Thank you for using our services. When you use our services, you trust us with your information. This Thinkware Privacy Policy (“Privacy Policy”) helps you understand what information we collect, why and what we do with it. Please take time to read through it carefully. Here, you will find information on how to manage your information and protect your privacy.
We work hard to protect your private information and improve such protection. Therefore, this Privacy Policy is updated from time to time. Our Apps downloaded from the AppStore usually contain the most recent version of this Privacy Policy. You may read the most recent version of this Privacy Policy at our website: [“Thinkware Privacy Policy”].
When you choose to use Thinkware Connected LTE Service, you can easily store your location-related information, event-related information on your car, condition of your car while it is parked and share with people who care about where you are. In this Privacy Policy, we want to explain clearly how we use the information and how you can protect your privacy. This Privacy Policy explains:
√ What information we collect and why;
√ How we use that information; and
√ The choices you can make on the provision and retention of that information.
We want to make this Privacy Policy as simple and clear as possible. Your privacy matters to us. Please take time to understand our practices.
We collect information to provide people you care about with information including (a) location-related information (“Location Information”); (b) information of your car in parking mode (“Parking Information”); and (c) shock and other information on your car (“Event Information”). We collect information in the following manner:
2.1 Information you provide:: You may need to sign up for a Thinkware Connected LTE Account. When you do, you’ll provide personal information like your email address and/or telephone number.
2.2 Information we get from your device: : We collect device-specific information from Thinkware devices (such as the unique device identifiers of the dashcam/blackbox hardware) and from the mobile phone (such as the MAC address, UUID (in case of iOS) or Android ID (in case of Android OS) and/or the telephone number). We may associate such device identifiers, MAC address, UUID or Android ID and/or telephone number with your Thinkware Connected LTE Account.
We also may collect and process information about your actual location. We may use various technologies to determine the location of the device such as GPS, IP address, Wi-Fi access points and cell towers.
We may collect the hardware sensor values such as the battery voltage value and the shock value (G-fence shock value) from your dashcam/blackbox device to determine if anything unusual happened to you.
We may collect the hardware sensor values such as the battery voltage value and the shock value (G-sensor shock value) from your dashcam/blackbox device to determine if anything unusual happened to you.
We may collect (a) the event video recording for 20 seconds surrounding an accident or any other event based on the G-fence shock value and the battery voltage (10 seconds before, and 10 seconds after the triggering event); and (b) the SOS video recording for 10 seconds after an SOS event (5 seconds before, and 5 seconds after such event).
Out of box, our dashcam/blackbox device gathers the location information and hardware sensor values every 10 seconds. If you use Thinkware Connected LTE Service and enable uploading through your cell phone, those data will be uploaded to our Thinkware Connected LTE Server. The Connected LTE Server will preserve most of the data (except video and image recording) for 90 days.
You may elect to delete those information we collect. For more information, see Section, Transparency and choice, below.
We use the information we collect for giving notices, to give notice of what is happening to you or your car to the people you care about (only after such person makes a registration), and to improve our services. We do not use them for any other purpose (such as advertisements) or provide to any other person unless you specifically designate them as recipient of the events or required by law.
The choice of who receives event notification is completely up to you. Unless required by law or a government agency, we will respect the choices you make on how the information is given to persons other than you.
We will not collect, use or associate an identifier with sensitive information such as information on your race, religion, sexual orientation or health. We will collect only the minimum personal identifier information for our service.
We will not collect, use or associate an identifier with sensitive information such as information on your race, religion, sexual orientation or health. We will collect only the minimum personal identifier information for our service.
We will ask for your consent where required to do so by law before using your information for purposes set out in this Privacy Policy. We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.
We may process information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live. Currently, all login-related information and driving history is stored and processed in Republic of Korea, and all other information is stored and processed in the country in service. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your personal information.
Thinkware wishes to be clear about what information we collect and store so that you can make meaningful choices about how such data is used. You can:
√ Review and update who an event notification is sent to when an event occurs such as when your car violently stops or accelerates or voltage value of the device fluctuates abruptly, suggesting an important event occurred with your car;
√ Review and update the device information, email address and/or telephone number linked to your account; and/or
√ Delete the data stored in our Thinkware Connected LTE Server.
We will gather minimum personal identifier information to enable our services, and to prevent divulging your sensitive personal identifier information to an unauthorized person.
6.1 We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws, disclosure to any regulatory authority or third parties) and perform obligations under our legal agreements and policies.
6.2 We will also retain any usage pattern and detailed of using the Service for internal analysis purposes. It is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
When you use our services, we will provide you with access to your personal information. If the information is wrong, we will give you ways to update it quickly or delete it, unless we have to keep that information for legitimate business or legal reasons. When you are updating your personal information, we may ask you to verify your identity and the ownership of the product before we can act on your request.
We may reject requests that are unreasonably repetitive, require disproportionate technical effort (such as fundamentally changing an existing practice or developing a new system), risk the privacy of others, or are extremely impractical (such as requesting information on a backup system). We aim to maintain our services in a manner that protects information from accidental or malicious destruction. For this reason, if you delete information from our services, we may not immediately delete copies from our servers and may not remove information from our backup systems.
