Welcome to Thrive Global Holdings, Inc. (“Thrive Global”, “we”, “us” and/or “our”). Our website (“Site”) also allows you (“Users,” “you,” or “your”) to easily access and use content, including features, resources and other information intended to help you change the way you live and work. Our mobile application and services (“App”) helps Users achieve behavior change through “too small to fail” incremental microsteps, personal assessments, video micro-learning, inspiring stories and other content and resources. Collectively, the services we provide through the Site and the App from time to time are defined as the “Service(s)”.
This Privacy Policy explains what personal data we collect through the Services, how we use and share that data, and your choices concerning our data practices. This Privacy Policy forms part of our Terms and Conditions Agreement, which is available at https://www.thriveglobal.com/terms.
Users in different regions might be subject to different data protection standards and based on their employer DPA (Data Protection Agreement) with Thrive Global (For App Users Only). This document has a section dedicated to European Union consumers and their privacy rights, as well as a section dedicated to California consumers and their privacy rights.
This Privacy Policy applies to all Services we provide, except for Thrive ZP Services, which are covered by a different privacy policy https://thrivezp.com/privacy/ and different terms and conditions https://thrivezp.com/tos/.
When you interact with us through the Services, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”), described below.
Personal Data You Provide Us. We collect information that visitors to the Site enter when you sign up on the Site (e.g., email and password) or send to us electronically, for example when completing any “free text” boxes in our forms (such as on our “Contact Us” page, support request or survey submission), requesting information, registering for an event, or subscribing to email lists. While the type of data we collect depends on the nature of the inquiry, it typically includes name and contact details, company information, and phone number.
When you use the Site or the App, the following information is created and automatically logged in our systems:
Where we provide the Services under contract with Thrive Global’s enterprise customers (“Customers”) (for example, your employer), we may process some Personal Data on behalf of the Customer, such as data identifying which employees are eligible to use our Services (“Service Data”). This Privacy Policy does not apply to Service Data. Our use of Service Data is governed by our contract with the specific Customer and may be subject to the Customer’s own privacy policies. We are not responsible for the privacy policies or privacy practices of Customers or other third parties. Service Data does not include any Personal Data or other data provided to us or to the Services by a User (including a User who has access to the Services in connection with an enterprise relationship between a Customer and Thrive Global).
We use your Personal Data collected for the following purposes:
To authenticate Users and provide the Services. This processing is necessary to provide you with access to and use of the Services.
As necessary for certain legitimate business interests, which include the following:
For individuals in the European Union (“EU”) and Switzerland, please see the “European Union (EU) Users” section below for information on what we mean by legitimate business interests and your rights.
Marketing. We may contact you to tell you about content, services or products we believe will be of interest to you. If we do, where required by law, for example if you are a User in the EU, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you or by updating your user settings. In addition, if at any time you do not wish to receive future marketing communications, please contact us at privacy@thriveglobal.com We will continue to contact you via email regarding the provision of our Services and to respond to your requests.
Usage Data. We glean valuable insights from your use of and interactions with the Services, including the aggregated and/or anonymized data that is derived from your and others’ use of the Services. We may create such aggregated and/or anonymized data from or using your interactions and contributions to the Services (including your content) and other metrics related to your usage of the Services. We use such aggregated and/or anonymized data in connection with our internal operations and functions, including, but not limited to, operational analytics and reporting, internal financial reporting and analysis, audit functions and archival purposes, as well as in connection with our other business purposes.
In addition to the Services, we may offer certain programs for Thrive Users to participate in, such as webinars, events, stories, promotional contests, etc. (each a “Thrive Program”). By participating in a Thrive Program and submitting to Thrive Global any requested Personal Data or other information, you expressly agree that (i) Thrive Global may, for the duration of the Thrive Program and thereafter, copy, modify, display, distribute, or otherwise use, for any legitimate business purpose, any audio, pictures, video, information of or disclosed by you (including any health or personal information of yourself or your family whom you have valid authorization to do so), and/or other materials you submit to Thrive Global or otherwise are recorded by Thrive Global during the applicable Thrive Program, and (ii) you release and hold harmless Thrive Global from any liability or damages that may arise from such use. IF YOU DO NOT AGREE, PLEASE DO NOT PARTICIPATE IN ANY THRIVE GLOBAL PROGRAMS.
