Privacy Policy
At Thrilld, safeguarding your privacy and being transparent about all things data is of utmost importance to us. As a core Web3 value, transparency is the foundational principle guiding the development and provision of our services and products.
We appreciate the trust you place in us when you entrust us with your information. Because we want you to have complete trust in our offerings, enabling you to focus on forming the right connections and obtaining new business value, we have created a Privacy Policy that is fundamentally built on five pillars.
GDPR-Compliance: Every product and service we create is meticulously designed with your privacy as a paramount consideration. Our servers are based in Germany, fully respecting the EU’s GDPR (General Data Protection Regulation). Furthermore, we prioritize the confidentiality and privacy of your conversations by facilitating fully private chats.
Transparency: We are acutely aware of the common issues surrounding privacy policies, such as inadequate information and convoluted language. We prefer to do things differently. Hence, we are happy to provide any necessary information. Feel free to contact us at support@thrilllabs.io if you have any questions.
Security: Thrilld employs a top-notch team that works every day to uphold the security and integrity of your data. We consistently update our security protocols to ensure your data remains protected.
Data Governance: Thrilld maintains rigorous ethical data governance practices. We do not function as an intermediary for data, nor do we compel members to share specific information beyond that baseline information needed to create an account. You have complete autonomy over the data you choose to include in your profiles. Safety: To filter out potential bad actors, Thrilld employs a proprietary hybrid human/AI mechanism that combines AI with human expertise to proactively prevent and mitigate malicious activities, ultimately fostering a positive and safe ecosystem. Because trust remains an integral part of business, even in Web3, we do recommend our members consult Thrilld’s Due Diligence Guidelines.Privacy PolicyWelcome to our Privacy Policy. Thank you for taking the time to read it.We appreciate that you trust us with your information and we intend always to keep that trust. This starts with ensuring you understand the information we collect, why we collect it, how it is used, and your choices regarding your information.
This Privacy Policy applies from September 12, 2023. Last update: May 6th, 2024.
1. Who we are
The company responsible for your information under this Privacy Policy (the “data controller”) is: Thrilld Labs B.V.
Vogelzand 181132 MJ Volendam
The Netherlands
2. Where this Privacy Policy applies
This Privacy Policy applies to websites, apps, events and other services we operate under the Thrilld brand. For simplicity, we refer to all of these as our “services” in this Privacy Policy.
3. Information we collect
It goes without saying that we can’t help you develop meaningful synergies without some information about you, such as basic profile details and the types of individuals and companies you’d like to meet.
Information you give us You choose to give us certain information when using our services. This includes:
When you create an account, you provide us with at least your phone number and email address, as well as some basic details necessary for the service to work, such as your occupation type, background or expertise, and who you’d like to talk synergies with.
When you complete your profile, you can share your expertise, background, or interests with us. Where you provide such elements to us, you consent to us using them for the purposes identified and as laid out in this Privacy Policy. You can also share additional information with us, such as details on yourself or the company you are associated with and your highlights, as well as content such as photos and videos. To add certain content, like pictures or PDFs, you may allow us to access your camera or files.
When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us with information related to the purchases you make and our payment processors with information, such as your debit or credit card number or other financial information.
When you participate in interviews or public community events, you give us your insights into our products and services. When you choose to participate in our promotions, events, or contests, we collect the information that you use to register or enter.
If you contact our customer care team, we collect the information you give us during the interaction.
If you share with us information about other people (for example, if you use contact details of a friend for a given feature or referral), we process this information on your behalf in order to complete your request.
Of course, we also process your chats with other members as well as the content you publish to operate and secure the services and to keep our community safe. We keep your chats private and secure.
Information we receive from others
In addition to the information you may provide us directly, we receive information about you from others, including:
Members: Members may provide information about you as they use our services, for instance, as they interact with you or if they submit a report involving you.
Other Partners: We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our members’ safety and security.
Information generated or automatically collected when you use our services
When you use our services, this generates technical data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details.
Usage Information: Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using) and your interactions with other members (e.g., members you connect and interact with, and when you matched and exchanged messages with them).
Device information: We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
Information collected by cookies and similar technologies: We use cookies and similar technologies (e.g., web beacons, pixels, SDKs) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them and how you can better control their use.
Other information collected with your consent
Precise geolocation data:
If you give us your consent, we can collect your precise geolocation (latitude and longitude) from your device in order for the hyperlocalisation feature to work. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise geolocation, we will not collect it, and our services that rely on precise geolocation may not be available to you.
4. How We Use Information
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you and our community safe. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.
A. To administer your account and provide our services to youCreate and manage your accountProvide you with customer support and respond to your requestsCommunicate with you about our services
B. To help you connect with other members and PartnersRecommend you to other members and recommend other members to youShow members’ profiles to one anotherEnable members to search for and connect with members and Partners
C. To provide new Thrilld services to youRegister you and display your profile on new Thrilld features and appsAdminister your account on these new features and apps
D. To improve our services and develop new onesAdminister focus groups, market studies and surveysUnderstand how members typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how members react to it)Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from members)
E. To prevent, detect and fight fraud and other illegal or unauthorized activities Find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between membersBetter understand and design countermeasures against violations of our Terms of UseRetain data related to violations of our Terms of Use to address the violation and prevent against recurrencesEnforce or exercise our rights, for example our rights set out in our Terms of UseCommunicate to individuals who submit a report, including what we’ve done as a result of their submission
F. To ensure legal compliance
Comply with legal requirements;
Assist law enforcement.
To process your information as described in this Privacy Policy, we rely on the following legal bases:
Provide our service to you: The reason we process your information for purposes A, B and C above is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other members and recommend other members to you and to otherwise provide our free and paid features to you and other members.
Legitimate interests: We process your information for purposes noted above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we process information to help keep our members safe, and we process data where necessary to enforce our rights.
Comply with applicable laws and regulations: We process your information for purpose G above where it is necessary for us to comply with applicable laws and regulations and evidence of our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement.
Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
5. How We Share Information
Since our goal is to help you create meaningful synergies, the main sharing of members’ information is, of course, with other members. Read on for more details about how your information is shared with others.
With other members
You share information with other members when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings. If someone submits a report involving you (such as a claim you violated our Terms of Use), we may communicate to the reporter actions, if any, we took as a result of their report.
With our service providers and partners
We use vendors to help us operate, distribute, market and improve our services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We may share information with vendors who distribute and assist us in advertising our services. We follow a strict vetting process prior to engaging any vendor or working with any partner. Our vendors and partners must agree to strict confidentiality obligations.
With our affiliates
We may share your information with our partners for limited legitimate purposes as laid out below:To make Thrilld safer and enable us to address (e.g., ban) bad actors found on one platform also on the othersFor them to assist us in data processing operations, as processors / service providers, upon our instructions and on our behalf. Their assistance may include technical processing operations, such as data hosting and maintenance, customer care, marketing, analytics, finance and accounting assistance, improving our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
With law enforcement / when required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our members, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will clarify why we want to share the information.We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, location in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances.
6. Cross-Border Data Transfers
When we transfer personal information outside of the EEA, the United Kingdom, Switzerland or other countries which data protection laws have been deemed adequate by the European Commission or other competent governmental body, we use standard contract clauses (standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data) or other appropriate transfer mechanism.
7. Your Rights and Choices
We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
Access / Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact support@thrilldlabs.io for help.
Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
Account closure. You can close your account by using the corresponding functionality directly on the service.
We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to:
Access/know. You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format. You can exercise your right to access directly within the service by contacting support@thrilldlabs.io.
Delete/erase. You may request that we delete the personal information we keep about you. You can exercise your right to delete by contacting support@thrilldlabs.io.
Correct/rectify/update. You can correct most information you provided to us by editing your profile directly in the service. If you believe the information we hold about you is inaccurate, you may contact us via support@thrilldlabs.io to rectify said information.
Object/restrict. You may also have the right to object to or request that we restrict certain processing. To do so, please contact us via support@thrilldlabs.io.
For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your phone number.
Crucially, please note that we do not “sell” your personal data, or use it for “targeted advertising” or “profiling”, so no opt-out choice is necessary.
In certain countries, including in the European Economic Area and the United Kingdom, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. You can find information about your data protection regulator in the European Economic Area here, and in the United Kingdom here. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement occurred.
8. How Long We Retain Your Information:
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 4) and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other members. Note that we will close your account automatically if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as laid out below:
1. To protect the safety and security of our members, we implement a safety retention window of three months following account closure, or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
2. Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
a) We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents members give us for five years to evidence our compliance with applicable law.
b) We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase for five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defence of legal claims, and data necessary to prevent members who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.
c) Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).
9. No Children Allowed
Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a member is under the age of 18, please use the reporting mechanism available on the service.
10. Job Candidates, Contractors and Vendor Representatives
We process the personal information of our job candidates, contractors and vendor representatives, as part of our recruitment and talent management operations and our management of the services that contractors and vendors provide to us. If you are a job candidate, contractor or vendor representative of ours, certain relevant terms of this Privacy Policy apply to our processing of your personal information. If you are a job applicant, the personal information we process about you may vary depending on the job you seek but typically includes what you provide to us as part of your job application as well as professional qualifications, background and reference information that recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract. For contractors and vendor representatives, we may process identification information and work-related information, as necessary to manage our relationship with you and your employer, which is necessary for the performance of the services agreement, and to establish, exercise or defend potential legal claims. We keep your personal information only as long as necessary for those purposes.
11. Privacy Policy Changes
Because we strive to make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
12. How to Contact Us
If you have questions about this Privacy Policy, you have different options below: Reach us via support@thrilldlabs.io By post:
Thrilld Labs B.V.
Vogelzand 18 1132 MJ, Volendam
The Netherlands