Privacy Policy.
I. INTRODUCTION
ThunderLink Ltd. (collectively “ThunderLink”, “we,” “us,” or “our”) is dedicated to protecting the privacy of our users (“User”, “you”) by informing you on how we collect, store, and use your Personal Information. The Privacy Policy (“Privacy Policy”, the Policy”) applies to the User Data we collect when you use ThunderLink’s Sites and Services, however, accessed and/or used, that are operated by us, made available by us, or produced and maintained by us and our related companies.
Please be advised that the practices described in this Privacy Policy apply to information gathered online through our Sites and otherwise by our customer service personnel. It does not apply to data and information that you may submit to organizations to which we may link or who may link to us or information that we may receive about you from other organizations.
This Privacy Policy applies in addition to the Terms of Use of our Sites and Services.
ThunderLink does not gather any Personal Information, such as your name, phone number, street or email address, from you without your consent. By using our Sites, you agree that you consent to:
The practices and conditions set out in this Privacy Policy and
The collection, use, and retention of the User Data listed in this Privacy Policy.
If you do not agree to the terms of this Privacy Policy, please do not use our Sites and Services.
II. DEFINITIONS
In this Privacy Policy:
“Affiliate”: An entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
“Business Partners”: Any natural or legal person who is collaborating with the Company to facilitate the Shared Power Bank Rental Service.
“Charging Station”: ThunderLink’s physical machine and infrastructure that stores Shared Power Banks and facilitates the Shared Power Bank Rental Service.
“Charging Station and Devices": Collectively represent the physical infrastructure and electronic components, including the Charging Station and Shared Power Banks, that facilitate the Shared Power Bank Rental Service.
"Contact Information": Information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual; as defined by PIPA.
“Electronic Device”: Any electronic device that can access the Sites and Services, such as a computer, a mobile phone or a tablet.
“Employee”: A volunteer or paid individual.
"Shared Power Banks": Portable charging devices designed for charging Electronic Devices available for rental through ThunderLink's Charging Station.
“Shared Power Bank Rental Service”: ThunderLink's Service provided on its Sites that allows users to borrow ThunderLink’s Shared Power Banks from its Charging Station for temporary use.
“Services”: ThunderLink’s Shared Power Bank Rental Service, and any other Services made available by ThunderLink and all other features provided and operated by ThunderLink.
“Server”: ThunderLink’s Server located in Silicon Valley, California. We store all of the User Data in our Server. We equip our Server with SSL encryption technology to protect the safety of the data.
“Sites”: The network of websites owned by ThunderLink, including thunderlink.ca, thunderlink.cloud, and any versions optimized for viewing on Electronic Devices.
“Service Providers”: Any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Services, to provide the Service on behalf of the Company, to perform the services related to the Services or to assist the Company in analyzing how the Service is used. A person retained under a contract to perform the Services for a public body.
“User Data”: Any data information that we collect from our users, including Contact Information, Personal Information and Non-Personal Information, either generated by the use of the Services or from the Services infrastructure itself.
“Personal Information”: Information about an identifiable individual, as from PIPA. The only time ThunderLink collects your Personal Information is when you volunteer to give it to ThunderLink.
“Non-Personal Information”: Information about an identifiable individual other than Contact Information, but it may include tracking and usage information.OurSites may automatically keep an activity log of your use of our Sites and Services.
“Users” (“you”): Any individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Personal Information Protection Act (PIPA): Governs the collection, use, and disclosure of Personal Information by organizations in a manner that recognizes both the right of individuals to protect their Personal Information and the need of organizations to collect, use, or disclose Personal Information for purposes that a reasonable person would consider appropriate in the circumstances in British Columbia, Canada.
III. USER INFORMATION COLLECTION
We only collect User Data from you for the purposes of administering our Sites and Services and to inform you of our Sites and Services, and will be used only for these purposes. We also may collect information about you that we may receive from other sources or from our offline interactions with you to, among other things, enable us to verify, update information contained in our records and to better customize the Sites for you. This data may be collected when You:
Register an account for accessing our Services;
Use of the account through the Sites;
Submit payment information to ThunderLink when accessing our Services;
Provide profile information and images for your account;
Send ThunderLink an email;
Request for customer service, support requests or other assistance;
Sites related communications, e.g. account verification; technical notification;
Register for an event sponsored by us;
Authorize social media information;
Participate in surveys, contests, sweepstakes or other promotional services;
Sign up to receive alerts or other information via email, text or instant message from ThunderLink;
Participate in communities, commenting to blog entries and participation in other forums;
Any other place on the Sites where you knowingly volunteer Personal Information.
