Privacy Notice

Last modified: July 16, 2022
Preface
THORN (“Company” or “We”) respect your privacy and commit to protecting it through our compliance with the practices described in this notice.
This notice describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our Service and mobile application(s) that link or refer to this notice (our “Service”). This notice applies to the personal data collected through our Service, regardless of the country where you are located.
The Service may include links to third-party Services, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party Services, and we encourage you to read the privacy notice of every Service you visit.
Please read this notice carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Service, you accept and consent to the practices described in this notice.
This notice may change from time to time (see Changes to Our Privacy). Your continued engagement with our Service after any such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.
Data We May Collect About You
We collect and use different types of data from and about you including:
  1. Personal data that we could reasonably use to directly or indirectly identify you, such as your email address, and any other identifier we may use to contact you online or offline (”personal data”).
  2. Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Service feature.
  3. Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
  4. Non-personal details about your Service interactions, including the full Uniform Resource Locators (URLs), clickstream to, through, and from our Service (including date and time); page response times, download errors, or any phone number used to call our customer service number.
  5. If we combine or connect non-personal, technical, or demographic data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.
How We Collect Data About You
We use your personal information to provide you services, communicate with you, or perform other business operations, such as using the data to improve and personalize your experience. Examples of how we use the personal information we collect include:
  1. Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you create an account, subscribe to our service, participate in discussion boards or other social media functions on our Service, and when you report a problem with our Service.
  2. Automated technologies or interactions. As you interact with our Service, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above.
  3. Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators.
How We Use Your Personal Data
We use your personal data to provide you with the Service, communicate with you, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:
  1. Present our Service and provide you with the information, products, services, and support that you request from us.
  2. Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
  3. Fulfill the purposes for which you provided the data or that were described when it was collected.
  4. Notify you about changes to our Service, products, or services.
  5. Ensure that we present our Service content in the most effective manner for you and for your computer.
  6. Administer our Service and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
  7. Improve our Service, products or services, marketing, or customer relationships and experiences.
  8. Protect our Service, employees, or operations.
  9. We may use non-personal data for any business purpose.
Disclosure of Your Personal Data
We may share your personal data with:
  1. Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
  2. Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Service improvement and optimization). We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
  3. To fulfill the purpose for which you provide it.
  4. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  5. To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
  6. To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  7. To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
  8. We may share non-personal data without restriction.‌
Consent to Personal Data Transfer
We are based in the People's Republic of China. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own, including the People's Republic of China.
By submitting your personal data or engaging with our Services, you consent to this transfer, storing, or processing.
Your Personal Data Use Choices
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional Offers from the Company. If you do not want us to use your email address to promote our own products and services, you can opt-out by checking the relevant box located on the form where we collect your data or at any other time by logging into the Service and checking or unchecking the relevant boxes to adjust your account profile’s user preferences, or by sending us an email with your request to support@thorn.so. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the opt-out links on that message.
Our Service may, from time to time, contain links to and from the Services of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party Service or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.
    Accessing and Correcting Your Personal Data
    You can access, review, and change your personal data by logging into the Service and visiting your account profile screen.
    You may also send us an email at support@thorn.so to request access to, correct, or delete personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information’s accuracy.
    Data Security
    The security of your personal data is important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to us behind firewalls on servers employing security protections.
    The safety and security of your information also depends on you. Where we have given you a login code for access to certain parts of our Service, you are responsible for keeping this code confidential. We ask you not to share your code with anyone.
    Children’s Online Privacy
    We do not direct our Service to minors and we do not knowingly collect personal data from children under 16. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at support@thorn.so.
    If you have any questions about the content of these Terms of Use, please send an email to contact@thorn.so
    How We Collect Data About You
    We use your personal information to provide you services, communicate with you, or perform other business operations, such as using the data to improve and personalize your experience. Examples of how we use the personal information we collect include:
    1. Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you create an account, subscribe to our service, participate in discussion boards or other social media functions on our Service, and when you report a problem with our Service.
    2. Automated technologies or interactions. As you interact with our Service, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above.
    3. Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators.