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Privacy Policy

Updated: August 25th, 2021

Thinx wants to give you the best Thinx experience possible. This Privacy Policy (this "Policy") describes the privacy practices of Thinx Inc. as well as our family of affiliated companies ("Thinx", "we", or "us") with respect to personal information which we collect:

  1. when you sign up for, use, access or otherwise interact with shethinx.com or thinxforall.com (the "Sites) or other websites, mobile applications, online services, products, or widgets owned or operated by Thinx or that reference this Policy (collectively, including the Sites, the "Services"),

  2. in connection with our marketing activities,

  3. in other settings where we reference this Privacy Policy,

and how we use, share and store that information.

As you read this Policy please click "read more" for additional details on a topic. You can reach us at service@shethinx.com or the postal address in the "How to Contact Us" section below if you have further questions.

BY USING THE SERVICES YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY

Personal Data we collect may be stored and processed in the United States or any other country in which Thinx or its affiliates, subsidiaries, agents, or third party service providers maintain facilities and/or infrastructure, and by using the Services and submitting information to us, you consent to the transfer, processing and storage of such information outside of your country. Note that the United States is a jurisdiction in which the data protection regime may not provide the same level of security as those in the nation where you reside. Unless applicable law requires different security and protections to be applied in any given relevant jurisdiction, we apply the same principles in using, handling and transmitting data as described in this Privacy Policy in all of our operations. If you do not agree with any part of this Privacy Policy or our Terms and Conditions, please do not access or continue to use any of the Services or otherwise provide your Personal Data.

This Policy covers the following areas:

I. Information We Collect

II. How We Use Your Information

III. How We Share Your Information

IV. Data Security

V. Data Retention

VI. Cookies and Other Data Collection Tools

VII. How To Manage Your Privacy Settings

VIII. Children

IX. Region-Specific Disclosures

X. Third Parties We Don't Own or Control

XI. How to Contact Us

XII. Amendments

I. Information We Collect

Thinx collects information from users in connection with the Services.

We collect your Personal Data in a number of ways and for various purposes. "Personal Data" means information that relates to you and identifies you personally, directly or indirectly, either alone or in combination with other information available to us. Examples of Personal Data are a name, an online identifier, a contact address, social media reviews and ratings, and precise geolocation data.

We collect your Personal Data as follows:

We ask for and may collect personal information about you such as your name, address, phone number, email address, user name and password, date of birth, gender, age, personal interests, location (e.g., city or country), commercial information such as credit card information and other similar details directly from you when you sign up for our Services, register an account with us, or when you access or utilize one or more of our Services.

When interacting with our Services, data is automatically collected by the technology platforms providing the experiences, including without limitation information about the Sites that you visit and how you use them and any GPS-based, Wi-Fi-based, or cell-based location information ("Location Data"), and any other identifier that permits direct identifying, locating, or contacting of the device or user. Precise Location Data may be collected in ways such as through Bluetooth beacons, wireless carrier, based on WiFi location, and your web browser or mobile device may share certain data with Thinx as those devices interact with Thinx's Sites or mobile apps. This data includes: Device IDs, network access, storage information and battery information as well as cookies, IP addresses, referrer headers, data identifying your web browser and version, the date and time of the visit and how long you remained on our Sites, and web beacons and tags. Location Data may include the presence of the device, its signal strength and mobile network information, its manufacturer (Apple, Samsung, etc.) and model, and information about the device's interaction with the Services or business services. Thinx may combine this information with other information collected in connection with your use of the Services. More information about these practices is included in the Cookies and Other Data Collection Tools section below.

If you engage with us through a social media account we may collect account or profile information associated with that account. To the extent you connect an account managed by third parties such as social media sites (e.g., Facebook) with a Thinx account, you authorize Thinx to have access to information related to that account (as permitted by the terms of service of your account with that social media site) and agree that Thinx may collect, store and use such information in accordance with this Policy. If you do not want to provide us with this data, please modify the privacy settings on your applicable social media account.

If you are accessing third-party products and services that we have made available to you via the Services, we may collect your name, email address, city, and payment information, and other information, including any personal information that the third party service makes available to us, in connection with your registration for or access to those products and services. You should check your privacy settings on these third party services to understand and change any information sent to us through these services.

