Last Updated: June 20, 2020
What Types of Information Do We Collect?
When you interact with our Site, we receive and store information to track customers, potential customers and people who access our websites, using cookies.
In addition, like many other website owners, we use automated data collection tools such as Cookies to collect certain information when you visit the Site. “Cookies” are small text files that are placed on your hard drive by a Web server when you access our Site. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services using Google Analytics.
We also use Zopim to place cookies to track your IP address and pages visited to link with information so that we can provide customer support for you.
If you create an account to use our Services or request information from us, we’ll collect certain information that can be used to identify you, such as your name, email address, postal address and phone number (“Personal Data”). In order to answer your questions or fulfill your requests, we may need to ask you for your Personal Data. We also may collect your IP Address and location (“Log Information”).
Cloud Services: Device and Network Information
When you apply for an unlock code to operate Thunder services, we will collect information about you and your device. This information includes, for example, Personal Data about you and your location and the serial number of the device or software.
Thunder Cloud Services collects and stores the name, address, email address, phone number for the account contact accessing the Thunder Cloud Services and stores the IP addresses operated by the customer. Thunder Cloud Services collects, information about the device administrator such as user name and password. It will also collect information regarding the ISP network and the network devices attached to it, such as the following: (i) MAC address, (ii) device type, (iii) operating system, (iv) geo-location information, (v) network traffic information (e.g., hostnames, protocols, port numbers, and IP addresses); and (vi) aggregate device data usage (“Network Provider Data”). For Thunder devices that use Long Term Evolution (LTE) technology, we may transmit certain geo-location information about those network devices (and the network(s) on which they are running) to Google and other third party geo-location services, which in turn provides us with related geo-location information that we store and make available to you as described above.
For customers serving the European Economic Area, we enter into agreements with your company to ensure that we treat Personal Data of the network administrators and any other data in accordance with applicable law, including, but not limited the General Data Protection Regulation (“GDPR”), including the incorporation of EU Model Contractual Clauses for data export.
How Do We Use The Information We Collect?
Non-Personal Information collected by the Site
Any non-personal information we collect from your use of the Site, whether through Cookies or otherwise, may be de-identified, aggregated and pooled with other information to track trends involving the use of our Services, such as the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors’ internet service providers, and how our users use and interact with the Site. We may provide aggregate statistics about our customers, traffic patterns and related site information to reputable third parties, but these statistics will include no personally identifying information.
Personal Data and Device and Network Provider Data
Network Provider Data
Thunder and its subsidiaries and affiliates may share Network Provider Data with the customer using the device and Thunder Cloud Services to assist them with managing the device and ensuring security and safety of the network accessing it. In our opinion, the data we collect regarding network use does not qualify as Personal Data as it cannot be used to identify any individual person. As a precaution, as a processor of data in general we enter into agreements with such customers to ensure that our processing is done in compliance with laws applicable to data processing, privacy and protection such as the EU Model Contract Clauses for data export to data processors. However, as the processor, we also have no control over how our customers use Network Provider Data. All inquiries regarding use, review, rectification or deletion of Personal Data should be directed to the network operator or other Thunder customer that is the network operator using the device.
Disclosures of Your Personal Data and Other Information
Thunder is not in the business of selling your information, and we do not sell our customer lists or any Personal Data you have disclosed to us to third parties. We consider this information to be a vital part of our relationship with you. We may, however, disclose information to certain third parties if you consent to us doing so, as well as in the following specific circumstances:
Thunder, like many businesses, may serve as data controller and hire third party service providers to perform certain processing functions in order for us to administer and provide the Services. When we employ another individual or company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These third-party companies may use and disclose Personal Data and other information that we disclose to them in accordance with the privacy policies and procedures outlined herein.
We share Personal Data with project management software and customer service providers storing data in the United States in order to track or provide customer service support requests and manage our projects and link such information together securely and efficiently.
We store Personal Data, Log Information and Network Provider Data with cloud storage providers in the United States for record keeping information related to providing the Services.
We also share Personal Data we collect from you with third party providers in order to track sales leads and communicate with our customers for direct marketing and administrative reasons.
When working with third party providers we take care to ensure that your Personal Data is only shared with vendors who have agreed to protect personal data through a data processing addendum and either adoption of EU Standard Contractual Clauses, EU-US and Swiss-US Privacy Shield certification or Binding Corporate Rules filed by the vendor with and approved by data protection authorities.
We collect Personal Data from the following third party service providers:
We may disclose Personal Data such as customer identity and contact information, as well as other information to our channel partners, such as distributors or resellers, in connection with the provision of and billing for the Services. Except as provided under the Business Transfers section, we do not sell Personal Data to third parties.
Information Disclosed for Our Protection or the Protection of Others:
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you or Network Provider Data to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, or as part of a legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to investigate or stop any activity that we consider an illegal, fraudulent, unethical or legally actionable activity.
Information about our users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor, or assignee 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 Data is transferred to one or more third parties as one of our business assets. We will take steps to inform you should such a transfer occur by contacting you at the email address we have on file in your account.
Your Choices and Digital Rights
Reviewing and Correcting Your Personal Data
In the event you would like view or correct data we store about you, you may correct information by logging into your account. If you cannot access the data there or would like to review the Personal Data we collect about you, please contact us at firstname.lastname@example.org with your request so that we may initiate proper procedures to respond to your request. We reserve the right to charge for copies of personal data undergoing processing. You can access and modify the Personal Data associated with your account by emailing us at email@example.com
Removing, Objecting to or Withdrawing Your Personal Data
If you would like to remove your Personal Data as an administrator and add a replacement, you may change such information through your account. However, if all administrator Personal Data or all administrators are removed, we cannot verify the account or conduct billing, and we shall discontinue the Services that we provide.
If you want us to delete your Personal Data and your account, please contact us via the form linked in your account with your request for our review. We will take steps to delete Personal Data unless we are permitted or required to retain such data by law.
If you would like your data made available for portability, please contact us at firstname.lastname@example.org to specify what data you would like made portable, and we will send it to you or another controller in a machine readable form.
If you live in the European Economic Area, and believe we are violating your digital rights, you have the right to file a grievance with the Information Commissioner’s Office in the United Kingdom.
Your California Privacy Rights
In the United States, California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their personally identifiable information for direct marketing purposes during the preceding calendar year and the categories of personally identifiable information shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email at email@example.com with “California Privacy Rights” in the subject line.
Thunder takes steps to regularly delete data when we no longer have legitimate business purposes to retain it. However, we are required by law and/or our contractual obligations with our customers to retain some data for reporting purposes or to protect against legal claims.
Thunder takes reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure, including protecting your Personal Data with encryption, passwords and SSL technology. We train our staff regarding security procedures and restrict access to the Personal Data we store to those who need to access it to provide Services to you. Our devices also have security measures to help ensure that data is securely transmitted. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
Do Not Track
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Data.
Links to Other Sites
Thunder does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data through this Site, please contact us at firstname.lastname@example.org, and we will endeavor to delete that information from our databases.
Our servers and data centers are located in the United States. If you choose to use the Services from outside the U.S., then you should know that you may be transferring your Personal Data outside of your region and into the U.S. for storage and processing in connection with the services we supply to our customers. When we receive Personal Data data from the European Economic Area we treat it in accordance with the GDPR and work with our customers to ensure that such Personal Data is processed in compliance with GDPR.