Privacy Policy
Effective Date: May 19, 2020
Protecting your privacy is important to us and part of our core values. At Thrivable, we have two fundamental principles:
  • We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
  • We aim to make it as simple as possible for you to understand what information we collect from you, why we collect it, and how we use it.
Below is our Privacy Policy, which incorporates and clarifies these principles.
Who We Are and What This Policy Covers
Thrivable is an organization dedicated to helping people thrive. Today, we do this by connecting people with health conditions, supporting them, and shining a light on their experiences.
This Privacy Policy applies to information that we collect about you when you use:
  • Our websites (including diabetesdaily.com, thrivable.app, thrivableinsights.com, and thrivablecoach.com);
  • Our other Thrivable products, services, and features that are available on or through our websites, such as the Thrivable rapid research platform which is also accessible via SMS and email.
Throughout this Privacy Policy we’ll refer to our websites, mobile applications, and other products and services collectively as “Services.”
Please note that this Privacy Policy does not apply to any of our products or services that have a separate privacy policy.
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Creative Commons Sharealike License
This Privacy Policy was inspired by Automattic’s privacy policy. They are the creators of WordPress and so much of our success would have been impossible without them. Like their policy, our privacy policy is available under a Creative Commons Sharealike license and can be freely shared and adapted under the terms of that license.
Privacy Shield
Thrivable complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Thrivable has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit Privacy Shield.
In compliance with the Privacy Shield Principles, Thrivable commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Thrivable at:

Thrivable, Inc.