When you purchase or browse Thinx products online, we collect contact, purchase and browsing data. As you browse our products online or submit product inquiries, we may collect Personal Data such as your contact information and information related to your account and your specific requests. We also may collect information regarding a completed purchase (payment amounts and methods, billing and shipping information, returns and other transaction information). We may associate purchase and browsing information to an account you have registered with us and combine it with information relating to all interactions with us.

When you shop at Thinx pop-up stores, we may collect contact and purchase information. When you are shopping at a Thinx pop-up store we collect any contact and purchase information that is necessary to process your transaction. For example, we may collect payment information and email address (to provide e-receipts). In addition, we may collect your email and phone number(s) in order to send you information about products and Surveys or Promotions (to the extent you have provided the consents required for such communications under applicable law and not opted out of such communications).

If you participate in or utilize or sign up for, as applicable, contests, sweepstakes, loyalty programs, surveys, referral programs, wear trial programs, discounts, research activities or initiatives or promotional sales ("Surveys or Promotions") being offered by Thinx, we may collect contact, demographic and eligibility information or other Personal Data. Promotions may also be run by a Thinx service provider or co-branded with one of our business partners. In such instances, Personal Data may be collected directly by and/or shared with Thinx, the service provider and/or business partner, including for marketing purposes. Personal Data associated with a Survey or Promotion may be shared with partners that sponsored or were involved with the Survey or Promotion. To the extent a Survey or Promotion collects information from you about your periods or period product usage, such information will be used to help us better understand your needs and provide you with additional information that you can incorporate into your evaluation of Thinx products and services and for purposes reasonably related to the Survey or Promotion and as otherwise described herein or the privacy notice governing such Survey or Promotion and only to the extent permitted by applicable law.

We collect Personal Data when you communicate with us and relating to your interactions with promotional campaigns, advertising on the Services or Thinx online communities. We collect Personal Data when you communicate with us (such as your requests for technical support, online services, product information or to any other communication you initiate) and sign up for promotional campaigns or to receive other marketing or informational materials via email, text message, push notifications or other media. Additionally, we may collect your Personal Data when you click on advertisements, submit content, make reviews, interact with our social media pages, or contribute to message boards, comment fields, blogs, and other media forums sponsored by or affiliated with Thinx.

We allow our trusted ad partners to collect information about you when you use our Services. These companies may collect information from you (e.g. subject of advertisements clicked or scrolled over) during your visits to the Services in order to provide advertisements about goods and services likely to be of interest to you. Our ad partners may use the data they collect from you for a variety of other purposes, including (a) in conjunction with advertising that appears on other websites, (b) to determine the popularity of certain content and analyze and track website traffic, statistics, advertisement data and other interaction with ads and the websites on which they are served, and (c) to measure the effectiveness of web-based and email ads. The ad partners that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

Within the past twelve months, Thinx has collected the following categories of consumers’ Personal Data: (i) name (ii) home address (iii) email address (iv) telephone number (v) age or date of birth, (vi) physical characteristics or description (vii) internet protocol address or other unique identifiers (viii) internet activity including browsing and search history, and interactions with websites and advertising,(ix) geolocation data, and (x) inferences drawn from the above information to create consumer profiles.

II. How We Use Your Information

We use the information we collect to:

Provide our products and services and customer support

We use Personal Data to process and deliver product orders and to notify you of the status of your order and to address your requests, inquiries, and complaints. For example, data may be used to troubleshoot problems with your experience with the Services. If you contact our customer service (or vice versa), we will use Personal Data such as your order information and contact history to process your request and provide you with the best service possible.

Customize experiences on our Services and gain insights into our customers and communities and operate, maintain, improve, and promote the Sites and the Services

We use Personal Data to present products and content tailored to you, your interests and location. Our use of Personal Data may also help you engage with other users of our Services. We also use Personal Data to better understand our customers and other individuals who access our Services which helps us develop more interesting and relevant products and services and to improve our Services.