We do not share your personal and/or location information with companies, organizations and individuals outside of Thinkware unless:
8.1 According to your request and/or consent: : We will share personal information with companies, organizations or individuals outside of Thinkware when you request, or consent to such sharing. We require opt-in consent for the sharing of sensitive personal and location information.
8.2 For external processing:: We may provide personal and location information to our affiliates or other trusted businesses or persons to process it for us according to our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. When practical, we may remove from, or unlink the location information from, the sensitive personal information.
8.3 For legal reasons:: We will share personal information with companies, organizations and individuals outside of Thinkware if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
√ meet any applicable law, regulation, legal process or enforceable governmental request;
√ enforce applicable terms of service, including investigation of potential violations;
√ detect, prevent or otherwise address fraud, security or technical issues; or
√ protect against harm the rights, property or safety of Thinkware, our users or the public as required or permitted by law.
We may share non-personally identifiable information (or after unlinking other data from the personally identifiable information) publicly and with our affiliates, partners or connected sites. For example, we may share information publicly to show trends about the general use of our services.
If Thinkware is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.
9.1 We will use our best endeavors to protect personal information in our possession or under our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risk. However, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
9.2 We strongly advise that you do not share or publicize any footage which contains any personal information which we send to you, on any social media or public platform which may cause, directly or indirectly, any parties to lodge any claims for unauthorized recording of the personal information.
9.3 You agree to hold us harmless from, and indemnify us for, any costs, expenses, losses, responsibility, claims, proceedings we may incur or face should there be any claims by any third parties arising from or related to your release or publication of any footage or personal information which we originally make available to you.
We promise to work hard to protect Thinkware and our users from unauthorized access to or alternation, disclosure or destruction of information we hold. For that purpose, we may use the following methods:
√ Encryption of personally identifiable information using SSL;
√ Field encryption for transmission of personally identifiable information using AES128 algorithm;
√ Separation of security server/firewall for access to servers storing personally identifiable information;
√ Storage of personally identifiable information in a physically separate server;
√ Additional approval procedure for access to servers storing personally identifiable information for administrative purposes;
√ Review of our information collection, storage and processing practices including physical security measures to guard against unauthorized access to systems; and/or
√ Restriction of access to personal information to Thinkware employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict professional or contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
11.1 We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information. Whenever made possible, you can update your personal information directly within your account settings section. If you are unable to change your personal information, please contact us to make the required changes. If you wish to be informed what personal information we hold about you and if you want it to be removed from our systems, please contact us by writing to our Data Protection Officer at Email address
√ AUSTRALIA
| Name | John Azzolina |
| Address | 78 Mills Rd, Braeside VIC 3195, Australia |
| Email address | jazzolina@tdj.com.au |
√ UNITED KINGDOM & Europe
| Name | Timothy Sagar |
| Address | Sagar-House Ltd. 54 Norcot Road, READING, RG30 6BU, UK |
| Email address | tim.sagar@thinkware.com |
√ Thailand
| Name | Patipon Swasdivong |
| Address | 30/331 Soi Namwongwang 47(1-3) Namwongwang Road, Tungsonghong Leksi Bangkok 10210 |
| Email address | thinkwarethailand@gmail.com |
12.1 Third parties:: We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
√ AUSTRALIA
| Name | TDJ Australia Pty Ltd |
| Address | 78 Mills Rd, Braeside VIC 3195, Australia |
| Purpose | To share the vehicle information with a service subscriber, or the designated person by subscriber. |
| Details of content | Location of your car, and event information |
| Email address | jazzolina@tdj.com.au |
√ UNITED KINGDOM & Europe
| Name | Chameleon Codewing Ltd, |
| Address | 97 Glsbecks Road, Colchester, Essex, C02 9JT, UK |
| Purpose | To share the vehicle information with a service subscriber, or the designated person by subscriber. |
| Details of content | Location of your car, and event information |
| Email address | Info@chameleoncodewing.co.uk |
√ Thailand
| Name | Patipon Swasdivong |
| Address | 30/331 Soi Namwongwang 47(1-3) Namwongwang Road, Tungsonghong Leksi Bangkok 10210 |
| Purpose | To share the vehicle information with a service subscriber, or the designated person by subscriber. |
| Details of content | Location of your car, and event information |
| Email address | thinkwarethailand@gmail.com |
12.2 Analytics:: We may use third-party Service Providers to monitor and analyze the use of our Service.
12.3 Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Policy Terms web page: https://policies.google.com/privacy?hl=en
Our Service does not address anyone under the age of eighteen (18) ("Children" or “Child”). We do not knowingly collect personally identifiable information from anyone under the age of eighteen (18). If you are a parent or guardian and you are aware that your Child has provided us with his/her personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.
Thinkware Privacy Policy applies when you elect to use our services such as Thinkware Connected LTE Service, but does not apply when using a service that has a separate privacy policy that does not incorporate this Privacy Policy.
Thinkware Privacy Policy does not apply to services offered by other companies or individuals that may include Thinkware services, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who may use our services or incorporate our services in their own services.
We regularly review our compliance with our Privacy Policy. When we receive formal complaints, we will contact the person who made the complaint to follow up. We will work with the appropriate regulatory authorities when necessary, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.
This Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on our website mentioned above and, if the changes are significant, we will provide a more prominent notice (including email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.
If you have any questions about the Privacy Policy, please contact our Data Protection Officer at Email address.