How we share information pursuant to our lawful business purposes: There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, unless required by the law, as set forth below:
How we share information at your direction: We may share or disclose your information at your direction, such as when you authorize a third-party service to access your account. Additionally, we may provide you the option to share reports on your engagement with the Services, including statistics such as the frequency and duration of your use of the App, with Customers.
How you share information on the App: You may choose to voluntarily share information with other Users on the Services, such as when you post public information on the App or chat or otherwise engage with the User community on the App.
We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.
To determine the appropriate retention period for your Personal Data, we will 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 use 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, in which case it is no longer Personal Data.
If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us as described in the “Contact Us” section below. We will address your request as required by applicable law.
If you would like to exercise your Data Privacy Rights, as applicable to your location of residence, please visit https://preferences.thriveglobal.com/privacy. For general inquiries regarding privacy requests and other concerns, please email privacy@thriveglobal.com.
Scope. This section applies if you are a User in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).
Thrive Global is based in the United States. If you are accessing our Services from the European Union or other regions with laws governing data collection and use, please note that your Personal Data will be transmitted to our servers in the United States as necessary to provide you with the Services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). Although the United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located, we safeguard your personal information by treating it in accordance with this Privacy Policy. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your personal information in storage. We use secure transmission methods to collect personal data through our Site and Apps.
“Legitimate business interest” means our interest in conducting our business, managing and delivering the best Services to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.
Thrive Global Holdings, Inc. is the data processor for processing Personal Data provided to us through the Services.
EU Users may contact DataRep, who has been appointed as Thrive’s Data Protection Representative in the EU pursuant to Article 27 of the General Data Protection Regulation on matters related to the processing of your Personal Data. If you want to raise a question to Thrive, or otherwise exercise your rights in respect of your personal data (described below), please contact DataRep as follows:
Your Rights. Subject to applicable EU law, you have the following rights in relation to your Personal Data that we hold about you:
Thrive Global complies with the EU-U.S. Privacy Shield Framework and Swiss-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 Global has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. Thrive Global is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and the Privacy Shield Principles, please visit https://www.privacyshield.gov/. Thrive Global’s Privacy Shield certification is available at: https://www.privacyshield.gov/participant?id=a2zt00000008XqRAAU&status=Active
In compliance with the Privacy Shield Principles, Thrive Global commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact the DataRep (as noted below) or privacy@thriveglobal.com.
Thrive Global has further committed to refer unresolved Privacy Shield complaints to JAMS Privacy Shield Program, an alternative dispute resolution provider located in the United Kingdom. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. Further, in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism. In cases of onward transfer of personal information to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield, Thrive Global remains liable.
Do Not Track Signals: The Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
Thrive Global does not sell your personal information for payment or other monetary consideration. However, because California law broadly defines a “sale” of your personal information to include the act of making cookies and other similar data available to third party advertising and analytics providers when you use Thrive Global Services (even though we never receive any money in exchange), we are required to disclose those practices here.
Your California Privacy Rights – California Consumer Privacy Act (“CCPA”)
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), beginning January 2020 you have certain rights with respect to that information. In particular, you have a right to request that we provide you with the following information:
You also have a right to:
If you would like to exercise your rights under CCPA, please visit https://preferences.thriveglobal.com/privacy. For general inquiries regarding privacy requests and other concerns, please email privacy@thriveglobal.com
A California resident who has provided Personal Data, as defined under California Civil Code section 1798.83, to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personal Data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Data was disclosed in the preceding calendar year, as well as a list of the categories of Personal Data that were disclosed. California Customers may request further information about our compliance with this law by emailing privacy@thriveglobal.com Please note that we are required to respond to one request per California Customer each year, and we are not required to respond to requests made by means other than through this email address.
