Privacy Policy

THRISSLE’S PRIVACY POLICY

This Privacy Policy (the “Policy”) applies to Thrissle.com (collectively, “MB Payments Inc., “Thrissle”, “us”, “we”), which is operated by MB Payments Inc,

We understand that the privacy of its members, subscribers, guests and/or visitors (collectively, “Members”, “you” or “your”) is very important. We developed this Policy to ensure that your privacy is protected while using Thrissle or its services.

Table of Contents

• How We Collect, Use, and Disclose Your Information
• Our Use of Cookies and Your Options; Pixel Tags; Do-Not-Track
• Collection, Use, and Disclosure of Personal Information by Third Parties
• A Special Note about Children
• How We Protect Your Information
• Where we are Located
• Reviewing, Updating, Accessing or Removing Your Personal Information and Registering Privacy-Related Complaints
• Revisions to Our Policy

1. How We Collect, Use and Disclose Information

What Information Do We Collect?

During the registration process for, or while using, Thrissle, you may choose to provide us with certain “Personal Information” including your name and email address

• When you register for an account or interact with our Services.
  We collect Personal Information when you use or interact with our Services, including when you register with us, This Information may include name, email address Location Data. “Location Data” means either approximate location or, with your consent, precise location. We use this data to create your account, enable your activity within our Services, and to provide the Services generally, including to develop, enhance, and improve our Services and your experience.

When you provide or share Personal Information within our Services.

We collect this information in order to provide the Services and to tailor features, products, advertising, and services to your interests.

• When you communicate with us or sign up for promotional materials.
  We collect your contact information when you communicate with us or sign up to receive promotional materials, magazine subscriptions, or other information via email, mail, or via push notifications or text messages.

• When you engage with our online communities or advertising.
  We may collect your Personal Information when you engage with our online communities, including when you click on advertisements, interact with our social media pages
• When we collect Personal Information from third parties or publicly-available sources.
  We may obtain certain information about you from third-party or publicly-available sources to help us provide and improve the Services and for marketing and advertising.

• When we leverage and/or collect cookies or device IDs.
  We may collect certain Personal Information using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising. Please see Section 2 for more information and options to control or opt-out of certain data collection or uses.

We may also collect information about your activities or postings on Thrissle when you choose to send us personal correspondence such as emails or letters or when other Thrissle.com users or third parties send us correspondence, which may include their comments about you. All this information will be kept in a file that is accessed only by authorized personnel or representatives.

Providing your Personal Information to us is voluntary. However, if you do not provide your Personal Information to us, you will not be able to access some or all of our services.

How do We Use Your Information?

When you provide Personal Information to us, we will use it to contact you about our servicesand to tailor our services to your meet your preferences.

We use your Personal Information for many specific purposes, including:

• emailing you with news and updates about the Thrissle
• improving and customizing our content and product offerings
• analyzing Thrissle usage and delivering information (such as banners and promotions) targeted to your interests
• providing you with information about the products and services provided by or third parties

We may also use your Personal Information to resolve disputes, troubleshoot problems, enforce any agreements, policies and rules governing the use of Thrissle, and observe the Thrissle for quality control and customer service purposes.

If you use our referral services, we will use your friend’s name and email address only to send an invitation and to track the status of the referral. Your friend(s) may use the unsubscribe function in the email or contact us at [email protected] request that we remove their email address from our records.

When and to Whom Will We Disclose Your Information?

We may share or transfer your Personal Information with our subsidiaries operating other Thrissle so that they can send you information about their products or services that you may be interested in.

We also disclose Personal Information to our service providers as reasonably necessary or appropriate to provide services on the Thrissle. Our service providers are legally required by us to protect your Personal Information. Because many of the Thrissle operate or use service providers located in different countries, your Personal Information may be transferred to a country in which you do not reside, and while in that foreign country, may be accessible to its law enforcement authorities.

We may be required to disclose your Personal Information in order to comply with a court order, subpoena, search warrant, or a lawful request by public authorities, including to meet national security or law enforcement requirements. In addition, we expressly reserve the right to disclose your Personal Information when we have a good faith belief that disclosure is necessary to protect our rights, to enforce our agreements, policies, and rules governing your use of the Thrissle, and/or to report information concerning a threat of serious injury or death.

We DO NOT sell or rent any of your Personal Information to third parties for marketing purposes without your express permission or consent. We may, however, disclose to third-party advertisers certain aggregated or hashed (i.e., encrypted) information in a manner that no longer reflects or references an individually identifiable user, for other marketing and promotional purposes.

When you provide your Personal Information and Sensitive Personal Information to us, you consent to our use and disclosure of that information as described in this Policy. If you do not want us to use or disclose your Personal Information as described in this Policy, do not provide it to us. We note that this may result in you being unable to access some or all of our services.

2. Our Use of Cookies and Your Options; Pixel Tags; Do-Not Track

Thrissle uses “cookies” to store and sometimes track information to make your online experience easier and more personalized.