Promote Thinx's business through direct mail and online advertising and marketing activities to you and others

We use Personal Data in connection with advertising and online and offline marketing campaigns, to provide you with information on the products and Services that we think are most relevant to or appropriate for you and to track the success of our marketing activities. We display ads on the online platforms that we own and operate. We also use third party ad partners to display ads for Thinx on third party websites and apps ("Retargeting"). Retargeting technologies analyze the information collected about your interactions with Thinx Sites as described in relation to marketing above and information about you obtained from reputable third party sources parties, including your cookies, and display advertisements matched to your interests, as inferred from your online activities. Ads may also be based on the content of the pages on which they appear and Location Data may be used to serve ads that are more relevant to you based on your particular location. For most devices, you can control the interest-based ads you see as a result of Retargeting by changing the privacy settings of the device itself or changing the privacy settings of your browser but note that our Sites generally are not configured to respond to web browser do-not-track signals.

Connect you with third-party products and services

We use the data we collect to provide third parties with the information required to enable those third parties to fulfill products or services that a Thinx user has ordered. 

Communicate with you

We may use Personal Data such as account information to contact you (through, for example, email or SMS messages (to the extent you have provided the consents required for such communications under applicable law and not opted out of such communications)) about the Thinx products or Services you have purchased or used and to notify you of other products, promotions and Services we think may be of interest to you. We may use your information to respond to requests for support, online services, product information or to any other interaction you initiate. We also may use your Personal Data to notify you of promotions and other special offers. Irrespective of your privacy settings, we may send you notifications pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to products or Services you have purchased or use.

Administer and Analyze Surveys or Promotions

In connection with Surveys or Promotions we may use Personal Data to verify identity, communicate with you about the Survey or Promotion or about other offers, conduct market research, and ask you questions relating to the Survey or Promotion. If you participate in questions and surveys regarding the Survey or Promotion we may share your responses with business partners for their own market research and communication purposes to the extent permitted by applicable laws. In connection with certain Surveys or Promotions such as research initiatives or wear trial programs Thinx may use Personal Data to evaluate the performance, comfort, usability and applicability of Thinx products. In some cases the Survey or Promotion may treat your Personal Data in a way that differs from this Privacy Policy in which case the Survey or Promotion shall provide notice to you of the privacy practice governing that collection of information in connection with that Survey or Promotion. To opt-out of this kind of collection and sharing, you can decline to answer these kinds of questions or decline to participate in the applicable Survey or Promotion altogether. 

Operate and analyze our business

We use Personal Data to analyze trends and statistics and otherwise monitor usage and performance of the Services, for purposes of data aggregation and centralization, to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Thinx, and for sales, supply chain and financial analysis purposes.

To protect our legitimate business interests and legal rights

Where required by law or where we believe it is necessary, we use the data we collect from you to protect our legal rights, legitimate interests and the interests of others. This includes using such data to comply with any applicable legal or regulatory requirements or other legal obligation, to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to protect the integrity of our Services, employees and users, to identify and prevent error, negligence, and crime, for audit functions, to enforce our agreements (such as terms of use, terms of sale and this Privacy Policy), and to resolve disputes. 

We may augment Personal Data we collect from you with information provided by reputable third party sources

We may combine Personal Data with information we receive from joint marketing partners, public databases, publicly available pages on social media platforms and other third parties, to give us better consumer insight into your needs, help us tailor our communications with you, deliver marketing messages to you and improve our business. For example, we may obtain updated email address information from email-change-of-address vendors or purchase third-party marketing data and address information and add it to our database to send you offline marketing materials, better direct our advertising and provide pertinent offers we think you are more likely to be interested in. You can opt-out of us combining your personal information with the information lawfully collected from third parties by contacting us using the contact details set out below.

III. How We Share Your Information

Thinx will share your Personal Data with third parties in the following ways:

To Affiliates

We will disclose Personal Data as well as, for the avoidance of doubt, anonymized and aggregate information, to businesses controlling, controlled by, or under common control with, Thinx Inc. for the use purposes and under the conditions outlined above.

To Partners and Suppliers

Thinx may (a) coordinate the provision of services and products to you through third party service providers, such as logistics and fulfillment or electronic infrastructure providers and (b) partner with third parties in order to promote, support, enable or expand Thinx's business and products and services or enable those third parties to deliver content or advertise the products and services of Thinx. We may share Personal Data with those service providers and partners and they may have access to or process your Personal Data. For example, Thinx may use third-party providers to assist us with delivering, marketing and advertising our products and Services, processing payments you make to us, delivering customer service and support, and for e-commerce order fulfillment. In addition, with your knowledge and consent, our Services may gather and transfer information from other applications, functions and tools within your mobile device.

