ThruDark Privacy Policy

Effective date: August 2022

This Privacy Policy (“Policy”) applies to the sites, applications, platforms, and forms where it is linked or posted and informs you of ThruDark’s (“ThruDark”, “we”, “us”, “our”) policies regarding the collection, use and disclosure of personal information when you use our websites, mobile applications, social media sites and handles, and receive emails we send (collectively our “Services”). By using the Services, you acknowledge that the collection and use of your information is subject to this Policy.

1.0 Information Collection

We collect both personal and anonymous information through our Services. For the purposes of this Policy, unless otherwise required by applicable law, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or household, and excludes the information that is otherwise excluded by the applicable data protection law. This means that personal information will  include information that can allow someone to identify you individually, for example, personal information will include your name, email address, as well as any other non-public information about you that is associated with or linked to any of this identifiable information. Anonymous information includes data that is aggregated and/or de-identified data, that is not associated with or linked to your personal information and typically cannot by itself identify individual persons. We collect personal information and anonymous information as described below.

You may not always need to provide us with personal information in order to browse our Services. However, if you do not provide the personal information that is necessary, we may not be able to respond to your query or provide certain Services to you.

2.0 Types of Information Collected

Depending on how you interact with the Services, we may collect the following personal information about or from you:

  • personal information  and contact information, such as your name, e-mail address, mailing address, and any other information you submit through the Services.

  • Payment information when you make purchases through our Services;

  • Communications between you and us. When you communicate with us, such as through e-mail or text message, we may collect and save a record of your communication and any personal information provided during the communication.

  • Settings and preferences that you may set through our Services.

  • Usage data and automatically collected technical information such as traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.

  • Information about your computer and internet connection, including, but not limited to, the type of device you use, the IP address of your device, your operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

  • Other data that we may collect from you where you voluntarily provide it or where we provide notice that information is being collected.

3.0 Sources of Information

We collect Information from various sources including data directly from you, from third parties, from public sources, and from automated systems.

Direct interactions. You may give us your personal information by providing it to us directly, including by corresponding with us by post, email or otherwise. This includes data you provide when you:

  • make a purchase on our Services;
  • subscribe to our Service;
  • participate in surveys;
  • engage customer support;
  • request marketing to be sent to you;
  • enter a competition, promotion, or survey; or
  • give us feedback or contact us.

Information We Collect from Third Parties. We may collect personal information about you from third-party sources. We may also collect anonymous or aggregated information from third-party sources (which may be combined with other personal information we have collected about you), such as:

  • Publicly available sources: We may collect information from publicly available sources such as public databases.

  • Third party partners: We may also receive information from business partners, enforcement partners, and other third parties we work with.

Automated technologies or interactions. As you interact with our Services, we may automatically collect technical data about your equipment, browsing actions and patterns, and frequency of use. We collect this information by using cookies and other similar technologies. Please see below for further details.

4.0 Retention of Personal Information

Except to the extent prohibited by law or as otherwise stated in this Policy or at the time of collection, and subject to this Policy, we will retain and use your personal information for as long as it is needed to fulfill the purposes related to your use of the Services and the purposes described in this Policy. These purposes include providing you with any of our Services, communications, information you have requested, or access to the Services, to document our business relationship with you, and as necessary to comply with our legal obligations, prevent fraud and abuse, resolve disputes, and enforce our agreements. We may continue to retain your personal information even after you deactivate your account and/or cease to use the Services for the reasons described in this Policy.

5.0 Use of Information

We use the information that we collect for various purposes, including:

  • To create and manage your personal account at ThruDark
  • To process your orders and returns via our online services
  • To contact you regarding the delivery of your items
  • To answer your queries and to inform you of new or changed services
  • To send marketing offers
  • To make analyses in order to provide you with relevant products
  • To analyse data in order to provide personal recommendations
  • To provide you notifications you have requested.
  • To process your payments.
  • To respond to your inquires, requests, and questions.
  • To notify you about changes to our Service, news about our Services and new features or offerings, and administrative notifications.
  • To allow you to participate in interactive features of our Services when you choose to do so.
  • To verify your identity and eligibility to use the Services. 
  • To improve the administration of our Services and your experience.
  • To provide customer support.
  • To gather analysis or valuable information so that we can improve our Services.
  • To monitor the usage of our Services.
  • To monitor the frequency with which you use our Services.
  • To investigate, detect, prevent and address fraud, abuse, technical issues, violations of our terms, policies, and agreements, and other harmful or unlawful activities.
  • To comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims.
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  • For reasons that we may describe to you at the time of collection.

We may create anonymous or aggregated information from personal information so that it is no longer personal information. We use this anonymous information to analyse use of our Services and improve our Services and other offerings. We reserve the right to use anonymous information for any legal purpose and to disclose anonymous information to third parties without restriction, except where it may be prohibited by applicable law.

6.0 Disclosure of Information

We may share information in the following circumstances:

Service Providers or Processors

We may disclose information to third-party service providers or contractors (processors) who use this information to perform services for us, such as hosting providers, payment processors, caterers, auditors, advisors, consultants, customer service and/or support providers and other similar service providers.

Advertising and Marketing Partners

We may share information with third parties that provide advertising, campaign measurement, promotions, online and/or mobile analytics, and related services. These third parties may receive or access browsing and/or other data about your use of the Services, in order to measure our ad campaigns, and/or to better understand how individuals interact with our Services.

Law Enforcement

Under certain circumstances, we may be required to disclose your information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

We may disclose your information to law enforcement, government officials, or other third parties when we believe that disclosure is necessary to comply with a legal obligation (such as a court order, warrant, or subpoena), to prevent or investigate fraud, abuse, possible wrongdoing in connection the Service, prevent physical or financial loss, or to protect against legal liability.

