Thoughtfull Privacy

At Thoughtfull, our goal is to be the world’s destination for thoughtful gifting.

 

We are privileged to have you as a user of our services. We understand how important trust is in a relationship. To earn and maintain your trust, we have created resources to help you understand our practices with respect to the personal information we collect, use and disclose.

 

Below, you will find our Guiding Principles. These provide you with a summary of key information about privacy at Thoughtfull. The Thoughtfull Privacy Notice that follows provides you with detailed information about how we handle personal information. Thoughtfull is also part of the Indigo Books & Music Inc. family. If you need information about Indigo, you can find the Indigo Privacy Policy at www.indigo.ca/privacypolicy.

 

Privacy Guiding Principles

1)   We want to delight you with our services and our insights 

We strive to be as transparent as we can about how we use your information to deliver the services and to help us improve our recommendations so that we can make thoughtful gifting easy and joyful for you and your gift recipient.

 

We collect information about you and information that you provide us about your gift recipient in order to provide you with gift recommendations, transmit your orders to our merchants, and process your payments on behalf of the merchants. When you give us information about a gift recipient, you are agreeing on their behalf to how we use that information. We will also collect information about you to set up your account if you choose to create one.

 

We also want to delight you with insights about your gift giving and your recipients. To do that, we also use information about you, your gift recipients and your transactions in order to learn more about how we can improve, what you like and don’t like, how we can make better, more personalized and more timely recommendations, and ultimately what works and doesn’t work in our services. Learn more in our Privacy Notice.

 

2)   We expect our merchants to meet our high standards

When you purchase a product or experience from a merchant on Thoughtfull.co, we transfer certain information to the merchant so that the merchant can fulfill your order. Merchants should meet our high standards in handling the personal information we transfer to them. We want to hear about it if they are not meeting your expectations.

 

When you purchase a gift, you are buying directly from the merchant. We process the payment on behalf of the merchant and transmit your order information to the merchant on your behalf. If you have the gift delivered, the merchant is responsible for fulfilling your order, including shipping the gift to you or your gift recipient. The merchant may be in a country other than the one in which you reside. Our merchants are responsible for explaining their privacy practices and for responding to your requests to access your personal information or the exercise of your other legal rights. We do not control the practices of our merchants. However, please contact us at the address below or by email at privacy@thoughfull.co if you have feedback on the privacy practices of one of our merchants. Learn more in our Privacy Notice

 

3)   We will be respectful of you when we share information with the Indigo Books & Music family

We will exchange information with other members of the Indigo family in a way that helps us serve you and our other customers better.

 

We do not share or receive information from other parts of the Indigo family for the purpose of building a profile about you. For example, Indigo does not share with us your Indigo loyalty program information. However, we do leverage certain Indigo services that require us to share your information, including customer service support. Information is also shared with Indigo for aggregated, non-identifiable data analytics and insights. For example, we share and receive information about when a visitor browses between Thoughtfull.co and another Indigo site. We also share information on an aggregated or statistical basis about how visitors use our services. In the future, we may offer you the opportunity to link your accounts and share purchase histories between Thoughtfull and the rest of the Indigo family. Learn more in our Privacy Notice

 

4)   We are accountable for our service providers

Like most businesses, we use third party service providers to assist us in our business operations. Our service providers may collect, use, process or transfer personal information on our behalf. We take responsibility for requiring our service providers to meet our high standards.

We use service providers to provide us with computing infrastructure and software, marketing and advertising services, and payments services. We remain responsible when our service providers collect, use, process or transfer personal information on our behalf. Learn more in our Privacy Notice

Merchants are not service providers to us. Merchants are the sellers of the products and experiences on Thoughtfull.co. Learn more in our Privacy Notice

 

5)   We provide you with choices 

We earn your trust by honouring your choices to opt-out of non-essential data collection and use.

We provide you with opportunities to opt-out of our promotional emails and text messages as well as our targeted online advertising using personal information you provided to us. You may also choose to use our services without registering for an account or without providing us information to curate a gift selection for you. Learn more in our Privacy Notice

 

6)   We help you exercise your rights

Whether you are using our services to purchase a gift or you are the gift recipient, we will help you exercise your right to access your personal information that we hold about you and to exercise other legal rights you may have regarding our use of your personal information.

We are committed to transparency. If you have registered for an account, you can view your transaction history and view and correct your basic profile information by logging into your account. If you would like to access or correct other information or exercise other rights, you can contact us by email at privacy@thoughfull.co or write to our Privacy Officer at Thoughtfull, 620 King Street West, Suite 400, Toronto, Ontario, M5V 1M6. Learn more in our Privacy Notice

 

Thoughtfull Privacy Notice

Date: September 18, 2019

 

Our goal is to be the world’s destination for thoughtful gifting. To earn and maintain your trust, this Privacy Notice provides you with answers to questions about how Thoughtfull (a division of Indigo Books & Music Inc.) handles your personal information.

