Privacy Policy

ThinkUp Ltd. and its affiliates (“ThinkUp”, “us”, “we”, or “our”) respect your privacy and take your personal data seriously. Please read the following to learn more about our Privacy Policy (the “Policy”). This Policy applies to ThinkUp’s Northstar growth diagnostic platform, powered by ThinkUp Ltd., available at https://northstar.thinkup.global/ and related products and services (the “Services”).

In order to contact ThinkUp or otherwise use the Services, you may be required to enter personal identifying information as described in this Policy. “Personal Data” means any information relating to an identified or identifiable natural person. This may include, but is not limited to: your name, email address, phone number, payment information, IP address, and any other data you provide or we collect in connection with your use of our Services. ThinkUp is committed to safeguarding the privacy of such personal information in standard measures, and will not disclose, share or use any personal identifying information except for providing you with the Services or information requested by you under ThinkUp’s terms of use — https://northstar-by.thinkup.global/terms

This Policy describes how we process your personal data, but it may not address all possible data processing scenarios. We may inform you of product or service-specific data collection through supplementary policies or notices provided before collection.

1. Collection & Use of Data

You provide us directly with such data when you use our Services, or interact with us by, for example, contacting us, creating an account, using our chatbot features, or interacting with experts. We may also obtain data from your interaction with the website. For example, we may use technologies like cookies or receive use data from software running on your device. As permitted by law, we may also obtain data from public and commercial third-party sources, for example, purchasing statistics from other companies to support our Services. The personal data we collect may include name, enterprise name, email address, phone number, country of residence, recorded activity during your use of our Services, etc., depending on how you interact with the website. We also collect the information you provide us and the content of messages you send us, such as the query information you provide, or the questions or information you provide for customer service or through our chatbot interface, and any other data you provide in using the Services.

We do not collect or process sensitive personal data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for identification purposes, health data, or data concerning sexual orientation, unless you voluntarily provide such information and we have obtained your explicit consent where required by law. We do not collect precise geolocation data or monitor your device beyond what is necessary to provide the Services.

If you choose to sign up for or access the Service using a third-party account (such as Google Sign-In), you authorize us to receive, store, and use the information that such third party provides to us via its API. In the case of Google Sign-In, this includes your name, email address, profile picture, and Google account identifier. We use this information solely to authenticate your account and provide the Service. We do not receive your Google password.

If you are a paying user of the Services, we receive your payment transaction details (for example, your name, the amount paid and the date of payment), from the payment service provider that processed your payment. Payments are currently processed by Stripe, Inc., please see https://stripe.com/privacy for further details.

Before using ThinkUp’s products or Services, and by clicking the “Contact Us” on the ThinkUp website, you may need to provide personal data such as an email address, name, Company name, Country of residence and all information you see fit to share, subject to your discretion, but please be advised that such information may be processed and stored with us. Furthermore, clicking the “Contact Us” constitutes your consent to communicate with ThinkUp electronically and acknowledgement of your data protection rights, as described in section 2 to this Privacy Policy.

We may also collect technical information on how the website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, chatbot interactions and conversation logs, and other diagnostic data.

In some cases, you may be able to opt not to disclose your personal data to ThinkUp. However, not providing ThinkUp with certain data may mean that we cannot provide you with certain functionalities or respond to an issue that you have raised.

ThinkUp may also collect and use non-personally identifiable information (Non-PII). Non-PII is information that cannot be used to identify a particular individual. For example, ThinkUp will collect statistical data, such as the numbers of visits to its website. We collect this data to understand how users use our websites, products, and services so that we can improve our services and better satisfy your needs. ThinkUp may collect, use, process, transfer, or disclose non-PII for other purposes at its own discretion.

We will endeavor to isolate your personal data from non-PII and ensure that the two types of data are used separately. If personal data is combined with non-PII, it will still be treated as personal data during processing.

ThinkUp will process your personal data following the requirements of applicable laws on an appropriate legal basis, including:

• Processing your personal data to fulfill the contract when responding to a transaction or service request;
• Processing your personal data with your consent;
• Processing based on the legitimate interests of ThinkUp or a third party when we use your personal data to contact you, conduct marketing or market surveys, improve our products and Services, execute and improve our loss prevention and anti-fraud programs, and other purposes. Legitimate interests include enabling us to more effectively manage and operate our business and provide our products and Services; protecting the security of our businesses, systems, products, Services, and customers; internal management; complying with internal policies and processes; and other legitimate interests described in this policy;
• Processing your personal data as necessary to comply with and fulfill legal obligations.

2. Data Protection Rights

It is your responsibility to ensure that all Personal Data submitted to ThinkUp is correct. ThinkUp would like to make sure you are fully aware of all of your data protection rights, as follows:

The right to access – You have the right to request ThinkUp for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that ThinkUp correct any information you believe is inaccurate. You also have the right to request ThinkUp to complete the information you believe is incomplete.

