Privacy Policy
Our Approach
Your privacy is important to us. We are thoughtful about the personal information we ask you to provide and the personal information we collect about you. Below is our Privacy Policy, which puts our approach into practice.
Privacy Policy
Introduction
David Loughry ("Company") operates the ProxThink.com website as well as all content, services, products, projects, events, and marketing related to the ProxThink framework (as described more fully in our Terms of Use), which are collectively referred to as our "Offerings." It is Company's policy to respect your privacy regarding any information we may collect as you use our Offerings. This Privacy Policy is part of our Terms of Use.
Note that some of our Offerings may occur in part or largely on or via other platforms/services run and controlled by other organizations, so some of your usage and/or interactions on those platforms/services may also be subject to the Terms of Use/Service and Privacy Policies of those platforms/services and organizations. To make a distinction between such other platforms/services and those controlled by Company, some language in this policy will use the phrase "Offerings under Company's control" or something similar. For a more detailed discussion of this, and for examples of such other platforms/services, see our Terms of Use.
This Privacy Policy applies to information we collect about you when you interact with us via our Offerings (as described in our Terms of Use), as well as in other interactions and relationships.
Information We Collect
We only collect information about you if we have a reason to do so — for example, to provide our Offerings, to communicate with you, or to make our Offerings better.
The amount and type of information that Company gathers depends on the nature of the interaction. For example, we ask those who sign up for an online course account to provide at a minimum, a username and email address.
Those who engage in financial transactions with Company, such as rewarding with a proxri, ordering some of our products/services, or joining a paid membership, are asked to provide additional personal and payment information like your name, credit card information, and contact information.
In each case, Company collects such information only insofar as is necessary or appropriate to fulfill the purpose of the interaction with Company.
Below are more details regarding when information is collected directly, indirectly, or automatically.
You directly provide most of the data we collect, such as when you:
• Register online, such as for an online course or website account.
• Sign up for communications and/or content via email or other messaging systems.
• Proxri (ProxReward) for your benefits and/or to support our efforts.
• Place an order for any of our products or services.
• Communicate with us
via messaging systems or email.
• Voluntarily complete a customer survey or provide feedback via messaging systems or email.
• Seek to and/or actually collaborate, cooperate, network, partner, and/or work with us.
We may also receive your data indirectly. The information we receive depends on which services you use or authorize and what options are available. Data received indirectly may come from sources such as the following:
• For events and related email communication, sources such as Eventbrite and LinkedIn.
• Email service providers such as MailerLite.
• Online course platforms such as Thinkific.
• Related to collaboration activities and the use of the Shared Situation Guide, sources such as Google, Quip (owned by Salesforce), or WordPress.
• Payment service providers such as Stripe, PayPal, Patreon, and Thinkific.
• Website platforms such as WordPress.
• Social media platforms such as
LinkedIn, Facebook, X/Twitter, YouTube.
• Advertising and direct response services such as those run by Google, Meta/Facebook, LinkedIn, etc.
• Video platforms such as Vimeo.
• Communication and meetings platforms such as Zoom, Microsoft Teams, Skype.
• Other
platforms/services described in our Offerings.
Some of your data may be collected automatically, such as:
• Log information — Like most online service providers, we may collect information that web browsers, mobile devices, and servers typically make available, including one or more of the following: browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information.
• Transactional information — When you make a purchase of our products and/or services, we may collect information about the transaction, such as product and/or service details, purchase price, financial proxri amount, and the date and location of the transaction. This includes when you purchase or proxri for things we offer directly, as well as things we offer via third parties.
• Usage information — We may collect information about your usage of our Offerings. For example, information about what happens when you use our Offerings, such as page views, support searches, site searches, and information about your device (like screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Offerings to you, get insights on how people use our Offerings so we can make our Offerings better, and understand and make predictions about usage and needs.
• Location information — We may determine the approximate location of your device from your IP address. We may collect and use this information to, for example, determine how many people visit our Offerings from different geographic regions. Location information also may help us determine the correct amount of sales tax (including VAT and GST taxes, if appropriate).
• Information from cookies and other technologies — A cookie is a string of information that a website stores on a visitor's computer, which 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. Company may use cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Offerings, 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 below.
How and Why We Use Information
We use information about you for the purposes listed below:
• To provide our Offerings. For example, to set up and maintain your account, provide customer service, provide support, process payments/orders, verify your information, and collaborate and/or coordinate with you.
• To ensure quality, maintain safety, and improve our Offerings. For example, by providing upgrades and new versions of our Offerings. Or, for example, by monitoring and analyzing how people interact with our Offerings so we can create new features that we think people will enjoy, or to make our Offerings easier to use.
• To market our Offerings and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to specific groups, advertising our Offerings, analyzing the results of our marketing campaigns, and understanding and forecasting retention.
• To protect our Offerings, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Company and others, which may result in us, for example, declining a transaction or terminating access to Offerings.
• To fix problems with our Offerings. For example, by monitoring, debugging, repairing, and preventing issues.
