Let’s talk about your privacy
This Privacy Policy describes the policies and procedures of Upthriver. (“UPTHRIVER”, ThriveUp Management, LLC, “we”, “our” or “us”) on the collection, use and disclosure of your information on www.upthriver.com (the “Site”) and the services, features, content or applications we offer (together with the Site, the “Services”).
We collect information about you from several sources, including: (i) when you register for the Site and Services via your user account (“Account”); (ii) your general use of the Services; and (iii) third-party websites and services. Any terms not defined here are as described in the Terms of Service, available at https://www.upthriver.com/privacy.
What does our policy cover?
This Privacy Policy covers Upthriver's processing of Personal Data that Upthriver gathers when you are accessing and using the Services. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.
This Privacy Policy also applies to how Upthriver handles any Personal Data it shares with others. It does not cover the practices of third parties, including their sites, services, or apps that Upthriver does not own or control, nor does it apply to individuals not employed or managed by Upthriver (“Third Parties”). While we strive to work with Third Parties who share our commitment to privacy, we are not responsible for their content, actions, or privacy policies. We encourage you to review the privacy policies of any Third Parties you interact with.
If you reside in the European Union, United Kingdom, Liechtenstein, Norway, or Iceland, you may have additional rights regarding your Personal Data under the General Data Protection Regulation (GDPR), EU Regulation No. 2016/679, dated April 27, 2016, as described below.
If you have any questions about this Privacy Policy or whether any of the following applies to you, please contact us at support@thriveupmgmt.com
Please be aware that we may also process Personal Data on behalf of our users' customers, end users, or employees as part of providing services. In this case, we act as the data processor under the GDPR. If we are processing your Personal Data as a processor (rather than a controller), please reach out to the data controller—the user or entity providing the course, product, or service with which you shared your Personal Data—to exercise your rights regarding that data.
What Personal Data does Upthriver Collect From You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
First and last name
Email address
Billing zip code and/or country of residence
In order to collect payments on your behalf from your customers, and provide payments to you, we, using Stripe as a third-party payment processor, collect payment information from you, whom we provide payments on your behalf and from whom we collect payments on your behalf. This information is used solely to collect and provide payments related to the Services, and is only stored by Stripe. You should review the terms of service and privacy policies of Stripe, available at https://stripe.com/us/legal & https://stripe.com/us/privacy.
Information we receive from third party sources: We have built services from some third parties into the Site, and those third parties provide us with Personal Data about you, such as the following:
Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (for example, signing up for an account with Facebook Connect), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our Site and Services.
Information from our service providers: We receive information collected by third parties about your use of the Services. For example, we may use analytics service providers to analyze how you interact and engage with the Services and our advertisements, so we can learn and make enhancements to offer you a better experience. Some of these entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, which may include tracking activity across time and unaffiliated properties, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. Third parties may also help us provide you with customer support, and provide us with information so that we may help you use our Services.
Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:
IP address
Device identifiers
Web browser information
Page view statistics
Browsing history
Usage information and click tracking
Transaction information (e.g. transaction amount, date and time such transaction occurred)
Cookies and other tracking technologies (see below for more information)
Log data (e.g. access times, hardware and software information)
Additional Information about Cookies:
Our Services use cookies and similar technologies, such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively referred to as "Cookies"), to help our servers recognize your browser and understand how and when you interact with our Site and Services. This allows us to analyze trends, learn about our users, and improve our Services. Cookies are small files, typically containing letters and numbers, that are placed on your computer, tablet, phone, or other device when you visit our Site. In some cases, we may combine data collected through Cookies that is not personally identifiable with Personal Data we have about you, such as confirming your identity or verifying your account. We may also enhance the data we gather by incorporating information from third parties.
Cookies are either "session" or "persistent." Session cookies are temporary and only stored while you're on our Site. Persistent cookies remain on your device after you leave, helping us remember your preferences and track your usage over time. We use them to measure ad effectiveness and gather data about your activity after you leave our Site. While your browser may offer a "Do Not Track" (DNT) option, we do not currently support DNT requests, so we may continue to collect your activity data both during and after your use of our Services.
Some cookies are set by third parties and may share information about your browsing activity, such as the pages you visit and ads you click, with us and others. These cookies help identify your interests, track the use of third-party services, retarget ads, and display relevant ads. We do not have control over these third-party cookies.
We may use the following types of Cookies:
Essential Cookies. Essential Cookies that are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site or Services. Disabling these Cookies may make certain features and services unavailable.
Functionality Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Site and Services such as by collecting information about the number of visitors to the Site, what pages visitors view on our Site and how long visitors are viewing pages on the Site. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google’s use of cookies by visiting the Google advertising opt-out page at https://www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/ .
Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Additional information about interest-based advertisements.”
You have the option to manage your Cookie preferences through your internet browser’s settings. Most browsers offer features that let you turn off Cookies altogether, block new ones, or selectively choose which Cookies to accept. You can also remove any existing Cookies stored on your device. Please note that by doing this, some of your site preferences may need to be reset each time you visit, and certain features or services might not function as expected.
Additional information about interest-based advertisements:
We may display ads on our Services and allow third-party advertising networks—including ad servers, agencies, technology providers, and research firms—to show ads to our users. These ads might be tailored to general user profiles or specific preferences and behaviors ("Interest-Based Ads"). Information used for these ads (including Personal Data) may come from you directly or be derived from user interactions on our Services or third-party services. This data is often collected by tracking user activity over time and across different websites. To facilitate this, we or our service providers may use Cookies, including small files called "web beacons" that allow ad networks to anonymously gather and analyze data. Web beacons support ad networks in performing auditing, research, and reporting functions for us and advertisers, and they also enable ad networks to show you personalized ads on other sites. Through web beacons, ad networks can set, view, or modify Cookies on your browser as though you were visiting their own site.