The right to erasure – You have the right to request that ThinkUp erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that ThinkUp restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to ThinkUp’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that ThinkUp transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If allowed by applicable laws, you have the right to withdraw your consent at any time when ThinkUp processes your Personal Data based on your consent. You may withdraw your consent by contacting us at support@thinkup.global or by clicking the “Manage Preferences” link in any marketing communication you receive from us. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent.

If you think that the way we process your personal information does not comply with applicable data protection laws, you can contact the relevant competent data protection authority. You can obtain the information for contacting EU data protection authorities at https://ec.europa.eu/newsroom/article29/news-overview.cfm.

3. Cookies & Similar Technologies

This website stores cookies on your computer. We use cookies to collect information about how you interact with our website and they allow us to remember you if you return; and in order to improve your experience or the experience of users on the website.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze the website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

For further information, visit http://www.allaboutcookies.org/.

4. Transfer and Disclosure of Data

Data collected or received may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Our data storage servers are located in Virginia, US.

If you are located outside of Israel, ThinkUp headquarters, and choose to provide information to us, please note that we transfer the data, including Personal Data, to Israel and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

ThinkUp will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

ThinkUp may disclose your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend the rights or property of ThinkUp, to prevent or investigate possible wrongdoing in connection with the website, to protect the personal safety of users of the Services or the public and to protect against legal liability.

We do not disclose your personal data to third parties without a valid legal basis. Such processing is justified on the basis of your consent, the necessity for the performance of a contract with you, compliance with a legal obligation, or the necessity for the purposes of our legitimate interests. We may share your personal data with the following categories of third parties:

We use various AI providers to power features of our Services. This may involve the processing of your Personal Data, including content you provide. These transfers are conducted under appropriate safeguards and are necessary for delivering our AI-powered services. All AI processing is conducted in accordance with our data protection commitments and applicable regulations.

The following table lists our AI service providers and links to their privacy policies:

1. OpenAI (e.g., GPT-4, GPT-4o, GPT-5) — https://openai.com/policies/row-privacy-policy/
2. Anthropic (Claude models) — https://www.anthropic.com/news/updates-to-our-consumer-terms
3. Google Cloud AI / Google Gemini — https://services.google.com/fh/files/misc/genai_privacy_google_cloud_202308.pdf
4. Perplexity AI — https://www.perplexity.ai/hub/legal/privacy-policy

We enter into data processing agreements with these AI providers that contractually obligate them to protect your data and process it only according to our instructions.

5. Security of Data

ThinkUp uses appropriate physical, management, and technical measures to protect your data from unauthorized access, disclosure, use, modification, damage, or loss. ThinkUp also provide training on security and privacy protection for employees to raise their awareness of personal data protection. However, please note that no security measure is perfect, therefore, you should take special care in deciding what information you disclose.

We will retain your personal information for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. We determine retention periods based on the following criteria: (a) the duration of your relationship with us and your use of our Services; (b) whether there is a legal obligation to retain the data (such as tax, accounting, or legal requirements); (c) whether retention is advisable in light of our legal position (such as regarding applicable statutes of limitations, litigation, or regulatory investigations); and (d) whether you have consented to a longer retention period. When we no longer need your personal data, we will either delete it or anonymize it so that it can no longer be associated with you.

Data files uploaded or connected by users (including CSVs and data sourced from third-party platforms) are retained for the period necessary to generate the relevant diagnostic analysis and to validate and improve the accuracy of our recommendations, and are deleted or anonymized when no longer needed for these purposes.

6. Service Providers and Third Parties

Third party companies and individuals may be retained by us to provide us certain services or products (“Service Providers”), to assist us in analyzing how the website is used. These third parties may have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We may also share Personal Data related to you with our Service Providers which process Personal Data related to you on our behalf. However, such Service Providers will be contractually bound to keep Personal Data related to you confidential and appropriately secure. We make sure that our third-party Service Providers provide us with adequate confidentiality and security commitments and we will take all steps reasonably necessary to ensure that Personal Data related to you is treated securely and in accordance with this privacy policy.

To ensure a positive user experience, you may receive content or web links from third parties other than ThinkUp (“Third Parties”). ThinkUp does not have the right to control such Third Parties, but you can choose whether to use the links, view the content and/or access the products or Services provided by Third Parties.

ThinkUp cannot control the privacy practices and data protection policies of Third Parties that are not subject to this Policy. When you submit personal information to such a Third Party, the operators of these Third Parties may collect information from you which will be used by them in accordance with their own privacy policy that may differ from this one, please read and refer to the privacy protection policy of the Third Party.

7. Children’s Privacy

This Website does not address anyone under the age of 16 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

8. Changes and updates to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We may notify you through different channels, for example, by posting a notice on our website or sending you direct notification.

Prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

9. Incorporation to the Terms of Use

This policy is part of ThinkUp’s Terms of Use and any applicable service agreement between you and us.

10. How to Contact Us

If you have any questions or suggestions, please contact us via our email support@thinkup.global.

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