Table of Contents

• Introduction

• Data Protection Officer

• How we collect and use (process) your personal information

• Use of the thriveaihealth.com website

• Cookies and tracking technologies

• Use of the Thrive AI Health, Inc. services

• When and how we share information with third parties

• Transferring personal data to the U.S.

• Data Subject rights

• Security of your information

• Data storage and retention

• Questions, concerns, or complaints

Introduction

Thrive AI Health, Inc. is an application service provider that uses the power of generative AI to hyper-personalize and scale behavior change across the five key and interconnected daily behaviors that govern our health: sleep, food, fitness, stress management and connection. Given that behavior accounts for a significant share of health outcomes than medical care or our genes, by adopting healthier habits in these five behaviors, people can make dramatic improvements in health outcomes.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes the Thrive AI Health, Inc.’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

Data Protection Officer

Thrive AI Health, Inc. is headquartered in San Francisco, California, in the United States. Thrive AI Health, Inc. has appointed an internal data protection officer for you to contact if you have any questions or concerns about Thrive AI Health, Inc.’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Thrive AI Health, Inc.’s data protection officer. Thrive AI Health, Inc.’s data protection officer can be contacted as follows:

Privacy Protection Officer
Thrive AI Health, Inc.
66 Franklin Street, Suite 300
Oakland, CA 94607
privacy@thriveaihealth.com

How we collect and use (process) your personal information

Thrive AI Health, Inc. collects personal information about its website visitors and customers. With a few exceptions, this information is generally limited to:

• name

• job title

• employer name

• work address

• work email

• work phone number

We use this information to provide prospects and customers with services.

We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services.

From time to time, Thrive AI Health, Inc. receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third party website (e.g. LinkedIn).

Use of the Thrive AI Health, Inc. Website

As is true of most other websites, Thrive AI Health, Inc.’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of Thrive AI Health, Inc.’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Thrive AI Health, Inc. has a legitimate interest in understanding how members, customers and potential customers use its website. This assists Thrive AI Health, Inc. with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet member and customer needs.

Cookies and tracking technologies

To the extent Thrive AI Health, Inc. uses cookies or other tracking technology, Thrive AI Health, Inc. will make available a comprehensive policy that describes the cookies and tracking technologies used on Thrive AI Health, Inc. website and provides information on how users can accept or reject them. Currently, no such technology are in use.

Sharing information with third parties

The personal information Thrive AI Health, Inc. collects from you is stored in one or more databases hosted by third parties located in the United States. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. On occasion, Thrive AI Health, Inc. engages third parties to send information to you, including information about our products, services, and events.

A list of our third party sub processors can be found here: 

• Microsoft Azure

• Stripe

• Google Cloud

• Twillio

• Vital

• Langsmith

• Pincone

We do not otherwise reveal your personal data to non-Thrive AI Health, Inc. persons or businesses for their independent use unless: (1) you request or authorize it; (2) it’s in connection with Thrive AI Health, Inc.-hosted and Thrive AI Health, Inc. co-sponsored conferences as described above; (3) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (5) to address emergencies or acts of God; or (6) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.

The Thrive AI Health, Inc. website connects with third party services such as Facebook, LinkedIn, Twitter and others. If you choose to share information from the Thrive AI Health, Inc. website through these services, you should review the privacy policy of that service. If you are a member of a third party service, the aforementioned connections may allow that service to connect your visit to our site to your personal data.

Transferring personal data to the U.S.

Thrive AI Health, Inc. has its headquarters in the United States. Information we collect about you will be processed in the United States. By using Thrive AI Health, Inc.’s services, you acknowledge that your personal information will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Pursuant to Article 46 of the GDPR, Thrive AI Health, Inc. is providing for appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.

Depending on the circumstance, Thrive AI Health, Inc. also collects and transfers to the U.S. personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Thrive AI Health, Inc. in a manner that does not outweigh your rights and freedoms. Thrive AI Health, Inc. endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Thrive AI Health, Inc. and the practices described in this Privacy Statement. Thrive AI Health, Inc. also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate. Since it was founded, Thrive AI Health, Inc. has received zero government requests for information.

For more information or if you have any questions, please contact us at privacy@thriveaihealth.com.

Data Subject rights

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

• Right to be informed

• Right of access

• Right to rectification

• Right to erasure

• Right to restrict processing

• Right of data portability

• Right to object

• Rights related to automated decision making including profiling

This Privacy Notice is intended to provide you with information about what personal data Thrive AI Health, Inc. collects about you and how it is used. 

If you wish to confirm that Thrive AI Health, Inc. is processing your personal data, or to have access to the personal data Thrive AI Health, Inc. may have about you, please contact us.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Thrive AI Health, Inc. might have received the data from Thrive AI Health, Inc.; what the source of the information was (if you didn’t provide it directly to Thrive AI Health, Inc.); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Thrive AI Health, Inc. if it is inaccurate. You may request that Thrive AI Health, Inc. erase that data or cease processing it, subject to certain exceptions. You may also request that Thrive AI Health, Inc. cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Thrive AI Health, Inc. processes your personal data. When technically feasible, Thrive AI Health, Inc. will—at your request—provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Thrive AI Health, Inc. will provide you with a date when the information will be provided. If for some reason access is denied, Thrive AI Health, Inc. will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email us at privacy@thriveaihealth.com. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation’s data protection authority.

Data storage and retention

Your personal data is stored by the Thrive AI Health, Inc. on its servers, and on the servers of the cloud-based database management services the Thrive AI Health, Inc. engages, located in the United States. The Thrive AI Health, Inc. retains service data for the duration of the customer’s business relationship with the Thrive AI Health, Inc. and for a period of time thereafter, to analyze the data for Thrive AI Health, Inc.’s own operations, and for historical and archiving purposes associated with Thrive AI Health, Inc.’s services. Thrive AI Health, Inc. retains prospect data until such time as it no longer has business value and is purged from Thrive AI Health, Inc. systems. All personal data that Thrive AI Health, Inc. controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: privacy@thriveaihealth.com.

Children’s data

We do not knowingly attempt to solicit or receive information from children.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:

Privacy Protection Officer
Thrive AI Health, Inc.
privacy@thriveaihealth.com
66 Franklin Street, Suite 300
Oakland, CA, 94607