PRIVACY POLICY

Last updated: [14 January 2025]

Welcome to Thinkle, a mobile application and website provided by M/s. Thinkle Technologies Private Limited and its affiliates (collectively referred to as “Thinkle,” “us,” “we,” or “our”). We respect your privacy, and we are committed to protecting it.

This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information and to help you understand and exercise your privacy rights. This Policy will be applicable to you when you use Thinkle. Users are offered choices about the data that is collected, used, and shared, as stated in the Privacy Policy.

This Privacy Policy, together with our Terms of Use (“Terms”), governs the collection, disclosure, and processing of your data and is applicable to all the information collected through the Platforms, upon the use of such Platforms, any related services, marketing, events, and/or any other locations that are in any way linked to this Privacy Policy (collectively, the “Services”).

Please read this Policy and our Terms carefully. By accessing our Platforms, you consent to the information collection and use practices described in this Privacy Policy. If you do not agree to this Privacy Policy, you should immediately cease to continue the use of the Services. This privacy policy is in accordance with the statutory mandate under Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and other applicable rules, regulations, and laws.

1. Scope of this Privacy Policy

1.1 This Privacy Policy applies to personal information we collect from or about you through our websites, mobile applications, and any other Services that link to or reference this Policy (collectively, the “Services”).

1.2 This Privacy Policy does not apply to any personal information you share directly with a coach, client, or any third party outside of our Services. You must use your own discretion when sharing personal information about yourself or anyone else outside Thinkle’s platform.

1.3 The Services may contain links or integrations to third-party websites or services. Their data practices are governed by their own privacy statements. We encourage you to review those policies carefully.

2. Data We Collect

We collect personal information that you voluntarily provide, information automatically collected during your use of our Services, and information from third parties. The type of personal information we collect depends on your relationship with Thinkle (e.g., coach or client) and how you use our Services.

2.1 Information You Provide

As a Client:

  • Account & Profile: Name, phone number (for OTP verification), email address, password or login credentials, profile picture, Date of Birth, Preferences, Education information (e.g., degrees, schools/universities attended), Career background (company name, professional title, skills, location).
  • Payment Information: Handled securely by our third-party payment processor (e.g., Razorpay). We receive only limited payment status (e.g., transaction success/failure).
  • Journaling: Any content you enter in your personal journal (e.g., diary entries) is stored privately and encrypted. Thinkle does not have access to your journal notes unless you explicitly share them.
  • Psychometrics & Assessments: We may offer assessments, surveys, or questionnaires to help evaluate your personality, aptitudes, or motivators. You may choose to provide this information, which we process to personalize recommendations, match you with coaches, train our AI models, and improve our Services.
  • User-Generated Content: You may post comments or respond to daily polls within the Platform. These comments are visible to other users, so please avoid sharing sensitive personal data or confidential information in public sections.
  • Customer Support: If you contact us via email or other methods (e.g., Whatsapp), we collect and store the content of your message and your contact details to respond to you.

As a Coach:

  • Account & Profile: Name, contact information (email, phone), profile picture, location, and password or login credentials.
  • Professional & Educational Background: Education data (e.g., degrees, schools attended, test scores), career history, awards, achievements, video clips describing your services, and any relevant information used for matching with potential clients.
  • Payment/Payout Details: Bank account or other financial data (collected by our secure third-party payment processor) to facilitate payouts.
  • Availability & Scheduling: Calendar data to coordinate client sessions or calls.
  • User-Generated Content: Session summaries (if applicable).
  • Psychometrics & Assessments: Similar to clients, coaches may voluntarily complete assessments or questionnaires, which we process to personalize recommendations, match you with clients, train our AI models, and improve our Services.
  • Customer Support: If you contact us via email or other methods (e.g., support tickets), we collect and store the content of your message and your contact details to respond to you.

2.2 Information Collected Automatically

When you use the Services, our servers may automatically log or collect:

  • Device & Usage Information: We may automatically collect data about your device (model, operating system, unique device identifiers), IP address, browser type, app version, and usage patterns (e.g., pages or screens viewed, features used, crash logs).
  • Cookies & Similar Technologies: We use cookies, pixels, or other tracking tools to improve and customize the Services, analyze usage, and measure the effectiveness of our communications.

2.3 Information from Third Parties

  • LinkedIn: With your explicit consent and by providing your LinkedIn profile URL, we may fetch certain LinkedIn data (e.g., name, headline, experience and education history, public profile info) to enrich your Thinkle profile.
  • Analytics & Crash Reporting: We integrate with Google Analytics, Mixpanel, and Sentry, which receive usage data (e.g., IP address, app events, device information). This helps us diagnose issues and improve our Services.

