THORS LLC Privacy Policy

Last updated August 1, 2023

Introduction

THORS LLC (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites https://www.thors.com and/or https://academy.thors.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this website privacy policy carefully. Your use of this site constitutes your acceptance of/agreement to this Privacy Policy.

We reserve the right to make changes to the Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of the Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

Collection of Your Information

We offer a variety of applications and services that are collectively referred to as the “Services”. We may collect information from individuals who visit our Site and from individuals who register to use the Services (“Customers”). The information we may collect on the Site includes:

Personal Data

We collect the following personally identifiable information about you that you voluntarily give to us when you fill out Contact Us forms on our Site, register with the Site, or when you choose to participate in various activities on the Site, such as online chat, blog, or message board:

• Contact information such as name, email address, phone number, billing information, and information you input into open text fields
• You also have the option of adding a job title and other details to your profile information to be displayed in our services
• Information about your business such as a company name, industry, company size, company annual revenue, company contact information
• Contact information provided when seeking technical support, including a summary of problem and attachments that may be helpful in resolving an issue
• Information about you when you visit and interact with our website and training portal. This may include the file attachments you download and frequently used search terms
• Device information including your connection type and settings, information about your operating system, browser type, IP address, and URLS of referring/exit pages

You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Electronically Submitted Data

Customers may electronically submit data or information (other than Data About THORS, LLC Customers or Web Site Navigational Information) to the Services for hosting and processing purposes (“Customer Data”). THORS LLC will not review, share, distribute, or reference any such Customer Data except as provided in the THORS LLC Master Subscription Agreement, or as may be required by law. In accordance with the THORS LLC Master Subscription Agreement, THORS LLC may access Customer Data only for the purpose of providing the Services, preventing or addressing service or technical problems, at a Customer’s request in connection with customer support matters, to review or contact a connected supplier, or as may be required by law.

Derivative Data

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. If you are using a mobile device, this information may also include your device name and type, your operating system, your phone number, your country, and any other interactions with the Site and other users via server log files, as well as any other information you choose to provide.

Financial Data

Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about Services from the Site. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor. You are encouraged to review their privacy policy and contact them directly for responses to your questions.

Mobile Device Data

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Third-Party Data

Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

Data from Contests, Giveaways, and Surveys

Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

Use of Your Information

We use the information collected to perform the Services requested. For example, if you fill out a “Contact Us” or “Request a Demo” web form, we will use the information provided to contact you about your interest in the Services. We may also use information collected for marketing purposes. For example, we may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding THORS LLC and its partners, such as information about promotions or events.

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may also use information collected about you via the Site to:

• Communicate with you in a timely and efficient manner such as responding to customer service requests.
• Provide requested information on our products and service such as demo and trial requests.
• Administer sweepstakes, promotions, and contests.
• Assist law enforcement and respond to subpoena.
• Compile anonymous statistical data and analysis for use internally.
• Create and manage your account.
• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.
• Email you regarding your account or order.
• Enable user-to-user communications.
• Fulfill and manage purchases, orders, payments, and other transactions related to the Site.
• Generate a personal profile about you to make future visits to the Site more personalized.
• Increase the efficiency and operation of the Site.
• Monitor and analyze usage and trends to improve your experience with the Site.
• Notify you of updates to the Site.
• Offer new products, services, mobile applications, and/or recommendations to you.
• Perform other business activities as needed.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Process payments and refunds.
• Request feedback and contact you about your use of the Site.
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
• Send you a newsletter.
• Solicit support for the Site.

Disclosure of Your Information

We shall hold all information in strict confidence and shall not disclose any information except in certain situations. Your information may be disclosed as follows:

By law or to protect rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. To learn more about our third-party service providers, contact us at the email address provided below.

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. ln such cases, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

Data Processing in Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Public Forums and Interactions with Other Users

We may provide bulletin boards, blogs, or chat rooms on THORS LLC’s web site. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums.

We post customer testimonials on the THORS LLC web site that contain information such as name and title. We obtain the consent of each customer prior to posting any testimonials.

Online Postings

When you post comments, contributions or other content to the Site, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

To facilitate our global operations, we may transfer and access collected information from around the world. This Privacy Statement shall apply even if THORS LLC transfers collected data to other countries.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur, and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

Tracking Technologies / Use of Cookies

Cookies are small text files or other data records that store information on end devices and read information from the end devices – for example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the contents accessed or the functions used. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Information on Consent

We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is strictly necessary in order to provide an information society service explicitly requested by the subscriber or user. Essential cookies usually include cookies with functions related to the display and operability of the online service, load balancing, security, storage of users’ preferences and choices or similar purposes related to the provision of the main and secondary functions of the online service requested by users. The revocable consent will be clearly communicated to the user and will contain the information on the respective cookie use.

Information on Legal Basis Under Data Protection Law

The legal basis under data protection law on which we process users’ personal data with the use of cookies depends on whether we ask users for consent If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online services and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For which purposes the cookies are processed by us, we do clarify in the course of this privacy policy or in the context of our consent and processing procedures.

Retention Period

With regard to the retention period, a distinction is drawn between the following types of cookies…

Temporary cookies (also known as “session cookies”)

Temporary cookies are deleted at the latest after a user has left an online service and dosed his or her end device (i.e. browser or mobile application).

