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Thinkifi Privacy Policy

Date: November 9, 2025

Last Updated: November 9, 2025

1) Introduction and Overview

This Thinkifi Privacy Policy (“Privacy Policy”) describes the types of personal information that Thinkifi, Inc. (“we”, “us”, “our”, or “Thinkifi”) collects in connection with your access and use of the services provided by Thinkifi (“Services”), Thinkifi’s website www.thinkifi.com, or any successor or complementary website made available by Thinkifi from time to time (“Website”), Thinkifi’s platform (“Platform”) and social media pages, as well as any products, services, applications, and documentation provided by Thinkifi; how we use the information; with whom we may share it; and the choices available to you regarding our use of the information. We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.

For purposes of this Privacy Policy, “Client” means any institution or organization that, through a relationship with Thinkifi pursuant to a separate agreement, manages your access to and use of the Services (“Client”).

This Privacy Policy governs the Personal Information (meaning information that you provide to Thinkifi, that a user or Client makes available to Thinkifi, or that Thinkifi creates or obtains on your behalf or on behalf of a user or Client, that directly or indirectly identifies an individual, or can be used to authenticate an individual) collected from any user, any Client pursuant to an agreement with Thinkifi by which the Services are enabled to a user, or anyone else (collectively, “you”, “your”) who engages with Thinkifi or our offerings, whether by visiting, using, or accessing the Services, the Website, the Platform and Thinkifi’s social media pages, or by interacting with us offline.

It does not extend to individuals or organizations outside our ownership, control, or management. Thinkifi is not responsible for the data-handling practices, products, information, or services of any third party that may be linked to or accessible through the Services, including, without limitation, links to websites or applications controlled by parties other than Thinkifi, nor does Thinkifi endorse or make any representations regarding such third parties.

By using the Services, you agree and acknowledge that we may collect, use, and share your information as described in this Privacy Policy. If you do not agree with the content of this Privacy Policy, we ask that you kindly discontinue use of the Services.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below. If you are a Nevada resident, California resident, or other United States (“U.S.”) resident whose state provides additional statutory privacy protections, please see the additional disclosures at the end of this Privacy Policy.

2) Information Collection

a) Information You Provide.

We collect information about you when you access and use the Services, the Website, the Platform, or our social media pages, including information you provide when you register an account, update your profile, access our content and functionalities, or contact support. The categories of information we may collect include:

  • Contact data, including your first and last name, email address, and any other information you include in the comments or message field of the contact form on the Website;
  • Account credentials, including your username and password (“Account Credentials”), as well as any information for authentication and account access;
  • Demographic data, including your age, birthdate, gender, race, religion, political leaning, and jurisdiction (you may opt out from providing demographic data);
  • If you are a Client, billing data, including name, email address, mailing address, phone number, bank name, bank account number, your payment instrument number (such as credit or debit card number), expiration date, and security code, as necessary to process your payments;
  • Profile data, including any photographs or information you choose to include in your profile;
  • Educational credentials, including your educational institution, background and future intended educational pursuits;
  • Communications, including when you contact us via email, the Website, the Platform, or through any other channel with questions, feedback, surveys, ratings, questionnaires, intake forms, or reviews, as well as any communications we exchange with you;
  • Structured discussions built around affirmative propositions within the Platform (“Thinks”), as well as any posts, submissions, comments, opinions, reactions, votes, and any other forms of interaction collected or processed for the purpose of providing the Services, including the date and time of such interactions and any information obtained and derived through the use of artificial intelligence (“AI”) in connection with those interactions;
  • Other user-generated content, including content within the Platform or any comments, submissions, opinions, and messages you send to us; and
  • Data of other individuals associated with Clients (e.g., students, advisors, or staff), including first and last name and email address. We may collect data about them with Client’s consent and in order to fulfill a request by them, such as enabling a test of the Services, integrating with third party systems, or inviting these individuals to join the Services.

You acknowledge and agree that both you and the individuals whose information you provide to access and use the Services, are accessing and using the Services from within the U.S. or otherwise in a manner subject to U.S. privacy laws in accordance with this Privacy Policy, and that you have obtained all necessary consents for us to use such information to fulfill your request.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

b) Information Collected Automatically.

In addition, we automatically collect information when you access and use the Services, the Website, the Platform, or our social media pages. The categories of information we may automatically collect include:

  • Usage data, including data about features you use in the Platform, the Website, or our social media pages, error logs, language preferences, and other similar information;
  • Marketing data, including preferences for receiving our marketing communications, and details about your engagement with them (e.g., marketing emails and links that you open); and
  • Performance data, including system-generated technical information, such as server logs, usage metadata, and telemetry, captured automatically by the Services’ analytics tools to measure access patterns, functionality, efficacy, reliability, and accuracy. For the avoidance of doubt, “usage metadata” and “telemetry” refer to technical information automatically generated as users interact with the Platform (i.e., data produced without direct user input). Specifically, “usage metadata” means data about how users interact with the platform (e.g., pages visited, time of access, features used), while “telemetry” refers to performance and diagnostic data (e.g., error logs, response times, or crash reports).

For further information on your rights and choices see the “Your Rights and Choices” section below.

c) Information from Other Sources.

We also collect information from other sources. The categories of sources from which we may collect information include:

  • Social media or networks with which you interact, including if you interact with our pages on social media (such as LinkedIn), post content using the Services, or otherwise link accounts, devices, or features to your account;
  • Partners that may offer co-branded services, sell, or distribute our products or services, or engage in joint marketing activities;
  • Other partners, such as employers, insurance companies, advisors, or other organizations that we may engage; and
  • Publicly available sources, including data in the public domain.

d) Technologies.

The types of technologies we use to collect information include:

  • Log files, which are files that record events that occur in connection with your use of the Services;
  • Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We may use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our websites and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, supporting security features, and providing advertising. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings; and
  • AI technologies, which include features and other functionalities that may be used to provide and improve the Services. For these technologies, we incorporate third party components on a pass-through basis, whereby Thinks-related content within the Platform is transmitted to and processed on our systems without storage of such data by those third parties. Thinkifi may update or replace AI technologies from time to time while maintaining equivalent privacy protections.

3) Use of Information

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business and commercial purposes for collecting and using information may include:

  • Offering, providing, operating, developing, understanding, personalizing, and managing the Services;
  • Establishing, maintaining, and managing our relationship with users and Clients, including communicating about the Services; responding to inquiries and support requests; sending administrative information such as updates, notices, and changes to policies or terms; and conducting user satisfaction surveys;
  • Creating and managing accounts and other user profiles, including log ins and authenticating users, and remembering information so that a user does not have to re-enter it during subsequent visits;
  • Preventing and addressing fraud, breach of policies or terms, threats or harm, and maintaining the safety, security, and integrity of the Services;
  • Tracking and analyzing trends, usage, and activities within the Services for their operation and improvement;
  • Conducting research to develop new products and services, and improve dialogue in education settings in accordance with applicable laws, including, without limitation, testing, analysis, product development, focus groups, and surveys;
  • Understanding users’ and Clients’ needs and improving the quality of the Services, the Website, the Platform, and any other Thinkifi applications, products, and services, as well as improving our use of AI technologies, tracking use of the Services, and generating internal reports and data models that we may use to improve the Services;
  • Complying with and enforcing our legal, regulatory, and contractual obligations, resolving disputes, auditing, and enforcing this Privacy Policy, Thinkifi’s terms and conditions, and agreements with Clients;
  • Responding to law enforcement requests or a government agency asserting lawful authority to obtain the data or where Thinkifi has reasonable grounds to believe the data could be useful in the investigation of unlawful activity. This includes, but is not limited to, complying with a subpoena or warrant or an order made by a court, person, or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending Thinkifi in a legal, regulatory, or administrative proceeding or in a contractual dispute or providing information to our legal counsel, and as required or permitted by applicable laws;
  • Fulfilling any other purpose at your direction; and
  • With notice to you and your consent.