If you are under the age of 13, Thoughtfull.co is not for you. If you are under the age of majority in your place of residence, please only use Thoughtfull.co with a parent or guardian. Certain products and experiences on Thoughfull.co are restricted to only those visitors of age of majority.

In this Privacy Notice, “we” or “us” refer to Thoughtfull, including our service providers when they are acting on our behalf. When we refer to “you”, we mean visitors to our website Thoughtfull.co.

When we refer to “Indigo” we mean Indigo Books & Music Inc., its subsidiaries, and their websites, mobile applications and retail stores (which includes stores operating under the banners Indigo, Chapters, Indigospirit, Coles and The Book Company) other than Thoughtfull.co. If you are also a customer of Indigo, please see the Indigo Privacy Policy at www.indigo.ca/privacypolicy.

 

1)   What are Thoughtfull’s services?

We help you select and purchase meaningful gifts for recipients you care about. Using our proprietary technology, processes and know-how, we are able to curate gift recommendations based on information you provide to us about you and the gift recipient.

If you like what we recommend, you can purchase your gift from one of our independent merchants that has been selected by us to offer products and experiences to Thoughtfull.co visitors. We will process your payment and facilitate your transaction with the merchant. However, the merchant, and not us, is the seller of the product or experience that you purchase.

We use third party service providers to deliver the services. For example, we use third parties to host our website and databases, provide us with software, and to facilitate processing of payments.

 

2)        Does this Privacy Notice apply to merchants on Thoughtfull.co?

Our merchants are independent businesses offering their products and experiences through Throughtfull.co. Although we require our merchants to comply with applicable laws and we expect our merchants to meet our high standards for privacy and security of your personal information, we do not control the merchants from whom you make a purchase. Our merchants may also use third party service providers to fulfill your order, including, for example, shipping companies who will receive your, or your gift recipient’s, contact information in order to make a delivery. We encourage you to familiarize yourself with the privacy policies provided by our merchants prior to making a purchase.

 

3)        What personal information about you do we collect and how do we use it?

We use personal information that is about you as an identifiable individual as well as information that is automatically collected but that does not identify you. We also use personal information that you provide us about your gift recipients. By providing us with that information, you consent to the collection and use of it in accordance with this Privacy Notice.

 

Account Registration Information

  • You can use our services without registering for an account. If you create an account, we will collect your first name, last name, email address, and all shipping addresses used for your purchases.
  • We use this information to communicate with you, to manage your order history, to manage your wish lists and favourites, to prepopulate payment information and to enhance your profile with insights regarding your use of the curated gift recommendations. For more information, please see “What are data analytics and insights?”

 

Curated Recommendations Information

  • This is the information that you provide us about your gift recipient and our curated gift recommendations. This information also includes how you interacted with our curated gift recommendations and whether you placed an order.
  • We use Curated Recommendations Information to provide you with the curated gift recommendations and to perform data analytics and gather insights regarding your use of the curated gift recommendations. For more information, please see “What are data analytics and insights?”

 

Order Information

  • When you order a product or experience, we will collect information about the product or experience (such as price, quantity, description) and delivery information (which may include information about the gift recipient if you have the gift delivered). We will also collect information from the merchant about when they accepted your order as well as shipping or delivery details.
  • We use and share this information to facilitate your order, to maintain a history of your transactions, to monitor the performance of our merchants, and to perform data analytics and gather insights regarding your orders and our merchants. For more information, please see “What information about you do we share with merchants?” and “What are data analytics and insights?”

 

Gift Recipient Information

  • When you use our Curated Recommendations Feature you will provide us with information about your gift recipient, such as their name and interests. Although you can use a nickname for your gift recipient when using our recommendations features, you will need to provide us with your gift recipient’s name and relevant contact information when arranging for delivery to the gift recipient.

 

Payment Information

  • We collect your credit or debit card type, number, expiration date and CVV code in order to process payments and refunds on behalf of the merchant. If you have previously used Shopify Payments, you may permit Shopify to provide us with this information on your behalf.
  • We do not share Payment Information with the merchant. However, in order to process payments and refunds, we share your Payment Information with payment card networks and your credit or payment card issuer.

