Privacy Policy

1. Commitment to Privacy and Data Protection

At Thinking Clarely (“we,” “us,” or “our”), accessible at thinkingclarely.com, your privacy and the protection of your personal data are of paramount importance. We are committed to maintaining the confidentiality, integrity, and security of the personal information entrusted to us. This Privacy Policy outlines how we collect, use, store, protect, and disclose your data in accordance with applicable data protection laws, including the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

2. Scope of Policy and Data Controller Role

This Privacy Policy governs the data processing activities in connection with the website thinkingclarely.com and any related services or communications. Thinking Clarely operates as the data controller for all personal data collected through or in relation to our services. This means we determine the purposes and means of processing your personal data. If you have any questions about this Policy or our data practices, you may contact us at [email protected].

3. Categories of Data Processed

We may collect, use, and store the following categories of personal data, depending on your interaction with our website and services:

a) Usage Data
This includes information about how you interact with the website, such as IP address, browser type and version, operating system, referral sources, device identifiers, pages visited, visit duration, and session characteristics.

b) Account Data
Data you provide when creating or managing an account, including your full name, email address, mailing address, phone number, and password credentials.

c) Profile Data
Details about your preferences, browsing behavior, purchase history, interests, feedback, and survey responses.

d) Communication Data
Records of your communications with us, including support queries, contact form submissions, and customer service exchanges.

e) Technical Data
Information from your device environment, including device type, operating system, language settings, and browser configurations that help us improve compatibility and performance.

f) Transaction Data
Details related to any purchases made on thinkingclarely.com, such as order details, billing and shipping information, and payment confirmations. Payment data is handled by our trusted payment processors and is subject to their privacy terms.

g) Preference Data
Information regarding your choices related to marketing communications, notification settings, interest categories, and opt-in or opt-out status for promotional messages.

4. Legal Bases for Processing

We rely on the following lawful bases under GDPR to process your personal data:

– Consent: You have given explicit permission for us to process your data for one or more specific purposes (e.g., marketing communications).
– Contract: Processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract (e.g., account registration, purchase fulfillment).
– Legal Obligation: Processing is necessary to meet our legal or regulatory obligations.
– Legitimate Interests: Processing is necessary for our legitimate interests, provided these are not overridden by your data protection rights. This includes business analytics, website optimization, fraud prevention, and service improvement.

Under the CCPA, we do not sell your personal information. We use your information strictly to provide you with requested services, communicate effectively, and enhance our offerings.

5. Your Rights

Subject to applicable law, you may have the following rights regarding your personal data:

– Right of Access – Obtain confirmation and access to your data held by us.
– Right to Rectification – Request correction of inaccurate or incomplete data.
– Right to Erasure – Request deletion of your data where no legal ground exists to retain it.
– Right to Restriction – Request processing of your data be limited under certain circumstances.
– Right to Data Portability – Receive your data in a structured, commonly used, machine-readable format and have it transferred to another controller.
– Right to Object – Object to our processing based on legitimate interests or for direct marketing.
– Right Not to Be Subject to Automated Decision-Making – Including profiling, where it produces legal effects.

To exercise any of these rights, please contact us at [email protected].

6. Security Measures

We implement appropriate organizational and technical measures to protect your data against unauthorized access, loss, alteration, or disclosure. These include, but are not limited to:

– Encryption of data in transit and at rest
– Role-based access controls and authentication
– Regular data backup procedures
– Routine security audits and monitoring
– Employee training on data privacy responsibilities

Despite our efforts, no internet transmission is 100% secure. We advise users to exercise caution when sharing personal information online.

7. International Transfers

Your data may be processed or stored in countries outside of your jurisdiction, including those that may not have the same level of data protection obligations. Where applicable, we implement appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, or ensure data transfers occur only to jurisdictions deemed adequate under GDPR. We comply with all relevant regional laws concerning international data transfers.

8. Data Retention

We retain your personal data only for as long as is necessary for the purposes for which it was collected, including to satisfy applicable legal, accounting, or reporting requirements. Specific retention periods may include:

– Account and Profile Data: Retained for active account duration + 5 years, or until request for deletion
– Transaction Data: Retained for 7 years to comply with financial and tax recordkeeping laws
– Communication Data: Retained for 3 years following the last interaction
– Technical and Usage Data: Retained for 12–24 months for analytical and security purposes
– Preference Data: Retained until withdrawal of consent or modification of preferences

Once the applicable retention period has expired, data is securely deleted or anonymized.

9. Cookie Policy

thinkingclarely.com uses cookies and similar tracking technologies for the functionality and improvement of our website. The types of cookies used include:

– Essential Cookies: Enable core website features and prevent fraudulent activity
– Functional Cookies: Remember user settings and preferences
– Analytics Cookies: Help us understand user behavior, traffic sources, and performance
– Performance Cookies: Monitor system performance and detect technical issues

These cookies do not contain personally identifiable information, and we do not use cookies for advertising or cross-site tracking purposes.

10. Cookie Management and Compliance

Under GDPR and CCPA, users have the right to choose whether to accept non-essential cookies. You can manage your cookie preferences using our cookie consent tool available on the website. Additionally, you can adjust your browser settings to refuse, accept, or delete cookies. Declining certain cookies may impact some features of your browsing experience.

Our cookie implementation respects Do Not Track (DNT) signals and enables opt-out mechanisms consistent with applicable regulations.

11. Children’s Privacy

We do not knowingly collect or solicit personal data from children under the age of 13. If you believe that a child has provided us with personal data without proper consent, please contact us immediately at [email protected]. Any such data will be deleted promptly upon verification.

12. Policy Updates and Notifications

We reserve the right to amend or update this Privacy Policy at our discretion to remain compliant with evolving legal, regulatory, or operational obligations. Material changes will be communicated via notices on thinkingclarely.com or via email where appropriate. Continued use of our services after such updates signifies acknowledgment and acceptance of the updated policy.

13. Contact

For any questions, concerns, or requests related to this Privacy Policy or your personal data, you may contact us at:

Email: [email protected]
Website: https://thinkingclarely.com

We are committed to maintaining the highest standards of privacy and data protection. If you believe your data protection rights have been violated, you also have the right to lodge a complaint with a supervisory authority in your jurisdiction.