Business Transfers

We may share some or all of your information in preparation for, during negotiation of, or in the process of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. We might also transfer or share information in the event of an insolvency, bankruptcy, or receivership.

Protect our Rights and our Users

We may disclose personal information where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements, terms, and policies, for fraud prevention, risk assessment, investigation and/or to protect our rights, property, or safety and that of our affiliates, partners, clients, customers, users and/or others.

Other Disclosures

We may disclose information to other parties and for other purposes based on (a) your consent, (b) at your direction, (c) as described to you at the time the information is collected.

7.0 Cookies and Analytics

Our website uses cookies. Please see our Cookies Notice for full details of the cookies used.

8.0 Your Choices

If you opt-in to email marketing, you can choose to opt-out at any time by following the instruction in such emails.  To opt-out of certain targeted advertising cookies go to http://optout.aboutads.info/. The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit http://www.networkadvertising.org to learn more.

9.0 Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use industry standard means to protect your personal information, we cannot guarantee its absolute security.

10.0 Links to Other Sites and Platforms

Our Service may contain links to other websites, plug-ins and applications that are not operated by us. If you click a third party link, you will be directed to that third party's site, which may allow third parties to collect or share data about you. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11.0 Children's Privacy

Our services are not offered to children and we do not knowingly collect personally identifiable information from anyone under the age of 18 (or majority in the jurisdiction they are accessing the services from). If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verifiable parental consent, we will take steps to remove that information from our servers.

12.0 Do Not Track

We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Third parties may be able to collect information, including personal information, about your online activities over time and across different websites or online services when you use the Services. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.

13.0 Users Outside of the United States.

If you access the Service from outside of the United States, by visiting the Services and providing us with your personal information, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your personal information, you consent to such transfer.

14.0 AdRoll   

Description of Service
This is a marketing and retargeting service.
 
Processing Company
NextRoll, Inc.
2300 Harrison St, Fl 2, San Francisco CA, 94110 United States of America
 
Data Protection Officer of Processing Company
Below you can find the email address of the data protection officer of the processing company.
 
Data Purposes
This list represents the purposes of the data collection and processing.
- Retargeting
- Marketing
 
Technologies Used
This list represents all technologies this service uses to collect data. Typical technologies are Cookies and Pixels that are placed in the browser.
Cookies
Data Collected
This list represents all (personal) data that is collected by or through the use of this service.
IP address
Date and time of visit
Downloads
Advertiser website activity
Customer ID
What page an ad appeared on
Device type
Third party information
Data from advertising partners
Hashed version of email address
Browsing activity
Website activity
Mobile device's unique identifier
How many times an ad has been served
Page views
Amount of time spent on a page
Pseudonymized advertiser identifiers
Cookie ID
Items placed in shopping cart
Views and interactions with content and ads
 
Legal Basis
In the following the required legal basis for the processing of data is listed.
Art. 6 para. 1 s. 1 lit. a GDPR
 
Location of Processing
This is the primary location where the collected data is being processed. If the data is also processed in other countries, you are informed separately.
 
United States of America
Retention Period
The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.
The data will be deleted as soon as they are no longer needed for the processing purposes.
 
Transfer to Third Countries
This service may forward the collected data to a different country. Please note that this service might transfer the data outside of the EU/EEA and to a country without the required data protection standards. If the data is transferred to the US, there is a risk that your data can be processed by US authorities, for control and surveillance measures, possibly without legal remedies. Below you can find a list of countries to which the data is being transferred. This can be for different reasons like storing or processing.
United States of America
 
Data Recipients
In the following the recipients of the data collected are listed.
Other advertising companies in the digital advertising ecosystem
NextRoll, Inc.
Click here to read the privacy policy of the data processor
Click here to opt out from this processor across all domains
 
Storage Information
Maximum age of cookie storage: 1 year, 1 month
Stored Information
Name: __adroll; This cookie is set by AdRoll Group, to identify the device when the users move between different Digital Properties, for the purpose of serving targeted advertisements.; Type: cookie; Duration: 1 year, 1 month; Domain: d.adroll.com;
Name: __adroll_shared ; The domain of this cookie is owned by Adroll. This cookie is used for collecting user data across website. The collected data is used to serve more relevant advertisement. ; Type: cookie; Duration: 1 year, 1 month; Domain: .adroll.com ;
Name: __adroll_fpc ; This cookie is set by AdRoll Group to identify the device when the users move between different Digital Properties, for the purpose of serving targeted advertisements. ; Type: cookie; Duration: 1 year
Name: tluid; This cookie is set by the provider AdRoll.This cookie is used to identify the visitor and to serve them with relevant ads by collecting user behaviour from multiple websites.; Type: cookie; Duration: 3 months;

15.0 Jurisdiction Specific Notices

If you are a resident of specific states you have additional rights described below:

California Residents

California Civil Code Section 1798.83 allows California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. You can exercise this right by contacting us at support@thrudark.com with the subject line “California Shine the Light Request” and providing us with your name and email address. 

Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information . You can exercise this right by contacting us at support@thrudark.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and email address.  Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

16.0 Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. Please check the “effective date” at the top of this Privacy Policy If required by applicable law, we will let you know via email and/or a prominent notice on our Service, prior to any significant changes becoming effective and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

17.0 Contacting us

If you have any questions about this Policy, please contact us using the details set out below.

Email address: support@thrudark.com

Mailing address:

ThruDark HQ, 1920 Hillhurst Avenue, Los Angeles California 90027, United States