• To customize experiences. For example, to personalize your experience by serving you relevant notifications and/or advertisements for our Offerings, as well as recommending events, courses, activities, collaborations, and related content and information.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our Offerings, keep you up to date, or share relevant events, courses, activities, collaborations, new offerings, and related content and information 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. (If you opt out, we’ll still send you important updates relating to your account.)
• To find, work with, and retain employees and/or independent contractors. For example, by evaluating prospective contractors or applicants (including verifying their identity, experience, and other information submitted) and communicating with them by phone, email, or social media platforms. If the process progresses, we may collect interview information and background check information. This may also include verifying information required to initiate employment or a contract, for purposes such as confirming the ability to legally work or provide services in a specific location, setting up payroll, and complying with statutory reporting requirements.
• To seek, connect with, and communicate with related people, organizations, and groups. For example, to seek, connect with, and communicate with people who may want to collaborate, cooperate, network, partner, and/or work with us.
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 use 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 accept proxri from you; 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 Offerings; to improve our Offerings so that we can offer you an even better experience; to safeguard our Offerings; to communicate, coordinate, and/or collaborate with you; to measure, gauge, and improve the effectiveness of our advertising and marketing; to understand our prospective or actual user/visitor retention and attrition; to monitor and prevent any problems with our Offerings; 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.
How We Share Information
We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below.
• Subsidiaries and independent contractors: We may disclose information about you to subsidiaries and independent contractors who need the information to help us provide our Offerings or process the information on our behalf. We require subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us. This includes vendors that help us provide our Offerings to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, chat/messaging and email services that help us communicate with you, registrars, registries); 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, by placing ads to market our services, and by providing email marketing services); those that help us understand and enhance our Offerings (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations; and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them, some of the most important of which are listed below in the Privacy Commitments section.
• 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 Company, 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.
• 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 Company 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 when you authorize us to do so.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Offerings, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
• Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.
Information Shared Publicly
Information that you choose to make public is disclosed publicly. That might mean information such as your public profile, posts, other content that you make public, and your "Likes" and comments. 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 publicly.
How Long We Keep Information
We generally discard information about you when it's no longer needed for the purposes for which we collect and use it (as described in the section above called How and Why We Use Information) and we’re not legally required to keep it.
If you are a job applicant, we will keep your personal data during the application process, and for a certain period thereafter. To determine that period, we take into account a number of factors, like our legal and regulatory obligations (such as equal opportunity obligations) and whether we may need to retain personal data for internal business purposes like analyzing our applicant pool.
Information Security
While no online service is 100% secure, for Offerings under Company's control, we work to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so.
Your Choices
You have several choices available when it comes to information about you:
• Limit the information you provide: If you have an account with us within Offerings under Company's control, you can choose not to provide any 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 Offerings may not be accessible. If you are a job applicant, and you choose not to provide certain data elements to us, we may not be able to proceed with the recruitment process.
• Limit access to information on your mobile device: If we develop a mobile app or apps, your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, such as geotagging for photographs.
• Opt out of marketing communications: You may opt out of receiving marketing communications from us. Just follow the instructions in those communications or let us know. If you opt out of marketing communications, we may still send you other communications, such as those about your account and legal notices.
• Set your browser to restrict or reject cookies: You may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior such as the length of time they are stored – either through built-in functionality or by utilizing third party plugins. If you disable cookies, please be aware that some of the features of our Offerings may not function correctly. On a mobile device, you may also be able to adjust your settings to limit tracking. Please see our Cookie Policy below for more information about our use of cookies.
• Close your account: If you have an account with us within Offerings under Company's control, you can close your account if you no longer want to receive or participate in our Offerings. Please keep in mind that we may continue to retain your information after closing your account, as described in the section above called How Long We Keep Information — 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 organizational interests.
Your Rights
If you are located in certain parts of the world, including some US states and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to your data or to request deletion of your data.
European General Data Protection Regulation (GDPR)
If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain 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 also have the right to make a complaint to a government supervisory authority.
US Privacy Laws
Laws in some US states, including California, Colorado, Connecticut, Utah, and Virginia, require us to provide residents with additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. You’ll find that information in this section (if you are a California resident, please note that this is the Notice at Collection we are required to provide you under California law).
In the last 12 months, we may have collected the following categories of personal information, depending in part on the Offerings used and whether those Offerings were under Company's control:
• Identifiers (like your name, contact information, and device and online identifiers);
• Commercial information (your billing information and purchase history, for example);
• Characteristics protected by law (for example, you might provide your gender as part of a research survey for us or you may choose to voluntarily disclose your race or veteran status as part of your job application);
• Internet or other electronic network activity information (such as your usage of our Offerings);
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Professional or employment-related information; and
• Inferences we make (such as likelihood of retention or attrition).
If you are a job applicant, we may have also collected:
• Education information, such as the education you disclose in your job application.
You can find more information about what we collect and sources of that information in the Information We Collect section above.
We collect personal information for the organizational and commercial purposes described in the How and Why We Use Information section above. And we share this information with the categories of third parties described in the How We Share Information section above. We retain this information for the length of time described in our How Long We Keep Information section above.