With Social Networks

Our Sites and apps will, in certain circumstances, provide you with social plug-ins from various social networks. If you choose to interact with a social network such as Facebook or Twitter (for example by registering an account), your activity on Sites or via our apps will also be made available to that social network.

For Joint Marketing and Interest-Based Advertising

We disclose various types of information for purposes of interest-based advertising, including third party interest-based advertising. From time to time Thinx might establish joint marketing relationships with other persons or entities whom we believe trustworthy and have privacy practices that are consistent with ours. In such cases and where permitted by applicable law we might exchange, share and/or cross-reference information, including information about you that will enable such persons or entities to contact you (for example through web, mobile app or other advertising) regarding products and services that may be of interest to you. If you would like to opt out of our exchange of your information with other marketers, please let us know by writing to our Support Team. To learn more about third parties that are members of self-regulatory programs such as the Network Advertising Initiative, please visit the NAI's website (www.networkadvertising.org) which will allow you to opt out of interest-based advertising by one, or all, NAI members.

In Discussion Forums

Content you post through the Services such as reviews, commentary on discussion boards or blogs, and certain social networking preferences (e.g. pages you "Like" or "Recommend") may be accessible by other users and companies and may appear on other websites or web searches, and therefore this information could be read, collected, and used by others. Thinx cannot ensure the privacy of any Personal Data included in such user generated content. Please note that Thinx does not necessarily verify, endorse, or agree with any content posted in discussion forums. 

In Connection with Business Transfers (country specific disclosures may apply)

Personal Data may be disclosed or transferred as part of, or during negotiations of any purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, securitization or financing involving Thinx. In the event Thinx goes through a corporate transaction resulting in a structural change, such as a merger, sale of assets, acquisition by another company, bankruptcy, insolvency, or dissolution, to the extent permitted by applicable law Personal Data may be transferred to a third party as part of such event and thereby become subject to the privacy practices of that third party, which may materially different than those of Thinx. 

With Your Consent or at Your Direction

Thinx will share your Personal Data with other third parties (different from those described in this section) when we have your consent to do and when you intentionally direct us to do so or when you use our Services to intentionally interact with third parties.

For Legal Compliance and Special Circumstances

We may be required, subject to applicable law, to disclose your Personal Data if: (i) it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority, (ii) such a disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) it is necessary to protect our legal rights or property (such as enforcing or applying applicable terms and conditions and other agreements, including the Services' terms of service), or (iv) it is necessary to protect the legal rights or property or physical security of others, or for the prevention or detection of crime and such disclosure is lawful. For residents of the European Economic Area our disclosure is limited to situations where we are permitted to do so under applicable European and national data protection laws and regulations.

Please note that while Thinx does not sell its consumers Personal Data to third parties, the definition of “sale” or “sell” is broadly defined under the California Consumer Privacy Act (CCPA), so as to potentially encompass marketing activities Thinx employs involving the sharing of your Personal Data with third parties. See Cal. Civil Code §1798.140(t).

Within the past twelve months, Thinx has “sold” (as we read the CCPA’s definition of that term) the following categories of consumers’ Personal Data: (i) name (ii) home address (iii) email address (iv) telephone number (v) internet protocol address or other unique identifiers (vi) internet activity including browsing and search history, and interactions with websites and advertising,(vii) geolocation data, and (viii) inferences drawn from the above information to create consumer profiles.

California consumers may opt-out of the above Thinx activities that may constitute “selling” Personal Data as defined under the CCPA by using our Do Not Sell My Personal Information opt-out form.

Otherwise, within the past twelve months, Thinx has disclosed the following categories of consumers’ personal data for a business purpose (not constituting a “sale” under the CCPA) to third parties: (i) name (ii) home address (iii) email address (iv) telephone number (v) internet protocol address or other unique identifiers (vi) internet activity including browsing and search history, and interactions with websites and advertising,(vii) geolocation data, and (viii) inferences drawn from the above information to create consumer profiles.

IV. Data Security

Thinx takes precautions to secure your personal information and protect it from loss, theft, unauthorized access, destruction, use, modification and disclosure. Such measures include technological, physical and organizational safeguards that are appropriate given the sensitivity of the personal information, including maintaining controlled access to electronic and paper documents and files, and using appropriate technology safeguards such as passwords firewalls and encryption as well as non-disclosure or confidentiality agreements as we deem appropriate to protect your data. However, please note that Thinx's security measures may change or be unavailable from time to time and no data transmission over the Internet or any wireless network is 100% secure.