3. How We Use Your Data

We collect and process your data for various legitimate business purposes, including:

3.1 Providing and Personalizing Services:

  • To create and manage your Thinkle account, give you access to functionalities, and tailor Services (e.g., AI-driven career recommendations, daily polls).
  • To evaluate your profile as a client or coach and enable appropriate matching between you and other users.

3.2 Coach-Client Matching & Engagement:

  • If you are a client, certain profile information (e.g., career background, goals, psychometric insights) may be shared with potential coaches.
  • If you are a coach, your profile information (e.g., expertise, background) may be shared with prospective clients.

3.3 Psychometrics & Assessments:

We process responses to psychometric tests or other assessments to provide personalized feedback, measure readiness or aptitudes, train our AI/ML models, and improve matching.

3.4 AI & Machine Learning:

We may use anonymized or pseudonymized user data to train, refine, or develop our AI models. In certain features, we may send anonymized metadata to our AI partner (OpenAI) to generate personalized insights. We have opted out of letting OpenAI use your data for its own model improvements.

3.5 Improve & Develop the Services:

We analyze usage trends, user feedback, crash data, and poll results to enhance Service performance, user experience, and product offerings.

3.6 Communications:

To send updates, respond to inquiries, or notify you about new features and promotions. You can opt out of certain emails through your account or unsubscribe links.

3.7 Legal & Security:

To comply with applicable laws and regulations, detect and prevent fraud or misuse, investigate suspicious activity, or enforce our Terms of Use.

3.8 Analytics & Research:

To understand how users engage with Thinkle and to measure the effectiveness of certain features. We use aggregated or de-identified data for analytics, market research, and internal business purposes.

4. AI Data Training & Consent

By using Thinkle's services, you consent to the use of your career profile, psychometric insights, and in-app behavior and preferences for training and improving Thinkle's AI models. This data will be anonymized and aggregated to ensure individual privacy. If you do not wish for your data to be used for these purposes, you may opt out by contacting us at support@thinkle.xyz.

5. When We May Disclose Your Data

We value your privacy and do not sell your personal information to third parties. However, we may transfer or disclose your personal information under these circumstances:

5.1 With Coaches & Clients:

  • Clients: We share your relevant personal information (e.g., name, profile picture, professional background, psychometric insights) with the coaches we match you with.
  • Coaches: We share your profile (e.g., profile picture, expertise, availability, career background) with clients seeking coaching.

5.2 Service Providers & Partners:

We may engage trusted third parties to perform functions on our behalf (e.g., payment processing via Razorpay, analytics via Mixpanel, Sentry, or Google Analytics, cloud hosting). These partners have contractual obligations to process personal information only under our instructions and in compliance with applicable laws.

5.3 Payment Processing:

For in-app wallet and other financial transactions, we use Razorpay. Razorpay handles sensitive financial data (e.g., credit card, UPI) directly on its secure platform, subject to Razorpay’s Privacy Policy.

We do not store or have direct access to your full payment details.

5.4 Public Content:

Certain features (e.g., daily poll comments, community discussions) are visible to other users. Avoid sharing sensitive data in publicly accessible areas.

5.5 Business Transfers:

If Thinkle (or a portion of our assets) is merged, acquired, or sold, your personal information may be transferred to the acquiring entity. Any such entity will be bound to honor any pre-existing commitments in this Privacy Policy.

5.6 Legal Obligations & Enforcement:

We may disclose information when required by law, court order, or other legal processes, or if we believe it is necessary to protect the rights, property, or safety of Thinkle, our users, or others.

6. Anonymized & Aggregated Data

Anonymized or Aggregated Information is data that does not relate to an identified or identifiable individual (or data that has been rendered anonymous in such a manner that the individual is no longer identifiable). Protections for personal information do not apply to anonymized information. We may process, use, and share anonymized or aggregated information for any purpose (e.g., research, analytics, service improvements, AI model training) without further notice and without attribution or compensation to any party.

7. Children’s Privacy

  • Minimum Age Requirement: Thinkle is generally intended for individuals 18 years of age or older.
  • Parental Consent: If you are under 18 but above the age of 13, you may use Thinkle only with the involvement and consent of a parent or legal guardian. We do not knowingly collect personal data from children under 13.
  • If we discover that a child under 13 has provided us personal information without verifiable parental consent, we will promptly delete such data. If you believe a child has used Thinkle without your permission, please contact us at support@thinkle.xyz

8. Data Security

We employ industry-standard security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption (where appropriate), secure server infrastructure, and strict access controls.

