Privacy Policy


At Thoropass, respect for the privacy of personal and other information is extremely important to us. This privacy policy describes our collection of personal information from users of our Web site (“Website” or “Site”), our Platform, as well as all related applications, widgets, software, tools, and other services provided by us and on which a link to this Policy is displayed (collectively, together with the Website, our “Service”). This Policy also describes our use and disclosure of such information.

The Thoropass Service is intended for and provided to businesses and other organizations, and not individual consumers or end-users.  In providing the Service we may process personal information of consumers or end-users at the direction of our enterprise customers. When we do, we do so as a service provider or a “data processor” to those organizations, but we do not control and are not responsible for the privacy practices of those organizations. This Policy does not apply to personal information we process as a service provider or data processor on behalf of our enterprise customers. If you are a consumer end-user of one of those organizations, you should read that organization’s privacy statement and direct any privacy inquiries to that organization.


The personal data we collect depends on how you interact with us, the services you use, and the choices you make. Note that we do not “sell” personal information as defined by the CCPA and have not done so in the past.

We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data. 

Information you provide directly. We collect personal data you provide to us. For example:

  • CONTACT INFORMATION. We collect name, username or alias, email address, postal address, phone number, fax number.
  • DEMOGRAPHIC AND PREFERENCE DATA. In some cases, such as when you register or participate in surveys, we request that you provide details on your interests, preferences, or other demographic information.
  • PAYMENT INFORMATION. If you make a purchase or other financial transaction, we collect credit card numbers, financial account information, and other payment details.
  • CONTENT AND FILES. We collect documents or other files you upload to the Service or otherwise provide to us; and if you send us email messages or other communications, we collect and retain those communications.

Information we collect automatically. When you use our services, we collect some information automatically. For example:

  • IDENTIFIERS AND DEVICE INFORMATION. When you access the Service, our web servers automatically log your internet protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the cookies and similar technologies section below, our Service stores and retrieves cookie identifiers and other data.
  • GEOLOCATION DATA. Depending on your device and browser settings, we collect geolocation data when you use the Service.
  • USAGE DATA. We automatically log your activity on the Service, including the URL of the website from which you came to the Service, pages you viewed, how long you spent on a page, cursor movements, text input, access times, and other details about your use of and actions on the Service.

INFORMATION WE OBTAIN FROM THIRD-PARTY SOURCES. We may receive personal information about you from data brokers, partners, service providers, social networks, including publicly available sources. We may combine this information with other personal information we maintain about you.

When you are asked to provide personal information, you may decline and you may use web browser or operating system controls to prevent certain types of automatic data collection, but if you choose not to provide or allow information that is necessary for the Service, the Service or certain aspects of it may not be available or fully functional.


We use cookies, web beacons, and similar technologies to operate our Service and to help collect data, including usage data, identifiers, and device information.

What are cookies and similar technologies? 

Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our Site (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We may also include web beacons in email messages to tell us if you open and act on them.

How do we and our partners use cookies and similar technologies?

We, and our analytics and advertising partners, use these technologies on our Service to collect information (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information) when you use the Service. This information is used to store your preferences and settings, enable you to sign-in, analyze how our Service performs, track your interaction with the Service, develop inferences, show you advertising about the Service after you visit our Website, combat fraud, and fulfill other legitimate purposes.

What controls are available? 

These choices are specific to the browser you are using. If you access the Service from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.

  • BROWSER COOKIE CONTROLS.  Most web browsers are set to accept cookies by default.  If you prefer, you can go to your browser settings to learn how to delete or reject cookies.  If you choose to delete or reject cookies, this could affect certain features or services of our website.  If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
  • EMAIL WEB BEACONS.  Most email clients have settings which allow you to prevent the automatic downloading of images, including Web Beacons, which prevents the automatic connection to the web servers that host those images.
  • DO NOT TRACK.  Some browsers have incorporated “Do Not Track”  (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked.  Because there is not a common understanding of how to interpret the DNT signal, our Service does not currently respond to browser DNT signals.  Instead, you can use a range of other tools to control data collection and use, including the cookie controls and advertising controls described above.


