Privacy Policy

THINX wants to give you the best THINX experience possible. This Privacy Policy (this "Policy") describes the privacy practices of Thinx Inc. as well as our family of affiliated companies ("THINX", "we", or "us") with respect to information collected when you sign up for, use, access or otherwise interact with shethinx.com or iconundies.com (the "Sites") and any online services and products of THINX, including mobile applications and websites or applications operated by THINX and connected products and services (collectively, including the Sites, the "Services") that reference this Policy, and how we use and share that information. By using the Services (including the Sites) you consent to the terms of this Policy.

As you read this Policy please click " read more" for additional details on a topic. You can reach us at service@shethinx.com or the postal address in the "How to Contact Us" section below if you have further questions.

BY USING THE SERVICES YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY.

Personal Data we collect may be stored and processed in the United States or any other country in which THINX or its affiliates, subsidiaries, agents, or third party service providers maintain facilities and/or infrastructure, and by using the Services and submitting information to us, you consent to the transfer, processing and storage of such information outside of your country. Note that the United States is a jurisdiction in which the data protection regime may not provide the same level of security as those in the nation where you reside. Unless applicable law requires different security and protections to be applied in any given relevant jurisdiction, we apply the same principles in using, handling and transmitting data as described in this Privacy Policy in all of our operations. If you do not agree with any part of this Privacy Policy or our Terms and Conditions, please do not access or continue to use any of the Services or otherwise provide your Personal Data.

I. Information We Collect

THINX collects information from users in connection with the Services.

We collect both Personal Data and Non-Personal Information. "Personal Data" means information that relates to you and identifies you personally, either alone or in combination with other information available to us. Examples of Personal Data are a name, an online identifier, a contact address, social media reviews and ratings, and precise Location Data. "Non-Personal Information" means information that is aggregate, anonymous, practicably de-identified, or otherwise does not reveal your identity. Some examples could include age, annual income, gender, browser, IP addresses, hardware model, operating system and version, time spent using our Services, web pages visited, and advertising identifiers (such as the Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID)).

We collect your Personal Data and Non-Personal Information as follows:
  1. If you register for a THINX account, install or use our mobile apps, or place an order, we collect directly or indirectly
  2. When interacting with our Services, data is automatically collected by the technology
  3. If you engage with us through a social media account,
  4. If you are accessing third-party products and services that we have made available to you via the Services,
  5. When you purchase or browse THINX products online,
  6. When you shop at THINX pop-up stores, we may collect contact and purchase information.
  7. If you participate in or utilize, as applicable, contests, sweepstakes, loyalty programs, surveys, discounts, or promotional sales ("Promotions") being offered by THINX,
  8. We collect Personal Data relating to your interactions with advertising on the Services or THINX online communities.
  9. We allow our trusted ad partners to collect information about you when you use our Services.

II. How We Use Your Information

We use the information we collect to:
  1. Provide our products and services and customer support
  2. Customize experiences on our Services and gain insights into our customers and communities
  3. Promote THINX's business through direct mail and online advertising and marketing activities to you and others
  4. Connect you with third-party products and services
  5. Communicate with you
  6. Administer Promotions
  7. Operate and analyze our business
  8. Resolve security issues and disputes
  9. Resolve security issues and disputes

III. How We Share Your Information

THINX will share your Personal Data and Non-Personal Information with third parties in the following ways:
  1. To Partners and Suppliers
  2. To Partners and Suppliers
  3. With Social Networks
  4. For Joint Marketing
  5. In Discussion Forums
  6. In Business Transfers (country specific disclosures may apply)
  7. With Your Consent
  8. For Legal Compliance and Special Circumstances

IV. Data Security

THINX takes precautions to secure your personal information and protect it from loss, theft, unauthorized access, destruction, use, modification and disclosure. Such measures include technological, physical and organizational safeguards that are appropriate given the sensitivity of the personal information, including maintaining controlled access to electronic and paper documents and files, and using appropriate technology safeguards such as passwords firewalls and encryption as well as non-disclosure or confidentiality agreements as we deem appropriate to protect your data. However, please note that THINX's security measures may change or be unavailable from time to time and no data transmission over the Internet or any wireless network is 100% secure.

