Think Data Group Privacy Policy
Last Updated: October 8, 2024
This privacy policy (“Policy”) applies to personal information collected, processed, and sold by New Gold Ventures, LLC dba Think Data Group, a Massachusetts limited liability company (“Think Data Group” or “we”). We provide data monetization and data strategy services to our Clients who are data owners, sellers, buyers, or users (each a “Client”). We do not monetize data from online visitors to our website, https://thinkdatagroup.com (the “Site”). Capitalized terms not defined herein shall have the meaning given to them in our Terms.
1. Applicability
This Policy applies to the personal information we process from third party sources, and from the Site. Personal information, as used in this Policy, means information that identifies, relates to, or could reasonably be linked with you or your household. This Privacy Policy explains our information practices, the kinds of personal information we may process, how we use and share that personal information, and how you can exercise the choices you may have.
Personal information does not include:
Publicly available information from federal, state, or local government records.
Aggregate Data (defined below).
Users with disabilities who wish to access this Policy in an alternative format can contact us by calling us at: (833)-THINKDG or (833) 844-6534; emailing us at: info@thinkdatagroup.com; or sending us U.S. Mail to: PO Box 2, Whitinsville, MA 01558.
2. Purpose of Collection
Think Data Group provides strategic, brokerage and other data related services in support of Clients so that agencies and brands can use their data for offline, digital, and CTV advertising, analytics, and measurement. We advise Clients on how to build data segments with their data to help marketers perform “cross-channel” marketing. The personal information we sell may be used for targeted advertising by our Clients or third parties.
By visiting the Site or agreeing to a contract that refers to this Policy, you agree to be bound by this Policy. You may not use this Site or become a Client if you do not agree with this Policy.
Our Clients manage their first party data and will retain that data based on each of their specific retention policies. We assume no responsibility for the personal information collection of our Clients.
We may change this Policy at any time by posting the revised Policy on the Site along with changing the “Last Updated” date above. Please check back periodically for the newest Policy.
If you have any questions about this Privacy Policy, or the practices discussed herein, please contact us at info@thinkdatagroup.com.
3. Sensitive Personal Information and Children’s Privacy
Neither the Site, nor our Services for our Clients, are directed toward or intended for children under the age of 18. We do not collect, and we are forbidden from processing or selling, personal information from any person we or our Client(s) have actual knowledge is under the age of 18. Users under 18 years of age are not permitted to use and/or submit their personal information at the Site. Think Data Group does not knowingly solicit or collect personal information from people under 18 years of age. If you believe we have the information of your child, please contact us at info@thinkdatagroup.com or request deletion through our webform below.
We do not and have not for the past 12 months collected, processed, shared, or sold sensitive personal information, as defined by applicable laws, such as a Social Security number, driver’s license number, state identification card number, passport numbers, account log-in information, financial accounts, debit or credit card numbers used in combination with any required security code, access code, password, or log-in credentials; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; the contents of a consumer’s U.S. mail, electronic mail, or text messages; genetic data; sex life or sexual orientation; gender identity; mental or physical health condition, treatment, or diagnosis; genetic or biometric data for the purpose of uniquely identifying an individual; or citizenship or immigration status.
4. Third Party Privacy Policies
The websites of our Clients, social media sites, and advertising publishers, applications on which they place advertisements, and any third party websites linked to one of our Clients’ sites, may also collect personal information from you for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you. Although we choose our Business Partners (defined below) carefully, Think Data Group is not responsible for, has no liability for, and has no control over the privacy practices of websites and mobile applications operated by our Business Partners, and any other third parties. Please read the applicable privacy policies of such websites and mobile applications you visit to determine how they handle any information they collect from you.
5. Sources of Information
We collect personal information from the following categories of sources:
From third parties who interact with individuals, for example from loyalty program providers, advertisers, or consumer goods companies.
Directly from our Clients.
Directly and indirectly from activity on the Site as set forth in Section 8 below.
From third-party data brokers or aggregators.
From publicly available sources.
6. Categories of Information We Process
We have processed the following categories of personal information within the last twelve (12) months:
7. How we Use your Personal Information
Think Data Group sells, shares, or licenses personal information from third parties as described herein to third parties via platforms in connection with our business, including to our Clients and other third parties (collectively our “Business Partners”). This information may be categorized to create audience segments with common interests, intent, or other characteristics. The information we share may also be combined with first or third party data.
Without limiting the foregoing, in general we use your personal information for one or more of the following business purposes:
To fulfill or meet the reason for which the information is provided.
To provide your information to third parties that provide you with e-mail, direct mail and telemarketing messages concerning certain third-party products and/or services, that they believe may be of interest to you.
To carry out our obligations and enforce our rights, including without limitation arising from the Site’s Terms and Conditions.
To improve the Site and better present its contents to you.
For customer service purposes and to respond to inquiries from you.
For testing, research, analysis and product development.
As necessary or appropriate to protect our rights, property or safety, and that of our clients or others.
To evaluate or conduct a 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, in which personal information held by us is among the assets transferred.
With your consent, as prescribed by applicable law.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without first updating this Policy.