Personal Information We Collect
Personal Information is any information that can individually identify you. We may collect Personal Information when you perform certain functions on our Sites and we will not collect any additional data beyond the data listed below without notifying you first. You are responsible for the regular maintenance of your Personal Information, to keep your Personal Information accurate and valid. The Personal Information we may collect through the Sites includes:
First name;
Last name;
Date of birth;
Email address;
Phone number;
Mailing Address;
Payment information;
Profile picture;
Consent to opt-in for email communication options from ThunderLink;
Information regarding your account username in order to connect your profile with ThunderLink’s Sites and Services.
Other Information and Data We Collect
Non-Personal Information includes information that does not personally identify You, but it may include tracking and usage information. In addition, when you interact with the Sites, we may collect certain information that does not identify you individually, and our Sites may automatically keep an activity log of your use of our Sites and Services. Generally, we collect and store the following categories of Non-Personal Information:
Non-identifiable demographic data;
Device information, including timestamps, and battery status.
Additional “traffic data” and log files such as time of access, date of access, software crash reports, session identification number, access times, and referring Sites addresses.
Collection of Your Source IP Address/Location Information
We collect and store location information about you on the Sites and associated with your account or enable through the Sites or your Electronic Device. We will collect information regarding the rental status of these Shared Power Banks. We will not collect any location information that you do not volunteer or enable, but you must agree to provide certain location information in order to use the Sites and Services. We also collect and store your device’s source IP address which may disclose the location of your Electronic Device at the time you access the Sites.
Collection of Personal Information From and Through Using Social Media Websites or Logins
When you interact with any of our Service Provider’s websites or accounts on social media platforms, such as Facebook, Google, or Instagram, we may collect the Personal Information that you make available to us on that page or account including your account ID or username. However, we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such Personal Information that we are permitted to collect by these social media platforms. If you publish your social media profile on our Sites and Services, we may collect Personal Information that you make available as part of that profile.
Collection of Personal and Non-Personal Information Through Sweepstakes or Other Promotions
From time to time, we may provide you with the opportunity to participate in sweepstakes or other promotions on our Sites and Services, which might be sponsored or conducted by a third party. If you participate, we will request certain Personal Information from you. Participation in these sweepstakes and promotions are completely voluntary and you therefore have a choice whether or not to disclose this Personal Information. If you follow links or hyperlinks from websites from a third party, please note that we are not responsible for and have no control over their content, privacy policies or practices of any third party websites or services. We strongly advise you to review the Privacy Policy of every site you visit.
Collection of Third Party Personal Information Through Invite-A-Friend Feature
We may provide you the opportunity to participate in a referral program to introduce individuals you know to our Sites and Services. If you choose to use our referral program to tell someone about our Sites and Services or a discount on the Sites and Services, we will ask you for your contact’s name and phone number. We will provide you with an invitation code to provide to the individuals you wish to refer. We store this information for the purpose of generating and providing a referral code to you and tracking the success of our referral program.
IV. USE OF COLLECTED INFORMATION
Data collected on our Sites will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Sites. We will not use your data beyond what we disclose in this Privacy Policy.
The data we collect when a User performs certain functions may be used for the following purposes:
To create an account;
To access our Sites and Services and provide the Services to you as you have purchased through our Sites;
To track the duration of use of our Shared Power Banks;
To upload your content to our Sites as you request;
To permit you to update, edit, and manage your content on our Sites;
To provide and maintain our Sites and Services, including to monitor the usage of our Sites and Services;
To communicate with you about your account or transactions with us (including service-related announcements) and send you information about features and enhancements on our Sites;
To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or Services, including the security updates, when necessary or reasonable for their implementation;
To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our Sites and Services;
To generate and provide you with a personalized referral code;
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which User Data held by us about our users is among the assets transferred;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
For internal administrative and auditing purposes;
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities;
For other purposes, such as to optimize or improve and update our products, Sites and Services and operations, to detect, investigate, and prevent activities that may violate our policies or be illegal, and to perform statistical, demographic, and marketing analyses of users of the Sites.
Use of Your Location Information
Specifically, we may use your location information to:
Optimize or improve our products, Sites, Services and operations;
Detect, investigate, and prevent activities that may violate our policies or be illegal;
Perform statistical, demographic, and marketing analyses of users of the Sites and purchasing pattern.
We also use a web analytics service on our Sites. It uses Cookies or other tracking technologies to help us analyze how users interact with and use the Sites, compile reports on the Sites’ activity, and provide other services related to our Sites’ activity and usage. The technologies used may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring Sites. The Sites do not gather analytics information that personally identifies you. The information generated will be transmitted to and stored by the Server and will be subject to the Privacy Policies.
