©2025 Thnks. All rights reserved.
Effective Date: Monday, April 28, 2025
Last Revised/Reviewed on: April 28, 2025
This Notice at Collection and Privacy Policy (“Privacy Disclosure”) explains how Thnks (Thnks, “Company,” “us,” “our,” or “we”) collects, uses, discloses, sells, shares, and/or retains personal information (“Information Practices”) subject to applicable privacy laws.
Thnks typically acts as a service provider or processor of data provided to us by our Customers. In those instances, Thnks is bound by contract or data protection agreements to process data in accordance with specific instructions from our Customers.
The terms used in this Privacy Disclosure shall have the same or similar meaning as those terms in each of the applicable laws, or the closest approximation of such terms.
1.1 The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used, including whether that information is sold or shared for the purposes of cross-context behavioral advertising (e.g., targeted advertising).
|
Categories of Personal Information |
Purposes for Collection, Use, or Processing |
Sold to Third Parties or Shared with Third Parties for Cross-Context Behavioral Advertising |
|---|---|---|
|
Identifiers: For example, a name, address, online identifier, internet protocol (“IP”) address, email address, or other similar identifiers. |
|
We may sell or share certain personal information—including IP addresses, device types and characteristics, and unique device identifiers—with web analytics providers and advertising partners. If you wish to opt out of such sales or sharing, please follow the instructions provided in the “Opt-Out Preference Signals” section below. We do not sell or share the personal information of California residents with third parties for cross-context behavioral advertising unless you have explicitly opted in or consented to the use of cookies or tracking technologies. If you have previously provided such consent, you may withdraw it at any time by either: (1) clicking the “Do Not Sell or Share My Personal Information” link and completing the interactive form; or (2) enabling an opt-out preference signal, as described in the “Opt-Out Preference Signals” section below. |
|
(Pursuant to California Law) Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, a name, address, telephone number, credit card number, or debit card number. |
No |
|
|
Commercial Information: For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
No. |
|
|
Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement. |
We may sell or share certain personal information—including IP addresses, device types and characteristics, and unique device identifiers—with web analytics providers and advertising partners. If you wish to opt out of such sales or sharing, please follow the instructions provided in the “Opt-Out Preference Signals” section below. We do not sell or share the personal information of California residents with third parties for cross-context behavioral advertising unless you have explicitly opted in or consented to the use of cookies or tracking technologies. If you have previously provided such consent, you may withdraw it at any time by either: (1) clicking the “Do Not Sell or Share My Personal Information” link and completing the interactive form; or (2) enabling an opt-out preference signal, as described in the “Opt-Out Preference Signals” section below. |
|
|
Geolocation Data: For example, information that can be used to determine a device’s physical location. |
No. |
We do not collect Characteristics of CA or Federal Protected Classifications, Biometric Information, Sensory or Surveillance Data, Education Information, Financial Data, Precise Geolocation Data, Profile Data, or Professional or Employment-Related Information.
2.1 We do not collect Sensitive Personal Information.
3.1 The period of time for which we retain information depends on the purposes for which we collect or use that information. We will delete or de-identify information when it is no longer needed to fulfill the purposes listed for each category above unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing of your information.
4.1 We may sell or share certain personal information—including IP addresses, device types and characteristics, and unique device identifiers—with web analytics providers and advertising partners. If you wish to opt out of such sales or sharing, please follow the instructions provided in the “Opt-Out Preference Signals” section below.
4.2 We do not sell or share the personal information of California residents with third parties for cross-context behavioral advertising unless you have explicitly opted in or consented to the use of cookies or tracking technologies. If you have previously provided such consent, you may withdraw it at any time by either: (1) clicking the “Do Not Sell or Share My Personal Information” link and completing the interactive form; or (2) enabling an opt-out preference signal, as described in the “Opt-Out Preference Signals” section below.
Please review our Privacy Policy below.
For U.S. residents, certain states provide specific rights to their residents as listed below. While we will attempt to respond to a request from any U.S. resident, we reserve the right to deny requests if allowed under applicable law. Unless you are a California resident, any rights that may be available in your state are not afforded to you under this Privacy Disclosure while you are operating in your commercial or employment capacity.
The purpose of this privacy policy is to provide you with a comprehensive description of our online and offline practices regarding our Information Practices. You have certain rights to control the use of your personal information. This privacy policy describes your rights as it relates to our information practices regarding your personal information and how you can exercise those rights.
