Privacy Policy

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Phone Numbers
• Email Addresses
• Organization Affiliation
• Job Title
• Location (Such as State and Zip Code)

Sensitive Information. We do not knowingly collect Sensitive Personal Information from website visitors or account holders. The approximate location we infer from your IP address at the city or region level is not Sensitive Personal Information under California law.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

2. How Do We Process Your Information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “What Are Your Privacy Rights?” below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. When and With Whom Do We Share Your Personal Information?

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. Where the transfer would result in a change of controller for your personal information, we will provide reasonable advance notice to account holders and, where reasonably practicable, an opportunity to delete your account before the transition takes effect. Where Customer Data subject to a BAA is involved, the BAA’s continuity provisions apply.
• Affiliates. We may share your information with our corporate affiliates (entities under common control with THINQPOINT LLC), in which case we will require those affiliates to handle the information consistent with this Privacy Policy. At the date of this Notice, Thinqpoint has no affiliates.
• Service Providers and Subprocessors. We share personal information with the service providers and Subprocessors we engage to deliver the Services, including cloud hosting, our identity and content-management platform, our analytics provider, AI Model Providers (see Section 5), email delivery, our payment processor, and error-tracking and customer-support tooling. Each Subprocessor is engaged under a written contract that restricts the use of personal information to the purpose for which we provided it and prohibits onward sale or sharing. A current list is published on our Subprocessor List at /legal/subprocessors. Personal information described in this Policy is stored and processed in the United States. We will provide at least thirty (30) days’ advance notice before adding a Subprocessor that will process personal information described in this Policy. Customer organizations have a corresponding objection right with respect to new Subprocessors processing Customer Data under the Terms of Use § 8.2.

4. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

PostHog. We may share your information with PostHog to track and analyze the use of the Services through event-level product analytics (such as page views, button clicks, and feature usage). We do not record sessions inside the authenticated Thinqpoint Platform application; session recording is not performed on routes behind the platform’s authentication wall. On the public corporate website, PostHog may capture limited usage events as described above. For more information on the privacy practices of PostHog, please visit the PostHog data privacy documentation at https://posthog.com/privacy.

5. How Do AI Features Work?

When you interact with an AI feature in the Services, your prompts and the intermediate content used to generate a response may be transmitted to one or more third-party AI Model Providers that we engage as Subprocessors. The current list of Subprocessors is published on our Subprocessor List. We will provide at least thirty (30) days’ advance notice before adding a Subprocessor that will process personal information described in this Policy.

Our cloud-infrastructure BAA covers PHI flowing through AI features. Our AI Model Providers are accessed through the same cloud infrastructure that hosts the rest of the Services. Thinqpoint has an executed Business Associate Agreement with the cloud-infrastructure provider that, by its terms, covers PHI processing through the platform — including the AI Model Providers’ processing of PHI when it flows through an AI feature. No PHI flows to AI features absent a current BAA between Thinqpoint and the customer organization.

Thinqpoint does not authorize, and contractually requires its Model Providers not to, use your prompts or the AI’s outputs to train or fine-tune any foundation AI model, where commercially reasonable enterprise-tier configuration permits. Model Providers may retain prompts and outputs for limited periods for abuse monitoring, safety review, or operational support, consistent with their published terms.

We do not use the personal information of website visitors or account holders described in this Privacy Policy to train, fine-tune, or evaluate AI Models.

6. How Long Do We Keep Your Information?

We retain personal information only for as long as needed for the purpose for which it was collected, plus a reasonable period for legal compliance, dispute resolution, and security. When the period ends, we delete or de-identify the data.