Cookies are small pieces of data that are stored by a user’s web browser on the user’s storage drive. Cookies may record information that is accessed by a user on a webpage in order to simplify subsequent interactions with that website by the same user, or to streamline the user’s transactions on related webpages. Cookies make it easier for a user to move from webpage to webpage and to complete transactions over the Internet.

Most major web browsers are set up so that they will initially accept cookies, but you may modify your computer’s preferences to issue you an alert when a cookie is downloaded, or to disable the ability of third parties to download a cookie to you. If you choose to reject all cookies, there are areas of Thrissle that may not function properly. You may obtain further information about cookies and how they function at: https://en.wikipedia.org/wiki/HTTP_cookie.

We, or a data provider or advertiser that we have engaged, may also place or recognize a cookie on your browser to enable you to receive customized ads or content. These cookies contain no Personal Information. The cookies may reflect de-identified demographic or other data that is linked to data that you have voluntarily have submitted to us (e.g., your email address) that we may share with the data provider or advertiser solely in a hashed (i.e., non-human readable) format. To opt-out of these cookies or to learn more about them, please go to https://www.aboutads.info/choices.

We may also use standard Internet technology, such as web beacons or 1×1 “gifs” and other similar technologies (collectively “Pixel Tags”). A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to Members and may be associated with cookies on the Members’ storage drives. We use Pixel Tags to track your use of the Thrissle, for advertising, marketing, or promotional purposes, and to determine whether you opened an email message from us. The information also enables us to customize the services we offer.

Other parties may collect Personal Information about your online activities over time and across different websites when you use our services. We honor web browser “do not track” signals that provide you with the ability to exercise choice regarding the collection of Personal Information about your online activities over time and across third-party websites or online services, when the web browser’s http header includes the field “dnt:1”. We do not presently honor any other types of “Do Not Track” mechanism.

3. Collection, Use and Disclosure of Personal Information by Third Parties

This Policy only addresses the use and disclosure of Personal Information that we collect from you. To the extent that you disclose your Personal Information to others while using the Thrissle or other websites throughout the internet, different rules may apply to its use, maintenance, or disclosure. We do not control the privacy policies of third parties, and you are subject to the privacy policies or practices of those third parties.

4. A Special Note about Children.

Children under thirteen years of age are prohibited from using the Thrissle or services. 

5. How We Protect Your Information

Thrissle uses reasonable security measures to help protect and prevent the loss, misuse, and alteration of the information under our control. We use industry standard efforts, such as firewalls, to safeguard your Personal Information. While “perfect security” does not exist on the Internet, or elsewhere, our technical staff works hard to help ensure your secure use of our services.

6. Where we are Located

We are located in the United States. If you are visiting any of the Thrissle from outside the United States, you must be aware that your Personal Information may be transferred to, stored, and processed in the United States or other countries in which we or our service providers are located. The data protection and other laws of the United States and these other countries might not be as comprehensive as those in your country, and your Personal Information may be accessible to law enforcement authorities in the United States or of other countries.

When you use the Thrissle, you consent to us transferring your Personal Information (which includes, for the avoidance of doubt, your Sensitive Personal Information) from your country to the United States or countries in which we or our service providers are located for the purposes described in this Policy.

7. Reviewing, Updating, Accessing or Removing Your Personal Information and Registering Privacy-Related Complaints

If applicable, once you register, you will be able to review and change much of your Personal Information including: your name and email address

Please promptly update your information by logging in to your account and following the screen prompts. We strongly urge you to change your password periodically to help reduce the risk of unauthorized access to your account information.

You have the right to ask in writing whether we hold any Personal Information about you, and to see that information as well as how we collect, use or disclose your Personal Information. We note that we may not be able to provide you with all of the information you request, depending on the circumstances (e.g., if it contains the Personal Information of other Members). There may be a charge for any copy of Personal Information requested.

Upon your request, we will remove your credit card number, credit card expiration date and other Personal Information from our main databases. We note that, despite your request, we may retain in our files certain data (including credit card information) if necessary to:

• resolve disputes
• troubleshoot problems
• enhance security, reduce fraud, or comply with the law, or
• enforce any agreements, policies, and rules governing your use of Thrissle

We note that despite our best efforts to remove information from our database on your request, removed information may exist in backup For  requests to access, update, modify or delete your Personal Information, please:

Email us at: [email protected] 

Write us at: Thrissle, 1615 S. Congress Avenue, Suite 103, Delray Beach, Florida 33445 USA

You may contact us using the above contact information to register a privacy-related complaint. We will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right. We will also let you know what other complaint procedures may be available to you.

8. Revisions to this Privacy Policy

We reserve our right, in our sole and absolute discretion, to revise, amend, modify or revoke this Privacy Policy at any time, and in any manner to the fullest extent permitted by law. If the changes are significant, we will provide a more prominent notice. Changes to this Policy will be effective by posting revisions on the Thrissle.

