Privacy Policy

​

Policy last updated: June 30, 2023

 

Welcome to our privacy policy!

 

ThrivingLivesGroup.com and its associated websites are operated by Thriving Lives Limited, which uses 3rd party website platforms and other supportive services. We highly value your privacy and comply with data privacy laws. This policy herein reflects how we collect and use your personal information. It includes the rights and choices available to our visitors and users regarding such information.

​

1. Please read carefully!

 

This Privacy Policy (“Privacy Policy”) describes how we (Thriving Lives Limited, “TL”, “we” or “us”), along with 3rd party service providers, by nature of utilizing such services, collect and use information pertaining to each of our unregistered visitors and registered users, including users with Paid Services (each, a “Visitor” or “User” (respectively), or “you”), in connection with their access to and use of TL (including and any of its web domains and subdomains, the “Website”), web applications (“Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”).

 

The purpose of this Privacy Policy is to provide you with a clear explanation of when, why and how we collect and use your personal information, as well as an explanation of your statutory rights. This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.

 

Read this policy and make sure you fully understand our practices in relation to your personal information, before you access or use any of our Services. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave this website, application or service, and avoid or discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us at support (at) ThrivingLivesGroup.com.

 

 

2. What information do we collect?

 

We collect two types of information regarding our Visitors and Users:

 

2.1. Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.

 

2.2. Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.

​

3. How do we collect such information?

 

There are two main methods we use:

 

3.1. We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website, register a User Account, edit your User content and upload information and content, and/or download and use any Apps and/or Mobile Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 6 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 7 below.

 

3.2. We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as Facebook or Google; when you place purchases and/or register domain names; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel (e.g., messaging Apps, emails).

 

3.3. We also collect information from third party sources as described in Section 6 below.

 

4. Why do we collect such information?

 

We collect such Non-personal and Personal Information for the following purposes:

 

4.1. To provide and operate the Services;

 

4.2. To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;

 

4.3. To provide our Users with ongoing customer assistance and technical support;

 

4.4. To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed in Section ‎10 below);

 

4.5. To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;

 

4.6. To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;

 

4.7. To enhance our data security and fraud prevention capabilities;

 

4.8. To comply with any applicable laws and regulations.

 

We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:

 

1. Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with webpage access, to provide you with our customer assistance and technical support), or

 

2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or

 

3. Our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of our campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.

​

5. Where do we store your information?

 

5.1. TL Visitors’ and Users’ Personal Information may be maintained, processed and stored by us and our authorized affiliates and service providers in the United States of America, in Europe (including in Bulgaria, Lithuania, Germany and Ukraine), in Hong Kong, in Israel, and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).

 

TL affiliates and service providers that store or process your Personal Information on our behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

 

5.2. Data Localisation Obligations: If you reside in a jurisdiction that imposes “data localisation” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are capable and legally obligated to do so.

 

You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America and Hong Kong as explained above.

​

6. Sharing personal information with third parties

 

TL may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:

 

6.1. Third Party Services:

 

TL has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).

 

Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.

 

Note that while our Services may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third -party websites and services.

 

6.2. Law Enforcement, Legal Requests and Duties:

 

Where permitted by local data protection laws, TL may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.

 

6.3. Protecting Rights and Safety:

 

TL may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of TL, any of our Users, or any member of the general public, with or without notice to you.

 

6.4. Social Media Features and Framed Pages:

 

Our Services include certain Social Media features and widgets, single sign on features, such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”).These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.

 

In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.

 

6.7. TL Subsidiaries and Affiliated Companies:

 

We may share Personal Information internally within our family of associated companies, for the purposes described in this Privacy Policy. In addition, should TL or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. If we have good faith that such change in control might materially affect your Personal Information stored with us, we will notify you via e-mail and/or prominent notice on our Website of this event and certain choices you may have regarding your Personal Information.

 

TL may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, TL may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.

 

7. Use of cookies and other tracking technologies

 

TL, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.

 

Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy and we do not have any control over them.

 

Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our services.

 

If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by TL, and we, therefore, cannot ensure its accuracy, completeness or availability).

 

Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.

 

Clear Gifs: We and certain Third Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however are not stored on your device, but instead embedded within our Services.

 

Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies.

 

Behavioural Targeting/Re-Targeting: Certain Third Party Services and ad networks may display advertising on our Website, on Apps and on mobile apps, or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party Services to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by clicking: http://preferences-mgr.trustarc.com (or if you are located in the European Union clicking: http://www.youronlinechoices.eu. Please note this does not opt you out of receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will continue to receive advertising for which you have not opted out.

 

User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and Services that may be of interest to you. Where we obtain your Personal Information from these third parties, we ensure that such parties are contractually committed to inform you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

 

“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.

 

8. Communications from TL

 

8.1. Promotional Messages:

 

We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from TL or our partners (acting on TL’s behalf) through such means.

 

If you do not wish to receive such promotional messages or calls, you may notify TL at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.

 

We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.

 

8.2. Service and Billing Messages:

 

TL may also contact you with important information regarding our Services, or your use thereof.

 

For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.

 

It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a TL Visitor or User (which can be done by deactivating your account).

 

We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.

 

9. Your rights in relation to your personal information

 

It is imperative that you have control over your Personal Information. That’s why TL is taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.

 

Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).

 

You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

 

If you are a TL Visitor or User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please contact us at contact (at) ThrivingLivesGroup.com

 

We will make all reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.

 

Please note that permanently deleting your TL account erases all of your information from TL databases. After completing this process, you can no longer use any of your TL services, your account and all its data will be removed permanently, and TL will not be able to restore your account or retrieve your data in the future. If you contact TL Support in the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.

 

10. Questions and Complaints

 

If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.

 

TL will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.

 

We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly. Our target response time is 30 days.

 

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with your local supervisory authority for data protection.

 

You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.

​

11. Data Retention

 

We may retain your Personal Information (as well as your Users-of-Users’ Information) for as long as your User Account is active, as indicated in this Privacy Policy or as otherwise needed to provide you with our Services.

 

We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

 

We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.

​

12. Security

 

TL has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to many areas on our Services; the transmission of sensitive payment information (such as a credit card number) through their designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and they regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. Such systems are regularly evaluated for possible vulnerabilities and attacks, and we regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

 

Regardless of the measures and efforts taken by TL, we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other User Content you upload, publish or otherwise share with TL or anyone else.

 

We therefore encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. If you have any questions regarding the security of our Services, you are welcome to contact us at contact (at) ThrivingLivesGroup.com.

​

13. Public forums and user content

 

Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any information you provide in any such areas may be read, collected, and used by others who access them. In some cases, we may not be able to remove your Personal Information from such areas. In any event, we advise against posting any information (or use any posting means to post information) you don’t wish to publicize on these platforms.

 

If you upload any User Content to your User Account or post it on your User webpage or provide it in any other way as part of the use of any Service, you do so at your own risk.

 

We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Webpage (including, for instance, password-protected areas on the TL site). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.

​

14. Updates and interpretation

 

We may update this Privacy Policy as required by applicable law, and to reflect changes to our information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you. We encourage you to periodically review this page for the latest information on our privacy practices.

 

Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you, with respect to our Website, Apps, Mobile Apps and other Services.

​

15. Contacting us

 

If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in Section 9, please contact us at support (at) ThrivingLivesGroup.com. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.

 

You may also contact us by mail at: Thriving Lives Limited, Suite 2311, 23/F, BEA Tower, Millennium City 5, 418 Kwun Tong Road, Kwun Tong, Kowloon, Hong Kong Lives Limited Have any questions or suggestions? Please let us know!