In some US states you have additional rights subject to any exemptions provided by your state’s respective law, including the right to:
• Request a copy of the specific pieces of information we collect about you and, if you’re in California, to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, and the categories of third parties we share it with;
• Request deletion of personal information we collect or maintain;
• Request correction of personal information we collect or maintain;
• Opt out of the sale or sharing of personal information;
• Receive a copy of your information in a readily portable format; and
• Not receive discriminatory treatment for exercising your rights.
Right to Opt Out of Sharing with Certain Advertising, Marketing, or Analytics Vendors
We never directly sell your personal information in the conventional sense (i.e., for money).
We may share your information as necessary with our third-party service providers to provide Offerings under Company's control to you. To the extent that we share your information with certain advertising, marketing, or analytics vendors, this can be considered a “sale” or “share” in certain U.S. States, which you may have the right to opt out of. The process of opting-out of sharing with such advertising, marketing, or analytics vendors is managed through cookies, so if you delete cookies, or your browser is set to delete cookies automatically after a certain length of time, or if you visit sites in a different browser, you’ll need to make this selection again.
We do not collect or process your sensitive (and potentially sensitive) personal information except where it is strictly necessary to provide you with our Offerings, where the processing is not for the purpose of inferring characteristics about you, or for other purposes that do not require an option to limit under California law. We don’t knowingly sell or share personal information of those under 16.
Contacting Us About These Rights
When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us. To contact us, see the How to Reach Us section below.
Appeals Process for Rights Requests Denials
In some circumstances we may deny your request to exercise one of these rights. For example, if we cannot verify that you are the account owner we may deny your request to access the personal information associated with your account. As another example, if we are legally required to maintain a copy of your personal information we may deny your request to delete your personal information.
In the event that we deny your request, we will communicate this fact to you in writing. You may appeal our decision by responding in writing to our denial email and stating that you would like to appeal. All appeals will be reviewed by an internal or external expert who was not involved in your original request. In the event that your appeal is also denied this information will be communicated to you in writing. Please note that the appeal process does not apply to job applicants.
If your appeal is denied, in some US states (Colorado, Connecticut, and Virginia) you may refer the denied appeal to the state attorney general if you believe the denial is in conflict with your legal rights. The process for how to do this will be communicated to you in writing at the same time we send you our decision about your appeal.
Information Controller
A "controller" is the particular company responsible for processing your information. As far as your information collected related to Offerings under Company's control, the controller is:
David Loughry
908 S. Hobart Blvd., Unit 105
Los Angeles, CA 90006 USA
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 contact us here.
Other Things You Should Know
Transferring Information
Because our Offerings are available worldwide, the information about you that we process when you use our Offerings in the European Union (EU) may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for or with us, 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 Offerings may be delivered by advertising networks. Other parties may also provide analytics services about our Offerings. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Offerings and across other websites and online services. Such technologies allow these third parties to recognize your device in order 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 ads that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by Company and does not cover the collection of information by any third-party advertisers or analytics providers.
Privacy Commitments
As mentioned above in the section called How We Share Information (in the bullet related to third-party vendors), we require vendors to agree to privacy commitments in order to share information with them. Some of the most important of these privacy commitments with vendors are listed in this section.
MailerLite — We use MailerLite for email communication and email marketing. MailerLite is a third-party provider, which may process your data using industry-standard technologies to help us monitor and improve both our communications with you and our email marketing. You can unsubscribe from our communications and marketing by clicking on the unsubscribe link at the end of each email. MailerLite's privacy policy is available here: https://www.mailerlite.com/legal/privacy-policy
Cookie Policy
A cookie is a string of information that a website stores on a visitor's computer, which 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, and are often used in conjunction with cookies, though they are not stored on your computer in the same way.
As mentioned above, some of our Offerings may occur in part or largely on or via other platforms/services run and controlled by other organizations. These other organizations may use cookies, web beacons, and pixel tags, and such use should be covered by and subject to the Terms of Use/Service and Privacy Policies of those platforms/services.
Currently, on or via Offerings under Company's control, Company itself is not directly deploying cookies, web beacons, and pixel tags, in addition to the use of any cookies, web beacons, and pixel tags deployed by the other platforms/services included in our Offerings as mentioned above. If and when Company does directly deploy cookies, web beacons, and pixel tags, this Cookie Policy will be updated.
Privacy Policy Changes
Although most changes are likely to be minor, Company may change this Privacy Policy from time to time. Company 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 sending you a notification via email). Your further use of the Offerings after a change to our Privacy Policy will be subject to the updated policy.
Acknowledgment and Notice
Thanks to Automattic for making their Privacy Policy, which we modified to create our policy above, available under a Creative Commons license. However, rather than a Creative Commons license, our Offerings operate under the various agreements mentioned in our Terms of Use, which we believe are more flexible and have greater potential to create vibrant and sustainable proximities with sustainable variety.
Change Log
• January 31, 2024: Major update to reflect changes to our Offerings, and for compliance with European Union General Data Protection Regulation (GDPR) law.
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