Last updated: April 1, 2014
"Personal Information" or "Information" means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and/or (4) can be linked to that individual.
The Company may receive Personal Information from UK companies, including, but not limited to, name, postal address, telephone number, e-mail address, bank account, credit card number or other payment account number (including the three (3) or four (4) digit validation code for your debit/credit card).
The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party, or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
The Company works with third parties that provide services such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail delivery services, credit card processing and other similar services. The Company may share Personal Information that we receive from a UK company with these third parties to enable them to provide services. These service providers may be given access to Personal Information that we may receive from a UK company to the extent needed to perform their functions, but are restricted from using the Personal Information for purposes other than providing services for us. We require that our agents and service providers that have access to Personal Information received from a UK company (a) subscribe to the Principles, (b) are subject to the EU Privacy Directive or another adequacy finding, or (c) enter into a written agreement with us that requires them to provide at least the same level of privacy protection as is required by the relevant Principles.
The Company shall take reasonable steps to protect the Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. The Company cannot guarantee the security of information on or transmitted via the Internet. We ask that you do your part by, at a minimum, keeping any computer passwords you use to access the Internet or the website strictly confidential.
The Company shall take reasonable steps to ensure that Personal Information we process is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information.
If you want to review and, if necessary, correct personal information about you that the Company holds, you may contact the Company's legal department by sending an email to firstname.lastname@example.org. The Company may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. Finally, we are not responsible for removing or suppressing information from the databases of third parties with whom we have already shared Personal Information about you, or limiting their use of Personal Information about you.
Safe Harbor Enforcement and Dispute Resolution:
If you have any questions or concerns, please write to us at the address listed below. The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the Safe Harbor Principles.
In order to comply with the European Union's Safe Harbor Principles, the Company commits to the resolution of complaints about your privacy and our collection or use of your personal information. We have committed to resolve any complaints by European Union citizens relating to this policy, which cannot be resolved directly with our Company, through the American Arbitration Association.
If you have any questions regarding this policy, please contact:
Think Finance, Inc.
Attention: General Counsel
4150 International Plaza, Suite 400
Fort Worth, Texas 76109
If you do not receive acknowledgment of your complaint or your complaint is not satisfactorily addressed by the Company, you should then contact:
International Centre for Dispute Resolution
A Division of the American Arbitration Association
Case Filing Services
1101 Laurel Oak Road, Suite 100
Voorhees, NJ 08043
Toll Free Number in the U.S.: 877-495-4185
Fax: 877-304-8457 Fax number outside the U.S.:212-484-4178