V. WHO WE SHARE USER DATA WITH
Except as disclosed in this Privacy Policy, we do not disclose information about your Personal Information collected online to any companies not part of ThunderLink or its parent, subsidiaries, or related entities. In no event will we sell or rent your Personal Information as part of a customer list or similar transaction.
Our Sites may contain links or hyperlinks to other websites not operated by ThunderLink. Please be advised that the practices described in this Privacy Policy for ThunderLink do not apply to information gathered through these other websites. If you follow links or hyperlinks from our Sites to another website, please note that we are not responsible for and have no control over their content, privacy policies or practices of any third party websites or services. We strongly advise you to review the Privacy Policy of every site you visit.
Employees
We may disclose User Data to certain members of our organization who need reasonable access to User Data to achieve the purposes set out in this Privacy Policy. Our employees are bound by strict confidentiality agreements, and a breach of this agreement would result in the employee's termination.
Business Partners
We may share your Non-Personal Information with our sponsors and other Business Partners from time to time as necessary to operate our Sites and Services.
Third-Party Service Providers
We have third party agents, subsidiaries, Affiliates and partners that perform functions on our behalf, such as hosting, billing, push notifications, storage, bandwidth, content management tools, analytics, customer service, fraud protection, etc. These entities have access to the Personal Information needed to perform their functions and are contractually obligated to maintain the confidentiality and security of that Personal Information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested Services to the Sites.
Payment Processor: Stripe. We do not store or collect your payment details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their Privacy Policy. Stripe adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, and American Express. PCI-DSS requirements help ensure the secure handling of payment information. their Privacy Policy can be viewed at https://stripe.com/us/privacy;
Advertising Agency: We may partner with third party advertising companies to better provide advertisements about our products and Services that may be of interest to you.
Location functionality: We use Google Maps to display all of our Charging Station locations. Google’s Privacy Policy available at https://policies.google.com/privacy.
Other Disclosures
We may use or disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to:
Conform to applicable law or comply with legal obligations;
Prevent or investigate possible wrongdoing in connection with our Sites and Services;
Protect against legal liability;
Protect and defend our rights or property, the Sites or our users, and
Act under emergency circumstances to protect the personal safety of us, our Affiliates, agents, or the users of the Sites or the public. This includes exchanging information with other companies and organizations for fraud protection;
We may use or disclose Personal Information in the event negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
VI. USER DATA STORAGE PERIOD
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. You will be notified if your data is kept for longer than this period.
We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Sites and Services, or we are legally obligated to retain this data for longer time periods.
VII. USER DATA PROTECTION
The security of your Personal Information is important to us. We exercise great care in providing secure transmission of your information from your device to our Servers. Personal Information collected by our Sites are stored in secure operating environments that are not available to the public. Our security procedures mean that we may occasionally request proof of identity before we disclose your Personal Information to you.
We use the following to protect our User Data: (not sure if we have these features as part of GoDaddy)
Data Encryption: SSL certificates encrypt data transmitted between your device and our platform. This encryption ensures that even if intercepted, the data remains unreadable and secure.
Authentication: SSL certificates verify the identity of our platform, assuring you that you're communicating with ThunderLink and not an imposter.
Secure Communication Channels: SSL establishes secure communication channels, making it extremely difficult for third parties to eavesdrop on your interactions with ThunderLink.
HTTPS Protocol: We use the HTTPS protocol, indicated by the padlock icon in your browser's address bar, which signifies a secure connection between your device and our Servers.
By using SSL certificates, we provide a robust layer of protection for your data, reducing the risk of unauthorized access, data breaches, or alterations. Our commitment to these security measures ensures a safe online environment for our website and users, maintains trust, and protects the security of your valuable information.
Please understand that while we take all reasonable precautions to ensure that User Data is secure and that users are protected, no transmission of data over the Internet or any other public network, or method of electronic storage can be guaranteed to be 100% secure. We cannot guarantee its absolute security and there always remains the risk of harm.