Specific Disclosures for the European Economic Area

(This section is effective on May 25, 2018)

This section applies to data processing activities of data subjects residing in the European Economic Area as well as, regardless of residence, to the processing of any Personal Data in the European Economic Area. To the extent there is any conflict between the Specific Disclosures for the European Economic Area and any other part of the Privacy Policy or Terms of Use, this section shall control.

For purposes of this section, the following definitions apply:

• “Personal Data,” means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• “Sensitive Personal Data” or “Special Categories of Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

1. Legal Basis for Processing

We collect and process your Personal Data for a variety of different purposes which are set out in further detail in this section.

In some cases, we will ask for your consent so that we may process your Personal Data. However, in certain circumstances, applicable data protection laws allow us to process your Personal Data without needing to obtain your consent.

1.1. CONSENT FOR PROCESSING SENSITIVE PERSONAL DATA

We obtain your explicit consent to process your Sensitive Personal Data. Certain Sites may require this data to provide the Services. Please note that, if you choose not to provide Sensitive Personal Data, certain features or Services may be unavailable or not function properly.

In certain limited circumstances, we may process or otherwise disclose your Sensitive Personal Data without your consent to protect the vital interests of you or of another person where the data subject is physically or legally incapable of giving consent, or where it is necessary to establish, exercise, or defend legal claims, including to comply with law enforcement or other legal or judicial orders or requests for such purposes.

1.2. CONSENT FOR PROCESSING NON-SENSITIVE PERSONAL DATA

In cases where we are not already authorized to process the Personal Data under applicable law, we may ask for your consent to process your non-Sensitive Personal Data, including:

• Marketing
  We may ask for your consent for Magnolia or our partners or vendors to contact you by telephone, SMS, post and/or email about other offers, products, promotions, developments or Services which we think may be of interest to you and for other marketing purposes.

• Use of Cookies
  Our Site uses cookies and similar technologies to improve user experience and for analytics. We also use cookies and similar technologies for purposes of marketing and advertising, including interest-based advertising. For more information on interest-based advertising, see section 3 (Interest-Based Advertising). In those jurisdictions that require it, we allow the data subject to give explicit permission or to deny the use of certain categories of cookies.
  
  If you want to block the use and saving of cookies from the Site on to their computers hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Site. Please note that if you choose to erase or block your cookies, certain parts of our Site may not function correctly. For information on how to disable cookies, refer to your browser’s documentation.

1.3. PROCESSING PERSONAL DATA WHERE CONSENT NOT REQUIRED

In certain cases where we are not processing Sensitive Personal Data, separate consent may not be required, including:

• For the performance of a contract.
  To perform our contractual obligations to you, including fulfilling orders or purchases you have made, contacting you in relation to any issues with your order or use of our Services, in relation to the provision of our Services, or where we need to provide your Personal Data to our service providers related to the provision of the Services.

• To comply with legal obligations.
  To comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.

• To protect data subjects’ vital interests.
  To protect the vital interests of you or of another person.

• Legitimate Interests.
  To operate our business and provide our Services (other than in performing our contractual obligations to you) for our “legitimate interests” and for the purposes of applicable law, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Legitimate interests may include:
  • To communicate with you regarding the Services, including to provide you important notices regarding changes to our Terms of Use and to address and respond to your requests, inquiries, and complaints.
  • To assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights and property, or the rights or safety of third parties.
  • To develop, provide, and improve our Services.
  • To enforce our Terms of Use or this Privacy Notice, or agreements with third parties.

2. WITHDRAWING YOUR CONSENT

You may at any time withdraw the consent you provide for the processing of your Personal Data or Sensitive Personal Data for the purposes set forth in this Privacy Notice by contacting us at [email protected] provided that we are not required by applicable law or professional standards to retain such information.

If you want to stop receiving future marketing messages and materials, you can do so by clicking the “unsubscribe” link included in our email marketing messages or by contacting us [email protected]

3. DATA SUBJECT RIGHTS

You have the right in certain circumstances to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, you also have the right to request access to, modification of, or deletion of such Personal Data.

You also have the right in certain circumstances to receive the Personal Data concerning you that you provided to us, to restrict processing of your Personal Data, or to transmit such data to another controller.

To exercise your rights with respect to your Personal Data, please contact us alias at [email protected]. As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. Furthermore, where permissible, we may charge for this service. We will respond to reasonable requests as soon as practicable and as required by law.

4. DE-IDENTIFIED OR ANONYMIZED DATA

We may create de-identified or anonymous data from Personal Data by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of anonymized data is not subject to this Privacy Notice.

5. DATA RETENTION

We will retain your Personal Data for as long as long as you maintain an account or subscription agreement or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You may have a right to lodge a complaint with a supervisory authority.

7. CONTACT US

For questions regarding this Privacy Notice, please contact us at: [email protected]