Customer Privacy Policy

Introduction

Always Thinking, Inc. and its affiliates (“Always Thinking”) respect your concerns about privacy. This Privacy Policy explains Always Thinking’s policies and procedures regarding information we collect from or about our customers and their use of our products and services. Always Thinking intends to provide you with a level of comfort and confidence in how we collect, use, share, and safeguard information that we collect. This Privacy Policy also explains how you can contact us if you have any questions or concerns. By providing information to us or by using our products or services, you agree to the terms and conditions of this Privacy Policy.

Information We May Collect

We collect two main types of information related to you or your use of our products and services. Information from or about you or your devices; Depending on the Always Thinking products and services you request, own, or use, not all of these types of information may be applicable to you. We collect nothing unless you contact us. Then we have your name, email or phone. We will not use your information for anything but replying to you. If you choose to send us video files, we will have that and only retain it for the purpose of providing you support.

From or about you or your devices

We may collect information from or about you (such as your name, address, phone number, e-mail, including:
You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

How We May Use Information We Collect

We may use information we collect to communicate with you to respond to your inquiries and fulfill your requests.

How We May Share Information We Collect

We do not share information we collect with anyone except law enforcement or other third parties you authorize.

Always Thinking may transfer and disclose information, including information that may or may not personally identify you, to third parties to comply with a legal obligation (including, but not limited to, subpoenas); when we believe in good faith that the law requires it; in response to a lawful request by governmental authorities conducting an investigation, including to comply with law enforcement requirements; to verify or enforce our policies and procedures; to respond to an emergency; to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable, Always Thinking, third parties, visitors, or the public, as determined by us in our sole discretion.

We may rely on various legal grounds to collect, use, and otherwise process your information, including: your consent; that the information is necessary for the performance of a contract with you; to comply with a legal obligation; to protect your, or someone else’s vital interests; or for a legitimate interest that is balanced against your rights and interests. These legitimate interests may include protecting Always Thinking or its business partners against wrongful conduct, and responding to customer inquiries and claims. Where applicable, we will inform you whether and why we need certain information from you, for example, whether we need the information to fulfill a legal requirement and what the consequences are of not providing the information.

In certain jurisdictions you may have the rights to request access to and receive information about certain information we maintain about you; update and correct inaccuracies in that information; have the information restricted or deleted; object or withdraw your consent to certain uses of information; and lodge a complaint with your local supervisory authority. You may also have the right to data portability with regard to the data you provided to us. These rights may be limited in some circumstances by local law.

If you would like to exercise your rights regarding information from or about you, you may contact us at the address below.
In your request, please make clear what information you would like to have changed or otherwise let us know what limitations you would like to put on our use of the information that you have provided to us. For your protection, we may only implement requests with respect to the information associated with the particular e-mail address that you use to send us your request, or we may need to verify your identity before implementing your request.

Security

We seek to use reasonable organizational, technical, and administrative measures to protect information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “How to Contact Us” section below.

Retention Period

We will retain information we collect from or about our customers and our products for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you. When determining this retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, and retention periods required by law.

Links

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which our Digital Services link. The inclusion of a link on our Digital Services does not imply endorsement of the linked site or service by us or by our affiliates, nor does it imply an affiliation with the third party.

Please note that we are not responsible for the collection, use, or disclosure policies and practices (including the data security practices) of other organizations, such as any other app developer, app provider, social media platform provider, operating system provider, or wireless service provider, including any information you disclose to other organizations through or in connection with our software applications or social media pages.

We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Security

We use reasonable and appropriate measures to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

Access to Personal Information

Our Customer Privacy Policy sets forth methods by which you may access and/or submit requests to review, correct, update, suppress, or delete information from or about you. Always Thinking U.S. will comply with the Principles in its handling of such requests with respect to Personal Information.

Contact Information

If you have questions, concerns, or complaints about Always Thinking’s privacy practices, please contact us by email at support@alwaysthinking.com. Please note that e-mail communications are not always secure, so please do not include sensitive information in your e-mails to us. You may also write to us at the following address:

Always Thinking, Inc.
Attn: Legal Department
15608 Edgegrove Road
Purcellville, Virginia 20132
United States

Privacy Shield Policy Changes

This Policy may be changed from time to time. You can determine when this Policy was last revised by referring to the “Last Updated” legend at the bottom of this Policy. Any changes to this Policy will become effective when posted to our website. By using our products or services, or otherwise providing information to us following these changes, you accept the revised Privacy Policy.


Last Updated July 2019