Data you store in your private journal is encrypted and inaccessible to us.

Despite our best efforts, no data transmission or storage system can be guaranteed 100% secure. Please use strong passwords and safeguard your login credentials.

9. International Data Transfers

We currently use reputable cloud providers (e.g., AWS, GCP) that may store or process your data in various locations. We do not have strict data localization rules in place at this time.

9.1 Compliance with Laws: By using our Services, you acknowledge that your personal data may be transferred to servers located in countries other than your own, subject to applicable data protection laws and safeguards.

10. Data Retention

We retain personal information for as long as necessary to provide the Services or for other essential purposes (such as complying with legal obligations, resolving disputes, and enforcing our agreements).

Account Deletion: If you would like to delete your Thinkle account or request that we stop using your information, please reach out to us at support@thinkle.xyz We will make reasonable efforts to delete your data unless certain information must be retained for legal or legitimate business purposes.
You can delete your Thinkle account in one of the following ways:

11. Your Rights & Choices

Depending on the laws of your jurisdiction, you may have rights regarding your personal data:

  • Access & Correction: You can request access to or correction of personal data we hold about you.
  • Deletion: You can request deletion of your personal information, subject to certain limitations under law.
  • Withdrawal of Consent: Where we rely on consent, you have the right to withdraw it at any time.
  • Parental Consent: If you are a parent or guardian who has provided consent for your minor, you may request access to or deletion of the minor’s data.

Please contact us at support@thinkle.xyz to exercise any of these rights.

12. Payment Processing & Subscriptions Terms

All financial transactions, including in-app purchases, wallet top-ups, and premium service payments, are processed through third-party payment providers. Thinkle does not store or process full payment details. Instead, transactions are securely handled by Apple Pay, Google Pay, or Razorpay.

12.1 Payment Methods

Thinkle supports the following payment methods based on your platform:

  • Apple Pay (for iOS users via the App Store)
  • Google Pay (for Android users via Google Play)
  • Thinkle Wallet (Top-Ups via Razorpay: UPI, Cards, Net Banking)

12.2 Auto-Renewable Subscription Terms

Thinkle offers auto-renewable subscriptions that provide users access to premium features on the thinkle app.

Billing & Renewals:

  • Subscriptions auto-renew unless canceled at least 24 hours before the renewal date.
  • Payment will be charged to your Apple ID or Google Play account at the time of purchase and at the start of each new billing cycle.
  • The renewal charge will be the same as the original purchase price, unless otherwise notified.

Cancellation & Subscription Management:

  • Users can manage or cancel their subscriptions directly through Apple or Google.
  • Cancelling a subscription prevents future charges but does not provide refunds for the current period.

12.2.1 Managing Subscriptions on Apple (iOS Users) & Google Play (Android Users)

Apple Refund Requests: https://support.apple.com/billing
Google Refund Requests: https://support.google.com/googleplay/

12.3 Apple Pay & App Store Payments

For users who purchase plus or ultra subscriptions or services via the Apple App Store:

  • Payments are securely processed via Apple Pay or your Apple ID-linked payment method.
  • Thinkle does not store or access your payment details.
  • Billing, auto-renewals, and cancellations are managed by Apple.

12.4 Google Pay & Google Play Payments

For users who purchase plus or ultra subscriptions via the Google Play Store:

  • Payments are securely processed via Google Pay or your Google Play-linked payment method.
  • Thinkle does not store or access your payment credentials.
  • Billing, auto-renewals, and cancellations are managed by Google.

12.5 Thinkle Wallet (Top-Ups via Razorpay: UPI, Cards, Net Banking)

Thinkle offers an in-app wallet that allows users to add funds for booking 1:1 career coaching sessions.

12.5.1 Wallet Top-Up Process

  • Users can add funds to their Thinkle Wallet via UPI, Credit/Debit Cards, or Net Banking using Razorpay.
  • All payments are encrypted and processed through PCI-DSS-compliant security standards.
  • Thinkle does not store your payment details (e.g., credit card numbers, UPI IDs, or banking details).
  • We receive only transaction confirmation details (success/failure status, amount added).

12.5.2 Non-Refundable Wallet Policy

  • Funds added to the Thinkle Wallet are final and non-refundable.
  • Wallet balances cannot be withdrawn, transferred, or converted into real currency.
  • If a service booked using wallet credits is canceled, any refund (if applicable) will be credited back to the wallet, subject to Thinkle's Refund Policy.
  • If a user deletes their Thinkle account, the remaining wallet balance will be forfeited.

