Privacy Policy
Last Updated | November 15, 2024
Introduction and Overview
This Privacy Policy ("Privacy Policy") applies to you and anyone who uses Thrive Health Tech, Inc (d/b/a Thrive Mobile) ("Thrive Mobile," the "Company," "we," "us," or "our") Devices, Products, or Services (collectively, "Services") under your account, except where we identify for you that separate terms and conditions apply. You are responsible for making sure all users under your account understand and agree to this Policy. You are responsible for making sure all users under your account understand and agree to this Policy.
Those subscribers to Thrive Mobile Powered by SafetyNet Wireless Lifeline services are subject to the Safety Net Wireless Privacy Policy, which can be found at https://www.safetynetwireless.com/safetynet-privacy-policy/.
Please take a moment to review the full terms of our Privacy Policy below, because by continuing to access or use our Services you accept and agree to be bound by all terms of the Privacy Policy. If you do not agree with any portion of it, then you must not access or use our Services. We may change this Privacy Policy from time to time, so check this policy regularly for updates.
This Privacy Policy is part of the Terms and Conditions and Agreement to Arbitrate Disputes and Judge or Jury Trial Waiver ("Terms and Conditions") governing the use of our Services, https://www.thrivemobile.com/terms-conditions. To the extent that any provision or clause in our Terms and Conditions, https://www.thrivemobile.com/terms-conditions conflicts with any provision or clause in this Privacy Policy or a specific service plan offer, the terms of those more specific documents will govern.
Contents
Definitions
"Call Detail Information" means any information that pertains to the transmission of specific telephone calls, including, for outbound calls, the number called, and the time, location, or duration of any call and, for inbound calls, the number from which the call was placed, and the time, location, or duration of any call.
"Device" means any phone, smartphone, tablet, accessory, or other device provided or sold to you by Thrive Mobile or that you activate or use with our Services.
"Health Partner" means an entity (typically a subscriber's healthcare provider) with whom Thrive Mobile has entered into an agreement (business associate agreement) to guard protected health information as required by the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191 ("HIPAA"), as set forth in 45 C.F.R. Parts 160 and 164, and as amended by the Health Information Technology for Economic and Clinical Health Act, Public Law 111-5 ("HITECH Act"), or by contract. Our current Health Partners are listed at www.thrivemobile.com/partner-companies.
"Geolocation Data" means any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area.
"Precise Geolocation" means any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by law or regulation.
"Personal Information" is information that identifies you or is reasonably capable of being associated with or linked, directly or indirectly, with you or your household. It does not include aggregate, de-identified, and/or anonymous information that is not reasonably capable of being associated with or linked, directly or indirectly, with you or your household.
"Services" means voice telephony ("talk"), text messaging ("text"), broadband Internet access services ("data"), and any other services provided to you by Thrive Mobile, services and devices subject to Affordable Connectivity Program discounts, and prepaid wireless service.
"Underlying Carrier" means the wireless provider whose facilities we use to provide you wireless Services.
Types of Personal Information We Collect About You
Depending on how you interact with us or our Services, we may collect the following categories of Personal Information from or about you, including, for example:
•
Identifiers, such as your name, address, e-mail address, telephone number, date of birth, internet protocol ("IP") address, social security number, account name, username(s), social security number, driver's license number, state identification card number, passport number, IMEI, and cookies.
•
Information in customer records such as your name, address, social security number, driver's license or state ID card number, passport, phone number, insurance policy number, education, employment, bank account number, financial information.
•
Financial information associated with you such as such as credit card, debit card, checking account information, purchase and order history, and billing information related to your use of our voice and text services.
•
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, such as your purchase and order history, frequency of use, and quantity of use, your interaction with our communications and advertisement, broadband usage, your activity on your Device, and Customer Proprietary Network Information ("CPNI"), as described in the CPNI section below.
•
Biometric information, such as interactive voice control communications with our customer service system, and recorded audio interactions with our customer service representatives.
•
Internet or other electronic network activity information, such as information about your use of the Services and our Health Partners' applications on your device, including the date and time of your use, frequency of use, and quantity of use, your interaction with our communications and advertisement, broadband usage, website click and other activity on your Device, and CPNI as described in the CPNI section below; your internet protocol ("IP") address, browser type, operating system, software version, and Device type, model, or identifier.
•
Geolocation Data, such as the location of your Device when it is connected to our network and our Underlying Carrier's network.
•
Audio, electronic, visual, thermal, olfactory, or similar information, such as interactive voice control communications with our customer service system, and recorded audio interactions with our customer service representatives and Thrive Assistants.
•
Professional or employment-related information, such as employment status.
•
Sensitive Personal Information, such as your social security number, driver's license number, state Identification card number, and/or passport number; your login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; and health information.
•
Inferences drawn from any of the categories identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, such as such as information about your use of the Services, including the date and time of your use, frequency of use, and quantity of use, your interaction with our communications and advertisement, broadband usage, your activity on your Device, and CPNI as described in the CPNI section below.
California Resident Privacy Rights and Notice
Individuals residing in California on a permanent basis (California residents) have certain rights described below.
California Civil Code Section 1798.83
Under California's "Shine the Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of Personal Information, such as name, e-mail, mailing address, and type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes; and (b) the names and addresses of all such third parties.
To request this information, please contact us at help@thrivemobile.com or at (888) 445-1069.
California Consumer Protection Act
This section provides additional information for California residents under the California Consumer Privacy Act ("CCPA") and any effective amendments thereto. The terms used in this section have the same meaning as those used in CCPA. This section does not apply to information that is not considered "Personal Information" under CCPA such as anonymous, deidentified, aggregated, or public information. The CCPA defines these terms as:
"Aggregate consumer information" means information that relates to a group or category of consumers, from which individual consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device. "Aggregate consumer information" does not mean one or more individual consumer records that have been deidentified.
"Deidentified" means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer, provided that a business that uses deidentified information:
(1) Has implemented technical safeguards that prohibit reidentification of the consumer to whom the information may pertain.
(2) Has implemented business processes that specifically prohibit reidentification of the information.
(3) Has implemented business processes to prevent inadvertent release of deidentified information.
(4) Makes no attempt to reidentify the information
"Personal information" means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following:
(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
(B) Any categories of personal information described in subdivision (e) of Section 1798.80, i.e., including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. "Personal information" does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.