REMY.CO PRIVACY POLICY

At Thinkwise Technology, Inc. d/b/a Remy.co (hereinafter “Remy.Co”), we pride ourselves on our commitment to protecting your privacy. This Privacy Statement (“Privacy Policy”) describes in greater detail the privacy practices of Remy.co and its affiliates and subsidiaries, meaning companies related by common ownership or control (“us,” “we,” “our”), how we are responsible for collecting and maintaining certain information collected about you and is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service.

For purposes of this Privacy Policy, “Services” refers to the Remy.co’s products and services which can be accessed via our website at www.remy.co (the “Site”). By accepting our Privacy Policy and Terms of Use, you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

We participate in the E.U. - U.S. Privacy Shield Framework and comply with the Privacy Shield Principles.

If you have questions or complaints regarding our Privacy Policy or practices, please contact us at privacy@remy.co

  1. WHEN THIS PRIVACY POLICY APPLIES.

    If a Service you're using links to this Privacy Policy, this policy applies to you.

    This Privacy Policy applies to our Services. We are the controller of all Personal Information subject to this Privacy Policy for our Services targeted to US customers.

  2. WHAT WE DO WITH YOUR INFORMATION.

    We want to be clear about what information we collect and how we use it to deliver our Services to you, operate our business, and help make our Services better for you. We do not sell or share your Personal Information with third parties for their own commercial uses without your consent.

    This Privacy Policy applies to our Services. We are the controller of all Personal Information subject to this Privacy Policy for our Services targeted to US customers.

    1. Types of Information We Collect.

      In connection with our Services, we collect “Non-Personal Information” and “Personal Information.” Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Personal Information includes information we may collect from you which can be used to identify you, such as your name, email address, phone, username and password.

      We collect Personal Information when you register or open an account, sign in, pay a bill, purchase a Service, call us for support, or give us feedback. We may also obtain Personal Information from other companies or third parties, such as when you sync a third party account or service with our Services, or when we may use service providers to supplement the Personal Information you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better service. Finally, we also collect content or other Non-Personal and Personal that you may provide or create when you interact with our Services. By registering an account, you are authorizing us to collect, store and use your email address in accordance with this Privacy Policy.

      In an effort to improve the quality of our Services, we may also automatically collect certain usage information provided to us by your browser or by our software application when you view or use the Service ("Usage Data"), such as the website you came from (known as the “referring URL”), Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, the type of browser you use, the device from which you connected to the Services, any links you click on to leave or interact with our Services, the device from which you connected to the Service, the time and date of access, and other usage information collected from Cookies and tracking technologies which that does not personally identify you and which shall be considered Non-Personal Information. We track this information using cookies, or small text files, web beacons, pixels, local shared objects, and similar technologies which include an anonymous unique identifier (collectively, "Cookies"). Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a Cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when utilizing our Services, both on an individual and aggregate basis. The Company may use both persistent and session Cookies; persistent Cookies remain on your computer after you close your session and until you delete them, while session Cookies expire when you close your browser. We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data.

      Our Services may change over time and we may introduce new features that may collect new or different types of information.

    2. How We Use and Share Your Information.

      We may use your information, including your Personal Information, for the following purposes:

      Account Registration. We may use your name, address, phone number, and email address to register your account for our Services and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current. If you set up an administrator account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your Personal Information.

      To Provide Our Services and Operate Our Business. We may use your Non-Personal Information and Personal Information to operate our business, including providing Services you requested, provide you with support related to our Services, and to help us protect our Services, including to combat fraud and protect your Personal Information.

      Customer Service and Technical Support. We may use your name, phone number, email address, how you interact with our Services, and information about your computer configuration to resolve questions you may have about our Services and to follow up with you about your experience.

      To Improve Services and Develop New Services. We may use your Non-Personal Information and Personal Information to personalize or customize your experience and the Service, develop new features or services, and to improve the overall quality of our Services.

    3. How We Share Your Personal Information. From time to time, we may need to share your Personal Information with others in connection with our Services.

      Third Party Service Providers. Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We may share your information, including Personal Information and Usage Data, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and at our direction, and not use Personal Information for purposes other than the product or service they're providing to us or on our behalf and only in accordance with our Privacy Policy.

      Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we're required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.

      Protection of Remy.co and Others. We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our products' Terms of Service and other agreements; or protect the rights, property, or safety of Remy.co, our Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

      Sale of Our Business. In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.

      With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Information may be shared with other third parties.

  3. WHAT YOU CAN DO TO MANAGE YOUR PRIVACY.

    You can view and edit information that identifies you online through your Remy.co Service. How you can access and control information that identifies you will depend on which Services you use. You have a choice about the use of information that identifies you, marketing communications you receive from us, and our use of cookies and other tracking technologies.
    1. Cookies and Other Tracking Technologies.

      The following is a high-level summary of our practices and your controls for Cookies and other tracking technologies.

      In accordance with applicable law, Remy.co and our service providers may use commonly-used tools to recognize your visit and track your interactions with our Services such Cookies. Sometimes this tracking is necessary in order for us to provide you the Service you requested. Other times, we combine Usage Data collected from Cookies with that of other customers to improve your and other users’ experience. You have control over some of the Usage Data we collect from Cookies and how we use it. Information on changing your browser settings to opt out of Cookies can be found in your browser settings. If you opt-out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.

    2. Opting-Out of Marketing Communications.

      You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the Settings section of the Site, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

  4. DATA RETENTION AND YOUR ACCESS RIGHTS.

    1. Data Retention.

      In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and Remy.co’s records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.

    2. Your Access Rights.

      As required by applicable law, you may contact us to confirm whether we maintain, or process on behalf of a third party, any of your Personal Information and to review it in order to verify its accuracy and the lawfulness of our processing of such Personal Information. Where you have determined that the Personal Information we collected about you is inaccurate or processed in violation of applicable law, you may also request that your Personal Information be corrected, amended, or deleted. Requests for access to your Personal Information and to have it corrected, amended, or deleted should be sent toprivacy@remy.co

  5. SECURITY OF YOUR INFORMATION.

    Keeping your Information safe is important to us and this is how we protect it.

    We provide reasonable and appropriate security measures in connection with securing Personal Information we collect. We also implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Services, you acknowledge that you understand and agree to assume these risks.

    We constantly work to update our security practices to implement accepted best methods to protect your Personal Information, comply with applicable laws and security standards, and securely transmit your sensitive Personal Information.

  6. INTERNATIONAL DATA TRANSFERS.

    In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your information, process and store it outside your country of residence to wherever we or our third party service providers operate.

  7. LINKS TO OTHER WEBSITES.

    As part of the Services, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Services. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Services. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

  8. CHANGES TO OUR PRIVACY STATEMENTS.

    From time to time we may change or update our Privacy Policy. Remy.co reserves the right to change this policy and our Terms of Service at any time. More information about how we will notify you is below.

    If we make material changes to the way we process your Personal Information, we will provide you notice via our Services or by other communication channels, such as by email or by placing a prominent notice on our site. Please review any changes carefully. If you object to any of the changes and no longer wish to use our Services, you should close your account. All changes are effective immediately upon posting and your use of our Services after a notice of material change or posting of an updated Privacy Policy shall constitute your consent to all changes. You should periodically check the Site and this privacy page for updates.

  9. COLLECTION AND USE OF CHILDREN'S PERSONAL INFORMATION.

    We do not knowingly collect information from minors.

    Remy.co’s Services are intended for and directed to adults. Our Services are not directed to minors and we do not knowingly collect Personal Information from anyone under the age of 18.

  10. YOUR CALIFORNIA PRIVACY RIGHTS.

    We do not share your Personal Information with third parties for their marketing purposes without your consent.

  11. GOVERNING LAW.

    This Privacy Policy shall be governed, construed and enforced in accordance with the laws of the United States and the State of New York, without regard to any conflict of law rules. You agree by your use of the Site and Services that any dispute or claim in any way relating to this Privacy Policy shall be subject to the exclusive jurisdiction and venue of the courts within New York, New York.

  12. CONTACT US.

    We welcome your questions or comments regarding this Privacy Policy. If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to privacy@remy.co

Last Updated: This Privacy Policy was last updated on April 1, 2017.