SCHEDULE B

ThinkOn Privacy Policy 

Reviewed September 6th, 2023
V1.5 

The website thinkon.com (the “Website” or “Site”) is owned and operated by Think On, Inc. (“ThinkOn”) ThinkOn is committed to protecting the privacy of its visitors while they interact with the content, products and services on this site (the “Site”). 

It does not apply to other websites to which ThinkOn links.  Because ThinkOn gathers certain types of information about its Subscribers, it is important that Subscribers understand what information is collected about them, how it is collected, how that information is used, and how Subscribers can control ThinkOn’s disclosure of that information. 

You (“the Subscriber”) agree that your use of the Site signifies your assent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Site. 

A. INFORMATION COLLECTED

ThinkOn collects two types of information from its Subscribers: i) information that Subscribers voluntarily provide to ThinkOn (e.g. through a voluntary registration process, sign-ups or emails); and ii) information that is derived through automated tracking mechanisms. 

  1. Voluntary Registration Information. In order to fully access this Site, Subscribers must first complete the registration process, during which ThinkOn will collect personal information about the Subscriber. The information may include the Subscriber’s name, telephone number, email address, billing address, shipping address, payment information, email notification preferences, site Subscriber name, and password. ThinkOn does not collect personally identifiable information about the Subscriber except when the Subscriber specifically provides such information to ThinkOn on a voluntary basis. By registering with ThinkOn, the Subscriber consents to the use and method of disclosure as described in this Privacy Policy. 
  2. Voluntary Information for Services and Features. ThinkOn also collects personally identifiable information when the Subscriber chooses to use certain other features of the Site, including: i) making inquiries, ii) consenting to receive email or text messages about upcoming promotions or events, iii) consenting to receive email, v) commenting on articles, and others.  When the Subscriber chooses to use these additional features, ThinkOn may require the Subscriber to provide “Contact Information” in addition to other personal information that may be required to complete a transaction such as a phone number, and billing and shipping addresses. Occasionally, ThinkOn may also request information such as the Subscriber’s site preferences and demographics which will help ThinkOn better serve the Subscriber and its other Subscribers in the future. 
  3. Cookies. ThinkOn Website may use “cookies” and other tracking technologies.  Cookies enable ThinkOn to serve secure pages to its Subscribers without asking them to sign in repeatedly.  Most browsers allow the Subscriber to control cookies, including whether or not to accept them and how to remove them. If a Subscriber’s system is idle for a defined time, the cookie will expire, forcing the Subscriber to sign in again to continue their session. This prevents unauthorized access to the Subscriber’s information while they are away from their computer.
    The Subscriber may set most browsers to notify the Subscriber if a cookie is received, or the Subscriber may choose to block cookies with his/her browser, but please note that if the Subscriber chooses to erase or block cookies, the Subscriber may need to re-enter his/her original Subscriber ID and password to gain access to certain parts of the Site. 

B. REFERRALS

The Subscriber may choose to invite friends to visit the Website by sending invitation emails via the invite feature. ThinkOn may store the email addresses the Subscriber provides so that the respondents may be added to the Subscriber’s social network, confirm orders/purchases and also to send reminders of the invitations. ThinkOn does not sell these email addresses or use them to send any other communication besides invitations and invitation reminders. Recipients of invitations may contact ThinkOn to request removal of their information from ThinkOn’s database.

C. HOW THINKON USES WEBSITE SUBSCRIBER INFORMATION

ThinkOn only uses the personal information of its Subscribers for the original purposes it was given. A Subscriber’s personal information will not be sold or otherwise transferred to unaffiliated third parties without the Subscriber’s approval at the time of collection. 

ThinkOn will not disclose, use, give or sell any personal information to third parties for any purposes other than to its suppliers and other third parties who need to know in order to deliver services on behalf of ThinkOn unless required to do so by law. Further, ThinkOn reserves the right to contact its Subscribers regarding matters relevant to the underlying service provided and/or the information collected. 