V. Data Retention

Thinx will retain Personal Data for as long as needed to provide the service to you (for example, as long as you have an online account with us) or as needed to fulfill our own obligations, such as preventing fraud, meeting regulatory requirements, resolving disputes, improving our services or maintaining security, and in each case, as consistent with applicable law. We may retain non-personal information that has been sufficiently aggregated or anonymized for a longer period.

VI. Cookies and Other Data Collection Tools

Thinx and its partners use various technologies to collect information when you use our Services, including sending cookies to your device and using web beacons. By using the Services you consent to the use of such technologies, including cookies, advertising IDs, geolocation, and pixel tags, to collect information about you. These technologies help us personalize your use of our Sites and mobile applications, customize the Services, and mitigate risks and the potential for fraud. These technologies are also used by Thinx and its advertising partners to deliver ads to you based on your interests and online activities.

How We Use Cookies

When you access or use the Services, our web server may send a cookie to your device. "Cookies" are small data files placed on a device's hard drive or memory when you interact with a website or view a message. Among other things, cookies support the integrity of our account creation process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may use cookies to:

  1. Remember that you have visited us or used the Services before and personalize our content for you and remember your preferences (for example, your choice of language or region).

  2. Ensure we have enough capacity to accommodate all of our users and that users are finding what they are looking for easily and do not encounter technical errors.

  3. Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

  4. Helps us and our ad partners to deliver ads or messages that are relevant to you and your interests. We may also share this information with third parties for this purpose. For example, these cookies allow us to identify and send you messages about items you have left in your cart and make other purchasing recommendations.

We Use Third-Party Cookies

We may allow third parties to collect information via the Services through cookies, third party plug-ins and widgets. Third party cookies enable third party features or functionality to be provided on or through the Sites (e.g., we may use Google Analytics and Google Adwords to collect and process certain analytics data). Note that you may visit https://youradchoices.com/appchoices or https://www.youronlinechoices.eu to learn about the options that some of the third parties we work with offer for opting out of certain ad targeting activities. You will need to visit those websites from each browser and device that you would like to be covered by your opt-out. Because the opt-out tools may depend on cookies, you may need to visit these sites again to reinstate your preferences if you delete your cookies.

How We Use Web Beacons

Some of our websites and Services may contain electronic images called "web beacons". Web beacons are objects embedded in a web page or email which are used to check if a user has accessed content. In addition to allowing us to count how many persons read our messages, web beacons allow us to develop statistical information about the activities and features that most interest our users in order to provide more personalized content.

Do Not Track Browser Signals

Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking across websites. Unless required by applicable law our Sites are not generally configured to respond to DNT signals. We and third parties operating on the services may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.

If you reside in a jurisdiction that mandates Thinx respond to DNT signals and wish to opt-out of cookies or other data collection technologies, please write to our Support Team at service@shethinx.com. You also can learn more about cookies by visiting https://www.allaboutcookies.org or https://ww.aboutads.info/appchoices, which include additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. For most mobile devices, you can control the interest-based ads you see in two different ways: (1) changing the privacy settings of the device itself; and (2) changing the privacy settings of your browser. In addition, please note that if you use ad blocking software on your device, this may interfere with certain features and cause a disruption of service. 

VII. How To Manage Your Privacy Settings

We provide you several ways to manage your privacy settings:

Update or Delete your Personal Data

You may update or delete and deactivate certain of your Personal Data by signing into and managing your Thinx account or, if your account does not so permit, by contacting us at service@shethinx.com. In addition, depending on the nature of your account, your account management page may allow you to control certain aspects of how information that you submit to the Services is used or shared. In all cases you may contact us specified in the How to Contact Us section below in order to exercise your rights under applicable privacy laws.

Set your preferences to opt-out of communications

There are several ways for you to control how Thinx communicates with you:

  1. Email and Mobile Messages: You have the ability to unsubscribe to promotional emails or text messages received from us by following the instructions in those emails or text messages. If you use more than one Service then opting out of the emails relating to that Service will not necessarily stop you receiving emails from other Services.