VIII. TRANSFER OF USER DATA
Your information collected through the Sites is processed in any country in which ThunderLink, its Affiliates or Service Providers maintain facilities. It means that this information may be transferred to, stored and processed on computers located outside of your country or jurisdiction where the data protection laws may differ than those from your jurisdiction. When we transfer User Data we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring User Data. Wherever your Personal Information is transferred, stored, or processed by ThunderLink, ThunderLink will take reasonable steps to safeguard the privacy of your Personal Information.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. By registering for and using the Sites, you consent to the transfer of information to any country and jurisdictions in which ThunderLink, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
IX. PROTECTION OF MINORS’ INFORMATION
ThunderLink's Sites are open to users of all ages, including those under the age of majority. We are committed to protecting the privacy and Personal Information of all users, particularly minors. If you are under the age of majority, we encourage you to use our Sites and Services responsibly and ensure that you have obtained appropriate parental or guardian consent. If you have any concerns about the privacy or safety of a minor who uses our platform, please contact us using the Who to Contact below. We will take appropriate steps to address these concerns.
X. WHAT ARE YOUR CHOICES AND HOW DO YOU OPT-OUT?
We believe you should have choices about the collection, use and sharing of your information. Although you cannot opt-out of all data collection when you visit our Sites, you can limit the collection, use and sharing of your personally identifiable information.
Collection of Personal Information
All Personal Information is provided on a voluntary basis. If you do not want ThunderLink to collect such information, you should not submit it to our Sites. However, doing so will restrict your ability to access some content and use some of the functionality of the Sites.
Tracking
You also have choices to limit some tracking mechanisms on your Electronic Device that collect User Data when you use our Sites. Many browsers automatically accept Cookies, but you can usually modify your browser’s setting to decline Cookies if you prefer. If you choose to decline Cookies, certain features of our Sites, including the Sites themselves, may not function properly or remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated Cookies. Note that if you choose to remove Cookies, you may remove opt-out Cookies that affect your advertising preferences. For more detail on your ability to opt out, see the Cookie Policy below.
Your browser or device may include “Do Not Track” functionality. Because a “Do Not Track” compliance protocol has not yet been finalized, ThunderLink’s information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.
Accessing and Correcting Your Information
If you have an account with ThunderLink, you may review and change your account information by logging into your account and editing your profile. You will not be permitted to examine the Personal Information of any other person or entity and may be required to provide us with Personal Information to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete Personal Information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.
XI. ACCESS, MODIFY, DELETE, OR CHALLENGE THE DATA COLLECTED
If you would like to know if we have collected your User Data, how we have used your User Data, if we have disclosed your User Data and to whom we disclosed your User Data, or if you would like your data to be deleted or modified in any way, please contact us using the Who to Contact below
Following termination or deactivation of your account, ThunderLink, its Affiliates, or its Service Providers may retain information (including your profile information) and user Content for a commercially reasonable time for backup, archival, and/or audit purposes. If you have any questions about termination or deactivation of your account, please contact us directly using the Who to Contact below.
XII. COOKIE POLICY
A Cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can also choose to disable Cookies in your internet browser or Electronic Device to decline these technologies, but this may decrease the quality of your user experience. We may also use Cookies to monitor traffic, improve the Sites and make it easier and/or relevant for your use. Like many websites, we use Cookies, web beacons and similar technologies to record your preferences, track the use of our Sites. We may also use these technologies to monitor traffic, improve the Sites and make it easier and/or relevant for your use.
We use the following types of Cookies on our Sites:
Necessary Cookies: These Cookies are essential to provide you with Services available through ThunderLink’s Sites and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of users' accounts.
Persistent Cookies: These Cookies identify if users have accepted the use of Cookies on the Sites.
Functionality Cookies: These Cookies allow ThunderLink to remember choices you make when you use our Sites, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid having to re-enter certain information everytime when using our Sites.
XIII. GOVERNING LAW
Any Personal Information you provide to ThunderLink is collected, used and disclosed in accordance with the Personal Information Protection Act.
We will take reasonable steps to protect the User Data of all users of our Sites as described in this Privacy Policy and comply with applicable legal requirements for local data protection and consumer rights laws to the extent they may apply to the Services. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your Personal Information to ThunderLink.
XIV. MODIFICATIONS
We reserve the right to modify or amend the terms of our Privacy Policy from time to time in order to maintain compliance with the law and to reflect any changes that affect our Privacy Policy without notice. When we amend this Privacy Policy we will update the "Last Revised" at the top of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of our Sites following the posting of changes to these terms will mean you accept those changes. We recommend that users periodically review our Privacy Policy to ensure that you are notified of any updates. We will not materially change our policies and practices to make them less protective of Personal Information we have previously collected from you without your express consent. If necessary, we may notify users of changes to this Privacy Policy on our Sites with notice of the modifications or amendments.
XV. CUSTOMER SUPPORT AND WHO TO CONTACT
If you encounter any questions or concerns using the Sites and Services, you can also contact us through the contact form available on our Sites or contact us using the information below:
By email: customerservice@thunderlink.ca