Last updated: September 1, 2015

Windows Open, LLC DBA TheThree ("TheThree", "we", "us") and its affiliates (listed in the "Affiliates" section below) are concerned about privacy issues and want you to be familiar with how we collect, use and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through our website located at www.thethree.us (the "Website"), our Facebook, Twitter, Instagram, and other social media pages (our "Social Media Pages") as well as HTML-formatted email messages that we send to you that link to this Privacy Policy (collectively, including the Website, the Social Media Pages, the "Services").  Please note that the Privacy Policy applies only to our online information-gathering and dissemination practices in connection with the Services, and does not apply to any of our practices conducted offline.  If you have any questions or comments about the Privacy Policy or our privacy practices, please contact us at privacy@thethree.us.

Your use of any of the Services, signifies that you agree with all the terms of this Privacy Policy, so do not use the Services, if you disagree with any part of this Privacy Policy.

PERSONAL INFORMATION

Personal Information We May Collect

"Personal Information" is information that identifies you as an individual, such as:

• Name
• Postal address (including billing and shipping addresses)
• Telephone number
• Email address

How We May Collect Personal Information

We and our service providers may collect Personal Information in a variety of ways, including:

• Through the Services:  We may collect Personal Information through the Services, e.g., when you sign up for a newsletter or register for a seminar.
• From Other Sources:  We may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties.  

How We May Use Personal Information

We may use Personal Information:

• To respond to your inquiries and fulfill your requests, such as to send you newsletters or publications that you request or to register you for events.
• To send you our updates and mailings relating to our seminars or events that we think may be of interest to you.
• To keep a record of your contact information and correspondence, and use it to respond to you, if you contact us through the Services.
• To send administrative information, for example, information regarding the Services and changes to our terms, conditions, and policies.
• To provide services, including the provision of seminars and other events.
• To allow you to send Services-related content to a friend through the Services.  By using this functionality, you are telling us that you are entitled to use and provide us with your friend's name and email address.
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

• To our affiliates (listed in the "Affiliates" section below) for the purposes described in this Privacy Policy, consistent with our goal of providing the highest level of global service. Subject to local requirements, this information may be used to provide legal and related services offered by our other legal entities and for all the purposes outlined in this Privacy Policy.  TheThree remains responsible for the management of the jointly-used Personal Information.  If you are a Californian user of the Services, and would like more information regarding our provision of your Personal Information to affiliates of TheThree, please refer to the "Special Notification for Individual California Users" section below.
• To our third-party service providers that provide services such as website hosting, Services-related consulting and monitoring, data analysis, information technology and related infrastructure, customer service, email delivery, auditing and other similar services.
• To identify you to anyone to whom you send messages through the Services.
• By you on services to which you are able to post information and materials (including, without limitation, our Facebook Page).  Please note that any information you post or disclose through these services will become public information, and may be available to us, to users of the Services and to the general public.  We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services.
• To a third party (whether affiliated or unaffiliated with us) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. 

OTHER INFORMATION

Other Information We MayCollect

"Other Information" is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you
• Aggregated information

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device:  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using.  We use this information to ensure that the Services function properly.
   
• Through your use of a mobile App:  When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your iPhone, iPad or iPod Touch accesses our servers and what information and files have been downloaded to the App based on your iPhone's, iPad or iPod Touch's device number.
   
• Using cookies:  Cookies are pieces of information stored directly on the computer that you are using.  We may use cookies in connection with the Services.  To learn more about how we use cookies, or to opt-out of the collection and use of cookies, please see our Cookies Policy.
   
• Using pixel tags and other similar technologies:  Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.  
   
• IP Address:  Your "IP Address" is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP).  An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited.  Collecting IP Addresses is standard practice and is done automatically by many websites and applications.  We use IP Addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
   
• From you:  Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information.  Unless combined with Personal Information, this information does not personally identify you or any other user of the Services.
   
• By aggregating information:  Aggregated Personal Information does not personally identify you or any other user of the Services, (for example, we may aggregated Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, then we may use it as described in "How We May Collect Other Information" section above, as well as for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location).  If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

SPECIAL NOTIFICATION ABOUT WEBINARS

Webinars offered as a service to users of the Services are hosted by unaffiliated third party vendors, and not by us.  Our third party vendors require users to provide Personal Information, such as name and email address. Please note that this Personal Information is collected by our vendors, and not by us.  We encourage you to read the privacy statements of our vendors, which control how such vendors handle Personal Information provided by you to register for the Webinars.

Additionally, our third party vendors provide us with Personal Information about users of our Webinars.  We use this Personal Information to track attendance, facilitate future communication with such users, and for other purposes set forth in this Privacy Policy.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as any app, social media platform, or wireless service provider, including any Personal Information you disclose to other organizations through or in connection with the Services.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section below.

CHOICES AND ACCESS

Your choices regarding our use of your Personal Information for marketing purposes

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in any such message or by contacting us by email at privacy@thethree.us.  We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How you can access, change or suppress your Personal Information

You may request to review, correct, update, suppress, or otherwise modify any of your Personal Information that you have previously provided to us through the Services, or object to the use or processing of such Personal Information by us.  You may exercise these rights by logging on to your email subscriptions account or by contacting us by email at privacy@thethree.us

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to usFor your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed.

SPECIAL NOTIFICATION FOR INDIVIDUAL CALIFORNIA USERS

As noted above, we may disclose Personal Information to affiliates of TheThree, which may use this information for all purposes outlined in this Privacy Policy.  Because separate legal entities are considered "third parties" for purposes of California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting their legal services, we are providing the following information for California residents who have provided us with their Personal Information during the creation of or during the course of an established legal services relationship that is primarily for personal, family, or household purposes ("Individual California Users").  Individual California Users may request information about our disclosures of certain categories of Personal Information to third parties (i.e., our affiliates) for such third parties' direct marketing purposes.  Such requests must be submitted to us either by email at privacy@thethree.us 

We will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties.  This request may be made no more than once per calendar year.  We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals not provide Personal Information through the Services.

CROSS-BORDER TRANSFER

The Services are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.  Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy.  Please take a look at the "Last Updated" legend at the top of this page to see when this Privacy Policy was last revised.  Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services.  Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us by email at privacy@thethree.us 

Please note that email communications are not always secure; so please do not include any sensitive information in your emails to us.

AFFILIATES

For purposes of this Privacy Policy, the following entities are considered to be "affiliates" of  TheThree:

• None

© 2018 TheThree. All Rights Reserved.