 

Customer Service Information

  • If you make an inquiry or a complaint (including via social media), we collect the information you provide to us, as well as any additional information we collect during our research, in order to investigate, analyze and respond to your inquiry or complaint. We will also use this information to perform data analytics and gather insights regarding what issues visitors are having with our services or merchants.
  • It may be necessary for Thoughtfull and the merchant to share information when we conduct research with respect to your complaint. For more information, please see “What information about you do we share with merchants?” and “What are data analytics and insights?”

 

Usage Information

  • As you browse and use Thoughtfull.co, we collect Usage Information, which includes the IP address assigned to your internet connection by your internet service provider, device information, your general location, the referring/exit pages, clickstream data (your activities on our site), and other technical information that is automatically captured as you use Thoughtfull.co. Generally, this information will not be personal information (information about you as an identifiable individual) unless we combine it with other information about you. We use this information to ensure that the website pages you are show are correctly formatted for your browser and device, to show you pricing in the relevant region where you are browsing and for other technical purposes. We also use this information to perform data analytics and gather insights regarding what issues customers are having with our services or merchants. For more information, please see “What are data analytics and insights?” For information on how to opt-out of these third-party services, please see “What are your rights and choices?”

 

Marketing Response Information

  • We use cookies, pixel tags, web beacons and other similar technologies to track engagement with our online advertising and email marketing campaigns. We may use and combine this information with your Account Registration Information, Curated Recommendations Information, Customer Service Information and Usage Information to create Marketing Response Information. We use Marketing Response Information to provide you with a selection of products and experiences that will be more relevant to you and to the person you are shopping for and to provide you with advertising that we think will interest you. For more information, please see “What are data analytics and insights?”
  • We may use third party platforms to help us promote interest-based advertisements. This may include converting the e-mail address, phone number or other contact information you have provided to us into a unique value that these platforms may compare to a unique value created on their platforms in order to identify you as part of an intended audience for our advertisements. For more information, please see “How do I opt-out of interest-based advertising?”

 

Social Media Information

  • We may collect information through social media when you mention us or our services or tag us or use one of our hashtags in your posts. We only collect this information if your privacy settings permit us to see your post. We use this information to understand what our visitors, customers and clients are sharing. We do not combine this information with other information about you unless we are helping you with a complaint or an inquiry.

 

Fraud Detection and Other Investigations Information

  • Fraud Detection and Other Investigations Information may include your Account Registration Information, Order Information, Payment Information, Customer Service Information, Usage Information and information we collect during an investigation into a potential breach of our Terms of Use. We use Fraud Detection and Other Investigation Information in order to detect and prevent fraud, to protect our security, the security of our services and of our merchants, and to enforce our legal rights and those of our merchants.

 

4)        What personal information do we share with merchants?

If you purchase a product or experience from a merchant using Thoughtfull.co, we will share your Order Information with the merchant, as well as whether your payment was successful so that the merchant can process your order. We do not share details of your payment card with the merchant or information about purchases you have made with other merchants. If the merchant will be shipping the gift to your gift recipient, we will also provide the gift recipient’s contact information.

If you require customer assistance or you have a dispute with the merchant or us regarding a product or experience you purchased, Thoughtfull and the merchant may share Customer Service Information relevant to the service request or dispute in order to address the issue.

In limited situations, we may share Fraud Detection and Other Investigations Information with a merchant in order to detect or prevent fraud, to protect the security of Thoughtfull, our services, or our merchants, or to enforce our legal rights or to assist the merchant in enforcing the merchant’s legal rights.

 

5)        What personal information do we share with Indigo?

We are part of the Indigo family. Indigo Books & Music Inc. (“Indigo”) and its subsidiaries operate Thoughtfull.co, Indigo.ca and stores operating under the banners Indigo, Chapters, Indigospirit, Coles and The Book Company. Although Indigo is ultimately in control of the information collected by Thoughtfull, we have implemented procedures to limit the internal sharing of information about you as an identifiable individual.

We do not share information about you with other members of the Indigo family for the purposes of building a profile of you. However, in the future, we may offer you the opportunity to link your accounts and share purchase histories between Thoughtfull and the rest of the Indigo family.

We share and receive limited Usage Information when visitors move between Thoughtfull.co and another Indigo site. We also use and share aggregated or statistical information that we derive from data analytics performed on Account Registration Information, Order Information, Customer Service Information, Usage Information and Marketing Response Information. See “What are data analytics and insights?”

 

6)        Who else do we share your personal information with?

We share information with your gift recipients if you request delivery to a gift recipient or a gift recipient makes an access request. We may also share information with third parties for operational and legal purposes.

 

To facilitate payments

We share information with Shopify Payments and payment card networks in order to process payments and refunds.