26201 Richmond Rd

Bedford Heights, OH 44146

team@diabetesdaily.com

Thrivable has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS for more information or to file a complaint: The services of JAMS are provided at no cost to you.
Thrivable is liable in cases of onward transfers of data to third parties that are in violation of this Privacy Policy. You have the right, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Learn more about that process here.
The Federal Trade Commission has jurisdiction over Thrivable’s compliance with the Privacy Shield.
Information
Information We Collect
We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.
We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
Identifiers: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Diabetes Daily account to provide an email address along with a username or name, depending on the service – and that’s it. You may provide us with more information – like your address and other information you want to share – but we don’t require that information to create a Diabetes Daily. You may provide a copy of a government ID so that we may verify your identity in order to participate in market research activities with Thrivable.
Public Profile Information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a Diabetes Daily account, your username is part of that public profile, along with any other information you put into your public profile, such as a photo or an “About Me” description. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
Billing and Contact Information: If you buy something from us, you will provide additional personal and payment information, such as your name, credit card information, and contact information.
Content Information: Depending on the Services you use, you may also provide us with information about you in draft and published content. For example, if you write a forum post that includes biographic information about you, we will have that information, and so will anyone with access to the Internet if you choose to publish the post publicly. This might be obvious to you…but it’s not to everyone!
Credentials: Depending on the Services you use, you may provide us with credentials to connect to another application. For example, a user of Thrivable may provide credentials to enable our Services to communicate with your corporate network.
Communications with Us (Hi There!): You may also provide us information when you respond to surveys, communicate with our engineers about a support question, post a question about your site in our public forums, or sign up for a newsletter. When you communicate with us via form, email, phone, Diabetes Daily comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
Protected classification information: You may provide information about your race, gender, and ethnicity while creating a public profile on Diabetes Daily or participating in marketing research on Thrivable. We use this information for the purposes of providing market research services.
Audio/video data: You may provide audio or video data while posting messages on Diabetes Daily or participating in marketing research on Thrivable. We use this information for the purposes of providing market research services.
Professional or employment-related information: You may provide professional or employment-related information while creating a public profile on Diabetes Daily or participating in marketing research on Thrivable. We use this information for the purposes of providing market research services.
Education information: You may provide educational information while creating a public profile on Diabetes Daily or participating in marketing research on Thrivable. We use this information for the purposes of providing market research services.
Information We Collect Automatically
We also collect some information automatically:
Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services–for example, when you create or make changes while logged into Thrivable or Diabetes Daily.
Usage Information: We collect information about your usage of our Services. For example, we collect information about the actions that users and administrators do on Thrivable or Diabetes Daily–in other words, who did what, when and to what thing on a site (e.g., [Thrivable username] updated “[profile field]” at [time/date]). We also collect information about what happens when you use our Services (e.g., page views, support document searches, interactions other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps if you allow us to do so through your mobile device operating system’s permissions.
Stored Information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a photo as part of a response to a Thrivable survey.
Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Thrivable uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log into your Thrivable account through another service (like Google) or if you connect your website or account to a social media service (like Twitter), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.
We may also get information, such as a mailing address, from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for example, for marketing and advertising purposes like postcards and other mailers advertising our services.
Categories of Information Sold in the Prior 12 Months
We have sold the following information during the prior year:
Clinical Study and Focus Groups: some users have requested that we share their personal contact information so that they may participate in a clinical study or market research activity conducted by a third-party.
How and Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
  • To provide our Services–for example, to set up and maintain your account, conduct market research, or compensate you for or charge you for any of our paid Services;
  • To further develop and improve our Services–for example, by adding new features that we think our users will enjoy;
  • To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
  • To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition — for example, we may analyze how many individuals purchased a paid plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
  • To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Thrivable and others, which may result in us declining a transaction or the use of our Services;
  • To communicate with you. For example, we may email you to solicit your feedback, share tips for getting the most out of our products, or keep you up to date on Thrivable; text you to verify your payment; or call you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (Please keep in mind that even if you opt out, we’ll still send you important updates relating to your account); and
  • To personalize your experience using our Services, provide content recommendations, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time), and serve relevant advertisements.
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or
(5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookie Policy.
Sharing Information
How We Share Information
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.
Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, payment providers you use for your ecommerce operations, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), and those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies (e.g. our Cookie Policy).
Legal and Regulatory Requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Thrivable, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Thrivable goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so, such as if you would like to be contacted to participate in a focus group or clinical trial.
Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
Information Shared Publicly
Information that you choose to make public is–you guessed it–disclosed publicly.
That means, of course, that information like your public profile, posts, other content that you make public on your website, and your “Likes” and comments on other websites, are all available to others.
Public information may also be indexed by search engines or used by third parties.
Please keep all of this in mind when deciding what you would like to share.
How Long We Keep Information
How long we keep the personal information we collect depends on the type of information, the purpose for which it is used, how sensitive it is, and similar factors. In general, we will retain your personal information for the length of time reasonably needed to fulfill the purposes outlined in this privacy policy (including for as long as need to provide you or our customer with products and services), unless a longer retention period is required or permitted by law.
We will also retain and use your information for as long as necessary to resolve disputes and/or enforce our rights and agreements. We retain your account information for the Services for as long as your account is active. Anonymous and aggregated information may be stored indefinitely.
Security
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
Choices
You have several choices available when it comes to information about you:
  • Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services — for example, participating in research activities–may not be accessible.
  • Limit Access to Information on Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features (like adding a location to a photograph, for example).
  • Opt-Out of Marketing Communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
  • Set Your Browser to Reject Cookies: At this time, Thrivable does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Thrivable’s websites, with the drawback that certain features of Thrivable’s websites may not function properly without the aid of cookies.
  • Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services, you can close your account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
Your Rights
California Residents
If you are a resident of California, the California Consumer Privacy Act of 2018 (CCPA) law gives you rights with respect to your personal data, subject to any exemptions provided by the law.
You may request personal information up to twice in a 12-month period. We are permitted to require that you provide information to verify your identity. We will respond to your request within 45 days.
You may contact us via our contact page, team@thrivable.app, or call us toll-free at (800) 519-3981. Please leave a message including an explanation of your request and we will respond.
European Residents
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
  • Request access to your personal data;
  • Request correction or deletion of your personal data;
  • Object to our use and processing of your personal data;
  • Request that we limit our use and processing of your personal data; and
  • Request portability of your personal data.
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.
EU individuals also have the right to make a complaint to a government supervisory authority.
Controllers and Responsible Companies
Thrivable’s Services are worldwide. The controller and responsible company is:
Thrivable Inc.
26201 Richmond Rd
Bedford Heights, OH 44146
How to Reach Us
If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please email team@thrivable.app.
Other Things You Should Know (Keep Reading!)
Transferring Information
Because Thrivable’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies (in the future), or third party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law.
Ads and Analytics Services Provided by Others
Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by Thrivable and does not cover the collection of information by any third party advertisers or analytics providers.
Third Party Software and Services
We may make available third-party services through our Services. Please note that if you use the third-party service or grant access, your data will be handled in accordance with the third party’s privacy policy and practices. We don’t own or control these third parties, and they have their own rules about collection, use, and sharing of information, which you should review before using the software or services.
Privacy Policy Changes
Although most changes are likely to be minor, Thrivable may change its Privacy Policy from time to time. Thrivbable encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (such as adding a statement to our homepage or the Thrivable Blog, or sending you a notification through email or your dashboard). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.
Change log
  • April 15, 2020: Added Privacy Shield certification and additional rights and protection to users.
  • March 20, 2020: we are keeping a Change Log starting with this update. This major overhaul of the Privacy Policy follows the same principles of our existing policy, focuses on improving readability and comprehensiveness, and offers additional commitments to our users to protect their privacy.