V. Data Retention

THINX will retain Personal Data for so long as it continues to be useful in connection with providing or improving THINX's Services and product offerings and this Policy, except if required otherwise by applicable law. We may further retain and use data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

VI. Cookies and Other Data Collection Tools

THINX and its partners use various technologies to collect information when you use our Services, including sending cookies to your device and using web beacons. By using the Services you consent to the use of such technologies, including cookies and pixel tags, to collect information about you. These technologies help us personalize your use of our Sites and mobile applications, customize the Services, and mitigate risks and the potential for fraud. These technologies are also used by THINX and its advertising partners to deliver ads to you based on your interests and online activities.

  1. How We Use Cookies
  2. We Use Third-Party Cookies
  3. How We Use Web Beacons
  4. Do Not Track Browser Signals

VII. How To Manage Your Privacy Settings

We provide you several ways to manage your privacy settings:
  1. Update your Account Information
  2. Set your preferences to opt-out of communications
  3. Opt out of information exchange with other marketers
  4. Manage your Location Data through your mobile device

VIII. Children

The Services are intended for general audiences and is not directed to persons less than 13 years of age and we do not knowingly collect Personal Data from those persons. If you become aware that personal information about your child has been provided to THINX without your consent, please contact us. If we become aware that a child under 13 has provided us with Personal Data, we will take steps to delete the information, except where we are required by applicable law to keep it.

IX. Region-Specific Disclosures

  1. Residents of Canada
  2. Residents of the European Economic Area

THINX Inc. adheres to the EU-U.S. Privacy Shield Framework ("Privacy Shield") issued by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member states. For EU Personal Data received in the United States under the Privacy Shield, THINX adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability. If there is any conflict between the standards of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles govern. Under the Onward Transfer Principle, we may remain liable for the processing of European Personal Data that we transfer to our third-party agents or service providers. In some instances, we may also be required to disclose Personal Data to comply with valid requests from public authorities, including for national security or law enforcement purposes. In compliance with the Privacy Shield, THINX commits to resolve your complaints concerning data privacy and our collection or use of your Personal Data. We welcome you to bring any concerns directly to us at our Support Team. Eligible unresolved privacy complaints related to violations of the Privacy Shield Principles can be reported to JAMS, an alternative dispute resolution provider located in the United States and Canada. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by THINX, THINX will cooperate with JAMS pursuant to the JAMS Privacy Shield Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or you may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers. Under certain circumstances, you also may be able to invoke binding arbitration to address complaints about THINX's compliance with the Privacy Shield Principles.

Residents of California, United States Under law California residents have the right to periodically (typically once per calendar year) request information relating to the information we disclose to third parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us through our Support Team or at the mailing address below.

X. Third Parties We Don't Own or Control

This Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. For example, if you choose to pay through a third-party mechanism offered on our website, the information you choose to share with that third-party will be treated in accordance with that third-party's privacy policy. This Policy does not apply to, and we are not responsible for, for the content of such third party features or the privacy practices, including third-party cookies, web beacons, or other tracking technologies, of such third parties. We encourage you to read the privacy policies of each and every device, website, and service that you use.

XI. How to Contact Us

THINX welcomes questions and comments about this Privacy Policy. You can contact us by emailing us at service@shethinx.com or writing to us at:

THINX INC.

Attention: Privacy Office

601 W. 26th St. #515

New York, NY USA 10001

XII. Amendments

We may change this Policy from time to time. The most current version of this Policy will be effective at the time it is posted. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Policy. If you have a registered account, we may notify you of any changes to our Privacy Policy via email and/or we may ask you to affirmatively acknowledge and consent to the changes the next time you use our Services.