PRIVACY POLICY

Last revised on January 10, 2017.

This Privacy Policy (“Policy”) describes the information gathering and dissemination practices of Thrive TRM LLC (“THRIVE”) . This Policy may be modified at any time. Any modifications to the Policy will become effective when posted; and by continuing to use this Website following the posting of any such changes, you agree to be bound by the Policy, as modified. This Policy outlines THRIVE’s practices for handling personal information and data.

THRIVE respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does THRIVE strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, it also upholds the highest ethical standards in its business practices.

1. Your Privacy on the Internet

This Policy covers the Website and any other website that references this Policy. 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. THRIVE ’s privacy practices reflect its current global principles and standards on handling personal information. These principles and standards include the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.

2. Collection and Processing of Your Personal Data

using this Website, you consent to the collection, processing and use of the information as described in this Policy. As may be required by applicable law, and from time to time, THRIVE may seek your explicit consent to process data and information collected on the Website or provided by you. THRIVE will not subsequently change the way your personal data is used without your consent, as required by applicable law. THRIVE may further collect and process any information and data that you provide to us, for example, when you register with THRIVE , fill out a form, engage THRIVE to conduct its services, subscribe to newsletters, or participate in online surveys, discussion groups or forums, or interact with the Website in any other manner.

3. Purpose of Collected Data

THRIVE collects and uses your personal data for the purposes of providing its products and services to its customers, communicating with corporate business partners about business matters, processing your personal data on behalf of corporate customers, providing information on its/their services, and conducting related tasks for legitimate business purposes.

The information THRIVE collects, processes and uses to understand your needs and interests helps THRIVE deliver to you a consistent and personalized experience in connection with its services and work product. THRIVE will use personal data only in ways that are consistent with the purposes for which it was collected or subsequently authorized by you. THRIVE will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

THRIVE may use your data in such ways that include, but are not limited to:

  • Delivering the services that you have requested;
  • Keeping you up to date on the latest search developments, announcements, and other information;
  • Tailoring information about our services to your individual interests;
  • Providing the ability to create personal profile areas and view protected content;
  • Providing the ability to contact you and provide you with feedback and support;
  • Conducting questionnaires and surveys in order to provide better products and services to our customers and end users. Your completion of any questionnaire is voluntary;
  • Supporting recruitment inquiries; and
  • Generating general industry reports (which exclude personal or corporate identification information) about industry trends such as hiring, compensation, etc.

4. Automated Data Collection

THRIVE may collect information during your visit to the Website through automated tools, which include cookies, embedded Internet links and other commonly used information-gathering tools. These tools collect certain standard information that your browser sends to the Website such as your browser type and language, access times and the IP address of the website from which you arrived at the Website. This information may be used for quality control purposes, to help diagnose problems, to administer the Website and to gather demographic information. THRIVE may aggregate such data only in an anonymous way and will not tie it to a particular individual and/or company. THRIVE uses cookies to deliver content, to save you having to re-enter your user ID and/or password repeatedly, and to customize information offerings to how you and others use the Website.

5. Embedded Web Links

Emails from THRIVE to you may use links to direct you to a relevant area on the Internet, after redirection through THRIVE ’s servers. The redirection system allows THRIVE to change the destination URL of these links, if necessary, and to determine the effectiveness of our marketing initiatives. In emails, such links also may allow THRIVE to determine if you have accessed the link in the email, and the information about this interaction may be connected to your personal identity. If you do not want THRIVE to collect information about the links you clicked, you can simply choose not to click on the links in an e-mail that THRIVE sends to you.

6. E-mail Addresses

If you choose to provide THRIVE with your e-mail address, THRIVE may communicate with you via e-mail, but THRIVE will not share your e-mail address outside of THRIVE .

7. Personal Data Security

THRIVE uses industry-standard security technologies and procedures to ensure data security and integrity for collected 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 ensure or warrant the security of the Website, and you use it at your own risk.

8. Opt-Out

THRIVE offers you the opportunity to choose (opt-out) whether personal information is: (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. For sensitive personal information, THRIVE will give you the opportunity to affirmatively consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by you.

THRIVE communicates regularly by email and may also communicate by phone. THRIVE may use your email address to confirm your registration of an account, to send you information about our services and/or your search project, and to send legal notices and other disclosures.

