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Privacy Policy

 

Effective Date:  May 25, 2018
Last Updated Date: September 3, 2026

Thought Industries
6 Liberty Square #6099
Boston, MA 02109
privacy@thoughtindustries.com

This Privacy Policy describes how Thought Industries, Inc. (“Thought Industries”, “we”, ‘us’ or “our”) collects Personal Information about you when you visit our website, communicate with us or request a demo or additional information about our services. This Privacy Policy explains how we use your Personal Information, disclose your Personal Information, or the limited circumstances by which we may share your Personal Information with others.  Thought Industries does not sell your Personal Information to third parties for any purpose. 

This Privacy Policy applies to all Personal Information that may be collected by us from you directly when you visit the Thought Industries website, when you communicate with us, or you request a demo or additional information about Thought Industries’ products and services. We may also collect Personal Information when you complete an online form, register for a Thought Industries event, submit an application for employment, when you communicate with us, or when you may otherwise provide us with your Personal Information.

Thought Industries is committed to using your personal data in a fair and transparent way. When you use your desktop or mobile device to visit our website, we may collect information about you, including information that can be used to identify you (“Personal Information”). We collect this data to enable Thought Industries to communicate with you and provide you with information about our products and services, and for the specific purposes described in this Privacy Policy.

This Privacy Policy is provided to help you understand: (i) the Personal Information we collect, how we collect it, how we use it, and how we share it, (ii) the applicable rights you have regarding your Personal Information, and (iii) how Thought Industries protects your Personal Information. Personal Information does not include, and this Privacy Policy does not apply to, aggregate information or information that has been fully de-identified or anonymized in accordance with applicable law.

1. Types of Personal Information We Collect

When you visit our website, and request additional information about our services, or register/enroll in events, we collect the following information from you:

Full Name – Collected to provide additional information, registration for services, and payment for services.  For example, we may ask you to provide your name along with information about your general interest in our services. Your submission of this type of information as a guest on our website is not required.

Personal Email Address – Collected to provide additional information, registration for certain events, or to learn more about our services. For example, we may ask you to provide your email address along with information about your general interest in our services. Your submission of this type of information as a guest on our website is not required.

Personal Telephone Number – Collected to provide additional information, registration for events or services, and payment for services.

Online Identifiers and your IP Address – Collected when you visit our website as well as the time and duration of your visit and the pages on the website you visited. Our website receives the internet protocol (“IP”) address of your computer (or the proxy server you use to access the World Wide Web). We use your IP Address to help diagnose problems with our server, and to administer our website. 

Cookies – Collected when you visit our website to include browser type. Our website receives your computer operating system and type of web browser you are using, email patterns, your mobile device (including your UDID) and mobile operating system (if you are accessing Our Site using a mobile device), as well as the name of your ISP or your mobile carrier.  We use cookies, web beacons, and other techniques to identify your browser and device to your guest activity on our website.  The cookies utilized by us are solely for the purpose of allowing our website and platform to function and perform better; there are no additional cookies utilized by Thought Industries for any third-party. See our Cookies Policy section for further information.

Geo Location – Collected when you visit our website. We use cookies, web beacons, and other techniques to identify your browser and device to your guest activity on our website.

MAC Address – Collected when you visit our website to include the type of device utilized. We use cookies, web beacons, and other techniques to identify your browser and device to your guest activity on our website.

Employment Information and your Company Name – Collected to provide additional information and registration for events.

Company Email Address – Collected to provide additional information, registration for services, and events.

Company Telephone Number – Collected to provide additional information and registration for events and services.

Web Analytics – Collected about your use of the website such as mouse clicks and scrolling activities.  For example, we use Google Analytics. The providers of these web analytics tools may capture data about your activity on our website, via cookies and other techniques. This data is used only by Thought Industries for the operation, performance and improvement of our website and platform. 

Website Referrer (from another website) – Collected to learn more about the activity on a referrer site. You may have arrived at our website by clicking on an advertisement or content published by a third party, that third party may provide information to us about your activity on their site. 

Combination with Other Data – We may combine information we collect about you as a website guest with the information we collect about you as a service user when you register for our service or an event, or request additional information.

End-User Data – processed by us to provide our B2B customers with services. For this purpose, we typically process name, email, location, employer, IP address, log-in credentials.

2. How We Collect Personal Information:

We collect Personal Information you provide to us when you visit our website, request or purchase products, services, or information from us, register with us for events and product demonstrations, participate in activities on our website, respond to surveys, visit our physical properties, call us, or otherwise interact with us using one or more devices. You may provide Personal Information in a variety of ways when interacting with our website and communicating with us.

