LAST UPDATED: AUGUST 2022
EFFECTIVE: AUGUST 2022
Think Digital Online runs a marketing platform solution which provides advertising and monetization services/products (whether owned or through its partners) to marketers and supply partners including through digital media, sites, surveys, owned or operated application(s)/widgets, exchange(s) for demand/supply, marketing automation solutions and other services, such as, fraud detection, reporting, audiences, attribution, analytics, modelling, segments, measurement (“Marketing Platform”).
To the extent that foregoing Consumer Offering promotes any interest-based advertising using the Marketing Platform Services, the terms of this policy would apply to the data processing practices for such Marketing Platform Services.
Marketing Platform Services and Consumer Offering are collectively referred to as “Services”.
3. Think Digital Online MARKETING PLATFORM SERVICES
Think Digital Online engages with third party site/app publishers and app developers to serve ads on their digital properties on behalf of its demand side advertising partners through various channels of advertising solutions including exchanges, network, off-network etc. Think Digital Online may also serve ads on Consumer Offerings. Think Digital Online also engages in campaign planning, measurement (e.g. whether an advertisement was viewed, its timestamp etc.) and attribution of advertisements, whether by itself or through third party measurement partners.
Think Digital Online provides Marketing Platform Services, including optimization of advertising campaigns, data analytics/enrichment, segment creation, user acquisition, re-engagement, remarketing or retargeting through various digital advertising channels. Think Digital Online receives data into its Marketing Platform from various sources, including end user information collected by our systems, applications/offerings, partners, data/cookie vendors or customers (“Sources”), which may include third party apps, sites and services that you use. Please refer to the privacy policies of the apps, sites, and services you use to understand how those apps, sites and services collect, use, and share data from your interactions with them. Think Digital Online is not responsible for how those third-party apps, sites and services collect and use data.
4. WHAT PERSONAL INFORMATION DO WE COLLECT?
When you view an advertisement distributed through Think Digital Online on a site, app or other digital media, we may collect information on your device and your interaction with the advertisement. This information enables us to serve advertisements to you, improve our Services including to recognize your device when you use other sites and applications that have partnered with us. Think Digital Online may also collect information about you when you elect to interact with our surveys or opinion-based applications. Information we may collect includes:
In the context of our Marketing Platform Services, our customers, partners or vendors may also disclose to us certain personal or non-personal information they have separately collected about you during your interaction with their apps, sites or services so that we can effectively provide our Services. This may in the context of websites, including mobile websites, include cookies, other technologies, or other aggregated characteristics or other identifiers related to your device to understand your interaction with such site and to serve certain types of ads relevant to your interests.
These parties serve you cookies in accordance with their own specific privacy/cookie policies and subject to their own applicable legal requirements. We do not use the information they provide to us for any purpose other than as permitted by such third parties or for providing or improving our Services.
Notably, one of our media partners is Google. Please see the link below which describes Google's collection/use of data:
We do not collect any sensitive data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, data concerning health. We may show targeted advertisements to fitness enthusiasts.
5. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the information that we collect about your device to:
6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Think Digital Online may share the information we collect or receive about you as described in this Policy as follows:
7. HOW DO WE KEEP PERSONAL INFORMATION SECURE?
Think Digital Online uses reasonable technical and organizational measures to protect the information it collects about you in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
Think Digital Online retains information collected in the context of our Marketing Platform for a period of up to thirteen (13) months, unless otherwise required by law or applicable contract.
Think Digital Online may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey or opinion-based application by Think Digital Online, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
After the applicable retention period, Think Digital Online will only retain and may only use your data: (i) in an aggregated or anonymized format; (ii) to comply with its legal obligations; and (iii) to resolve disputes and enforce agreements. Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.
9. PRIVACY RIGHTS
Think Digital Online provides consumers with data subject or consumer rights as and when and to the extent required under such applicable laws.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “17. CONTACT US” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include information about your device.
The privacy laws of your country may grant you the following additional privacy rights relating to their personal information: right to access, request correction, request deletion/anonymization/blocking, restrict/object to processing, withdraw your consent, request data portability, be informed about third parties with whom your data has been shared, and request review of decisions taken exclusively based on automated processing. To exercise these rights, please write to us at email@example.com.
10. INTERNATIONAL TRANSFERS
Think Digital Online may share your information with clients, customers, partners, the Group and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EEA resident, we may share your information with our non-EEA clients or the Group), subject to any contractual or legal requirements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world.
12. LEAD GENERATION CAMPAIGNS
Think Digital Online may offer form-based advertising solutions to marketers that include the collection of voluntary information from you as part of an advertisement that contains a questionnaire. Such information may consist of personal data, non-personal information or data, or both. All the information that you voluntarily provide in response to such form or questionnaire is typically forwarded directly to the relevant marketer’s servers or their landing page and in such cases will be governed by such marketer's privacy policies in place at the time of transfer.
In the event any personal data is directly processed by Think Digital Online, you acknowledge that Think Digital Online may be required to store such information for the period during which it continues to manage the applicable lead-generation campaign for its marketer on whose behalf the information is collected. This information may be temporarily stored by Think Digital Online solely for running such form-based campaigns and will be used only for the purpose of optimization of such campaigns, subject to applicable legal/privacy and contractual requirements. Think Digital Online has implemented internal safeguards to protect the temporary storage of this information and uses reasonable technical and organizational measures to protect the same. Think Digital Online has mechanisms to delete or anonymize any personal data after the said campaign is concluded or within a period thirty (30) days from the same. Pursuant to the conclusion of the applicable campaign, Think Digital Online may retain and use your Information only to the extent necessary for it to create reports for its client, comply with its legal obligations, resolve disputes and enforce agreements and no other purpose. Any non-personal information or data submitted by you may be used for improving our Services.
If you have any questions about Think Digital Online lead generation campaigns, please contact us at: firstname.lastname@example.org. Think Digital Online will refer any enquiries or complaints to the relevant marketer responsible for the processing of data provided as part of lead generation campaigns.
14. PRIVACY OF CHILDREN
Think Digital Online complies with the age-gating requirements under applicable privacy laws such as Information Technology Act, 2000 (India), Children's Online Privacy Protection Act (COPPA) and California Consumer Privacy Act (CCPA) in the U.S., Lei Geral de Proteção de Dados Pessoais (LGPD), General law of personal data protection in Brazil and GDPR in the EEA and does not knowingly collect personal data about users of sites or apps directed to children.
15. OTHER WEBSITES
17. CONTACT US