The following table includes disclosures for the preceding 12 months of categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.
|
Category |
In the preceding 12 months, this category was: |
Business or Commercial Purpose for Collection & Disclosure |
Categories of third parties to whom the information was disclosed |
|---|---|---|---|
|
Collected |
Disclosed to Third Parties |
||
|
Identifiers |
✓ |
✓ |
|
|
(Pursuant to California Law) Personal Information Categories from Cal. Civ. Code § 1798.80(e) |
✓ |
✓ |
|
|
Commercial Information |
✓ |
✓ |
|
|
Internet or Other Similar Network Activity |
✓ |
✓ |
|
|
Geolocation Data |
✓ |
✓ |
|
|
(Pursuant to California Law) Profile Data |
✓ |
✓ |
1.1 We do not collect Characteristics of CA or Federal Protected Classifications, Biometric Information, Sensory or Surveillance Data, Education Information, Financial Data, Precise Geolocation Data, or Professional or Employment-Related Information.
2.1 We do not currently collect sensitive personal information and, therefore, do not use or disclose any sensitive personal information for any purpose. As a result, we do not offer the right to limit our use or disclosure of these categories of sensitive personal information.
3.1 The categories identified as collected in the tables above were collected from the following categories of sources:
4.1 We may sell or share certain personal information—including IP addresses, device types and characteristics, and unique device identifiers—with web analytics providers and advertising partners. If you wish to opt out of such sales or sharing, please follow the instructions provided in the “Opt-Out Preference Signals” section below.
4.2 We do not sell or share the personal information of California residents with third parties for cross-context behavioral advertising unless you have explicitly opted in or consented to the use of cookies or tracking technologies. If you have previously provided such consent, you may withdraw it at any time by either: (1) clicking the “Do Not Sell or Share My Personal Information” link and completing the interactive form; or (2) enabling an opt-out preference signal, as described in the “Opt-Out Preference Signals” section below.
|
Categories sold to or shared with Non-Service Providers over the last 12 months. |
Categories of Non-Service Providers to whom this category of personal information has been sold or shared |
|---|---|
|
Identifiers |
|
|
Internet or Other Similar Network Activity |
|
5.1 We have not sold or shared any other personal information, including sensitive information, beyond what is described in the tables above.
5.2 The purpose of the notice of Right to Opt-Out is to inform you that you have the right to direct us to stop selling or sharing your personal information, which is called the “Right to Opt-Out.”
5.3 You may exercise your Right to Opt-Out by: (1) clicking “Do Not Sell or Share My Personal Information” to use the interactive form, or (2) submitting your request through an opt-out preference signal (described further below in the section titled “Opt-Out Preference Signals”).
5.4 Once you make an opt-out request, we will comply within 15 business days.
5.5 We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
6.1 Certain states provide the right to request our disclosure of any of the following:
6.2 You can do this through a verified consumer request. That process is described below in the section “How to Exercise Your Rights.”
7.1 Certain states provide you the right to request correction of inaccurate personal information maintained by us. We may request documentation from you to determine the accuracy of the information. If you provide us with documentation either upon our request or through your own initiative, that documentation will only be used for the purpose of correcting your personal information and complying with our recordkeeping requirements.
7.2 As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under applicable law or if we determine that the contested information is more likely than not accurate based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section ” How to Exercise Your Rights.”
8.1 Certain states provide the right to request that we delete any of your personal information, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section “How to Exercise Your Rights.”
8.2 There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your personal information.
9.1 You may exercise your rights, as applicable, by submitting a verified consumer request to know information (and to receive your personal information in a portable format), to correct information, or for deletion.
9.2 The response to a request to know will provide the personal information we have collected and maintained about you in a portable format unless an exception under applicable state law applies. Please note that, depending on the applicable state law, we may not be required to provide personal information to you if you make multiple requests in a certain time period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
9.3 To request your personal information or request to delete or correct your personal information. You may place a request by calling 615-510-7802 or email us at [email protected] or mailing us your request at the address below.
9.4 If you submit a request that is not through one of the above-designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies with your request.
9.5 Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days, or as allowed under applicable law, describing our verification process. We will respond to your request within 45 calendar days, or as allowed under applicable law, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.
9.6 Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.
10.1 California: Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information to opt-out of sale or sharing, or to limit the use or disclosure of your sensitive personal information. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request to verify your identity directly by submitting a verified consumer request according to the procedures in the section “How to Exercise Your Rights,” and directly confirm with us that you provided the authorized agent permission to submit the request. To submit authorized agent documentation, contact us at [email protected].