We also collect Personal Information through a variety of technologies, such as cookies, and web beacons, including when you visit our website. Please see our cookie policy described below for more information, including Do Not Track and how to disable cookies and otherwise make choices with respect to such data collection. We may also collect Personal Information using analytics tools, including when you visit our website.

3. How We Use Your Personal Information

We use your Personal Information to provide and manage our website and services for which you have registered or requested;

Analyzing your use of our website and service to better understand how they are being used to improve our website and service;

Diagnose issues with our website and service; 

Investigating and responding to website-based complaints; or

We’ll use your Personal Information to provide you with additional information about our services based on your consent and request for these services. This includes:

  • Providing a demonstration of our services;

  • Providing additional information about our service offering;

  • Placing cookies, web beacons, and other online data collection technologies according to our Cookies Policy section of this Privacy Policy and utilizing the information provided by these technologies;

  • Providing periodic email marketing and updates to customers and potential customers regarding our services, and updates, related product or service information with the option to opt-out of future contact included as an Unsubscribe link at the bottom of the email to be removed from future emails; or

  • Conducting surveys and market research about our customers and potential customers.

4. How We Share Your Personal Information:

We do not sell, trade, or otherwise transfer to any third parties your Personal Information except for the purposes identified herein and to the following categories of third parties that operate our website:

  • Information and Cloud Service Providers

  • Error Monitoring Service Providers

  • File Type Conversion Providers

  • Reporting Providers

  • Email Delivery and Management Service Providers

  • Video Assessment and Evaluation Platforms

  • Marketing, Sales, and Advertising Partners

  • Retailers and Resellers

  • Payment Processors and Gateway Providers

  • Video Hosting and Streaming Service Providers

  • Integration and Automation Platforms

  • Video Conferencing and Recording Tools Providers

  • Fraud Monitoring and Prevention Providers

These third parties and our sharing of data (including Personal Information as described above) are necessary for the function, operation, and improvement of our website. We require these companies to protect your Personal Information and comply with our Privacy Policy. We establish legally binding data protection agreements that implement specific data protection and privacy obligations of our third-party service providers.

We may also share your Personal Information with third parties when:

  • Required by law, subpoena, court order, or other legal proceeding;

  • To prevent fraudulent or illegal activity including potential attacks or to protect against the harm to us, our clients, or the public; or

  • New owners acquire or merge with us in a case of a merger or acquisition.

5. Your Rights Regarding Personal Information

We consider the privacy of your Personal Information very important and are committed to handling your Personal Information with care.  You have certain rights regarding your Personal Information, which include:

Right to Access:

We acknowledge your right to access the Personal Information that we maintain about you.  You have the right to obtain a list of the categories of Personal Information collected about you as well as other related information along with the source of the information. You also have the right to know the categories of information shared (or sold) to third parties and the purpose for such sharing as provided for in this Privacy Policy.  More information on how you can request your right to access the Personal Information we collect, use, disclose, or sell can be found under Requests to Exercise Rights section of this Privacy Policy.

Right to Deletion (the Right to be Forgotten):

We acknowledge your right to delete certain Personal Information that we may have collected about you. More information on how you can request your right to delete the Personal Information we collect, use, disclose, or sell can be found under Requests to Exercise Rights section of this Privacy Policy.

Right to Opt-out of Sharing:

You may have the right to opt-out of sharing certain Personal Information with third parties. More information on how to exercise this right to opt out can be found under Requests to Exercise Rights section of this Privacy Policy.

Right to Amend/Rectify:

You have the right to amend or rectify any inaccuracies that you have identified with the information that we have about you. We process Personal Information only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage, and processing practices to ensure that we only collect, store, and process the Personal Information needed to provide or improve our services. We take reasonable steps to ensure that the Personal Information we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Information whenever necessary. More information on how you can request to amend or rectify your information can be found under Requests to Exercise Rights section of this Privacy Policy.

Right to Object/Restrict/Withdrawal Consent:

You have the right to object to the processing of your Personal Information if it is being processed under legitimate interests such as for direct marketing. Let us know what you object against and we will consider your request. If there are no compelling interests for us to refuse to perform your request, we will stop the processing for such purposes. If we believe our compelling interests outweigh your right to privacy, we will clarify this to you.

You also have the right to withdraw your consent for the processing of your Personal Information at any time. We will cease processing of your information unless there is a legitimate purpose or required by law. We will primarily rely on your consent or legitimate interests for any use or disclosures that are not required by law.

Right to Data Portability:

You have the right to request a copy of your Personal Information in a structured, commonly used, and machine-readable format, where applicable. This right may be exercised only under certain conditions, including where processing is based on consent or contractual necessity, and where it is technically feasible.

Right to Non-Discrimination:

We will not discriminate or penalize you for exercising your rights.

