Third Economy Privacy Policy

LAST UPDATED: August 24, 2020

Third Economy respects and values your privacy. This Privacy Policy explains how we collect your Personal Data (defined below) on those web sites of Third Economy that post or link directly to this Privacy Policy (collectively, the “Site”) and through offline means, how we use, disclose, and protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. Third Economy may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was most recently revised.

For the purposes of this Privacy Policy, “Third Economy”, "we", "us", and "our" means Third Economy, Inc.

You do not have to provide us with any Personal Data to visit the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site.

This Privacy Policy shall also apply to any Third Economy mobile application and other forms of Third Economy online activity that reference this Privacy Policy. In such instances, the term “Site” shall include the applicable mobile application or other Third Economy online activity whenever that term is used herein. In connection with your use of any Third Economy mobile application, your Personal Data (and Other Data, as described below) may also be collected and used by your mobile device manufacturer, the mobile application store from which you obtained the Third Economy mobile application, your telecommunication provider, or other third parties involved in the delivery of the application or data to your mobile device, and such collection and use shall be subject to the privacy policy of the applicable third party. Third Economy is not responsible for any third party’s privacy practices.

Types of Data Collected

We gather Personal Data and Other Data (as described below).

Collection of Personal Data

Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number ("Personal Data"). We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so.

Use of Personal Data Collected

We use Personal Data for legitimate business purposes, including the following:

Personal Information: How Long Do We Keep It

Third Economy retains personal information only for as long as necessary for the uses we have set out above. Individual jurisdictions have different tax, accounting, regulatory and legal retention requirements and Third Economy is bound to keep certain personal information in accordance with these local requirements.

Personal Information: How We Store and Process It

All personal information we gather from you may be processed and stored in any one of our Company locations and may subsequently be transferred to other countries for further processing, storage, and/or use by Third Economy. Our staff who need to access personal information to perform their roles will have access to it and have agreed to comply with Third Economy’s policies on data protection.

Third Economy uses a small number of third parties to provide systems and software for its administrative functions, such as sales processing, accounting / finance management and procurement. In such cases Third Economy remains controller of the personal information, the third parties only process the data in accordance with our instructions and we are responsible for ensuring such third parties are compliant with all applicable data protection regulations in relation to their processing activities.

Protection of your personal information

We have technical, security and organizational measures in place, (and require our service providers do so as well), to protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction of personal information. The measures we use are appropriate to the nature, scope and purpose for which we use the personal information we collect. These measures include internal reviews of our data collection, storage, and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We have recently updated our processes to ensure we can comply with data subject requests as required under applicable law, to address complaints and comply with breach reporting procedures and incident management plans.

Third Economy operates secure data networks protected by industry-standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized individuals have access to the information provided.

Further information on our security and incident management is available from info@thirdeconomy.com.

Collection and Use of Other Data

We and our service providers may also collect and use the following types of data, referred to in this Privacy Policy as “Other Data”:

If we are required to treat Other Data as Personal Data under applicable law, then we may use and disclose it for the purposes described above, as well as for the purposes for which we use and disclose Personal Data as detailed in this Privacy Policy.

Site visitors

If you are accessing a Site to learn more about Third Economy and our products and services inquire about employment with a Third Economy company, subscribe to web services or access our research, the information we collect may include your name, physical and email addresses, and phone number(s) via one or more online registration forms. If you are subscribing to a web service with a subscription fee we also collect credit card or other payment details.

For personal information submitted via our US Site, you consent to the collection and use of any personal information and any related information in the manner described in this Privacy Policy. For non-US Sites local regulation may be in place in respect of obtaining your consent to the collecting and processing of your data and you are advised to read the information relating to the local Sites and any revisions or supplements to this Privacy Policy that may apply in your jurisdiction.

Disclosure of Personal Data Collected

We may disclose Personal Data for the following purposes:

Your Choices

We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.

We will comply with your request(s) as soon as reasonably practicable, and in accordance with applicable law. Further, please note that requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing emails from Third Economy. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.

You may also indicate your choices regarding marketing-related emails by contacting us via postal mail or telephone using the information in the “Contact” page on our Site, or if you have a Site profile/account, by changing your preferences on your Site profile/account at any time.

How you can access, change or suppress your Personal Data

If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may make a request by contacting us using the information provided in the “Contact” Page on our Site. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion.

Links

The Site may contain links to other Internet web sites, including social media sites and third-party hosted collaboration tools. These linked sites are not under Third Economy control. We provide links only as a convenience, and Third Economy does not endorse or control, and is not responsible for, the privacy practices or the content of these linked sites. If you provide any Personal Data through any third-party web site, or choose to communicate with us using third-party collaboration tools or other social media platforms, your transaction will occur on that third party's web site (not the Site) and the Personal Data you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES THAT DO NOT POST OR LINK DIRECTLY TO THIS PRIVACY POLICY.

Security Measures

Third Economy has established reasonable organizational and technical measures to protect Personal Data within our organization from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Please note that while Third Economy has endeavored to create a secure and reliable Site for users, no site is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by contacting us using the information provided below in "Contact" page of our Site (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).

Data Integrity

Third Economy will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Privacy Policy, or authorized by you. Third Economy will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you). Third Economy depends on you to update or correct your Personal Data whenever necessary.

Retention Period

We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Cross Border Transfer of Personal Data

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available on the EU Commission’s adequacy list online at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data. You may obtain a copy of these measures by contacting us using the information provided in the “Contact” page of our Site.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Third Economy’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Third Economy may process your Personal Data because:

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Third Economy aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at info@thirdeconomy.com.

In certain circumstances, you have the following data protection rights:

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Use of this Site by Minors

This Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through this Site.

Sensitive Personal Data Restriction

Unless we specifically request for information to comply with applicable anti-money laundering laws and other applicable laws, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, passport numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.

Contact Information for Third Economy

Questions or concerns regarding Third Economy data protection practices should be addressed to:
Legal Department
370 7th Street Suite 9
San Fransisco, California 94103
E-mail: info@thirdeconomy.com

If you choose to contact Third Economy via e-mail about this Privacy Policy, please mark the subject heading of your e-mail “Privacy Inquiry.”

Additional Information for the EEA

You may lodge a complaint with the data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs.

For Germany, you may contact our German Data Protection Officer by sending an e-mail to info@thirdeconomy.com with the subject heading “German Inquiry.”

Additional Information for California

If you are a resident of California, the California Consumer Privacy Act (“CCPA”) (Civil Code § 1798.100) provides you with specific rights regarding your Personal Data. These include:

To exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the Personal Data relates to you. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. We will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law.

During the past twelve (12) months, we collected the categories of Personal Data described above from California residents. We also disclosed such Personal Data to third parties for the purposes specified above during the past twelve (12) months.

Unless expressly stated in a privacy policy or statement applicable to a specific Third Economy affiliate’s website, product or service, Third Economy does not sell your Personal Data.

You may exercise any of the rights described in this section, by contacting us using the information provided in the “Contact” page of our Site.