12.6 Fraud Prevention & Security

To ensure safe and secure transactions, Thinkle and its payment partners:

  • Use SSL encryption for secure data transmission.
  • Partner with PCI-DSS-compliant payment processors.
  • Monitor transactions for fraud detection and security risks.
  • Reserve the right to suspend or terminate accounts involved in suspected fraudulent activity.

13. Cookies & Similar Technologies

We use cookies and similar technologies (e.g., device identifiers, pixels) in the Thinkle app and website:

  • Essential Cookies: To enable core functionality.
  • Analytics Cookies: To analyze usage patterns and improve our Services (e.g., Google Analytics, Mixpanel).
  • Managing Cookies: You may disable cookies through your browser settings, but some features of the Services may not function properly if you do so.

14. User-Generated Content

14.1 License to User-Generated Content

By posting, submitting, or otherwise making available any text, images, videos, or other content ("User Content") on or through the Services, you hereby grant Thinkle a non-exclusive, worldwide, royalty-free, perpetual, irrevocable, sublicensable, and transferable license to use, reproduce, modify, adapt, publish, translate, distribute, perform, and display such User Content for the purposes of (1) operating, maintaining, and improving the Services, and (2) marketing, promotion, or advertising of the Services or related offerings.

We will, however, strive to request additional explicit consent or provide notice when using personal information (e.g., your profile photo, personal details) in external marketing materials, where required by law.

14.2 User-Generated Content for Promotional Use

Certain content you post (e.g., comments, reviews or success stories) may be used for promotional or marketing purposes in accordance with our Terms of Use. In such cases, we may contact you for additional consent or notify you prior to using personally identifiable content in external marketing materials, unless your local laws do not require additional notice.

14.3 Public Posts & Moderation

Posts or comments you make in publicly accessible sections (e.g., daily polls, community discussions) may be viewed by other users. We reserve the right to remove or moderate user-generated content that violates our Terms of Use or is reported by other users. Do not share sensitive information in these public forums.

15. Coach-Client Communications

15.1 Confidentiality and Liability

  • General Confidentiality: Coaches and clients acknowledge that any information shared within the Platform is intended to be private. Thinkle does not typically view, monitor, or store the full content of coach-client communications. Users themselves are responsible for maintaining the confidentiality of shared information.
  • Limited Monitoring or Analysis: We do not record or transcribe the full sessions between coaches and clients. However, we may (i) log certain metadata (e.g., timestamps, participant IDs) and/or (ii) review limited portions of communications on an as-needed basis for troubleshooting, compliance, trust & safety, or to improve our Services (for example, to ensure that content does not violate our Terms or to gather aggregated insights). We handle any data obtained through such limited monitoring in accordance with this Privacy Policy and do not disclose it to third parties except as permitted or required by law.
  • Off-Platform Communications: Any exchange of personal or professional information happening off the Platform is solely at your discretion, and Thinkle assumes no liability for how such information is used, shared, or secured.
  • No Full Transcript Storage: We do not store or maintain permanent transcripts of any communications between coaches and clients. If any participant chooses to save or export content on their own (e.g., copying chat messages), this is outside of our control.

15.2 Respecting Confidential Nature

We respect the confidential nature of coach-client communications on our platform. We do not store or record transcripts or session data from these communications. If any participant chooses to save or export content on their own (e.g., copying chat messages), this is outside of our control.

15.3 Off-Platform Liability

We are not responsible for any information that you or a coach voluntarily share outside of the Thinkle platform (e.g., via third-party tools, email, or in-person meetings). Any personal data exchanged outside of our Services is not covered by this Privacy Policy or our data security measures.

16. Third-Party Links & Services

Our Services may include integrations or links to third parties:

  • LinkedIn: You can opt to share your LinkedIn URL to import certain profile information.
  • Razorpay: Payment processing is handled by Razorpay.
  • Analytics Providers: We use Google Analytics, Mixpanel, and Sentry for diagnostics and analytics.

We are not responsible for the privacy practices of these third parties. Please review their respective policies before engaging with them.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will notify you by email (if we have your email address) or through a notice within the Services, prior to the change becoming effective. Your continued use of Thinkle after the new Policy takes effect signifies your acceptance of the updated Policy.

18. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us at support@thinkle.xyz.

We will make every effort to address your inquiry promptly.

By using Thinkle, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms.