Privacy Policy
Privacy Policy of thryve.health
Thryve.health collects some Personal Data from its Users.
Users may be subject to different protection standards and broader standards may therefore apply to some. Users can contact the Owner, to learn more about such standards.
This document can be printed for reference by using the print command in the settings of any browser.
Policy summary
Analytics
Matomo
Personal Data: Tracker; Usage Data
Collection of privacy-related preferences
iubenda Cookie Solution
Personal Data: Trackers
Connecting Data
Zapier
Personal Data: company name; email address; first name; last name; Usage Data
Contacting the User
Contact form
Personal Data: company name; email address; first name; last name
Heat mapping and session recording
Hotjar Heat Maps & Recordings
Personal Data: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service
Interaction with live chat platforms
Zendesk Chat
Personal Data: email address; first name; last name
Interaction with online survey platforms
Hotjar Poll & Survey widgets
Personal Data: Trackers; Usage Data; various types of Data
Managing contacts and sending messages
Mailchimp
Personal Data: email address
Managing data collection and online surveys
Typeform
Personal Data: company name; email address; first name; last name; physical address; profession; website
Managing support and contact requests
Zendesk
Personal Data: various types of Data as specified in the privacy policy of the service
Marketing
OptiMonk
Registration and authentication
Mailboxvalidator
User database management
Pipedrive
Personal Data: various types of Data as specified in the privacy policy of the service
Owner and Data Controller
mHealth Pioneers GmbH
Körtestraße 10
10967 Berlin
Managing Directors
Friedrich Lämmel
John Trimpop
Paul Burggraf
Data privacy officer
Hannes Schenk
Owner contact email: privacy@thryve.de
Full policy
Owner and Data Controller
mHealth Pioneers GmbH
Körtestraße 10
10967 Berlin
Managing Directors
Friedrich Lämmel
John Trimpop
Paul Burggraf
Data privacy officer
Hannes Schenk
Owner contact email: privacy@thryve.de
Types of Data collected
Among the types of Personal Data that thryve.health collects, by itself or through third parties, there are: Tracker; Usage Data; first name; last name; company name; email address; various types of Data; physical address; profession; website.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using thryve.health.
Unless specified otherwise, all Data requested by thryve.health is mandatory and failure to provide this Data may make it impossible for thryve.health to provide its services. In cases where thryve.health specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by thryve.health or by the owners of third-party services used by thryve.health serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through thryve.health.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of thryve.health (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.Place
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Contacting the User, Heat mapping and session recording, Interaction with online survey platforms, Collection of privacy-related preferences, Interaction with live chat platforms, Managing support and contact requests, Connecting Data, Marketing, Managing contacts and sending messages, User database management, Managing data collection and online surveys and Registration and authentication. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Matomo (thryve.health)
Matomo is an analytics software used by thryve.health to analyze data directly without the help of third parties.
Personal Data processed: Tracker; Usage Data.
Collection of privacy-related preferences
This type of service allows thryve.health to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Cookie Solution (iubenda srl)
The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on thryve.health.
Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.
Connecting Data
This type of service allows the Owner to connect Data with third-party services disclosed within this privacy policy.
This results in Data flowing through these services, potentially causing the retention of this Data.
Zapier (Zapier, Inc.)
Zapier is a workflow automation service provided by Zapier, Inc. that automates the movement of Data between (third-party) services.
Personal Data processed: company name; email address; first name; last name; Usage Data.
Place of processing: United States – Privacy Policy.
Contacting the User
Contact form (thryve.health)
By filling in the contact form with their Data, the User authorizes thryve.health to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: company name; email address; first name; last name.
Heat mapping and session recording
Heat mapping services are used to display the areas of thryve.health that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User’s data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of thryve.health, in order to contact and be contacted by thryve.health‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Zendesk Chat (Zendesk, Inc.)
Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.
Personal Data processed: email address; first name; last name.
Place of processing: United States – Privacy Policy.
Interaction with online survey platforms
This type of service allows Users to interact with third-party online survey platforms directly from the pages of thryve.health.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Hotjar Poll & Survey widgets (Hotjar Ltd.)
The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User’s data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data; various types of Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (Intuit Inc.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
Managing data collection and online surveys
This type of service allows thryve.health to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed – e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Typeform (TYPEFORM S.L)
Typeform is a form builder and data collection platform provided by TYPEFORM S.L.
Personal Data processed: company name; email address; first name; last name; physical address; profession; website.
Place of processing: Spain – Privacy Policy.
Managing support and contact requests
This type of service allows thryve.health to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk (Zendesk, Inc.)
Zendesk is a support and contact request management service provided by Zendesk Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Marketing
OptiMonk
We use OptiMonk to display pop-ups allowing users to request whitepapers, case studies, or other content. Pop-Ups are displayed based on the user’s behavior on the website (e.g. button click, specific page visited, time spent on the website).
Personal data including the visitor’s Name, Company, and Email address is processed when the visitor submits the data on a form on the pop-up.
Registration and authentication
By registering or authenticating, Users allow thryve.health to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, thryve.health will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Mailboxvalidator
To avoid spam, the domain of the eMail address used in forms is checked by this service against a list of known domains. For this purpose we use the provider “mailboxvalidator” (https://www.mailboxvalidator.com/) based in Malaysia.
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to thryve.health, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving thryve.health.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on thryve.health.
Pipedrive (Pipedrive OÜ)
Pipedrive is a User database management service provided by Pipedrive OÜ.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Estonia – Privacy Policy.
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of thryve.health or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, thryve.health may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, thryve.health and any third-party services may collect files that record interaction with thryve.health (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within thryve.health and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through thryve.health (or third-party services employed in thryve.health), which can include: the IP addresses or domain names of the computers utilized by the Users who use thryve.health, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User
The individual using thryve.health who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of thryve.health. The Data Controller, unless otherwise specified, is the Owner of thryve.health.
thryve.health (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by thryve.health as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User’s browser.
Tracker
Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to thryve.health, if not stated otherwise within this document.
iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.