Notwithstanding the above, we may transform Personal Information or data and information related to you, Clients, and users’ use of the Services into aggregated, de-identified, or otherwise anonymous information, including, without limitation, to compile statistical information related to the provision and operation of the Services and performance data (including, without limitation, system-generated technical information, such as server logs, usage metadata, and telemetry) (“Resultant Data”) and, except where prohibited by applicable laws, use or disclose such data for any lawful purpose, including evaluating and enhancing the performance, features, and effectiveness of the Services; analyzing usage patterns, user demographics, and general behavioral trends; conducting or supporting research with academic or industry partners to advance the Services; potentially publishing it in academic journals or other forums, presenting it at academic conferences and related; and developing new insights, content, products, and services.

For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

4) Sharing of Information

We share information we collect in accordance with this Privacy Policy, Thinkifi’s terms and conditions, and agreements with Clients, as applicable. The categories of parties with whom we may share information include:

  • Service providers and subcontractors. We may share information with service providers and subcontractors that process information on our behalf. Service providers and subcontractors may assist us with services including, without limitation, billing and payment processing, identity verification, data analytics, AI and large language models (“LLMs”) services (for example, analyzing user content to assist such user in making a stronger or more civil argument), Client relationship management, website hosting, cloud hosting and storage, technical support, and security and fraud prevention. For the avoidance of doubt, as anticipated, for AI and LLMs services, we may incorporate third party components on a pass-through basis, whereby Thinks-related content within the Platform is transmitted to and processed on our systems without storage of such data by those third parties;
  • Vendors and other parties. We may share information with vendors and other parties for analytics, integration, and related purposes, including but not limited to, Learning Management System (“LMS”) platforms;
  • Affiliates. We may share information with our Affiliates and related entities, including where they act as our service providers or for their own internal purposes. For the avoidance of doubt, “Affiliates” means the entities that we may own, that may own us, or that may be under common ownership or control with us, including subsidiaries and parent companies;
  • Advisors. We may share information with our advisors, such as lawyers, auditors, bankers, insurers, business consultants, education and academic advisors, and other individuals or entities that support educational institutions, where necessary in the course of the services they provide us;
  • Users and Clients. We may share information among and between users to perform the Services. We may also share information with the Client which is linked to your use of the Services;
  • References and testimonials. We may share information, such as users’ and Clients’ references, testimonials, and case studies, with their consent;
  • Merger or acquisition. We may share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, consolidation, reorganization, corporate divestiture, or any other type of acquisition or business combination of all or any portion of our assets, our equity interests, or transfer of all or a portion of our business to another business;
  • Security and compelled disclosure. We may share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share information to protect the rights, property, life, health, security, and safety of us, the Services, or anyone else, as well as to prevent any physical or other harm;
  • Facilitating requests. We may share information at your request or direction; and
  • Consent. We may share information with notice to you and your consent.

Notwithstanding the above, we may share Resultant Data, except as prohibited by applicable laws.

For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

5) Other Parties

The Website, the Platform, our social media pages, or any products or services that Thinkifi may make available may contain links to websites or applications controlled by parties other than Thinkifi (“Third Party Content”). In addition, we integrate technologies operated or controlled by other parties into parts of the Services, including, without limitation, third party LLMs.

Some examples may include:

  • Links. The Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us;
  • Brand pages and chats. We may offer our content through social media, such as LinkedIn. Any information you provide to us when you engage with our content (such as through our brand page or chat) is treated in accordance with this Privacy Policy. Also, if you publicly reference the Services on social media (e.g., by using a hashtag associated with Thinkifi in a post), we may use your reference on or in connection with the Services; and
  • Platform linking. We may offer you the ability to link your account to another service in order to retrieve certain data about your account on that service. For example, if you link your account to another platform, the linking may allow us to obtain information such as your other usernames, email addresses, photos, comments, and others. For more information about how these platforms handle information about you, please refer to their respective privacy policies and terms of use.

Please note that when you interact with other parties, including when you leave the Services, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6) Analytics and Advertising

We may use analytics services, such as Google Analytics, to help us understand how users access and use the Services so that we may improve them.

In addition, we may work with agencies, advertisers, ad networks, and other technology services to place advertisements about our products, devices, and Services on other websites and services. For example, we may place advertisements through Google and Meta that you may view on their platforms as well as on other websites and services.

