Effective Date: June 24, 2019
Personal information Thunderbolt Innovation may collect and use
When Client first registers for a Thunderbolt Innovation Account, Thunderbolt Innovation collects some personal information about potential Users such as:
Client’s business name, username, and email address;
a unique Thunderbolt Innovation user ID (an alphanumeric string) which is assigned to Client upon registration;
Client’s password, in connection with Client’s Thunderbolt Innovation Account and Client’s log-in facility;
full names, usernames, and email addresses of potential Users;
the geographic area where potential Users computer and mobile devices are used;
Client’s credit card or ACH information, billing address, and such other information as is required to complete a commercial transaction on the Thunderbolt Innovation site;
other optional information as part of Client’s Thunderbolt Innovation Account profile.
Client may offer links to a third-party from its online applications generated by its Thunderbolt Innovation Account so that Users may connect to other third-party services or software, and Thunderbolt Innovation may access other information related to Users’ social profiles. When that occurs as a first instance, a prompt will inform Users of the details that will be accessible by Thunderbolt Innovation.
As a registered Client of Thunderbolt Innovation, Thunderbolt Innovation may also collect the following information about all Users associated with Client’s Account:
full names, social media names, email addresses and general profile information of all Users associated with Client’s Account;
information posted by any User in the form of messages, conversations, or contributions to discussions;
data, documents, images or other files that may be transmitted or uploaded by any User via Services;
information Thunderbolt Innovation may receive relating to communications sent by any User, such as queries or comments concerning the Thunderbolt Innovation Services;
information relating to the real time location of a relevant computer or mobile device, but only where such relevant computer or mobile has been enabled to send Thunderbolt Innovation location information
Thunderbolt Innovation uses the collected information for the following general purposes:
to identify Users logged in to Client’s Thunderbolt Innovation Account
to enable Thunderbolt Innovation to provide the Services to Users
to verify transactions Users make and for billing, security, and authentication
to analyze the Website, Services and Thunderbolt Innovation users, including research into Thunderbolt Innovation’s user demographics and user behavior in order to improve the Thunderbolt Innovation content and Services
to contact Client about its account and provide support
to share aggregate (non-identifiable) statistics about Users of the Services to prospective advertisers and partners
to keep Client informed of information about the Thunderbolt Innovation Services that Client may find useful or which Client has requested from Thunderbolt Innovation, provided Client has indicated it would like to be contacted for these purposes
By submitting information to Thunderbolt Innovation when registering, Client consents to the use of the User’s information for these purposes.
In the course of operations, Thunderbolt Technology’s servers may automatically collect information about Users’ web browsers and other relevant information about Users’ browsing sessions on the Website. This information is not used to obtain any personally identifiable information. Thunderbolt Technology has a strict “opt-in” policy and personally identifiable information about visitors to the Website is collected only when voluntarily submitted. Thunderbolt Innovation may gather Personal Information about Users via various methods (phone, email, online forms, in-person meetings) but only if such Personal Information is submitted voluntarily. Thunderbolt Innovation may use such Personal Information for sales, marketing, and support of the Services. Except as otherwise set forth herein, this Personal Information is never shared with third parties.
System and device information
Thunderbolt Innovation automatically collects and receives certain information from the computer or mobile device of Users, including the activities performed on the Thunderbolt Innovation Website, the type of hardware and software being used (for example, the operating system or browser), and information obtained from cookies (see “Cookies and Related Technologies” below). For example, each time a User visits the Website or otherwise uses the Services, Thunderbolt Innovation automatically collects the IP address, browser and device type, access times, the web page from which the User came, the regions from which the User navigated the web page, and the web page(s) the User accessed (as applicable) (collectively referred to as “traffic data”). Thunderbolt Innovation may link this traffic data to Client’s unique Thunderbolt Innovation user ID to better understand Client’s needs and the needs of Users in the aggregate, diagnose problems, analyze trends, provide services, improve the features and usability of the Services, and better understand and market to Thunderbolt Innovation customers and website users.
Thunderbolt Innovation also makes use of non-identifiable information gathered for statistical purposes to keep track of the number of visits to the Services and Website pages with a view to introducing improvements and improve usability of the Services. Thunderbolt Innovation may share this type of statistical data generated from non-identifiable information so that its partners also understand how often people use the Services, so that they, too, may provide Client with an optimal experience. Client’s IP address and other relevant non-identifiable information may be used in order to trace any fraudulent or criminal activity or any activity in violation of the Terms of Service.
Cookies and related technologies
1) Session Cookies: The Services use “session cookies”, which improve the user experience by storing certain information from a User’s current visit on the User’s device, such as login information. These enable Thunderbolt Innovation to remember a User’s login session so the User can move easily within the Website or the Services. Without these cookies, Thunderbolt Innovation would not be able to provide the Services to Users. These session cookies have limited functionalities and expirations, and a User will be required to re-enter its Thunderbolt Innovation login information after a certain period of time has elapsed to protect User against others accidentally accessing its account contents and related Personal Information.
2) Performance and Remarketing Cookies: Partners who help us serve advertising on and off the Website and analytics companies may also put cookies on a User’s device. Thunderbolt Innovation may from time to time use third-party vendors to help deliver ads for relevant Thunderbolt Innovation products and services to a User when a User visits certain pages on the Website and then visit certain third-party sites.
i) Google Analytics: Thunderbolt Innovation uses a specific cookie in order to facilitate the use of Google Universal Analytics for Users logged-in to their Account (“Logged-In User). For a Logged-In User, Thunderbolt Innovation may use the Thunderbolt Innovation user ID in combination with Google Universal Analytics and Google Analytics to track and analyze the pages of the Services visited. Thunderbolt Innovation does this only to better understand how User uses the Services and the Website, with a view to offering improvements for all Thunderbolt Innovation Users; and to tailor Thunderbolt Innovation’s business and marketing activities accordingly, both generally and specifically to Thunderbolt Innovation customers. Google Analytics cookies do not provide Thunderbolt Innovation with any Personal Information.
