we collect information necessary to process your application or to further the employment relationship.  This may include, among other things, your Social Security Number.
Feedback/Support If you provide us feedback or contact us we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.
Mailing List When you sign up for one of our mailing lists we may collect your email address or postal address.
Mobile Devices We collect information from mobile devices such as unique identifying information broadcast from devices when visiting our website.
Profile We collect your name and other information in order to allow you to create a profile.  To the extent that you engage in discussion groups or forums information relating to your profile (and other information that you insert in those forums) may be viewed by others.
Surveys With survey participation, we collect information provided through the survey.  If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of information.
Web logs We collect your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when using the Internet), domain name, click-activity, referring website, and/or a date/time stamp for visits.
Cookies and first party tracking We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed.  We use both session cookies (which expire once a web browser is closed) r) and persistent cookies (which stay on a device until deleted). Among other things, cookies allow us to provide a more personal and interactive experience and to improve our marketing efforts. Persistent cookies may be removed by following instructions provided by the browser.  If cookies are disabled some areas or features of our websites may not work properly.

Use of Information

In addition to the purposes and uses described above, we may use personal information in the following ways:

  • To identify you when you visit our websites.
  • To provide the products and services you request.
  • To improve our services and product offerings.
  • To conduct analytics.
  • To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
  • For internal administrative purposes, as well as to manage our relationship with you.
  • To, in an aggregated or anonymized form, generate industry reports about trends such as trends in hiring and compensation.

When we collect information on our own behalf, as discussed in the sections above, our processing is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.  When we receive information on behalf of our client, our client is responsible for identifying the purpose for which the information was collected.

Sharing of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

  1. Affiliates and Acquisitions. Companies affiliated with THRIVE may use the information internationally in connection with processing your inquiries, providing services, and improving our products and services.  In limited situations we may also share Business Contact Information that we collect with one of our affiliated companies so that they can provide you with information concerning the products or services that they provide.  We may also share your information if another company acquires our company, business, or our assets.
  2. Clients. With regard to Client Data, THRIVE’s clients determine what (if any) additional third parties may receive such information.
  3. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  4. Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with a request.
  5. Public. We may provide the opportunity to post comments, or reviews, in a public, or semi-public, forum.  If you decide to submit information on these pages, that information may be publically available.
  6. Service Providers. THRIVE may provide personal data to third parties that act as agents, consultants or contractors to perform tasks on behalf of and under THRIVE’s instructions. Such recipients must agree to abide by confidentiality obligations, and are not permitted to use your personal data except for the limited purpose that we request. THRIVE is potentially liable for onward transfers to service providers when it transmits personal data of EU individuals received pursuant to Privacy Shield.
  7. Third Party Tracking Companies. We may share your information with our advertising and analytics partners.  These third parties may also collect information directly from you as described in this Privacy Policy over time and across different websites. The privacy policy of these third party companies applies to their collection, use and disclosure of your information. For example, one of our partners is HubSpot, which collects and stores information from you such as email address, first name, last name and phone number. Another example is Google Analytics which collects information anonymously and report website trends without identifying individual visitors.  

Retention of Information

In the context of personal information that is part of Client Data, our Client determines how long information is kept unless we are required by law to keep such information for a longer period of time.  

In the context of personal information that we collect directly from individuals (i.e., other than Client Data), we retain that information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law, or an individual requests that we delete information about them.

Protecting Information

THRIVE uses industry-standard security technologies and procedures to ensure data security and integrity for personal data. THRIVE also uses reasonable organizational, technical and administrative measures to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information (under its control) about users of its online client services. Unfortunately data transmission over the Internet cannot be guaranteed as 100% secure. Therefore, while THRIVE strives to protect your personal data, THRIVE cannot guarantee the security of personal information.  In the event that THRIVE is required to notify you about a situation involving your data, THRIVE may do so by email, telephone, or mail.

Your Choices

You can make the following choices regarding your personal information:

  1. Access, Correction, and/or Deletion Of Your Personal Information. You may request to access, correct, or delete the personal information that THRIVE has collected about you by writing to the contact listed below under the section titled “Contact Information.”  Note that in some situations – such as when your personal information is part of Client Data – we may forward your request to the entity that is legally responsible for responding to such a request. For example if a client inserted your information into our platform for their use we may forward your request to that company. We will then await instruction from that company on whether your personal information should be shared, changed, or deleted.
  2. Ability to object to processing.  You may object to our continued processing of your personal data.  If we receive an objection, we will evaluate whether we are required by law to discontinue such processing.
  3. California Residents. California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.  If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Contact Information” section below.
  4. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
  5. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send, using automated means, free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties.  We may also send you such communications if you are an existing client, and the communication relates to the types of products or services that you already receive from us. In either case you can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive or contacting us using the information below.  If you decide not to receive promotional emails, we may still send you service related communications.
  6. Opt-Out / Revocation Of Consent. If we rely on your consent to process personal information you may revoke that consent by writing to the contact listed below under the section titled “Contact Information.”  Note that in some situations we may no longer be able to provide you services if you revoke your consent; we may also limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
  7. Different Purposes. If we use your information for a materially different purpose then it was collected, we will offer you the ability to either opt-in or opt-out of such a use, as required by law.

Transmitting Information to Other Countries

Personal information may be processed in a country where you do not reside that has privacy laws that may be less stringent than the laws in your country.  Where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.  By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.

THRIVE complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. THRIVE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, you can visit https://www.privacyshield.gov/

THRIVE commits to attempt to resolve any complaints about our collection or use of your personal data. European Union citizens with inquiries or complaints regarding this Policy should first contact THRIVE using the contact information provided in the “contact information” section below.  If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by THRIVE , please visit the JAMS Privacy Shield Dispute Resolution page here. You also may be able to invoke binding arbitration, under certain circumstances where permitted by the Privacy Shield program, if you believe that there has been a violation of Privacy Shield requirements that has not been appropriately addressed by THRIVE.  In some jurisdictions you may also be permitted to lodge a complaint to your national data protection authority.

THRIVE’s compliance with its Privacy Shield obligations is subject to investigation and enforcement by the U.S. Federal Trade Commission.

Contact Information

If you have any questions or concerns related to this Privacy Policy, please contact THRIVE at :

Thrive TRM LLC
56 N Haddon Avenue
Haddonfield, New Jersey 08033
ATTN: Privacy Officer
contactus@thrivetrm.com

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

Miscellaneous

  • Modifications to Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information. You will be provided with notice of material changes to the Policy.
  • Affiliated Companies. Some THRIVE affiliates, programs and/or sites may have their own, possibly different, privacy policies. THRIVE encourages you to read the privacy policies of any of THRIVE ’s affiliate websites that you may visit.