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Privacy Notice

THINK Surgical, Inc. Website Privacy Notice / Data Protection Notice (the “Notice”)


Introduction (the “Site”) is owned and operated by THINK Surgical, Inc. (“THINK”, “we”, “our” or “us”). THINK may collect personal and non-personal information from users of the Site (“Users”, “you” or “your”).

THINK recognizes that Users are entrusting THINK with their personal information as may be submitted and collected through the Site, and respects and values each User’s privacy. Therefore, THINK is committed to protecting the privacy rights of Users and has created this Notice in order to explain to Users, how THINK may collect, use, share, transfer, disclose, process, and protect User’s information obtained through the Site (as well as through certain other channels described in this Notice or which reference this Notice) in the course of operating THINK’s business.  This Notice also describes how you may exercise any rights you may have regarding the processing of your personal information collected through this Site (or through other channels described in this Notice or which reference this Notice).

THINK’s Notice and business practices are always intended to comply with the general principles related to protecting the privacy of personal information, and all applicable privacy laws and regulations, including, but not limited to, the California Consumer Privacy Act (CCPA) (if and to the extent applicable) and the European Union General Data Protection Regulation (GDPR) (if and to the extent applicable). THINK will continue to assess this Notice and its business practices against all then-current state, federal and global data protection and privacy laws as they may relate to this Site (or other channels referenced in this Notice or which reference this Notice).

Before using this Site and before providing any personal information to THINK, THINK encourages each User to read in their entirety: (i) the “Terms of Use” which outline the general rules about your use of this Site; and (ii) this Notice.  By using this Site, you agree to such Terms of Use. By providing personal information to THINK through this Site (as well as through certain other channels described in this Notice or which reference this Notice), you acknowledge that you have read, understand, and accept this Notice, including, but not limited to, certain uses and disclosures of your personal information consistent with this Notice and applicable law.  If you do not agree to and accept this Notice in its entirety, you should not provide THINK any of your personal information.  Except as may be set forth in writing by any other disclaimers, policies, terms of use, or other notices posted on this Site, this Notice and the Terms of Use are the complete agreement between you and THINK with respect to your use of this Site and your providing of personal information to THINK.



This Site is only intended to provide general information to the public about THINK’s business and its available products and technologies and to respond to submissions and inquiries made by the Site’s intended audience, including: (i) surgeons and health care facilities; (ii) patients (whose surgeons are or may be utilizing THINK’s products and technologies in furtherance of their health care treatment plan) and potential patients; (iii) actual or potential investors; (iv) potential employment candidates; (v) actual or potential business customers, partners, or suppliers.

What is “personal information”?  “Personal information” is any type of information that identifies, relates to, describes, is reasonably capable of being associated with or linked to or identify a particular individual, directly or indirectly.  The terms “personal information” and “personal data” are often used interchangeably or synonymously in privacy laws in the United States, and also include “sensitive personal information.”  For example, an individual’s name, address, email address, or telephone number are all considered “personal information”.

This Notice applies to all personal information that we collect from Users of this Site (as well as collected through certain other channels described in this Notice or which reference this Notice).  For example, collection of any personal information collected offline, such as in-person at an industry trade show or conference, to sign up for emails or newsletters, or online, such as social media sites or platforms (such as LinkedIn), email, or other electronic means, are also covered by this Notice (certain channels of collection of personal information are expressly excluded from this Notice as stated herein).  In addition, any personal information collected through any other channel which specifically references this Notice shall be covered by this Notice.  In certain circumstances or under different arrangements, THINK may reference a different privacy Notice, or a supplemental privacy Notice to this Notice, dependent on the channel of collection of personal information, in which case such different privacy Notice will govern, or such supplemental privacy Notice will supplement this Notice.


This Site is not intended to collect personal health information (“PHI”) from patients or potential patients of surgeons and healthcare facilities using THINK’s products and technologies.  This Notice specifically excludes PHI, which is instead, only intended to be received by THINK from health care providers (such as surgeons, scan centers and health care facilities), specifically authorized to share such PHI with THINK.  In all such cases, THINK complies with the Health Insurance and Portability and Accountability Act of 1996 (“HIPAA”) and HIPAA’s Privacy Rules and Security Rules, as any may be amended from time-to-time, as well as any Business Associate Agreement or other agreements which may be in place with THINK as a “Business Associate” and such health care provider (as a “Covered Entity”), with regard to its uses, disclosures, and security of such PHI.  Where we process a patient’s PHI at the request and instructions of his or her health care provider, please note that THINK does not have any control over the privacy and security practices and processes of such third parties.  A patient should refer to the separate HIPAA Notice of Privacy Practices or other privacy notices or policies of his or her health care provider, which will describe how your health care provider uses and discloses your PHI that it collects.