The Digital Advertising Alliance (DAA) and Network Advertising Initiative (NAI), along with other media and marketing organizations, have created a self-regulatory program to help consumers understand and control ads that are personalized based on browsing activity across different sites. To manage your preferences or opt out of Interest-Based Ads from participating third-party organizations, visit the DAA or NAI opt-out pages at https://www.networkadvertising.org/choices/ or https://www.aboutads.info/choices. Users in the European Union can manage their preferences on the European Interactive Digital Advertising Alliance’s website at https://www.youronlinechoices.eu/.
We do not disclose your Personal Data to advertisers without your consent. However, if you click on or engage with an ads, the advertiser may place a Cookie on your browser, recognizing that your profile matches their chosen criteria.
How Do We Use Your Personal Data?
We process Personal Data to operate, enhance, understand, and tailor our Services. Specifically, we use Personal Data to:
Communicate with you about our Services
Safeguard against fraudulent, illegal, or harmful activities
Enable you to create and manage your digital storefront, sales pages, and online courses
Support the creation, management, and subscription of membership platforms
Facilitate the creation, management, and sale of digital files, downloads, and online courses
Notify you of Service updates, announcements, or offers
Customize website content and communications according to your preferences
Provide customer support for the Services
Identify individuals who may have an interest in our Services
Gather insights and statistical data to benefit our business operations
Meet legal or contractual obligations
Resolve disputes
Uphold our Terms of Service, including this Privacy Policy and, if relevant, the EU Data Processing Addendum
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Requirement: We process certain categories of Personal Data as it is necessary to fulfill our obligations under the Terms of Service, allowing us to provide you with the Services. If you do not provide this data, you may not be able to access or use certain features of the Services that rely on it.
First and last name
Email address
User Content (which can include Personal Data if you include Personal Data in such content)
IP address
Billing zip code and/or country of residence
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
First and last name
Email address
IP address
Billing zip code and/or country of residence
Examples of these legitimate interests include:
Protection from fraud or security threats
Operation and improvement of our business, products and services
Marketing of our products and services, directly to you and to others
Provision of customer support
Compliance with legal obligations
Completion of corporate transactions
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
How and With Whom Do We Share Your Data?
We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:
Payment processors
Fraud prevention service providers
Analytics service providers
Hosting service providers
Marketing service providers
Email providers
Staff augmentation and contract personnel
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
Social media services (if you interact with them through your use of the Services)
Third party business partners who you access through the Services, including vendors
Other parties authorized by you
We also share Personal Data when we believe it is necessary to:
Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
Protect us, our business or our users, for example to enforce our Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Maintain the security of our products and services.
As part of the Services, you will receive email and other communications from Upthriver. By using the Services, you agree to allow Upthriver to send you emails and communications related to your use of the Services, as determined by Upthriver at its discretion.
We also share information with third parties when you provide consent. Additionally, if we decide to buy or sell assets, user information may be transferred as part of those transactions. In the event we are acquired, go out of business, or enter bankruptcy, user information could be transferred to a third party acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer may continue to use your Personal Data as outlined in this policy.
How Long Do We Retain Your Personal Data?
We retain Personal Data as long as you have an active account or as necessary to provide you with Services. In some cases, we may retain Personal Data longer to comply with legal obligations, resolve disputes, or collect fees. After this period, we may keep some information in a depersonalized or aggregated form, without identifying you personally.
What Security Measures Do We Use?
We aim to protect Personal Data by applying technical and organizational safeguards appropriate to the type of data and its processing requirements. It’s important for you to help secure your Account and Personal Data by choosing a strong password, protecting it, and limiting device and browser access by logging out when you finish using your Account.
We strive to maintain the privacy of user account information, but we cannot guarantee complete security. Factors like unauthorized access, hardware or software issues, or other unexpected events may impact the security of user data at any time.
Do We Store the Personal Data of Children?
As noted in the Terms of Service accessible at https://www.upthriver.com/privacy
we do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at support@thriveupmgmt.com.
What Do Users in the European Union Need to Know?
Your Rights Regarding Personal Data
Access: You have the right to request details about the Personal Data we hold about you, including a copy. Some of this data may be accessible by contacting us at support@thriveupmgmt.com.
Correction: If any of your Personal Data is inaccurate or incomplete, you can request updates by emailing support@thriveupmgmt.com. You may also update certain information directly through your account settings.
Deletion: You may request the deletion of some or all of your Personal Data from our systems.
Withdraw Consent: If your data is processed based on consent, you can withdraw this consent at any time. Note that you may need to provide consent again on a case-by-case basis to access certain Services.
Data Portability: You can request a copy of your data in a machine-readable format, and, where possible, request that it be transferred to another service.
Objection: If you object to specific uses of your data, such as for direct marketing, you can inform us to limit or cease this processing.
Restrict Processing: You may request a limitation on the processing of your Personal Data in certain situations.
File a Complaint: You have the right to file a complaint with the data protection authority in your country or EU Member State regarding our data practices.
For any of these requests, please reach out to us at support@thriveupmgmt.com.
Transfers of Personal Data
What If You Have Questions Regarding Your Personal Data?
If you have questions about this Privacy Policy or our data practices, please reach out to us at:
Thrive Up Management
Email: support@thriveupmgmt.com
Location: Tybee Island, GA
Privacy Policy Updates
Thrive Up Management may update this Privacy Policy periodically. Information we collect is governed by the Privacy Policy in effect at the time of use. If we make any significant changes to how we handle Personal Data, we will inform you by posting a notice on our Site or Services or by sending an email. By continuing to use our Services after these changes are posted, you agree to the updated Privacy Policy.