  2. Push Notifications: To the extent applicable you can manage the type of push notifications you receive from Thinx (if any) by modifying the settings of your Thinx applications and websites. You may set your mobile device to not allow push notifications from us. 

  3. Postal Mail: You may stop receiving marketing materials sent by postal mail from us by writing to our Support Team or following the opt-out instructions that may be included within those communications.

You may also contact us at service@shethinx.com to indicate or update your communication preferences. to indicate or update your communication preferences. If you like, you may use one of the following statements in your message to us: 

-I prefer not to receive email advertisements, such as updates regarding products and services, special promotions or upcoming events. 

-I prefer not to receive direct mail advertisements, such as periodic catalogs and mailings regarding products and services, special promotions or upcoming events.

Opt out of information exchange with other marketers

If you would prefer for us not to exchange your information with other companies, please write to us through our Support Team or the mailing address below.

Manage your Location Data through your mobile device

Most mobile devices give users the ability to control whether location signals are enabled. Disabling location signals will not allow us to collect your Location Data (by virtue of the location of your mobile device) and may impact the operation of a Service. If you have questions about how to set the location preferences for your device, you can contact your mobile service carrier or your device manufacturer. 

If you unsubscribe to email marketing messages it may take up to 10 business days before you stop receiving emails and we may still send you non-promotional communications, such as digital receipts (if applicable) and communications about your account. Requests to stop or update postal mail marketing communications may take up 6-8 weeks to process. 

VIII. Children

The Services are intended for general audiences and is not directed to persons less than 13 years of age and we do not knowingly collect Personal Data from those persons. If you become aware that personal information about your child has been provided to Thinx without your consent, please contact us. If we become aware that a child under 13 has provided us with Personal Data, we will take steps to delete the information, except where we are required by applicable law to keep it.

IX. Region-Specific Disclosures

Residents of Canada

If you reside in Canada, your consent to use or share your Personal Data for the marketing purposes identified above is optional and is not required as a condition of obtaining the Services. If you do not want your personal information to be used or shared for these additional purposes, please write to us through our Support Team or the mailing address set out below. We do not collect social insurance numbers from Canadian consumers.

Residents of the European Economic Area and the United Kingdom (“UK”)

a. You may choose not to provide Thinx with your Personal Data. If you so choose, however, you may not be able to enjoy the full range of Services. 

b. Residents of the European Economic Area and UK have the legal right to request: (i) access to the Personal Data we have collected from you and request information in relation to its processing; (ii) correction of Personal Data (in case of incomplete or inaccurate data); (iii) deletion of your Personal Data; (iv) restriction of processing under certain circumstances (including when the accuracy of your Personal Data is contested and when the processing is unlawful) and (v) to receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, subject, however, to legal restrictions which may apply. You also have the right to object to the processing of your Personal Data in certain circumstances, including opting-out from the use for direct marketing purposes and processing based on our legitimate interests or tasks in the public interest. Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time. In addition you can ask not to be subject to a decision which is based on automated processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us. In order to exercise these rights at any time, please visit our "Privacy Request Form" or contact us through our Support Team or at the physical address listed below mentioning your electronic contact details and identity sufficiently to allow Thinx to verify your identity. Solely to the extent permitted by applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

c. Sensitive Data. A limited amount of the data that we collect may be considered personal health or related data under the European Data Protection Directive or General Data Protection Regulation and its interpretation by applicable authorities. We use this data to better understand your needs and provide you with additional information that you can incorporate into your evaluation of Thinx products and services.

d. European and national data protection laws and regulations permit the sharing of Personal Data relating to users who are residents of the European Economic Area with third parties only under certain circumstances. If you reside in the European Economic Area, we will only share your Personal Data as described under the heading "How We Share Personal Data" if we are permitted to do so under applicable laws and regulations. Thinx shall only transmit your personal contact details to third parties for the purposes of e-mail marketing if you have provided us with your informed, freely given, explicit and prior consent.