Please note that THINK does not request nor want your PHI submitted through the Site nor through any other channel, other than through your health care providers outside of this Site


You should not in any way, provide any of your PHI or any PHI of any other person through this Site or through any channel other than through your or their health care providersFor clarity, the “Find a Surgeon” tool described below, is not intended to submit PHI to THINK.


Additionally, you should not provide personal information of any kind for any person other than yourself.  Health care providers should not submit any PHI of patients or potential patients through this Site.  If you, as the User, are a caregiver for a patient or potential patient, and are requesting information from THINK about its products and technologies, you should only provide your own personal information, and not the personal information of any other person unless you have the express written consent of such other person to submit their personal information to THINK (and in such case, you shall be solely liable with respect to the submission of the other person’s personal information to THINK and having his or her requisite consent). 


This Site is also not intended to collect any sensitive personal information (such as social security number or financial information) of any User or other person.  Please do NOT submit any sensitive personal information through this Site.


In summary, THINK’s primary goal in collecting information from Users is to enable us to provide such Users with requested additional information, to schedule product demonstrations (for surgeons and health care facilities only), to assist in finding a surgeon using our products and services, for career or investment opportunities, to improve the presentation of our products and services on the Site, and to improve our product and service offerings.  See the “Our Use of Information” section below for more details. In general, THINK does not collect personal information about Users, except when Users knowingly provide such information as the result of the use of one or more of the features of the Site. Although Users do not have to provide us with any personal information to visit the Site, a User may not be able to fully utilize all of the services or functions on the Site if a User chooses not to provide certain information. If a User does choose to give us personal information through the Site, we will collect and retain that information in accordance with this Notice.


Information We Collect

User Information:

Listed below are a number of Site pages where you, the User, in your sole discretion, may decide to submit your personal information to THINK (but excluding PHI and excluding sensitive personal information).

These pages allow our Users to contact us to inquire about THINK and its products and services, career opportunities, product demonstrations (for surgeons and health care facilities only), investment opportunities, or otherwise to make general inquiries or contact with THINK.  Users may also sign up to receive THINK’s periodic newsletters or informational materials, emails, or other marketing materials.  From time to time, the Site may have an option for Users to register to participate in various events, online forums, industry-related trade conference events involving THINK, surgical trainings (for surgeons and health facilities only), surveys or questionnaires.   To request information concerning our company and its products and services, Users may contact us using these various pages, where they are required to provide us with certain of their personal information described below.   By providing any information, you are acknowledging that this personal information is being voluntarily input into such pages and submitted by you to THINK.  Please refer to our requests above, requesting you to not submit any of your PHI or sensitive personal information on this Site. 


Site Use Information:

We may also automatically track certain information about Users based upon their behavior on the Site. Such information may include the URL from the webpage that the User accessed prior to accessing the Site, the URL for the webpage next accessed by the User after leaving the Site, and the User’s browser.


Information Not Collected:

“Sensitive personal information”.

What is “sensitive personal information”?   “Sensitive personal information” is personal information with a heightened sensitivity concerning the nature of such information and includes (but is not limited to) information such as:  social security number, driver’s license or state identification card numbers, or passport number, financial account numbers, debit card or credit card numbers, any required security or access codes, any account login credentials or passwords, geolocation data, racial or ethnic origin, religious or philosophical beliefs, sexual life or orientation, or union membership status, characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status genetic data, any biometric data to identify an individual, or medical/health or insurance information.  Various privacy laws may have broader or more specific definitions of “sensitive personal information”, sometimes also referred to as “sensitive data”.

THINK will never ask you for sensitive personal information on this Site, therefore, sensitive personal information should not be submitted by you to THINK on this Site or otherwise posted on this Site.


