Thinkingbox Privacy Statement:

Thinkingbox Media & Design Inc. has created the Courte-C Call experience for its client, United Airlines, Inc. In order to send a reminder about upcoming flights via mobile SMS or automated telephone call (the “Services”), Thinkingbox collects certain personal information. See below for Thinkingbox’s privacy statement in relation to the specific collection of data in connection with providing the Services.

How Thinkingbox Processes Your Personal Information

Thinkingbox Media and Design Inc. and its group of companies ("Thinkingbox", "Us", "Our", or "We") are committed to protecting Your privacy. This Services Privacy Policy sets out how We collect and process personal information through Our mobile SMS platform and related services including the development, transmission, analysis, and management of SMS and phone messages and other digital communications (the "Services") – such as when an individual who has registered to use the Services ("Customer"), potential Customer, or other third party engages with Us in relation to the provision of the Services (collectively "You" or “Your”). Please note that for the purposes of EU data protection legislation, Thinkingbox is the controller of Your personal information.

This Services Privacy Policy (this "Policy") does not cover how Thinkingbox collects and uses personal information collected from individuals who visit Our website ("Visitors"), as described in Our separate Website Privacy Policy.

1. Information Collected Through the Services

Through Our Services, Thinkingbox collects certain personal information, as follows:

● Information Customers Provide to Us: You may provide personal information to Us through the Services – for example, when You opt-in to use the Services, contact customer support, send Us an email, or communicate with Us in any other way. When opting into the services, you will provide us with your telephone number.

● Information We Collect Automatically Through the Services: We do not collect information automatically through the Services.

2. Use of Information

We may use the information We collect through the Services for a range of reasons, which include:

● To provide, operate, optimize and maintain the Services;

● To deal with Customer enquiries and support requests, and to provide information and access to resources or services that they have requested from Us;

● To send Our Customers technical alerts, reports, updates, security notifications and other Service-related communications;

● To send You marketing communications (where this is in accordance with Your communication preferences);

● To carry out other legitimate business purposes, as well as other lawful purposes about which We will notify You.

3. Legal basis for processing (EEA individuals only)

If You are from the European Economic Area ("EEA"), Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which We collect it.

However, We will normally collect personal information from You only where We have Your consent to do so, where We need the personal information to perform a contract with You, or where the processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms. In some cases, We may also have a legal obligation to collect the personal information in question.

If We ask You to provide personal information to comply with a legal requirement or to perform a contract with You, we will make this clear at the relevant time and advise You whether the provision of Your personal information is mandatory or not (as well as of the possible consequences if You do not provide Your personal information).

Similarly, if We collect and use Your personal information in reliance on Our or a third party's legitimate interests and those interests are not already listed above (in the "Use of Information" section), We will make clear to You at the relevant time what those legitimate interests are.

If You have questions about or need further information concerning the legal basis on which We collect and use Your personal information, please contact Us using the contact details provided in Section 14 below.

4. Information We Share

We may share and disclose Your personal information to third parties in the following circumstances:

● Within the Thinkingbox group of companies for the purposes outlined in this Policy.

● To vendors and other third-party service providers who require access to Your personal information to assist in the provision of the Services, and other business-related functions. For example, We may use various Sub-processors in provision of our services.

● To partners and sponsors: Certain parts of the Services may be offered in connection with other companies who are partners or sponsors. When You use these types of Services, We will ensure that the identity of those partners or sponsors is clearly visible and that You have an opportunity not to proceed or to opt out. Such information will be handled in accordance with their own privacy policies and if You have questions, You should contact the partner or sponsor directly.

● We may also disclose your information to third parties: (a) where required by law or regulatory requirement, court order or other judicial authorization, (b) in response to lawful requests by public authorities, including for the purposes of meeting national security and law enforcement requirements; (c) in connection with the sale, transfer, merger, bankruptcy, restructuring or other reorganization of a business; (d) to protect or defend Our rights, interests or property, or that of third parties; (e) to investigate any wrongdoing in connection with the Website or Our services; or (f) to protect the vital interests of an individual.