e. In order to use our Services, Thinx may require you to agree to the transfer, storage, and/or processing of your Personal Data in the United States. In situations where Personal Data is transferred outside of the European Economic Area or the UK, Thinx uses mechanisms for international data transfer including the European Commission-approved standard contractual clauses and consent. In addition, in relation to Personal Data Thinx Inc. has self-certified that it complies with the EU-U.S. Privacy Shield Framework ("Privacy Shield") issued by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member states. For EU Personal Data received in the United States under the Privacy Shield, Thinx has self-certified that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability. If there is any conflict between the standards of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles govern. Under the Onward Transfer Principle, we may remain liable for the processing of European Personal Data that we transfer to our third-party agents or service providers. In some instances, we may also be required to disclose Personal Data to comply with valid requests from public authorities, including for national security or law enforcement purposes. In compliance with the Privacy Shield, Thinx commits to resolve your complaints concerning data privacy and our collection or use of your Personal Data. We welcome you to bring any concerns directly to us at our Support Team or other contact mechanism specified in the How to Contact Us section below. Thinx has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Thinx, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or you may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers. Under certain circumstances, you also may be able to invoke binding arbitration to address complaints about Thinx's compliance with the Privacy Shield Principles. Further to the extent permitted by applicable law you will be informed of any disclosure by Thinx of your Personal Data to U.S. enforcement authorities. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

f. If you are an individual in the European Economic Area or UK, we collect and process information about you only where we have legal bases for doing so under applicable laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

  1. We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;

  2. It otherwise satisfies a legitimate interest in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interest, such as for research and development, to market and promote the Services (e.g, to allow you to participate in our special activities, offers or programs);

  3. You give us consent to do so for a specific purpose; or

  4. We need to process your data to comply with a contractual obligation. For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.

  5. We need to process your data to comply with a legal obligation.

g. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us. You may also contact your local data protection authority within the European Economic Area or the UK for unresolved complaints.

Residents of California

California law, including the California Consumer Privacy Act (CCPA), provides that California residents have the following rights with respect to their Personal Data collected by businesses subject to the CCPA: (i) to opt-out of the “sale” (as defined under the CCPA) of their Personal Data; (ii) to access their Personal Data in a format transmittable to another entity; (iii) to deletion of their personal information; (iii) to not be discriminated against due to exercise of the above-listed rights, such as through a denial of goods or services, receiving a different level or quality of goods or services, or being charged different prices for goods or services, and (iv) to receive, pursuant to a verifiable consumer request, a disclosure of the following requested information: (a) the categories of sources from which the consumer's Personal Data is collected; (b) our business or commercial purpose(s) for collecting or selling Personal Data (also disclosed in this Privacy Policy); (c) the categories of third parties with whom we share Personal Data (also disclosed in this Privacy Policy); (d) the categories of personal information we have collected about that consumer; and (e) the specific pieces of personal information we have collected about that consumer. If you are a California resident and would like to opt-out of the “sale” of your Personal Data, please use our “Do Not Sell My Personal Information” opt-out form. To submit a CCPA request to know more about the categories and specific pieces of personal data we collect, use, and disclose or a CCPA request to delete your Personal Data please visit our "Privacy Request Form". CCPA right requests may also be submitted to Thinx by contacting us as specified in the How to Contact Us section below. Once an individual rights request has been submitted, Thinx may ask you for additional information in order to verify your identity or to provide additional details to help us respond to your request. This may include your name, email address, phone number or other details related to your use of the Services. Where applicable, these requests can be submitted by an authorized agent in accordance with the applicable law. Please note that in certain circumstances, we may refuse to act or impose limitations on your rights, as permitted by the applicable law. Please note we are not required to respond to requests that are made more than twice in any 12-month period by the same California consumer.

X. Third Parties We Don't Own or Control

This Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. For example, if you choose to pay through a third-party mechanism offered on our website, the information you choose to share with that third-party will be treated in accordance with that third-party's privacy policy. This Policy does not apply to, and we are not responsible for, for the content of such third party features or the privacy practices, including third-party cookies, web beacons, or other tracking technologies, of such third parties. We encourage you to read the privacy policies of each and every device, website, and service that you use.

XI. How to Contact Us

Thinx welcomes questions and comments about this Privacy Policy. You can contact us by emailing us at service@shethinx.com or writing to us at:

Thinx INC.

Attention: Privacy Office

PO Box 158

Eastchester NY 10709

XII. Amendments

We may change this Policy from time to time. The most current version of this Policy will be effective at the time it is posted. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Policy. If you have a registered account, we may notify you of any changes to our Privacy Policy via email and/or we may ask you to affirmatively acknowledge and consent to the changes the next time you use our Services.