Site Pages for Users:

  • The “Contact” page. THINK’s Site includes a “Contact” page intended for a general, broad audience, for general information purposes and requires the User choosing to contact THINK to select a reason for the contact from the following options:  (i) Sales and Product enquiries, (ii) Product and technical support, (iii) Investor information, (iv) Career opportunities, and (v) Other.  A User choosing to contact THINK through this method is required to enter his or her name and email address.  Additionally, the User may choose to provide a telephone number and organization name, which are optional.   The User may check the method for THINK to contact him or her (i.e., phone, email, or both).  The User has the opportunity to choose whether he or she would like to receive emails with updates about THINK Surgical and featured technology.  The User may choose to input a “subject” and/or a “message”, each of which are optional for the User.  By providing your personal information within the “Contact” page, you are consenting to THINK’S transfer and use of this information as set forth in this Notice.
  • The “Find a Surgeon” page. THINK’s Site includes a “Find a Surgeon” tool intended to assist potential patients or caregivers in locating a surgeon that may utilize THINK’S products and technologies in a health care setting.  This tool allows the User to input: (i) a relevant zip code (which may be the zip code of the User’s residence, (ii) the selected THINK product/technology the User is interested in, and (iii) a mile radius selection from the entered zip code.  THINK does not guarantee that the output from this tool is the most up to date and current.  The tool and its output may contain some level of inaccuracy or incompleteness, as surgeons do periodically change practice locations and/or affiliated health care facilities; and additional surgeons and health care facilities are continually acquiring, and training on, THINK’S products and technologies.  This “Find a Surgeon” tool is for the User’s convenience and for informational purposes only.  THINK does not endorse any surgeon or any health care facility listed in this tool.  THINK will not share any information collected from a User who is a potential patient or their caregiver using this tool with any surgeon or any healthcare facility.  To the extent such User visits any 3rd Party Site of such a surgeon or health care facility, please refer to the section “3d Party Sites” below.  THINK makes no representation or warranty with respect to any surgeon or health care facility listed within its “Find a Surgeon” page, including with respect to any surgeon’s or health care facility’s service offerings, capabilities or competencies, all warranties of any kind, express or implied, being disclaimed by THINK.  Users are not required to contact or use any listed surgeon or health care facility.  If a User chooses to contact any surgeon or health care facility listed in this tool, the User does so as his or her own free and voluntary act, and the User shall be solely responsible for conducting any due diligence he or she deems appropriate with respect to health care decisions.  All patients should consult with their health care providers to determine what is in their best interests.
  • The “Schedule a Demo” page is ONLY intended for (i) surgeons or (ii) health care facilities; each with a genuine intent of observing a demonstration to assess THINK’S products and technologies for the purpose of purchasing or using the same in a health care setting. Such Users requesting to schedule a product demonstration are required to enter their name, email address, telephone number, and location, and optionally enter the name of their affiliate, institution, or company.  Users are also asked whether they intend to attend certain key industry events (such as the American Association of Hip and Knee Surgeons Annual Meeting or the American Academy of Orthopedic Surgeons Annual Meeting).  The User may check the method for THINK to contact him or her (i.e., phone, email, or both).  The User has the opportunity to choose whether he or she would like to receive emails with updates about THINK Surgical and featured technology.  The User may choose to input a “subject” and/or a “message”, each of which are optional for the User.  By providing your personal information within the “Schedule a Demo” page, you are consenting to THINK’S transfer and use of this information as set forth in this Notice.
  • The “Resource Center” page. This page is for customers of THINK and provides a range of materials to help customers inform people that the TMINI® Miniature Robotic System is now in the hands of their surgeons and that their institution offers state of the art robotic knee surgery to their patients.  This page requires a User to work with THINK to establish a login account requiring a username or email address and password to access such resources.
  • The “Investors” section of the “Corporate Information” page. The Investors section is intended only for individuals and entities interested in learning more about investor opportunities with THINK.  For Users seeking such information, a form must be completed, requiring you to provide your name and email address and optionally to provide your telephone number and the name of your organization. The User may check the method for THINK to contact him or her (i.e., phone, email, or both).  The User has the opportunity to choose whether he or she would like to receive emails with updates about THINK Surgical and featured technology.  The User may choose to input a “subject” and/or a “message”, each of which are optional for the User.  By providing your personal information within the “Contact” page, you are consenting to THINK’S transfer and use of this information as set forth in this Notice.
  • The “Work With Us” page. This page is intended for individuals interested in pursuing a potential career with THINK and highlights certain open positions within the organization by allowing Users to perform a “job search”. Users interested in applying for a job position with THINK may create an applicant account by providing their name, address and other contact information, and establishing a username and password.