8. Automatic Collection of Personal Information
IP Addresses/Browser Type. Through the use of analytics and other applicable tools, we may collect certain non-personally identifiable information about you when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use this information to improve the design and content of our Services and to enable us to personalize your experience. We also may use this information in the aggregate to analyze Site usage.
Cookies. When a user visits the Site, we place cookies, trackers, web beacons, or similar files (collectively, “Cookies”) to assign a unique identifier to the applicable user’s computer or other device. A Cookie is a piece of data stored on your hard drive containing personal information about you. We may use Cookies to improve the quality of the Site and our Services, including for storing user preferences and tracking Site-user trends (such as pages opened and length of stay at the Site). Most internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions below. Even in the case where a user rejects a Cookie, they may still use the Site; provided, however, that certain functions of the Site may be impaired or rendered inoperable if the use of Cookies is disabled.
9. How We Share your Personal and Business Information
In the preceding twelve (12) months, we have disclosed the following categories of personal and business information for a business purpose:
Category A. Identifiers
Category B. Internet activity
Category C. Commercial Information
Category D. Business Information
We disclose your personal information to the following categories of third parties:
Vendors and Service providers, for business purposes only.
Third parties who purchase and/or license your personal and business information (but not Sensitive Information) for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. If a third party purchaser of your personal or business information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt-out of further sales, unless the right to resell it was secured by third parties at the point of collection.
Third parties to whom you authorize us to disclose your personal information in connection with the products and/or Services that we provide to you.
In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:
Category A. Identifiers.
Category C. Commercial Information
In the preceding twelve (12) months, we have sold the above referenced categories of personal and business information to the third parties who purchase and/or license your personal information for:
Analytics (Clients, third party service providers)
Customer Acquisition (Clients, third party service providers)
Data Enrichment (Clients)
Enhanced Targeting (Clients)
Market Research (Clients, third party service providers)
Multi-Channel Marketing (Clients)
In addition to the foregoing, we share your personal information for the following purposes with the respective third parties noted below, as applicable.
Advertisers and Other Third Parties. Think Data Group discloses information, including information that identifies you, to other third parties. Third parties Think Data Group discloses information to may engage in Online Behavioral Advertising and the collection of Multi-Site Data as defined by the Digital Advertising Alliance. These third parties may use the information they receive about you to create other identifiers, such as the United ID 2.0 (UID2) identifier, which they use for targeted advertising purposes.
Vendors and Service Providers. We may disclose any information we receive to vendors and service providers retained in connection with the provision of our Services. This includes, for example, vendors that provide services to Think Data Group for marketing, analytics, fraud prevention, account security, and customer service, including through the use of artificial intelligence services. These service providers are prohibited from using the information we provide for purposes other than performing services for Think Data Group.
Merger, Sale, or Other Asset Transfers. We may disclose your information, including information that identifies you, to effect a corporate transaction involving Think Data Group, including a merger, acquisition, or otherwise, and to support the sale or transfer of our business assets or equity interests.
As Required by Law, to Enforce Laws and Similar Disclosures. We may disclose your information, including information that identifies you, to defend ourselves in litigation or a regulatory action; when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, or respond to a government request; or as needed to support auditing and legal compliance functions.
Analytics. We use third-party services (such as Google Analytics) to help us understand how visitors interact with our website and to help improve our user experience.
Aggregate Data. We may also share aggregated and anonymized personal information with anyone for any lawful purpose, including without limitation to our Business Partners, so long as such aggregate data does not identify individuals (“Aggregate Data”). In addition, we may share Aggregate Data with Business Partners and the general public, such as usage statistics or demographic trends regarding how you and others may interact with the Internet.
Consent. With your consent.
10. California Data Broker Consumer Request Reporting
11. Data Retention
We may retain all categories of your personal information that we process for the maximum period permitted by applicable law, but in no event longer than 7 years. We may also use certain criteria to determine whether and when to delete certain categories of processed personal information including:
• Date of collection.
• Frequency of consumer interaction with our Business Partners.
• Last interaction the consumer had with our Business Partners
• Whether the purpose of collection has been completed.
12. Security
We endeavor to safeguard and protect your personal information. Our Clients move personal information from their environment into systems managed by third parties.
We protect the personal and business information we process both online and offline (to the extent that we maintain any personal information offline). All personal information is encrypted with advanced TLS (Transport Layer Security). Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All personal information is restricted in our offices. Only employees or third-party agents who need the personal information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all personal information. Employees not adhering to our firm policies are subject to disciplinary action.
Any servers that we store personal and business information on are kept in a secure physical environment. We also have security measures in place designed to protect the loss, misuse and alteration of personal and business information under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Hackers that circumvent our security measures may gain access to certain portions of your personal and business information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal and business information will be absolutely secure.