The Services are not directed to children who are under the age of 16. Thrive does not knowingly collect Personal Data from children who are under 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Thrive through the Services please contact us and we will endeavor to delete that information from our databases.
The Site and the App may contain links to other websites not operated or controlled by us (“Third Party Sites”), including social media services such as Facebook or Twitter (“Social Media Services”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact those sites directly for information on their privacy practices and policies.
We use cookies and other technologies to operate and administer our Services, make it easier for you to use the Services during future visits and gather usage data on our Site or App.
What Are Cookies? A “cookie” is a piece of information sent to your browser by a website you visit. By choosing to use our Site after having been notified of our use of cookies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.
Some cookies expire after a certain amount of time, or upon logging out (session cookies); others remain on your computer or terminal device for a longer period (persistent cookies). Our Site uses first party cookies (cookies set directly by Thrive) as well as third party cookies, as described below.
Type of Cookies Used. The Site uses the technologies described below.
We use cookies that are strictly necessary to provide Users with the Services and to use some of their features, such as the ability to log-in and access to secure areas. These cookies are essential for using and navigating the Site. Without these cookies, basic functions of our Site would not work. We also use a cookie to record when a User has agreed to the cookie consent banner.
Who serves the technology: Thrive
Privacy Policy: Thrive
We use “analytics” cookies that allow us to recognize and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our Site works, for example by making sure users are finding what they need easily. The collected data provides us only with anonymous traffic statistics (like number of page views, number of visitors, and time spent on each page). These cookies also may allow us to track how often posts on third party websites, such as social media sites, are clicked on.
Who serves the technology: App:Segment, Site:Facebook, Google Analytics, Parsely, LinkedIn, Pardot, Twitter, 6Sense, Sailthru, Salesloft
Privacy Policy: Segment, Facebook, Google Analytics, Parsely, LinkedIn, Pardot, Twitter, 6sense, Sailthru, Salesloft
We use cookies to enhance the performance and functionality of the Site and our services (such as collecting performance and error data). These cookies are not essential for using and navigating the Site. However, without these cookies, certain functionality may become unavailable.
Who serves the technology: Cloudflare
Privacy Policy: Cloudflare
Technologies used on the App. We use Segment on the App to track how Users interact with our App to make better informed product decisions. The information collected includes event-based data to determine the value of individual features and demographic information on Users, which may include a User’s locations and device configurations. For more information on Segment’s privacy practices, visit https://www.twilio.com/legal/privacy. We also use Google Analytics, a web analytics service provided by Google Inc., to gather statistics on your use of the App. For more information on Google Analytics privacy practices, read here.
Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
You use Services at your own risk. Thrive Global takes steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Services may not be secure. Therefore, you should keep this in mind when disclosing Personal Data to us and take special care in deciding what information you disclose to us over the Internet or send to us via email. We cannot control the actions of other Users with whom you may choose to share information. Therefore, we cannot, and do not, guarantee that information or content posted by a User on or through the Services will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
Your access to and use of the Services is subject to any additional terms applicable to such Services that may be posted on the Services from time to time, including without limitation, Thrive Global’s Terms of Service at https://www.thriveglobal.com/terms.
The Services and our business may change from time to time. As a result, we may change this Privacy Policy at any time and when we do we will post an updated version on this page and change the Last Updated date above, unless another type of notice is required by the applicable law. You should consult this Privacy Policy regularly for any changes. By continuing to use the Services or providing us with information after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.
You may contact the Data Protection Officer at the contact address noted below.
Please feel free to contact us if you have any questions about Thrive Global’s Privacy Policy or the information practices of the Services. You may contact us as follows: You may send an email to privacy@thriveglobal.com or send mail to:
Thrive Global Holdings, Inc.
Customer Support
599 Broadway
6th Floor
New York, NY 10012
Tel: 1-888-700-8474
If you would like to exercise your Data Privacy Rights, as applicable to your location of residence, please visit https://preferences.thriveglobal.com/privacy. For general inquiries regarding privacy requests and other concerns, please email privacy@thriveglobal.com.