 

To inform your gift recipient who purchased their gift

If we or the merchant will be shipping the gift to your gift recipient, we will let the gift recipient know who sent their gift (we don’t permit anonymous gifting). We will also respond to requests by gift recipients for access to their information on file.

 

To service providers in our operations

We share information with our service providers who host our website and databases and who provide us with software. These service providers may collect information to facilitate functionality on our website, such as dynamic currency conversions, payments, and other features. These service providers will have access to your information for those purposes. Although these service providers are usually restricted to processing personal information for the purposes of performing their obligations under our agreements with them, they may also have the right to use your information if you already have a relationship with them. For example, we use Shopify apps to power our online marketplace. You may already have a relationship with Shopify through Shopify Payments. If you do, Shopify may use your information to prepopulate payment information on our site.

 

To facilitate data analytics

We also share your information with our service providers who perform data analytics and gather insights regarding your use of the website and to assist our efforts to optimize the platform, including providing you with curated gift recommendations. These service providers will have access to your information only for those purposes. See “What are data analytics and insights?”

 

For online advertising

Like other companies, we may display interest-based ads to you when you are using browsing other websites or use social media, such as Facebook, Instagram and Twitter. We may do this by using third party interest-based advertising partners who will show you advertisements from us because of your browsing history on Thoughtfull.co or other Indigo websites. To learn about how you can opt-out, see “How do you opt-out of interest-based advertising?”

We may also ask social media sites to show you advertisements based on the fact that you have an account with Thoughtfull.co and that social media site. For example, Facebook may show you advertising after we use tools that Facebook makes available to us that allows us to convert your e-mail address or telephone number that you provided to us to a unique number that Facebook uses to match to unique numbers that Facebook generates from information you provided to Facebook. You may opt-out of customized ads by adjusting your Facebook Ads setting on Facebook or selecting “Why am I seeing this” in the Facebook Ad from Thoughtfull. Other social media providers offer similar tools.

 

If we are legally obligated to disclose information

We will share your personal information if we believe we are required to do so in order to comply with a legal obligation under applicable law including a search warrant, a court order, or a subpoena

 

To assist law enforcement, investigations and to prevent harm

We also will share your personal information if we are permitted to do so under applicable law and it is relevant to national security, law enforcement, litigation, criminal investigations, protecting the safety of any person, or to prevent damage to property, death or imminent bodily harm.

 

For a business transaction

We may share your personal information to a buyer or prospective buyer of the Thoughtfull business or of Indigo or as part of a corporate reorganization transaction.

 

7)        Do we transfer your personal information to other countries?

Your personal information may be stored, accessed or processed in Canada, the United States and other countries where Thoughtfull has service providers. Thoughtfull uses contractual or other means to provide comparable protections for your personal information in other countries and to comply with any applicable laws regarding the transborder transfer of your personal information. However, the laws of jurisdictions where your personal information is stored, accessed or processed may be different from those where you reside, and your personal information may be available to government authorities under lawful orders and laws applicable in those countries.

Your personal information will also be transferred to the merchant from which you purchased a product or experience who may be located in another country or who may have servicer providers in another country. Please also see “Does this Privacy Notice apply to merchants on Thoughtfull.co?”

 

8)        What are data analytics and insights?

Data analytics involves processing elements of data collected about visitors to Thoughtfull.co to derive information about how our visitors use our services and to inform decisions about how to improve our services or develop new services. When we perform data analytics, we are interested in trends rather than how you use our services in particular. For example, we may want to understand how our users make gift giving decisions for specific occasions or based on certain types of relationships.

We may also gather insights from personal information that we collect about you. When we gather insights, we are analyzing how we can provide you with a better and more personalized experience using Thoughtfull.co. For example, we may use information we have collected about you to provide you with a selection of products and experiences that will be more relevant to you and to the person you are shopping for as well as to provide you with advertising that we think will interest you.

9)        What are your rights and choices?

We believe that our curated gift suggestions will be better and more personalized the more information you share with us. However, you can explore Thoughtfull.co without providing us with your name and contact information. You can access our curated gift suggestions without giving us the real name of the person you are shopping for. However, we require identifiable information about you if you wish to place an order or create an account and we require identifiable information about the individual you are shopping for if you want the merchant to deliver the gift to that person.

 

You have rights and choices regarding the information we collect.

 

Marketing Choices

  • You can opt-out of receiving promotional emails, text messages, telephone calls, and mailings by modifying your promotional preferences in your account profile management section, adjusting your text and notification preferences in your mobile device's settings, or by following the opt-out instructions in the promotional emails we send you. You can also contact us by email at privacy@thoughfull.co or write to our Privacy Officer at Thoughtfull, 620 King Street West, Suite 400, Toronto, Ontario, M5V 1M6.
  • For information on opting-out of interest-based advertising, please see “How do I opt-out of interest-based advertising?”