Once an applicant account has been created, an applicant may upload their résumé/curriculum vitae (or otherwise manually input their previous employment history, education history, professional qualifications, etc.). THINK does not require an applicant to provide his or her social security number or any other sensitive personal information at this juncture.

Upon submission from the applicant account, the applicant will be redirected to a secure, third party software platform known as an “applicant tracking system”. The information submitted through the applicant account is then imported into and saved on the third party applicant tracking system for THINK’s review and consideration for employment opportunities with THINK.

If the applicant has been selected to advance in the employment screening process, he or she may be required to provide further personal information (at a later time) in a secure, third party employee onboarding management system utilized by THINK. Within THINK, only THINK’s Human Resources staff has access to any personal information saved on such third party systems.

Please refer to the “Third Party Sites” section below regarding such third party’s different privacy policies.

  • Periodic “Interactive Features”: From time to time, THINK may offer in its discretion, public or group forums on our products or services, such as newsfeeds, blogs, message boards, or similar tools (“Interactive Features”).  Any posts or comments a User may make, may be publicly viewed by others. Therefore, Users of any Interactive Features should use caution and care prior to publicly posting any content, particularly personal information in such Interactive Features, as you should not expect privacy or confidentiality related to such postings; and doing so is at the User’s own risk.  THINK may de-identify personal information from any content submitted on Interactive Features at which time such de-identified information is no longer considered personal information and may be used in accordance with this Notice.


Third Party Sites

This Notice is only applicable to the Site, and not to any other websites, applications or platforms not owned by THINK Surgical, Inc. that you may be able to access from the Site or any links in any of our product or service resources or documentation (“3rd Party Sites”). Any links to 3rd Party Sites are provided solely as a convenience – as THINK does not review, control, or monitor the privacy practices of 3rd Party Sites. THINK does not endorse any of the following:  (i) any 3rd Party Sites, (ii) any Company or business referenced in any 3rd Party Sites, (iii) any 3rd Party products or services referenced in or offered on any such 3rd Party Sites, or (iv) the content, statements, positions, views or opinions expressed on any 3rd Party Sites; and THINK expressly disclaims all warranties of any kind whatsoever with respect to any of the foregoing, including but not in any way limited to truthfulness, accuracy or completeness.  Such 3rd Party Sites may have data collection, storage and use practices and policies that differ materially from this Notice. A User’s disclosure of personal information on a 3rd Party Site is at User’s own risk and subject to such third party’s privacy terms, if any. You should carefully review the privacy policies and practices of any such 3rd Party Sites as THINK cannot control and is not responsible for such 3rd Party Site policies, notices, or practices.


Our Use of Information

Generally, we collect information (including personal information) about our Users to operate, manage and maintain our business (and accomplish our business purposes and objectives), to analyze Site usage, to enhance, improve or modify our Site’s content, layout, and services to better present our products and services to Users, to better understand information Users are seeking and to guide enhancements or improvements to products and service offerings or development of future products and service offerings. We use information (including personal information) to process and respond to User requests, inquiries, and contacts, and we may use the information to contact Users regarding their use of, changes to, or new products or services that we offer, and to understand our Users’ demographics, interests, and behavior to better understand and serve our Users. We may use information to advertise and market our products and related services. These marketing and promotional materials may be sent to you by e-mail, postal mail or other means if Users provide such addresses. However, each individual or organization has the right and opportunity to elect to “opt out” of receiving further marketing information from us. See Section 8 below for ways to opt out.

We may contact Users periodically via e-mail, postal mail, or telephone—if a User agrees to such contact—to provide information regarding programs, products, services and content that may be of interest including to contact you to determine whether you would like to initiate a business relationship with us. In addition, some of the pages and features on this Site allow Users to communicate with us using an online form. If a User’s communication requests a response from us, we will send the User a response via e-mail or postal mail. Any e-mail response or confirmation may include the User’s personal information, including personal information about health, name, address, etc. We cannot guarantee that our e-mails to Users will be secure from unauthorized interception.  THINK may use information to determine the effectiveness of our marketing and promotional campaigns to improve them to better meet the needs and interests of Users.

With respect to any marketing or promotional e-mails which you may receive from THINK, you always have the option to unsubscribe from them.  To do so, either use the “unsubscribe” function in such e-mail(s) or other form of communication, as applicable, or email your request to unsubscribe by sending an email to: with the subject line “unsubscribe”.  Please be advised, following an unsubscribe request by you, you may still receive emails or communications for a short period of time until we are able to respond to your request.

