3. How we use the information we collect
4. How we share the information we collect
5. Cookies and other tracking technologies
6. Information collected by third parties
10. Children and COPPA compliance
12. California users consumer rights
13. Users located outside of the United States
14. EU users’ rights under the GDPR; Brazilian users’ rights under the LGPD
16. Cooperation with law enforcement; fraud protection
19. Annual consumer request metrics
The information we collect includes personal identifiers, commercial information, electronic network activity and geolocation data, and can be divided into the following broad categories:
Usage Data includes information about how you use our Website or Service, such as the particular pages you interact with, how often you visit, how long you’re on the Website, surveys, the service you’re looking at and the emails and text messages you interact with or send.
Verification Data includes proof of identity and proof of address as further detailed in our Subject Access Request Form.
More specifically, we may collect and store the following information relating to you:
We collect information from you when you voluntarily submit information directly to us or via our Website. For subscribers, this refers to personal data you provide when, for example, you create or join a group, complete a profile, or by corresponding with us via phone, email or live chat. This personal information may include name, age, address, phone and email, as necessary to set up your account or process an order. If you connect to the Website using credentials from a third-party application (e.g., Facebook), you authorize us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available on or through your third-party application account, including, for example, your name, profile picture, country, hometown, email address, date of birth, gender, friends’ names and profile pictures, and networks.
In addition to the information we may collect upon your initial registration, we may ask you for personal information at other times. We will not share that information in a manner that identifies you as an individual with any other entity unless we have your permission.
Information, pictures and media files you may upload to the Website will be posted on the Website, subject to ourSection 7 and accessible by all visitors to the Website; we have no control over how such visitors will use such submissions. Please remember that if you post any of your personal information in public areas of the Website, such as in online forums or chat rooms, such information may be collected and used by others over whom we have no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of the Website. You should take care to not use personal information in your screen name or other information that might be publicly available to other users.
As you interact with our Website, we may automatically collect technical and usage data about your device, browsing actions and patterns. For example, we collect information which may include your IP address, browser type, your location, language preferences, device information and access times. While an IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual. Your IP address can reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages. We also collect IP addresses for system administration and to report aggregate information to any sponsors. We may also receive information from our web logs, which automatically record anything a web server sees, which may include email addresses you enter into a form or pages viewed by a user at a particular IP address. We collect this personal data by using cookies, pixel tags and other similar tracking technologies. The sole purpose of passively collecting your information is to improve your experience when using our Website.
We may also receive information about you from our service providers and partners, which we use to personalize our Service, to measure ad quality and responses to ads, to display ads that are more likely to be relevant to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you.
We have set out below, in a table format, a description of all the ways we process your personal data, and the legal basis we rely on to do so.
|Purpose/Activity||Type of Data||Legal Basis|
|To allow you to visit the Website||Technical Data
|To allow you to create an account and join the website||Identity Data
|To allow you to create a Solutions Group||Identity Data
|To manage our relationship with you. For example general enquiries such as how the Website works, complaints, order fulfillment and payment queries||Any data you choose to share with us or request us to view||Consent|
|To administer and protect the Website (including troubleshooting, fraud prevention, spam prevention, security incident prevention and correction, data analysis, testing, system maintenance, support, reporting and hosting of data), operate the Website (including notifying you of any changes), optimize your user experience, and send you service and support messages such as updates, patches and security alerts||Financial Data
|To send you promotional messages, marketing, advertising and other such information we think may be of interest to you, either directly or through one of our partners, via emails, text messages or push notifications; you may opt out from receiving certain messages, as described in Section 7||Financial Data
|To enable you to partake in a prize draw, competition, referral scheme, rewards program, promotional activities, events, complete a survey or invite you to participate in Website testing
|To analyze your use of the Website and deliver relevant website content and third-party advertisements, for example by providing customized, personalized, or localized content, recommendations, features, and advertising||Usage Data||Consent|
|For purposes of legitimate interests|
|To maintain and retain records in connection with actual and potential legal claims and regulatory investigations; and for governance & compliance purposes||Financial Data
|Necessary for the compliance with a legal obligation to which we are subject|
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at [email protected]
Please note that we may process your personal data without your knowledge or further consent, in compliance with the above rules, where this is required or permitted by law.
This section describes how the information collected or generated through your use of the Website may be shared by us with third parties. The information we may disclose for a business purpose includes personal identifiers, commercial information, electronic network activity and geolocation data. We have never sold our users’ personal information and in no event will we ever sell your personal information.
We may send you promotional communications about our Website or our advertising partners, including relevant advertising for third-party products and services that may be of interest to you. The Thrive family encompasses multiple companies providing various offerings related to the THRIVE movies, including, without limitation, Thrive Movement International, Inc., Clear Compass Media, LLC, and THRIVE Movie, LLC. We may share your information with these companies for the sole purpose of keeping you informed of all things “Thrive”. We may also share aggregate user information in a non-personally identifiable manner with advertisers and other third parties in order to present to users more targeted advertising, products and services. We do not provide any personally identifiable information to third-party advertising companies.
