Privacy Policy

Effective date: June 1, 2024

Thank you for visiting www.ThinkLabs.ai (the “Site”) owned and operated by ThinkLabs. At ThinkLabs, we take your privacy seriously. Whether you are visiting the Site as an investor, founder, or member of the general public, you are entitled to the protection of your personal data. Please read this Privacy Policy to learn how we treat your personal data.

By using or accessing our Site in any manner, you acknowledge that you accept the practices and policies outlined below and you hereby consent that we will collect, use, and disclose your information as described in this Privacy Policy.

Remember that your use of ThinkLabs’s Site is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy by clicking here.

As we continually work to improve our Site, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the ThinkLabs website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Site and you are still responsible for reading and understanding them. If you use the Site after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Site. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing, and Improving the Site
• Creating and managing your account or other user profiles
• Processing orders or other transactions; billing
• Providing you with the products, Site, or information you request
• Meeting or fulfilling the reason you provided the information to us
• Providing support and assistance for the Site
• Improving the Site, including testing, research, internal analytics, and product development
• Personalizing the Site, website content, and communications based on your preferences
• Doing fraud protection, security, and debugging
• Marketing the Site
• Marketing and selling the Site
• Corresponding with You
• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Company or the Site
• Sending emails and other communications according to your preferences

Other Permitted Purposes for Processing Personal Data

In addition, each of the above-referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement or other parties to meet certain legal requirements and enforcing legal terms, including: fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property, or safety of you, ThinkLabs, or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice or obtaining your consent.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
• When you provide such information directly to us.
• When you use our interactive tools and Site.
• When you voluntarily provide information in free-form text boxes through the Site or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.
• When you use the Site and such information is collected automatically.
• Through Cookies (defined in the “Tracking Tools, Advertising, and Opt-Out” section below).
• Third Parties
• Vendors
• We may use analytics providers to analyze how you interact and engage with the Site, or third parties may help us provide you with customer support.
• We may use vendors to obtain information to generate leads and create user profiles.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

Service Providers: These parties help us provide the Site or perform business functions on our behalf. They include:

• Hosting, technology, and communication providers

Legal Obligations: We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers: All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part).

Data that is Not Personal Data: We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build, and improve the Site and promote our business, provided that we will not disclose such data in a manner that could identify you.

Data Security

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Site or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases, we retain Personal Data for longer if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Site or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at contact@thinklabs.ai.

State Law Privacy Rights

California Resident Rights: Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at contact@thinklabs.ai.

Nevada Resident Rights: If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Web: www.thinklabs.ai

Email: contact@thinklabs.ai

Mailing Address: 244 Fifth Avenue, Suite 2850, New York, NY 10001