We use the personal data we collect for purposes described in this Policy or otherwise disclosed to you. For example, we use each of the categories of personal information for the following purposes:

  • PRODUCT AND SERVICE DELIVERY.  To provide and deliver our Service, including troubleshooting, improving, and personalizing the services.
  • BUSINESS OPERATIONS.  To operate our business, such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.
  • PERSONALIZATION.  To understand you and your preferences to enhance your experience and enjoyment using the Service.
  • CUSTOMER SUPPORT.  To provide customer support and respond to your questions.
  • COMMUNICATIONS.  To send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • MARKETING.  To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our Services and those of our selected partners (see the Choice and Control section of this Policy for how to opt out from promotional communications).
  • ADVERTISING.  To display advertising to you (see the Cookies section of this Privacy Statement for information about personalized advertising and your advertising choices).


We will disclose your personal information to third parties with your consent or as necessary to complete your transactions or provide the services you have requested or authorized. For example, when you provide payment data to make a purchase, we will share that data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services. In addition, we share each of the categories of personal data described above for the following business purposes:

We may disclose personal information to third-party service providers (e.g., data storage and processing facilities, third-party vendors, consultants) that assist us in our work. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions.

We may also disclose personal information, including to law enforcement or other government agencies, if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

In addition, we may disclose personal information about our users as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.

Third-party analytics and advertising companies, acting on our behalf as our service providers, also collect personal information through our Service as described in the Cookies section of this Policy. For example, we use an analytics tool from FullStory to help us better understand how our Service is used. Likewise, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at

Finally, we may share de-identified information in accordance with applicable law.

Please note that the Service may contain links to other Websites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this Policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties.


ACCESS, CORRECTION, AND DELETION.  You can access, correct, or delete certain personal information you have provided logging into the Service with your account. If you are unable to access certain personal information via your account, you can request access by contacting us as described at the bottom of this Policy; however, to the extent permitted by applicable law, we reserve the right to decline requests that are unreasonable or excessive, where providing the data would be prohibited by law or could adversely affect the privacy or other rights of another person, where deleting data would interfere with a legal or business obligation that requires retention of the data, or where we are unable to authenticate you as the person to whom the data relates.

COMMUNICATIONS PREFERENCES.  If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us by sending us an email or by writing to us at the address given at the end of this policy.

CHOICES FOR COOKIES AND SIMILAR TECHNOLOGIES. See the Cookies section of this Policy for choices about cookies and other analytics and advertising controls.


If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

  • You can request access to, and rectification or erasure of, personal data;
  • If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
  • If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
  • You can object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
  • For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, please use the contact information at the bottom of this Policy.  When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party.  You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful basis for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.


If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.

RIGHT TO KNOW.  You have a right to request that we disclose to you the personal information we have collected about you.  You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information.  Note that we have provided much of this information in this Policy. You may make such a “request to know” by contacting us using the email address at the bottom of this Policy.

RIGHT TO REQUEST DELETION.  You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. You can exercise this right by logging in to the Service and removing information you have previously provided or by contacting us with your request using the email address at the bottom of this Policy.

RIGHT TO OPT-OUT.  You have a right to opt-out from future “sales” of personal information. Note that we do not “sell” personal information as defined by the CCPA and have not done so in the past.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.

Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.

Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law. California Customers may request further information about our compliance with this law by emailing [email protected]. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.


We retain personal information for as long as necessary to provide the Service and fulfill your transactions, comply with our legal obligations, resolve disputes, fulfill our contractual obligations, enforce our agreements, and other legitimate and lawful business purposes.


Our Service is hosted in the United States and all personal information collected in connection with the Service is stored in the United States. If you are visiting our Site, using our Service, or otherwise providing personal information to us from outside the United States, please be aware that you are transferring personal information to the United States.

When we transfer personal information from the European Economic Area (EEA), UK, or Switzerland to the United States, which has not been determined by the European Commission to have an adequate level of data protection, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit:


Thoropass protects the personal information it collects with reasonable and appropriate physical, electronic, and procedural safeguards. We use reasonable security measures that are designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any personal information or other information. You transmit information to us at your own risk.

If you have an account with us, to help us protect personal information, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.


We may occasionally update this policy. When we do, we will also revise the “last updated” date at the beginning of the policy. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law. Your continued use of this Service after such changes will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose personal information.


If you have any questions, comments, or concerns about this privacy policy or your personal information, please contact us at [email protected]. Our offices are located at 228 Park Ave S, PMB 41082, New York, NY 10003, United States.