To provide you with the best experience on our Website, we may use third parties who automatically process your Usage Data on our behalf. Where possible, we will make sure this data is anonymized.
We may make available a service through which you can receive messages on your wireless device via short message service. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies.
For your information, click here to view some examples of how third parties process your personal data.
When one or more of our business partners co-sponsor a service, promotion, contest/sweepstakes, or survey, we may share some or all of the information collected in connection with such service, promotion, contest/sweepstakes, or survey with the co-sponsor(s). If we intend to share such information, you will be notified prior to the collection of that information. If you do not want your information to be shared, you will be able to choose not to allow the transfer by not using or signing up for that particular service, promotion, contest/sweepstakes, or survey.
A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognize your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.
There are also technologies such as mobile device identifiers and SDK integrations to help companies recognize your device when you return to an app or otherwise use a service.
Our policy regarding cookies can be found here.
Please read these third parties’ privacy policies to find out how they collect and process your personal information.
Users who no longer wish to receive email updates, text messages or other notifications may opt out of receiving these communications by following the instructions contained in the applicable communication. Please know that such a decision will not stop advertising or content that is generated prior to the time when we can accomplish the removal of your information.
Credit card transactions are handled by a third-party processor that receives credit card numbers and other personally identifying information only to verify credit card accounts and process transactions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered or disclosed, used or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, the transmission of data via the internet is not completely secure and we cannot guarantee that unauthorized parties will not be able to defeat those measures: unauthorized entry or use, hardware or software failure, and other factors may compromise the security of our user information at any time.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We believe that parents should supervise their children’s online activities and consider using parental control tools available from online services and software manufacturers that help provide a child-friendly online environment. These tools can also prevent children from otherwise disclosing online their name, address and other personal information without parental permission.
California residents may choose to opt-out of our disclosure of personal information about them to third parties for direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email [email protected].
If you are a California resident, you also have the right to:
If you wish to exercise any of the rights set out above, please email us at [email protected]. You may also call this toll-free number: +1 (844) 784-2467. We will respond to you no longer than 45 days following receipt of your request. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that your personal data is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information, in relation to your request, to speed up our response. The California Consumer Privacy Act (CCPA) requires that we report on consumer request metrics annually. Metrics are reported on July 1 every year and can be found here.
California resident may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to [email protected]. We would, however, appreciate the chance to deal with your concerns before you approach the DCA, so please email us at [email protected] in the first instance.
If you are located in the European Union, or if the EU’s General Data Protection Regulation (“GDPR”) otherwise applies to your data as processed by us, you have the right to (to the extent required by the Lei Geral de Protecao de Dados (“LGPD”), some of these rights may also apply to users located in Brazil):
If you wish to exercise any of the rights set out above or request details about the specific legal basis we are relying on to process your personal data, please email us at [email protected] using the Subject Access Request Form.
We will respond to you within 30 days of receipt of your request. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise your other legal rights). This is a security measure to ensure that your personal data is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information, in relation to your request, to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of your other legal rights). However, we may charge a reasonable fee (or refuse to comply) if your request is clearly unfounded, repetitive or excessive.
You have the right to make a complaint under the GDPR at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please email us at [email protected] in the first instance.
If you are located in the European Union or Brazil, or if the GDPR or LGDP otherwise applies to your data as processed by us, we will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or internal reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for compliance, governance, legal and/or regulatory purposes in which case we may use this information indefinitely without further notice to you.
We fully cooperate with law enforcement agencies in identifying those who use our Website or Service for illegal activities. We reserve the right to disclose information about users who we believe are in violation of applicable laws or regulations, or as required to respond to a subpoena, court orders or other legal process requiring such disclosure. We also reserve the right to report to law enforcement agencies any activities that we reasonably believe to be unlawful and to exchange information with other companies and organizations for fraud protection.
Please note that if you opt out of receiving notices from us, change notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for changes, as posted on the Website.
For the purposes of the GDPR, THRIVE II LLC d/b/a “ThriveOn”, located at P.O. Box 40, Capitola, CA 95010, USA, is the Data Controller and is responsible for your personal data. This means that we determine the purposes and ways of the processing of your personal data.
Our European and UK representative for GDPR purposes is the Prighter Group with its local partners. If you want to exercise your European or UK data subject rights, please visit https://prighter.com/q/11218502009.
Request to Delete: Number Received = 45 Number Complied = 45 Number Denied = 0 Median Days For Response = 5 Mean Days For Response = 5
Request To Know: Number Received = 0 Number Complied = 0 Number Denied = 0 Median Days For Response = 0 Mean Days For Response = 0
Request To Opt-Out: Number Received = 12505 Number Complied = 12505 Number Denied = 0 Median Days For Response = 0 Mean Days For Response = 0