In compliance with applicable federal and state laws, we shall notify our Business Partners and third party sources and any applicable regulatory agencies if we learn of an information security breach with respect to your personal and business information. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
If you have any questions about these security practices, please email us at info@ThinkDataGroup.com
13. Your Choices
Under applicable laws, you may have some or all of the below rights in and to your personal information. Please note that while some of the options below may assist you in opting out of advertising tailored to you, you will still see advertisements on certain sites.
a. Universal Opt Out of Sale. To opt out of the sale of your personal information by Think Data Group, see here. We do not control how our clients and Business Partners respond to the universal opt out mechanism.
b. Think Data Group Marketing Opt Out. You may opt out of receiving promotional e-mail from Think Data Group. To do so, please click here. For e-mail, individuals may opt out at any time by using the unsubscribe mechanism within the e-mail, which allows individuals to manage their subscription preferences regarding Think Data Group offers. This mechanism does not allow a user to opt out of receiving transactional e-mail, such as registration confirmation, updates, and responses to direct requests.
c. Right of Access. You may request access to the personal information that Think Data Group has processed about you. If you choose to request such access, you will receive both an email confirming our receipt of your request and a follow-up email with the information addressing these questions. Specifically, you may ask us to tell you: (a) the categories of personal information we have processed about you; (b) the categories of sources from which the personal information was collected; (c) the business or commercial purposes for which Think Data Group has sold, or shared your personal information; (d) the categories of third parties to whom Think Data Group has disclosed your personal information; and the specific pieces of your personal information Think Data Group has processed and sold. If you request such access, we will provide you the information by email in a portable and readily readable format.
d. Right to Know. You have the right to know the categories and specific pieces of personal information that we may process and sell about you, the categories of sources from which we sold your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information. That information is in this Policy.
e. Right of Deletion. You have the right to request that we delete any of your personal information that we process and sell, subject to certain exceptions. Subject to the time period allotted to comply with such requests, where we receive and confirm your verifiable deletion request, we will delete (and direct our service providers, contractors and/or third parties to whom we sold/shared your personal information, to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you. We may deny your deletion request if retaining the information is necessary for us or our service providers, contractors and/or third parties to whom we sold/shared your personal information, to:
a.Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
b. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
c. Debug products to identify and repair errors that impair existing intended functionality.
d. Exercise free speech rights, ensure the right of another person to exercise their free speech rights or exercise another right provided for by law.
e. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Sec. 1546 seq.).
g. Enable solely internal uses that are reasonably aligned with Covered User expectations based on your relationship with us.
h. Comply with a legal obligation.
i. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
f. Right to Opt Out of Profiling. You have the right to opt-out from any Profiling that may be conducted by us. For purposes of this Policy, "Profiling" means any form of automated processing performed on your personal information to evaluate, analyze or predict personal aspects related to you or your economic situation, health, personal preferences, interests, reliability, behavior, location or movements. We do not currently conduct Profiling and will update this Policy if we do.
g. Right of Correction of Inaccurate Personal Information. You have the right to request correction of inaccurate personal information that we process. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate. Where we correct inaccurate personal and/or sensitive personal information, we shall instruct all service providers and/or contractors that maintain such personal and/or sensitive personal information in the course of providing services to us to make the necessary corrections in their respective systems.
h. Right of Non-Discrimination. We will not discriminate against you for exercising any of your rights under this Policy. Specifically, we will not:
Deny you goods or services;
Charge you different prices or rates for goods or services
Provide you a different level or quality of goods or services;
Retaliate against any employee, job applicant or independent contractor; and/or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
i. Response Timing and Format. We endeavor to respond to all verifiable requests within forty-five (45) days of receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
j. Authorized Agents. You may permit an authorized agent to exercise any rights granted under applicable state laws as set forth above. To utilize an authorized agent, you must provide the authorized agent with written permission from you to act on your behalf for these purposes. When you use an authorized agent to submit a request, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the subject request. We may also require you to directly confirm with us that you provided the authorized agent permission to submit the request. Authorized agents may submit requests by emailing info@thinkdatagroup.com. We may contact you directly to verify the authorized agent’s status before completing such a request.
k. Exercising Your Rights. You can exercise any of your rights listed above by visiting our webform here, writing us at the contact information below, or by calling toll-free (833) 844-6534. Additionally, you may request that we not sell or share your personal information by selecting the “Do not sell or share my personal information” option in the footer of our Site.
l. Verification and Appeal. We use a two-step information verification process to validate identity before requesting modification to personal and business information. To appeal our decision regarding a request related to these rights, you may email us at info@thinkdatagroup.com. In certain circumstances, we may decline a request to exercise the right, particularly where we are unable to verify your identity or if an exception applies.
14. Data Broker
The entity maintaining this Site is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas Secretary of State website.
15. Daniel’s Law. If you are considered a “Covered Person” under Daniel’s Law within the State of New Jersey and wish to request that your address and private phone number not be shared with any third parties for marketing purposes, please click here. Recognizing the essence of Daniel’s Law as a safeguard for covered persons against targeting and the imperative for safety underpinning its creation, Think Data Group is committed to ensuring these requests are managed appropriately and in strict adherence to legal requirements. Please note that all submissions must go through the link provided above, and any submissions directed to info@thinkdatagroup.com will be disregarded.
16. Contact Information
New Gold Ventures, LLC
Attn: Privacy
PO Box 2
Whitinsville, MA 01588
Email: info@ThinkDataGroup.com
Toll Free: (833)-THINKDG or (833)-844-6534