Users may opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on.
ii) Google Display Advertising: Additionally, Thunderbolt Innovation uses Google Analytics code that allows for certain forms of display advertising and other advanced features. Subject to change, the Google Display Advertising features Thunderbolt Innovation currently uses are Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting.
Thunderbolt Innovation uses other third-party performance and remarketing cookies, and further information on those third-party cookies can be obtained by contacting Thunderbolt Innovation at the email address below.
Thunderbolt Innovation may also use related technologies including web beacons, bugs, pixels, and software tokens in order to facilitate a User’s use of the Services.
Most computer and some mobile web browsers automatically accept cookies; a User can change its browser to prevent automatic acceptance or to notify the User each time a cookie is set. The Network Advertising Initiative has also developed a tool that may help Users understand which third parties have currently enabled cookies for their browsers and opt-out of those cookies. Further information can be found at http://www. networkadvertising.org/managing/opt_out.asp. Please note however that, by blocking or deleting cookies, a User may not be able to take full advantage of the Website and/or Services. If a User does not want to receive tracking pixels, the User will need to disable HTML images in its email account, and that may affect the User’s ability to view images in other emails that it receives.
When Thunderbolt Innovation may share Personal Information
When User explicitly consents to the disclosure of such information to a third party when connecting to a third-party service that asks for consent to such sharing;
Where Thunderbolt Innovation is legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands;
If Thunderbolt Innovation believes it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;
If Thunderbolt Innovation believes it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Services generally);
To a parent company, subsidiaries, joint ventures, or other companies under common control with Thunderbolt Innovation;
If this information is not private, is aggregated or is otherwise non-personal information, such as a User’s public user profile information and related public data (such as Tweets, likes, etc.) or the number of Users who clicked on a particular link (even if only one did so).
Protecting the safety of children when they use the Internet is very important to Thunderbolt Innovation. The Services should only be accessed by Users who are individuals of at least 18 years of age. The Services are not designed nor intended for use by children under the age of 13. Thunderbolt Innovation does not currently knowingly collect any Personal Information from persons under the age of thirteen (13).If, in the future, we collect personally identifiable information from children on the Website, we will do so in compliance with the Children’s Online Privacy Protection Act of 1998 (15 U.S.C. 6501 et seq.) including, without limitation, obtaining necessary parental consent.
Thunderbolt Innovation uses industry best practices to keep any information collected and/or transmitted by the Services secure. This includes the use of HTTPS with TLS (Transport Layer Security), which encrypts all transmitted data, and OAuth 2.0 protocols for authentication and data transfer.
Certain Personal Information, such as Thunderbolt Innovation login details, is encrypted during transmission using TLS. Once validated within the Thunderbolt Innovation system, passwords are deleted from the system. In addition, Thunderbolt Innovation uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Services. These vendors have been selected for their high standards of both physical and technological security, including ISO and SSAE16 certifications.
When payments are processed via credit card, Thunderbolt Innovation uses third-party vendors that are PCI-DSS Compliant.
Submission of information over the Internet is never entirely secure. Thunderbolt Innovation cannot guarantee the security of information submitted via the Services while it is in transit over the Internet and any such submission is at a User’s own risk, and this risk is specifically disclaimed in our Terms of Service.
It is advisable that a User logs out of its Account at the end of every session and does not leave a logged-in account unattended for any period of time, particularly if using a shared computer or device.
Information storage and international transfers
Thunderbolt Innovation aligns itself with the Safe Harbor privacy principles as set forth by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of Personal Data transferred from the European Economic Area (“EEA”) or Switzerland to the United States. While Thunderbolt Innovation itself is not certified by the US Department of Commerce, the information that a User submits via the Thunderbolt Innovation Services is hosted on secure servers located in the United States that are certified under the Safe Harbor Scheme for transfers of Personal Information outside the European Economic Area. Safe Harbor is a European Union (EU) directive on data privacy that introduces high standards of data privacy to ensure the free flow of data throughout the European Union member states, and gives the individual the right to review the personal data, correct it, and limit its use. Safe Harbor provides a way for US businesses to demonstrate that they provide adequate protection for personal information transferred to it according to EU data protection standards. Further information on Safe Harbor is available from the US Department of Commerce’s website.
Thunderbolt Innovation uses email as a primary mode of communication with its Users. A User can manage its email preferences, such as opting-out or unsubscribing from emails sent by Thunderbolt Innovation, by adjusting its preferences in its account settings. A User may also opt out or unsubscribe from any future email communications from within a link provided in each email correspondence that Thunderbolt Innovation sends.
Users can contact Thunderbolt Innovation to obtain a copy of the Personal Information held about a User by Thunderbolt Innovation. This may be subject to a fee not exceeding any prescribed fee permitted by applicable law. A User can also ask Thunderbolt Innovation to correct and, where relevant, erase that information. Please note that certain Personal Information may need to be retained by Thunderbolt Innovation for a period of time following termination of a User’s Account where this is necessary for legitimate business purposes or required by applicable law.
GMail Data Policy
– The App will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read,and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
– The App will not use this Gmail data for serving advertisements.
– The App will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the App’s internal operations and even then only when the data have been aggregated and anonymized.
Thunderbolt Innovation, LLC
383 Central Ave, Suite 263
Dover, NH 03820