In that context, we may share data related to the use of our Website with various providers. We may also incorporate tracking technologies into our advertisements displayed on other websites and services. Some of these tracking technologies may track a user’s activities across time and services for the purposes of delivering relevant advertisements and/or other content.

Notwithstanding the foregoing, we do not sell your Personal Information, and we do not share Personal Information, usage metadata, or telemetry data with third parties for purposes of targeting advertising to users of the Platform.

7) Your Rights and Choices

a) Account Information.

Please note that we will retain and use information about you as necessary for our records, to perform the Services and to comply with any Clients’ agreements or policies, to fulfill our legal obligations, resolve disputes, and enforce our agreements. You may request access to or a full deletion of your Personal Information by emailing us at the email address set out in the “Contact Us” section below. To confirm that any access or deletion request is legitimate, we may ask you to complete a verification form demonstrating that you have the authority to act. Even after we honor a request to delete Personal Information, we may keep limited records as required or permitted by law, along with Resultant Data. For example, Thinkifi will not delete or de-identify certain transactional data that may contain Personal Information that Thinkifi must maintain for tax, audit, liability, or other legally required purposes. If you choose to delete your account, Thinkifi may be unable to retrieve or re-identify any Personal Information, any usage data, or any other information linked to you. You may also lose access to any and all content for which you have active access rights associated with your account.

Users may access, update, edit, or delete certain information they have provided to us through their account settings. If you wish to carry out any of these actions with respect to certain information and no direct mechanism is available through the Services, you may contact us at the email address set out in the “Contact Us” section below.

If you are a Nevada resident, California resident, or other U.S. resident whose state provides additional statutory privacy protections, please see the additional disclosures at the end of this Privacy Policy.

b) Tracking Technology Choices.

  • Cookies. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
  • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and application operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.

Please be aware that if you disable or remove certain technologies, some parts of the Services may not function correctly.

c) Opt Out.

You may opt out of certain data collection and advertising features provided by third parties. For example, Google and Microsoft provide tools that allow you to opt out of the use of certain information they collect.

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you.

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

d) Communications.

  • E-mails. You can opt out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of non-promotional emails, such as those about your account, the Services, or our ongoing business relations.
  • Text messages and calls. You can opt out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us, as set out in the “Contact Us” section below, and specifying you want to opt out of text messages; and (ii) for calls, requesting opt out during any call you receive from us or contacting us, as set out in the “Contact Us” section below, and specifying you want to opt out of calls.

Please note that your opt out is limited to the email address and phone number used and will not affect subsequent subscriptions.

8) Children’s Privacy

The Services, the Website, the Platform, our social media pages, and any other products, services, applications, or documentation provided by Thinkifi are not directed to individuals under 13 years of age. If you are under 13, or if you are the parent or legal guardian of a child under 13, please do not register for the Services or submit (or permit the child to submit) any Personal Information. We do not knowingly collect personal information (as defined under the U.S. Children’s Online Privacy Protection Act, or “COPPA”) from children under 13. Please contact us at info@thinkifi.com if you believe we have inadvertently collected Personal Information from a child so that we may delete such data as soon as possible.

9) Data Security

We implement and maintain reasonable organizational, administrative, physical, and technical security safeguards and encryption during transmission and at rest to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction, in accordance with Thinkifi’s terms and conditions, and agreements with Clients, as applicable. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once it is received. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. By using the Services, the Website, the Platform, or our social media pages, you acknowledge and agree that Thinkifi makes no such guarantee, and that you use them at your own risk.

10) Data Transfer and Storage

We are based in the U.S. and the information we collect is governed by U.S. law. Information collected through the Services, the Website, the Platform, our social media pages, and any other products, services, applications, or documentation provided by Thinkifi may be transferred to, processed, stored, and used in the U.S. and in accordance with applicable U.S. data protection laws. Therefore, you acknowledge and agree that your use of the Services, the Website, the Platform, or our social media pages, or the provision of any information, constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. as described in this Privacy Policy.