Please note that personally identifiable information is used only to provide the Subscriber with a more enjoyable, convenient online experience and to help ThinkOn identify and/or provide information, products or services that may be of interest to its Subscribers. ThinkOn uses personally identifiable information to support and enhance the Subscriber’s use of the Site and its features, including without limitation: fulfilling the Subscriber’s order; providing Subscriber service; tracking email invitations that Subscribers send; and otherwise supporting the use of the Site. 

Also, ThinkOn may share personally identifiable or other information with its parent, subsidiaries, divisions, and affiliates. 

ThinkOn may transfer personally identifiable information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of ThinkOn’s business or as part of a corporate reorganization, stock sale or other change in control. 

ThinkOn may disclose Contact Information in special cases where ThinkOn has reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating ThinkOn’s terms and conditions of use or may be causing injury or interference with ThinkOn’s rights, property, its Subscribers/Subscribers or anyone who could be harmed by such activities. 

THINKON IS NOT LIABLE OR RESPONSIBLE FOR THE PERSONALLY IDENTIFIABLE OR OTHER INFORMATION YOU CHOOSE TO SUBMIT IN FORUMS SUCH AS A BLOG OR ANY OTHER PUBLICLY ACCESSIBLE AREA OF THE SITE. 

Subscribers will receive notice when their personally identifiable information might be provided to any third party for any reason other than as set forth in this Privacy Policy, and the Subscriber will have an opportunity to request that ThinkOn not share such information. 

ThinkOn uses non-identifying and aggregate information to better design its Website and for business and administrative purposes. ThinkOn may also use or share with third parties for any purpose aggregated data that contains no personally identifiable information. 

D. HOW THINKON PROTECTS SUBSCRIBER INFORMATION

ThinkOn is committed to protecting the information it receives from Subscribers. ThinkOn takes appropriate security measures to protect Subscriber information against unauthorized access to or unauthorized alteration, disclosure or destruction of data. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, ThinkOn maintains appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on its system. While no computer system is completely secure, ThinkOn believes the measures it has implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.

E. ACCESSING AND UPDATING PERSONAL INFORMATION AND PREFERENCES

ThinkOn may provide mechanisms for updating and correcting the Subscriber’s personal information, in which case the Subscriber may modify or remove any of their personal information by logging into their account.

F. EMAIL CHOICE/OPT OUT

If the Subscriber no longer wishes to receive updates or notifications, the Subscriber may opt-out of receiving these communications by selecting the “Unsubscribe” link in the footer of ThinkOn’s email communications.

G. CHILDREN’S PRIVACY AND PARENTAL CONTROLS

ThinkOn does not solicit any personal information from children. If the Subscriber is not 18 or older, the Subscriber is not authorized to use the Site. Parents should be aware that there are parental control tools available online that can be used to prevent children from submitting information online without parental permission or from accessing material that is harmful to minors. 

H. DISCLAIMER TO SECURITY

By consenting to the Terms and Conditions of the Site and hence the Privacy Policy, the Subscriber consents that no data transmission over the Internet is completely secure. ThinkOn cannot guarantee or warrant the security of any information that the Subscriber provides to ThinkOn, and that the Subscriber transmits such information to ThinkOn at his/her own risk. 

I. COMPLAINTS & CONCERNS

For any privacy concerns, complaints or questions, please contact us at Ethics_Concerns@thinkon.com and we will respond to you within thirty (30) business days.

J. NOTIFICATION OF CHANGES

ThinkOn reserves the right to change this Privacy Policy from time to time at its sole discretion. If at some point in the future, there is a change to our Privacy Policy, unless ThinkOn obtains the Subscriber’s express consent, such change will only apply to information collected after the revised Privacy Policy took effect. The Subscriber’s continued use of the Site indicates his/her assent to the Privacy Policy as posted.

Review and Revision

This policy will be reviewed as it is deemed appropriate, but no less frequently than every 12 months.