Permanent cookies

Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

Revocation and Objection (Opt-Out)

Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Article 21 GDPR. Users can also declare their objection by means of the settings of their browser, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online services).

In the footer of our website you will find a link that allows you to change your cookie settings as well as revoke corresponding consents.

Processing Cookie Data on the Basis of Consent

We use a cookie management solution – Real Cookie Banner – in which users’ consent to the use of cookies, or the procedures and providers mentioned in the cookie management solution, can be obtained, managed and revoked by the users. The declaration of consent is stored so that it does not have to be retrieved again and the consent can be proven in accordance with the legal obligation. Storage can take place server-sided and/or in a cookie (so-called opt-out cookie or with the aid of comparable technologies) in order to be able to assign the consent to a user or and/or his/her device. Subject to individual details of the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the date/time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and used end device; legal Basis: Consent (Article 6 (1) (al GDPR).

The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

Real Cookie Banner: Cookie-Consent Manager
Service provider: devowl.io GmbH, Tannet 12, 94539 Graning, Germany
Legal Basis: legitimate Interests (Article 6 (1) (fl GDPR)
Website: https://devowl.io/wordpress-real-cookie-banner/
Privacy Policy: https://devowl.io/privacy-policy/

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies, such as Google Analytics, on the Site to help customize the Site and improve your experience. When you access the Site, your personal information is not collected using tracking technology.

Most browsers are set to accept cookies by default. You can remove or reject cookies but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

For information about Google Analytics privacy policy, please go to: http://www.google.com/privacy.html.

Internet-Based Advertising

Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

Service Provider: ActiveCampaign
Privacy Policy: https://www.activecampaign.com/legal/privacy-policy

Website Analytics

We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Site, using first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

Third-Party Websites

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

Disclaimer

THORS LLC attempts to provide accurate information on our Site, but it assumes no responsibility for accuracy. THORS LLC may change the information on the Site, or the products or services offered, at any time without notice. Content on our Site is provided “as-is” and THORS LLC disclaims all warranties, express or implied. This includes but is not limited to implied warranties of merchantability, or fitness for a particular purpose. It also includes any express or implied warranties arising from any course of dealing, usage, or trade practice.

Limitation of Liability

THORS LLC is not liable for any direct, indirect, special, incidental or consequential damages arising out of the use of material on our Site. This includes but is not limited to the loss of data or loss of profit, even if THORS LLC was advised of the possibility of such damages.

We Strive to Protect Your Personal Information

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

All employees and associates who are granted access to your personal information understand the need to keep this information protected and confidential. They know they are to access and use the information only for the purpose of providing you and supporting for you our products and services.

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. ln such cases, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

Content Provider: YouTube
Privacy Policy: https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/

Policy for children

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

Controls for Do-not-track features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. 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. Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.

Options regarding your information

Account Information / Your Privacy Choices

You may withdraw your consent at any time (subject to legal or contractual obligation and on providing us reasonable notice) by communicating to us in writing using the contact information provided below. Please be aware that withdrawing your consent may prevent us from providing you with requested Services.

You may at any time review or change the information in your account or terminate your

account by:

• Logging into your account settings and updating your account
• Contacting us using the contact information provided below

Customers may update or change their registration information by editing their user profile record. In the THORS Academy (Learning Management System), please login to https://academy.thors.com with your username and password and click “Profile” from the dropdown menu in the top right of the page. To update an organization’s information, please contact us using the contact information provided below and include your THORS Academy username and the new information in the body of the email. To update Billing Information or have your registration information deleted, please call us at the number provided below. To discontinue your account and to have information you maintained in the THORS Academy returned to you, please email or call us using the contact information provided below.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Master Subscription Agreement, Terms of Use Policy, and/or comply with legal requirements.

Requests to access, change, or delete your information will be handled within 30 days.

Emails and Communications

If you no longer wish to receive general correspondence, emails, or other communications from us, you may opt-out by contacting us using the contact information provided below. In regard to transactional emails directly related to their account with THORS LLC or the Services, Customers cannot opt out.

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

Erasure of data

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose). If the data is not deleted

because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. Our further information on individual processing operations may also contain additional and specific information on data retention and erasure applicable to the respective processing operations.

California privacy rights

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 using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

Miscellaneous

This Privacy Statement and all provisions hereunder, shall be construed in accordance with, and governed by the laws of the State of Ohio. The parties agree that any litigation brought by either party shall be filed exclusively in the state and federal courts having jurisdiction in Medina County, Ohio, and the parties hereby consent to the jurisdiction of such courts and waive all questions of jurisdiction and venue. If any provision of this Privacy Statement is held by a court of competent jurisdiction to be contrary to law, the provision shall be modified by the court and interpreted so as best to accomplish the objectives of the original provision to the fullest extent permitted by law, and the remaining provisions of this Privacy Statement shall remain in effect. To the extent of any conflict or inconsistency between the provisions of this Privacy Statement / Terms of Use Agreement and any Master Subscription Agreement if one has been entered into, the terms of such Master Subscription Agreement shall prevail. Master Subscription Agreement is available upon request from support@thors.com.

Contact Us

If you have questions or comments about this Privacy Policy, please contact us at:

THORS LLC
5054 Paramount Blvd
Medina, OH 44256
+1 330 576 4448
support@thors.com