Requests to Exercise Rights

If you seek to exercise your rights to access, delete, opt-out, amend/rectify, object/restrict/withdraw consent, data portability, or non-discrimination, you can reach us at:

Designated Email Address: privacy@thoughtindustries.com.

The methods for request will take two (2) steps: one to request the exercise of your rights and the other to verify your identity/request.  

We will respond to a request within ten (10) days and provide information on how it will be processed. We will respond to a request from a U.S. resident within forty-five (45) days that begins on the day the request was made. Note: It may take up to an additional forty-five (45) days to respond to a request from a U.S. resident for a maximum of ninety (90) days provided we notify you with an explanation within the initial forty-five (45) days to the reason why it is taking longer to fulfill the request.

We will provide information on action taken on a request from an EEA resident within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform an EEA resident of any such extension within one month of receipt of the request, together with the reasons for the delay.

As part of the request, we need to verify your identity.  Failure to verify identity may result in a denial of the request.  We will notify you of the failure to verify the request and treat the request accordingly.

Once a request has been approved, we will honor the request to the best of our ability.  The Record of request will be maintained for two (2) years.

If fulfilling a request would reveal Personal Information about another person or if you ask us to delete information that is required by law or defend ourselves against claims, your rights may be limited.

If the request is denied, we will inform you of the denial and the basis for the denial.  If the request was partially denied, we will notify you of the part that is exempt from the request and not use any Personal Information retained for any other purposes other than what may be exempt.

If you believe that our use of Personal Information violates your rights, or if you are dissatisfied with a response you received to a request you formulated to us, you have the right to lodge a complaint with the competent data protection authority of your choice.

Fees for making requests: You can exercise your rights above free of charge or without penalty, but we may limit the number of requests you make or charge a reasonable fee as legally permitted if we find the request to be too burdensome or too frequent.

6. How We Protect Your Personal Information

We implement a variety of security measures to maintain the safety of your Personal Information when you visit our website, or for any reason, submit, or access your Personal Information.  We maintain appropriate administrative, physical, technical and organizational measures and security controls as necessary along with abiding by strict confidentiality obligations with our employees and third parties.

7. The Security, Integrity and Retention of your Personal Information:

The security, integrity, and confidentiality of your Personal Information are extremely important to us. We have and will continue to implement technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your Personal Information only for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

8. International or Cross-Border Transfers of Personal Information:

In the event your Personal Information is transferred, stored, or processed by us in the United States, and you are located outside the United States, we will take reasonable and appropriate steps to ensure the security of your Personal Data and safeguard the privacy of your Personal Information. Our reasonable steps may include implementing the EU-approved Standard Contractual Clauses, in compliance with applicable data privacy laws; and we may also transfer your Personal Information by obtaining your consent, or by other lawful means or mechanisms for transferring Personal Information.  We shall at all times comply with the legal requirements for cross-border data transfers and provide the appropriate degree of protection for your Personal Information.

9. Data Privacy Framework

Thought Industries, Inc. has submitted its annual re-certification application to the U.S. Department of Commerce regarding the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”). Thought Industries’ re-certification is currently pending review by the U.S. Department of Commerce.

With respect to human-resources personal information transferred from the European Economic Area, the United Kingdom and Gibraltar, and Switzerland in the context of an employment relationship, Thought Industries commits to cooperate with and comply with the advice of the applicable European Union data protection authorities, the United Kingdom Information Commissioner’s Office, the Gibraltar Regulatory Authority, and the Swiss Federal Data Protection and Information Commissioner.

During the lapse in its certification status, Thought Industries has continued to apply the applicable DPF Principles to personal information previously received in reliance on its participation in the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. Thought Industries does not represent that its certification is currently active and will update this Privacy Policy once its active status is restored on the Data Privacy Framework List.

Thought Industries complies with the applicable DPF Principles when processing personal information covered by the DPF Program. If there is any conflict between this Privacy Policy and the DPF Principles regarding covered personal information, the DPF Principles will govern. Additional information about the DPF Program, the DPF Principles, and Thought Industries’ certification status is available at https://www.dataprivacyframework.gov/.

Scope and purposes

The DPF Principles apply to personal information that Thought Industries receives in the United States from the European Economic Area, the United Kingdom and Gibraltar, and Switzerland in reliance on the applicable part of the DPF Program. This includes non-human-resources personal information relating to customers, prospective customers, authorized users, learners, business contacts, website visitors, and other individuals whose information is processed through our services. It also includes human-resources personal information relating to current and former employees and job applicants.