Additionally, we may use personal information to communicate with you regarding our relationship, this Site, changes to our Terms of Use or other terms and conditions, and policies or to perform other administrative tasks, to audit internal processes and procedures, to assure compliance with various legal, regulatory, or contractual requirements as well as our internal policies (including, but not limited to record retention), perform research or data analytics.  We may also use information to enforce or defend against any legal claims.

As previously noted above, this Notice specifically excludes the collection, use and disclosure of PHI received by THINK from any patient or potential patient’s health care providers (such as surgeons, scan centers and health care facilities), which may be specifically authorized to share such PHI with THINK.  In all such cases, THINK only uses and discloses PHI in accordance with HIPAA and its Rules and Regulations and any agreement in place between THINK and such health care provider, such as a Business Associate Agreement.  Notwithstanding the foregoing, THINK uses such information to provide products and services to such health care provider at their request and instruction and may use de-identified data (as may be permitted by HIPAA and contractual agreement with such health care providers) to develop, enhance and improve its products and services.  THINK may use PHI to comply with applicable laws and regulations.  See section below regarding our disclosure of PHI.

Finally, we may combine personal information we collect with other personal information or data collected, including from other sources (including third party sources) for any of the purposes described above.


Our Disclosure of Information

THINK’s policies regarding the disclosure of User personal information are as follows:

  • Unless specifically stated otherwise herein, we do not sell, rent, license, loan, or share personal information of Users to any third party.
  • We will obtain permission before disclosing any User personal information for a purpose not authorized by a User or this Notice.
  • We may occasionally aggregate our User information and disclose such information to third parties in aggregate form for a number of business purposes, including running and enhancing the Site. In these situations, we do not disclose any information that could be used to personally identify our Users.
  • Occasionally, we may disclose User personal information to third parties we engage to facilitate our services to Users. In such instances, we obligate those third parties to conform to our privacy standards. In addition, our corporate policies require that employees with access to confidential information about our Users, not disclose or use the personal information except with respect to THINK’s legitimate and lawful business uses.
  • THINK may transfer personal information to others subject to this Notice pursuant to an assignment or transfer or certain rights or obligations, or pursuant to a merger, consolidation, corporate reorganization or restructuring, or to a purchaser in connection with the sale of all or a portion of its business or assets.
  • We reserve the right to disclose or report personal information about our Users in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with the government, including regulators or law enforcement or other public authorities, and to protect the rights, safety and security of THINK, the Site and our Users. Furthermore, we may disclose User personal information to enforce our Terms of Use or as may otherwise be permitted under this Notice and applicable law.
  • Although not covered by this Notice, as a general note, we may disclose PHI obtained by patient’s and potential patient’s health care providers, to certain subcontractors engaged by THINK to assist in our performance of product and service obligations to such health care providers.  For example, THINK may utilize certain third-party service provider cloud based or other platforms to transfer patient scans or surgical plans to perform our services to heath care providers.  Such third-party service providers or processors acting on our behalf are required to agree to certain obligations regarding confidentiality and limitations on the use and disclosure of such PHI consistent with HIPAA, typically under a subcontractor Business Associate Agreement. THINK may also use and disclose PHI to comply with applicable laws and regulations.


Security Measures to Safeguard Information

The security and confidentiality of User personal information is extremely important to us. We have implemented and use reasonable organizational, technical, administrative, and physical security measures to protect User personal information under our control from loss, misuse, alteration, theft, unauthorized access and improper use and disclosure, all consistent with applicable legal and regulatory requirements as well as industry standards. From time to time, we review our security measures and procedures in order to consider appropriate new technology and methods to continue to protect User personal Information. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable and are thus not guaranteed to be secure.  In particular, any data transmission online over the internet cannot be guaranteed to be secure.  As a User, you also have a shared responsibility to safeguard your personal information, including account information and any login credentials.  If you suspect or have any reason to believe that your interaction with THINK is not secure or that any account you have with THINK has been compromised in any way, immediately notify THINK.  Please refer to the “Contacting Us” section below.



We use cookies to assist us in securing your transactions and to enhance the performance of the Site. We use a common technique, HTTP-header cookies, to identify one page request from another. The cookies the Site creates do not contain any personal information. They merely allow us to recognize that a page request comes from someone who has already logged on. While your browser may allow you to “reject” cookies, the Site requires that you accept all cookies in order for the features and security mechanisms to function fully. Cookies are stored on a User’s hard drive, not on the Site. Cookies are “session cookies”, meaning that they are automatically deleted at the end of a session, or are automatically “timed out” after extended inactivity.