You can exercise an opt-out by emailing this link: contactus@thrivetrm.com

9. European Union and Swiss Citizens

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 and Switzerland 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, please visit https://www.privacyshield.gov/

THRIVE maintains an affirmative commitment to the U.S.-Swiss Safe Harbor Framework and its principles regarding the collection, use and retention of personal data from Switzerland, which will not be affected by THRIVE ’s participation in the Privacy Shield. THRIVE certifies that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement with respect to certain Swiss Personnel Data received in the United States from its affiliated companies in Switzerland.

In compliance with the Privacy Shield Principles and the U.S.-Swiss Safe Harbor Framework, THRIVE commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union and Switzerland with inquiries or complaints regarding our Private Shield policy should first contact THRIVE at: Thrive TRM LLC
56 N Haddon Avenue
Haddonfield, New Jersey 08033
ATTN: Privacy Officer
contactus@thrivetrm.com

THRIVE commits 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 above. THRIVE has further committed to refer unresolved privacy complaints under the U.S.-Swiss Safe Harbor Frameworks to the BBB EU Safe Harbor – an independent dispute resolution mechanism – operated by the Council of Better Business Bureaus or other EU Data Protection Authorities (DPAs). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by THRIVE , please visit the BBB EU Safe Harbor Web site at http://www.bbb.org/us/safe-harbor-complaints or contact the other EU DPA for more information and to file a complaint. The BBB EU Safe Harbor or other DPA will establish a panel to investigate and resolve complaints brought under the Privacy Shield, and THRIVE will cooperate with this panel. Furthermore, THRIVE will comply with the advice given by data protection authorities and take necessary steps to remediate any non-compliance with the Privacy Shield Principles.

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 .

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

THRIVE reserves the right to change its policy from time to time, consistent with the Privacy Shield Principles.

EU-U.S. Privacy Shield Policy Effective Date: 1/15/2017 (Supersedes: U.S.-EU Safe Harbor Statement Effective Date: 3/30/2015)

10. Disclosures/Onward Transfers of Personal Data

Except as otherwise provided herein, THRIVE discloses personal data only to third parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.

THRIVE may provide your personal data to third parties that act as agents, consultants or contractors to perform tasks on behalf of and under THRIVE ’s instructions. Companies affiliated with THRIVE may use the information internationally in connection with processing your inquiries, providing its services, and improving our products and services. Any data and information that you provide or that is otherwise collected on the Website or related sites may be sent electronically to a server in another country. THRIVE only provides third parties with the minimum amount of personal data necessary to provide the services on THRIVE’s behalf, and the third parties are not permitted to use your personal data except for the limited purpose of completing the requested service or transaction.

THRIVE safeguards your privacy interests around the world by ensuring that all THRIVE sites adhere to our data protection principles described in this Policy. For example, THRIVE may store your personal data in the facilities operated by third parties that have agreed or must agree to access and use your personal data only for the purposes for which they have been engaged by THRIVE and they must either:

  1. comply with the Privacy Shield principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of personal data; or
  2. agree to provide adequate protections for personal data that are no less protective than those set out in this Policy.

THRIVE also may disclose your personal data for other purposes or to other third parties if you have consented to or requested such disclosure. Please be aware that THRIVE may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. THRIVE is liable for appropriate onward transfers of your personal data to third parties.

THRIVE will not sell or rent your personal data to third parties for marketing purposes unless you have granted us permission to do so.

THRIVE may respond to subpoenas, court orders, or legal process by disclosing your personal data and other related information, if necessary. THRIVE may choose to establish or exercise our legal rights or defend against legal claims.

While visiting the Website you may be directed to content or functionality that is hosted by a third-party supplier. When information is collected on behalf of THRIVE exclusively, the appropriate THRIVE affiliate privacy statement will be referenced on the site and will govern how information is used.

11. Inquiries, Access and Updating Information

THRIVE requests your assistance in maintaining the accuracy of the information you have provided to THRIVE . If you are a registered user, you are invited to update the information yourself online at contactus@thrivetrm.com.

If you are an EU or Swiss citizen about whom THRIVE holds personal data on your or its client’s behalf, you may request access to, and the opportunity to update, correct or delete, your personal data. To submit such requests or raise any other questions, please contact the business that either collected or provided your personal data to THRIVE . You can also contact THRIVE’s EU-U.S. Privacy Shield Contact (above). In either case, THRIVE reserves the right to take appropriate steps to authenticate an applicant’s identity, to charge an adequate fee before providing access and to deny requests, except as required by the EU-U.S. Privacy Shield Framework.

If you have any other questions about this privacy statement or if you wish to inspect the information we hold about you, please contact: contactus@thrivetrm.com