Effective Date: January 8, 2024

Privacy Policy

This Privacy Policy (“Privacy Policy” or “Policy”) describes how Themis, Inc. and its subsidiaries and affiliates (“Themis,” “us,” “we,” or “our”) may collect, use, disclose, share and secure the personal information you provide in connection with our website at https://www.themis.com/ and any other websites we own and operate that link to this Privacy Policy (collectively, the “Site”) together with our products, services, social media pages, events, emails, and other electronic communications (collectively, the “Themis Services”). Any terms not defined in this Policy shall have the meanings attributed to them in the Terms of Service.

This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Themis or any third party; or any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Themis Services.

This Privacy Policy also does not apply to personal information that we may store or maintain on behalf of any of our customers who use our Service as part of a paid Themis subscription plan (a “Customer”), where applicable. For more information about the privacy practices of one of our Customers (such as your employer or another entity or legal person) who governs the delivery, access, and your use of the Service, please refer to their privacy policy or notice.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Themis Services. This Policy may change from time to time. Your continued use of our Site or Themis Services after we make changes is deemed to be acknowledgement of those changes, so please check the Policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about Users of the Themis Services, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number ("personal information");

• That is about you but individually does not identify you, such as the name of your employer or the state where you work; and/or

• About your internet connection, the equipment you use to access the Themis Services, and usage details.We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the Themis Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

• From third parties, for example, our business partners.

Information You Provide to Us.  
The information we collect on or through the Themis Services may include:

• Information that you provide by filling in forms on the Themis Services. This includes information provided at the time of registering to use the Themis Services or posting material to the Platform. We may also ask you for information when you report a problem with the Themis Services.

• Records and copies of your correspondence (including email addresses) if you contact us.

Information We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with the Themis Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Themis Services, including traffic data, location data, logs, and other communication data and the resources that you access and use through the Themis Services.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information. It helps us to improve the Themis Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize the Themis Services according to your individual interests.

• Speed up your searches.

• Recognize you when you return to the Themis Services.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Themis Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Themis Services.

Flash Cookies. Certain features of the Themis Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and through the Themis Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of the Themis Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Themis, for example, to count Users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, through the Themis Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us as set forth below:

• to present the Site and Themis Services and its contents to you;

• to provide you with information, products, or services that you request from us;• to fulfill any other purpose for which you provide it;

• to provide you with notices about your account, including expiration and renewal notices;

• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

• to notify you about changes to the Site or Themis Services or any products or services we offer or provide though it;

• to allow you to participate in interactive features through the Themis Services;

• to provide you with access to the Themis Services;

• in any other way we may describe when you provide the information.; and/or

• for any other purpose with your consent.

Disclosure of Your Information
We may disclose aggregated information about our Users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Privacy Policy:

• to our subsidiaries and affiliates;

• to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Themis's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Themis about the our Users is among the assets transferred;

• to fulfill the purpose for which you provide it;

• for any other purpose disclosed by us when you provide the information; and/or

• with your consent.

We may also disclose your personal information:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and/or

• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Themis, our Users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Customers determine their own policies and practices for the sharing and disclosure of personal information through the Services. Themis processes such personal information for the limited and specified purposes of providing the Services in accordance with the Customer’s instructions, including any applicable Customer Agreement. For the avoidance of doubt, Themis does not sell (for monetary or other valuable consideration) to a third party personal information it processes on behalf of its Customers.

Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Review, Request Changes to, or Delete Your Account. If you have a Themis account and want to review or need to make a change to the personal information stored in your account and are unable to do this through your account settings, or you need to delete your account, please email us using the contact information at the end of this Privacy Policy or contact the Customer (e.g., your employer or other entity or person) who administers your access to the Services. Note that we may keep historical information in our backup files as permitted by law.

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Security of Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. 

Data Retention
We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, as long as required to meet our legal obligations, or, where applicable, in accordance with a Customer’s instructions. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Changes to Our Privacy Policy

Contact Information

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our Users' personal information, we will notify you by email to the primary email address specified in your account. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Themis Services and this Privacy Policy to check for any changes.

Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at [email protected].