10.2 Other States: If you use an authorized agent, you may provide a power of attorney executed pursuant to applicable state law. If a power of attorney is not submitted, you may be required to provide commercially reasonable identification of your identity and evidence of your authorized agent’s authority to act on your behalf. For example, you may need to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section “How to Exercise Your Rights,” and directly confirm with us that you provided the authorized agent permission to submit the request, by contacting us at [email protected].
11.1 You have the right to opt-out or revoke your consent by clicking the “Do Not Sell of Share My Personal Info” link at the bottom of our website and selecting your preferences or by broadcasting an Opt-Out Preference Signal/Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. Because the signal is browser-specific, you will need to broadcast subsequent signals if you are accessing our website through different online devices (e.g., computers, smartphones, tablets).
12.1 We will not discriminate against you for exercising any of your state privacy rights. However, we may still offer you certain financial incentives permitted under applicable state law, such as discounts, rewards, premium features, loyalty accounts, or club card programs that can result in different prices, rates, or quality levels.
12.2 In addition to the privacy rights listed above, certain states provide supplemental privacy rights to residents of those states.
13.1 You have the right to opt-out of our use of profiling when used to make decisions that produce a legal or similarly significant effect concerning you or your interactions with us. Currently, we do not engage in such profiling.
14.1 You have the right to appeal our refusal to take action on or respond to a verified consumer request. Upon receipt of our denial or refusal to take action on or to respond to a verified consumer request, a consumer has 90 days to submit a request to appeal our decision by mail. We will timely inform you in writing of any action taken or not taken in response. We will also include a written explanation of the reasons for our decision.
This section of the Privacy Policy applies if you are in the European Economic Area (EEA) or the United Kingdom (UK) and supplements the Privacy Policy.
15.1 Under the General Data Protection Regulation (“GDPR”) and/or the UK General Data Protection Regulation (“UK GDPR”), we are required to have a valid legal basis for processing your personal information, and we must inform you of that legal basis. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. Generally, we will collect personal information from you only when you have consented to such collection, when we need the personal information to perform our obligations under a contract with you, or where the processing is in our legitimate business interests (for example, to detect and prevent fraud). In some cases, we may also have a legal obligation to collect personal information from you (for example, to verify your identity when making a purchase).
15.2 If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with us, we will make this clear at the time we request that personal information. We will also tell you whether providing that personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information, we will provide you with our legitimate business interests for such collection and use.
15.3 If you have questions about or need further information concerning the legal basis for which we collect and use your personal information, please contact us as provided in the “Contact for More Information” section above.
15.4 Data Storage, Transfers, and Security: We use industry-standard methods of securing electronic databases of personal information. However, you should know that no company, including Thnks, can fully eliminate security risks associated with personal information. To help protect yourself, please use a strong password, do not use the same password to access your Thnks account that you use with other accounts or services, and protect your usernames and passwords to help prevent others from accessing your accounts and services.
15.5 Transfer: Your personal and non-personal information will be transferred to Thnks for storage and processing in the United States. We rely on your consent or Article 49 of the GDPR for transfers of information collected from Data Subjects in the EEA and the UK.
15.6 While such information is outside of your country of residence, it is subject to the laws of the country in which it is held and may be subject to disclosure to the governments, courts, law enforcement, or regulatory agencies of such other country, pursuant to the laws of such country.
15.7 We will protect all personal information we obtain in accordance with this Privacy Policy and take reasonable steps to ensure that it is treated lawfully.
16.1 If you reside within the EEA or in the UK, you have the following rights, which you can exercise at any time:
16.2 If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
16.3 You have the right to opt-out of marketing communications we send you at any time. You can exercise this right here or by using the unsubscribe link provided in each email. It may take up to three business days to remove you from our marketing lists. Please note that even after you opt-out, you will still receive service and transaction emails from us.
16.4 You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA and the UK are available here and here.
17.1 We do not collect information from children under 16 within the EEA and the UK.
18.1 Our website uses cookies, both first-party and third-party, to improve your browsing experience, assess the use of its content, and offer you products and services that are in line with your preferences. To learn more about cookies, read our cookie policy.
19.1 We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
20.1 If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices, and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at [email protected].
Postal Address:
Thnks
231 Public Square
Suite 200, Franklin, TN 37064
©2025 Thnks. All rights reserved.