LAST UPDATED: August 24, 2020
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.
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.
- Third Economy requests Personal Data from you if the Site requires registration. The registration process requests that you provide Personal Data, such as your name, business email address, business address or country/jurisdiction location, business phone number, and company affiliation, and agree to the User Agreement presented at the time of registration.
- Third Economy may receive Personal Data from social media platforms. For example, if you elect to use your social media credentials to log-in to your Site account, certain Personal Data from your social media account will be shared with us, which may include Personal Data that is part of your social media profile.
- Third Economy may collect Personal Data voluntarily provided by you, including in emails, online forms, order and registration forms, surveys, promotion participation, online chats, phone calls , and through other means.
- Third Economy may request Personal Data from our customers to comply with applicable anti-money laundering laws and other applicable laws.
- On some of Third Economy Sites, including Thirdeconomy.com, you are able to maintain "portfolios," where, if you are a registered user, you have the option to list financial instruments in which you have a special interest. To be useful, this information must be stored on the Site, and is accessible to anyone with whom you share your username and password. For this reason, please safeguard your username and password carefully and do not disclose them to any other person.
- Third Economy collects information through various other means, including searches online, participation at conferences and events, individual introductions, from employers that enroll their employees in our services, and from selected third-party business partners. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services.
Use of Personal Data Collected
We use Personal Data for legitimate business purposes, including the following:
- Fulfillment of Requests. Third Economy may use Personal Data about you to deliver products and services to you, and to provide you with information about products and services you’ve ordered. We will engage in these activities to manage our contractual relationship with you and to fulfil our contractual obligations.
- Marketing Communications. From time to time, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If your employer is a Third Economy customer, we may also inform you of such products, programs, services and promotions using Personal Data about you that your employer provided to Third Economy. We may also use Personal Data of media contacts for press release distribution or sharing other newsworthy developments related to our business activities.
- Other Business Purposes. We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the efficiency of our services), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site, completing business transactions (for example, to confirm content requested is received by customers), development and delivery of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of the Site are of most interest to users), product development, conducting surveys and market research, and administering individual accounts.
- Compliance with law and regulation. We may use Personal Data as necessary to comply with applicable legal and regulatory requirements such as sales tax collection, audits, etc.
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 email@example.com.
Collection and Use of Other Data
- Monitoring Data. Third Economy and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of the Site ("Monitoring Data"). We use Monitoring Data to help us understand who uses the Site and to improve and market it, as well as our other web sites and services.
Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
- Aggregated Data. We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.
- We do not respond to browser do-not-track signals at this time.
- IP Addresses. When you visit and interact with the Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how the Site is used by our users, to improve the Site and to enhance user experience of the Site. We may also derive your approximate location from your IP address.
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.
Disclosure of Personal Data Collected
We may disclose Personal Data for the following purposes:
- Third-Party Service Providers. We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, data analysis, order fulfillment, payment processing, and other services.
- Third-Party Data Providers. If you subscribe to a Third Economy product or service that contains third-party data, we may be required to provide your Personal Data to the third party as part of our reporting obligations. We will only do so if a third-party data provider conditions your receipt of their data on knowing your identity.
- Assignment. We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
- Legal Requirements. We may disclose your Personal Data in the good faith that such action is necessary to comply with a legal obligation, including, but not limited to the following scenarios: to protect and defend the rights of Third Economy; to prevent or investigate possible wrongdoing in connection with the Service; to protect the personal safety of users of the Service or the public; or to protect against legal liability.
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.
- If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by sending an e-mail to firstname.lastname@example.org.
- If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an e-mail to email@example.com.
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.
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).
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)
Third Economy may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it's not overridden by your rights
- For payment processing purposes
- To comply with the law
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 firstname.lastname@example.org.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data by contacting us on email@example.com.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Third Economy relied on your consent to process your personal information.
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:
370 7th Street Suite 9
San Fransisco, California 94103
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 firstname.lastname@example.org 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:
- You can request information about our collection and use of your Personal Data over the past twelve (12) months concerning: (i) the categories of Personal Data we collected about you, (ii) the business or commercial purpose for collecting your Personal Data, (iii) the categories of sources from which your Personal Data is collected, and (iv) the categories of third parties with whom we share your Personal Data. You can request a list disclosing the categories of your Personal Data we have shared in connection with a business purpose.
- You can request to receive a copy of your Personal Data in a commonly used and machine-readable format.
- You can request that we delete your Personal Data, subject to certain exceptions.
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.
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.