Category	How long we keep it
Account profile data (name, email, organization, role, password hash, preferences)	Lifetime of the account plus a 90-day wind-down for account recovery and dispute resolution.
Authentication and session data	Session token TTL; refresh tokens revoked on logout or password change.
Billing records and invoices	Seven (7) years from issuance, for U.S. tax compliance and audit defense.
Payment-method metadata (last-4, expiration, brand, tokenized reference)	Lifetime of the payment method on file.
Support and transactional communications	Approximately 36 months from last interaction.
Marketing communications and preferences	Until you unsubscribe; suppression list retained for 12 months thereafter.
Application and security logs	Application logs approximately 90 days; security logs approximately 12 months, longer if subject to a legal hold.
Product-analytics events	Per the configured retention at our analytics provider.
Backups and disaster-recovery snapshots	Rolling backup retention; deletion requests are honored against primary stores immediately and against backups on the next overwrite cycle.
Customer Data under a BAA (PHI)	Governed exclusively by the BAA — not by this Policy.

Where a longer retention period is required by law (such as for tax, accounting, or litigation-hold purposes), we keep the data for the period required. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or — if deletion is not immediately possible (for example, because the data is in encrypted backup archives) — securely isolate it from further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Specific controls, certifications, and current security attestations are published in our Trust Center.

8. Do We Collect Information from Minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@thinqpoint.com.

9. What Are Your Privacy Rights?

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How Can You Contact Us About This Policy?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “How Can You Contact Us About This Policy?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Policy.

If you have questions or comments about your privacy rights, you may email us at privacy@thinqpoint.com.

10. Controls for Do-Not-Track Features

Most Web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preferences not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing and honoring DNT signals, we do not respond to them at this time.

11. Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have specific privacy rights under your state’s law. Those rights generally include the right to request access to and receive details about the personal information we maintain about you and how we have processed it, the right to correct inaccuracies, the right to obtain a copy of, or delete your personal information, and the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information.	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data.	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information.	NO
E. Biometric information	Fingerprints and voiceprints.	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our or other websites, applications, systems, and advertisements.	YES
G. Geolocation data	Approximate (city- or region-level) location inferred from IP address.	YES (non-precise only)
H. Audio, electronic sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities.	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level, or job title, work history, and professional qualifications if you apply for a job with us.	YES
J. Education information	Student records and directory information.	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.	NO
L. Sensitive personal information	SSN, financial-account number, precise geolocation, contents of communications, racial/ethnic origin, religious beliefs, union membership, genetic or biometric data, health, sex life or sexual orientation.	NO (not knowingly)

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels.
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in “What Information Do We Collect?”

How We Use and Share Personal Information

Learn more about how we use your personal information in the section “How Do We Process Your Information?”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers and Subprocessors pursuant to a written contract between us and each one. Learn more about how we disclose personal information in the section “When and With Whom Do We Share Your Personal Information?” and on our Subprocessor List.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data.
• Right to access your personal data.
• Right to correct inaccuracies in your personal data.
• Right to request the deletion of your personal data.
• Right to obtain a copy of the personal data you previously shared with us.
• Right to non-discrimination for exercising your rights.
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law).
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law).
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy law).
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law).
• Right to limit the use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law).
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law).

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at privacy@thinqpoint.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an unauthorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable law.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@thinqpoint.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “How Can You Contact Us About This Policy?”

12. Do We Make Updates to This Notice?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated effective date at the top of this Privacy Policy.

Where we make material changes that expand the categories of personal information we process, the purposes for which we process it, or the categories of recipients with which we share it, we will provide at least thirty (30) days’ advance notice — by email to the account contact, by in-product banner, or both — before the change takes effect. For changes that materially and adversely affect your rights or our handling of your personal information, we will provide at least sixty (60) days’ advance notice, consistent with the corresponding obligation in the Terms of Use § 16.3. We will not apply less-protective practices retroactively to information we collected under a prior version of this Notice.

We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. How Can You Contact Us About This Policy?

If you have questions or comments about this Privacy Policy, you may email us at privacy@thinqpoint.com, or contact us by post at:

THINQPOINT LLC
Attn: Privacy
3943 Irvine Blvd., Unit 2101
Irvine, CA 92602
United States of America

14. How Can You Review, Update, or Delete the Data We Collect from You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at privacy@thinqpoint.com.