11) Changes to This Privacy Policy

We reserve the right to revise and reissue this Privacy Policy at any time (each an “Update”) and shall make each Update available on the Website. Unless Thinkifi states otherwise, an Update is automatically effective thirty (30) days after posting on the Website, except in such case where an Update is immaterial to any of your legal rights or legal obligations of Thinkifi and such Update is made only to correct a typographical, formatting, or grammar inaccuracy, and in such case, an Update is effective immediately after posting on the Website. You are deemed to accept an Update by continuing to use the Services, the Website, the Platform, or our social media pages.

12) Contact Us

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable laws, please contact us at info@thinkifi.com.

13) Additional Disclosures for Nevada Residents

Nevada law requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. We do not sell personal information. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please email us at the email address set out in the “Contact Us” section above.

14) Additional Disclosures for California Residents

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

a) Notice of Collection.

The categories of personal information, as described in the CCPA, we may collect include:

  • Identifiers, including name, postal address, email address, and online identifiers (such as IP address);
  • Client records, including phone number, billing address, and credit or debit card information;
  • Characteristics of protected classifications under California or federal law, including gender;
  • Commercial or transactions information, including records of products or services purchased, obtained, or considered;
  • Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement;
  • Employment and education information; and
  • Inferences drawn from the above information about your predicted characteristics and preferences.

For further details on information we collect, including the sources from which we receive information, review the “Information Collection” section above. We collect and use these categories of personal information for the business purposes described in the “Use of Information” section above, including to manage the Services.

To the extent “sale” under the CCPA is interpreted to include the activities set out in this Privacy Policy, such as those disclosed in the “Analytics and Advertising” section above, we will comply with applicable laws as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, and inferences drawn. Please review the “Sharing of Information” section above for further details about the categories of parties with whom we share information.

While the CCPA does not currently apply to Thinkifi, if it becomes applicable in the future, you will have the rights listed below.

b) Right to Know and Delete.

This is the right to know certain details about our data practices. In particular, you may request the following from us:

  1. The categories of personal information we have collected about you;
  2. The categories of sources from which the personal information was collected;
  3. The categories of personal information about you we disclosed for a business purpose or sold;
  4. The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  5. The business or commercial purpose for collecting or selling the personal information; and
  6. The specific pieces of personal information we have collected about you.

In addition, you have the right to delete the personal information we have collected from you.

To exercise any of these rights, please email us at the email address set out in the “Contact Us” section above. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. You may appoint an authorized agent to exercise your privacy rights on your behalf. Any request the agent submits must follow our usual process, and we may require a signed authorization proving the agent’s authority. We may also ask you to verify your identity directly and confirm that you granted the agent permission to act for you. If we are unable to verify your identity, we may deny your requests to know or delete.

California’s “Shine the Light” statute (CA Civil Code §1798.83) may allow you, as a California resident, to request once per calendar year a disclosure of any categories of personal information that Thinkifi has shared with third parties for those parties’ direct-marketing purposes, along with the names and addresses of the third parties involved. While currently, the California’s “Shine the Light” law does not apply to Thinkifi, if it becomes applicable in the future, and you would like to make this request, please email us at the email address set out in the “Contact Us” section above.

c) Right to Opt Out.

Although Thinkifi does not sell your personal information to third parties, to the extent that any sharing of your personal information constitutes a “sale” under the CCPA, you have the right to opt out of the sale of your personal information by us to third parties at any time. You may submit a request to opt out by emailing us at the email address set out in the “Contact Us” section above.

15) Additional Disclosures for Other U.S. Residents

If you are a resident of a U.S. state such as, without limitation, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, or any other U.S. state that enacts a comprehensive consumer privacy law, your state’s privacy statute may afford you certain rights. Specifically, you may:

  1. Request details about the categories and sources of personal information we collect, as described in the “Information Collection”, “Use of Information”, and “Sharing of Information” sections above;
  2. Obtain a copy of the personal information we hold about you;
  3. Ask us to delete that data;
  4. Request that we correct any inaccuracies;
  5. Direct us not to sell or share your personal information, or to use it for targeted advertising or automated profiling that produces legal or similarly significant effects; and
  6. Appeal any denial of a privacy request.

Thinkifi will honor these rights as required by the laws of your state.