● With Your consent.

5. We may also share personal information collected through the Services with third party companies so that they may offer products and services that We believe will be of interest to You. We may also share personal information with third party advertising-serving companies to better target the adverts and other content displayed on Our site and to provide offers We think may be of interest to You. You may opt-out of disclosure of Your information to third parties for direct marketing purposes – see the Choice and Opt-Out section below. In addition, third party advertisers may receive certain personal information about You if you click on advertisements displayed through communications delivered in providing the Services. If You do not wish these third parties to process Your personal information, please do not click on these adverts.

6. Third Party Sites

Our Services may contain links to other websites and services which are outside Our control and are not covered by this Policy. For example, We may provide a link to our client United Airlines’ website. While We try to link only to partners that share Our standards for privacy, We are not responsible for the content, security or privacy practices employed by other sites. If You access other websites or services using the links provided, the operators of these websites and services may collect information from You which will be used by them in accordance with their privacy policy, which may differ from Ours.

7. Our Security

We maintain reasonable and appropriate security measures to protect Your personal information from loss, misuse, and unauthorized access, disclosure, alteration and destruction. We will take all reasonable steps to ensure the safety of Your personal information.

8. Sensitive Data

Thinkingbox does not knowingly solicit or collect, and You should not provide, any information regarding an individual’s medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other sensitive data.

9. Information about International Transfers

Your personal information may be stored and processed by Us in any country where We have facilities or where We engage service providers, and by reading this Policy and using the Services You acknowledge that Your personal information may be transferred to countries outside of Your country of residence, including the United States or Canada, which may have different data protection rules to those of Your country. Where We do so, Our collection, storage and use of Your personal information will be in accordance with the purposes set out in this Policy.

10. Children

The Services are not directed at children under the age of 16. We do not knowingly solicit or collect personal information from children under the age of 16.

11. Your Choices and Opt-Outs

You can opt out of receiving communications from Us at any time, or opt out from having Your contact information shared with third parties for direct marketing purposes. All opt out requests can be made by emailing Us at hello@thinkingbox.com. Once You opt out of receiving communications from Us, we will cease to provide the Services to you.

Please note that it may take up to 3 days to remove Your contact information from Our marketing communications lists, so You may receive correspondence from Us for a short time after You make Your request. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management and You may not be able to opt out of these messages.

12. Other Data Rights

Thinkingbox takes reasonable steps to ensure that the data We collect is reliable for its intended use, accurate, complete and up to date. If You want to contact Us directly about accessing, changing or deleting Your personal information, or altering Your data or marketing preferences, please email Us at hello@thinkingbox.com. We will consider Your request in accordance with applicable laws.If You are from certain territories (such as the European Union), You may have additional data protection rights, such as broader rights to access and deleted personal information.

13. Your California Privacy Rights

California law provides that California residents have a right to request that businesses tell them how their personally identifiable information has been shared with third parties for those third parties’ direct marketing purposes. However, there is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s personally identifiable information to third parties for those third parties’ direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their personally identifiable information to third parties for such purposes. Thinkingbox has adopted a policy of allowing You to opt-out of the disclosure of Your personally identifiable information to third parties for their direct marketing purposes and thus falls within this exception. Instructions for opting out can be found in the section entitled found in the Your Choices and Opt-Out section above.

14. Retention of Your Personal Information

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes. Where We have no ongoing legitimate business need to process Your personal information, We will either delete or anonymize it or, if this is not possible (for example, because Your personal information has been stored in backup archives), then We will securely store Your personal information and isolate it from any further processing until deletion is possible.

Updates to this Policy

We reserve the right to change or update this Policy from time to time. If material changes are made, We will place a prominent notice on Our Website or Services for at least 30 days prior to the change taking effect, or communicate with You directly by email or through the Services, and will update the last revised date at the top of this Policy. We encourage You to regularly check back on this page to ensure You are up to date with any changes.

15. How to Contact Us

If You have any questions or concerns regarding the use or disclosure of Your personal information through the Services, You can contact Us by sending an email to hello@thinkingbox.com.

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