The types of personal information Thought Industries may collect or receive, the purposes for which it is collected and used, and the categories of third parties to which it may be disclosed are described elsewhere in this Privacy Policy. Thought Industries may also be required to disclose personal information in response to lawful requests by public authorities, including requests made to satisfy national security or law-enforcement requirements.

Choice, access, and correction

Where required by the DPF Principles, Thought Industries provides individuals with the opportunity to choose whether their personal information may be disclosed to a third party or used for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized.

Thought Industries obtains affirmative express consent before disclosing sensitive personal information to a third party or using it for a materially different purpose when the DPF Principles require such consent.

Individuals may request access to personal information Thought Industries maintains about them and may request that inaccurate information be corrected, amended, or deleted, subject to the limitations permitted by the DPF Principles and applicable law. Requests may be submitted to privacy@thoughtindustries.com.

When Thought Industries processes personal information on behalf of a customer, individuals should ordinarily submit their request directly to that customer. Thought Industries will assist its customers in responding to applicable requests as required by contract and law.

Accountability for onward transfers

Thought Industries remains responsible under the DPF Principles for covered personal information it transfers to third parties acting as agents on its behalf. Thought Industries requires such third parties to process covered personal information only for limited and specified purposes and to provide at least the same level of privacy protection required by the applicable DPF Principles.

Thought Industries may remain liable under the DPF Principles if an agent processes covered personal information in a manner inconsistent with the DPF Principles, unless Thought Industries proves that it was not responsible for the event giving rise to the damage.

Questions and complaints

Individuals with questions or complaints regarding Thought Industries’ handling of personal information under the DPF Principles should first contact:

Privacy Office
Thought Industries, Inc.
6 Liberty Square, #6099
Boston, MA 02109

privacy@thoughtindustries.com
(866) 206-4011

Thought Industries will investigate and attempt to resolve DPF-related questions and complaints within 45 days of receipt.

Thought Industries has committed to cooperate with the applicable European Union data protection authorities, the United Kingdom Information Commissioner’s Office, the Gibraltar Regulatory Authority, and the Swiss Federal Data Protection and Information Commissioner, as applicable, regarding unresolved complaints concerning personal information transferred under the relevant part of the DPF Program. Thought Industries will comply with the advice of those authorities where required by the DPF Principles. These independent recourse services are available to individuals at no cost.

Under certain conditions described in Annex I of the DPF Principles, an individual may invoke binding arbitration before the EU-U.S. Data Privacy Framework Panel when other dispute-resolution procedures have been exhausted.

Enforcement

Thought Industries is subject to the investigatory and enforcement powers of the United States Federal Trade Commission with respect to its compliance with the DPF Principles.

10. If You Have Complaints or Concerns

We regularly review our compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of Personal Information by contacting us through this website, contacting our Privacy Office at privacy@thoughtindustries.com, or by writing to us at Your Privacy Rights, c/o Thought Industries, 6 Liberty Square, #6099, Boston, MA 02109. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between you and Thought Industries.

11. Changes to Our Privacy Policy

We may, from time to time, make changes to this Privacy Policy to address new technologies, practices, regulatory requirements, or other purposes required by law.

12. California Residents:

If you are a resident of California, you may have certain additional privacy rights regarding your Personal Information.

Under the California Consumer Privacy Act (CCPA) California residents have the following rights regarding their Personal Information:

Right to Know and Right to Deletion. You have the right to request: (i) information about our collection, use, sharing, or disclosure of your Personal Information; and (ii) to access the specific Personal Information we may have processed about you. You can also request that your Personal Information be deleted. You may make such a request by calling us at (866) 206-4011 or by emailing us at privacy@thoughtindustries.com. Prior to completing your request, we may verify your request and your identity (based upon the information you provided). Your request must include your full name, email address, where you live (city and state), and the basis for your request (what you want us to do regarding your Personal Information).

You may also designate an authorized agent to make such a request on your behalf by providing us with a signed, notarized letter appointing your agent and specifying the purpose of the authorization.  If you are such an authorized agent, you must provide us with the information described above regarding the California resident (or consumer under the CCPA) on whose behalf you are acting; and your complete name, email, and a letter signed by the California resident authorizing you to act on their behalf.

Right to Opt-Out of the Sale of Personal Information. You have the right to opt out of any “sale” (as defined under the CCPA) of Personal Information; we do not “sell” your Personal Information as defined under the CCPA.

Right to Non-Discrimination. You also have the right not to be discriminated against (or receive any discriminatory treatment) due to your exercising any of these CCPA rights.  

13. How to Contact Us

Privacy Office
c/o Thought Industries, Inc.
6 Liberty Square, #6099
Boston, MA 02109

privacy@thoughtindustries.com
(866) 206-4011

 

©2026 Thought Industries, Inc. All rights reserved.