Security and Browsers

Any time a User enters information on the Site, we encrypt it using Secure Socket Layer (SSL) technology. SSL protects information as it crosses the Internet. To support this technology, Users need an SSL-capable browser, preferably with strong encryption. THINK recommends the following browsers: Edge, Firefox or Google Chrome.



Users can opt-out and not receive future marketing communications from us by sending in an email to with the subject line “unsubscribe”. With respect to any marketing or promotional e-mails which you may receive from THINK, you always have the option to unsubscribe from them.  To do so, either use the “unsubscribe” function in such e-mail(s) or other form of communication, as applicable, or request to unsubscribe by sending an email to: with the subject line “unsubscribe”.  Following an unsubscribe request by you, you may still receive emails or communications for a short period of time until we are able to process your request and update your preference.


California “Do Not Track” Disclosures

California’s Online Privacy Protection Act (“CalOPPA”) requires THINK to let Users know how we respond to web browser “Do Not Track” (“DNT”) signals. Because there currently is not an industry or legal standard for recognizing and honoring DNT signals, we do not honor “Do Not Track” requests as of the date of this updated Notice and unless and until a further updated Notice is released stating otherwise.



We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child’s name or e-mail address) from persons under the age of eighteen (18). If you know or think that we have collected personal information from a person under the age of eighteen (18), please contact us (as described below) so such personal information may be removed.  The Site is not directed to individuals under the age of 18, and we request that these individuals not provide any personal information whatsoever through the Site and that no other User provide the information of any other person under the age of eighteen (18) on or through the Site.


Your Rights as a Data Subject 

Please be advised that under certain laws which may apply to you, you may have certain rights as a “data subject”.  For example, under applicable law, you (or a person you may authorize to act on your behalf, as may be permitted) may have the right to request further information about how your personal information is or has been processed, request a copy of your personal information, request that inaccuracies related to your personal information be corrected promptly, object to how your personal information is processed, request erasure/deletion of, or limitation or restriction on the processing of, your personal information.  THINK will, at all times, comply with its legal obligations, so in any such case, please contact us by referring to the “Contact Us” section of this Notice below so we may review your request and assist you.  To the extent permitted or required by applicable law, THINK reserves the right to decline a request or to otherwise impose certain restrictions or requirements on your request, but in such case will respond to you consistent with applicable law.  When a User (or authorized person) makes a data subject request, THINK may request information to verify the User’s or authorized person’s identity or authority/consent to comply with such data subject request.  THINK will never discriminate against you for exercising your data subject rights under applicable law. If you disagree with our decision regarding your data subject request, please contact us again, and we will re-evaluate your request as may be appropriate.  You may also file a complaint with the data protection authority in your jurisdiction.


Cross Border Transfers

Your personal information may be stored and processed in any country where THINK has facilities or service providers.  By using the Site or by providing your personal information through other channels referenced as covered under this Notice, and to the extent allowed by applicable law, your personal information may be transferred to states or countries outside of the state, province or country of your residence, including outside of the United States, which may provide for different data protection laws than the state, province or country of your residence.  Nonetheless, appropriate contractual and other measures will be in place to protect personal information when any such transfer occurs as allowed by applicable law.


Retention Period

We will retain your personal information for as long as reasonably necessary for the purposes for which it was collected and the allowable uses described in this Notice, or for a longer period of time as may be required by applicable law or regulation or a shorter period of time as may be restricted by applicable law or regulations.  The retention period will fluctuate depending on the status of our relationship with you, status of our ongoing legitimate business needs, and applicable legal or regulatory requirements.


Contact Us

If you have any questions or concerns about this Notice, please contact THINK by email at:, or by postal mail to:  47201 Lakeview Blvd, Fremont, CA 94538 (to the attention of:  Chief Legal and Compliance Officer).


Updates and Changes to this Notice

We reserve the right, at any time and without notice, to add to, change, update, or modify this Notice, simply by posting such change, update, or modification on the Site and without any other notice to Users. Any such change, update, or modification will be effective immediately upon posting on the Site. Should THINK decide to make a significant change to our Notice, we will post a notice on the homepage of our Site for a reasonable period of time after the change is made.


Effective Date

This Notice, as updated May 31, 2024, supersedes the last amended version dated January 5, 2021.

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