 

Third Party Analytics Providers

  • Many analytics providers allow you to opt out from the collection of your information. For example, you can opt-out of Google Analytics by installing the Google Analytics opt-out browser add on (available at tools.google.com/dlpage/gaoptout). To opt-out of Adobe Omniture, visit the Adobe Privacy Centre (at www.adobe.com/ca/privacy/opt-out.html). If you opt-out, these providers will not share information with us, but it will not affect other use of your Usage Information by us.

 

Access and Correction

  • You have the right to request access to the personal information that we have collected about you. If we have recorded incorrect information about you, you can ask that we correct or rectify that information. To make an access or correction request, email us at privacy@thoughtfull.co or write to our Privacy Officer at Thoughtfull, 620 King Street West, Suite 400, Toronto, Ontario, M5V 1M6.

 

Deletion and Erasure

  • You may request that we delete or erase your personal information, unless we are legally permitted or required your personal information such as: (i) if there is an outstanding order, complaint, or dispute; (ii) to fulfill legal, tax, audit, and accounting obligations or (iii) if we anonymize it. To make a deletion or erasure request, email us at privacy@thoughtfull.co or write to our Privacy Officer at Thoughtfull, 620 King Street West, Suite 400, Toronto, Ontario, M5V 1M6.

 

10)        How do you opt-out of interest-based advertising?

We use service providers to display advertising to you that is based on your online activities across websites and online applications. You can click the AdChoices icon or visit www.youradchoices.ca (Canadian visitors), or www.aboutads.info (U.S. visitors), or information on interest-based advertising or to opt-out of receiving interest-based advertising using your personal information. You can also visit www.networkadvertising.org/choices for opt-out options for Network Advertising Initiative member companies.

 

11)    How long do we retain personal information?

We retain your personal information for no longer than is reasonably necessary for the purposes for which we collected it or as required by law. How long we keep your personal information depends on the type of information and the purpose for collection.

If you have created an account with Thoughtfull, we may retain your Account Registration Information, Order Information, Payment Information, Customer Service Information and Fraud Detection and Other Investigations Information for as long as your account remains open. For other personal information and, if you have not created an account, the criteria we use to determine the retention period for certain categories of personal is as follows:

  • whether the information is still relevant for the purposes for which we collected it;

  • whether there are contractual obligations that exist that require us to retain the data for period of time;

  • whether there is any ongoing legal claim that relates to any product or experienced purchased by you from a merchant, or that is otherwise related to your relationship with us; and

  • whether any applicable law, statute, or regulation allows for a specific retention period.

12)    How do we secure your personal information?

Security of your personal information is a shared responsibility. If you create an account, we encourage you to use a unique and strong password. You should be careful if you receive unexpected emails from senders. We will never ask you for your payment card or other financial information by email or text message. If you receive an email from us asking you to log into your account, please check the website address carefully to ensure that you are logging into Thoughtfull.co.

We use (and we require our service providers to use) physical, technical and organizational security measures designed to help protect the security of the personal information we collect. We limit access to those employees, contractors, agents and merchants with a need to know. However, please note that no system is ever completely secure.

We are not responsible for the security practices of merchants on the Thoughtfull.co marketplace. Although we expect our merchants to use appropriate measures to safeguard your personal information, you should review the privacy policy of the merchant from whom you are purchasing a product or experience for information on their privacy and security practices.

 

13)    Do we collect personal information from children?

Thoughfull.co is not intended to be used by children under the age of 13. Children between the age of 13 and the age of majority in their place of residence should only use Thoughtfull.co with the supervision of a parent or legal guardian.

Even though Thoughtfull.co is not intended to be used by children under the age of 13, we may collect personal information of a child under the age of 13 if the child is a gift recipient and the person sending the gift provided us with the child’s personal information as part of our Curated Recommendations Feature or for the purposes of arranging shipping. If you are a parent or guardian and believe we may have collected information about a child and would like us to delete it, please contact us at the addresses below.

 

14)    Who do you contact with questions, comments or concerns?

We welcome your questions, comments and concerns about privacy. You can email us at privacy@thoughtfull.co or write to our Privacy Officer at Thoughtfull, 620 King Street West, Suite 400, Toronto, Ontario, M5V 1M6.

 

15)        Updates and Changes

We may update or change these Privacy FAQs as our practices or laws changes or to improve clarity. If we make material changes to how we use your personal information, we will provide you with a prominent notice on our website. Updates and changes will be effective when posted unless we state otherwise.