Privacy Policy

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE.

THE SITE IS INTENDED FOR INDIVIDUALS LOCATED IN THE UNITED STATES, AND IT IS NOT INTENDED FOR INDIVIDUALS LOCATED IN OTHER COUNTRIES.

Introduction

Thriving Cities Group (also referred to herein as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as a part of our business. We also believe in transparency, and we are committed to informing you about how we treat the personal information we collect and process.

When Does This Policy Apply? This Privacy Policy (the “Policy”) describes our practices for the personal information collected when you visit our website, https://thrivingcitiesgroup.com/ (the “Site”). This Policy applies where Thriving Cities Group is the controller of your personal information. To the extent we process personal information on behalf of our customers as a service provider or processor, such processing is governed by our agreements with those customers, and not by this Policy.

How We Process Personal Information

What Personal Information Do We Collect? We collect the following categories of personal information, and we process this information for the purposes described in the “How Do We Use Personal Information” and the “How Do We Disclose Personal Information” sections below.

Category	Description
Contact Information	When you visit the Site, fill out our forms, or contact us, we may collect or receive your name, email address, mailing address, telephone number, job title, company name, and other contact details.
Communications and Inquiries	If you contact us, in addition to your Contact Information, we will receive any comments, content, questions, complaints, requests, or other information that you choose to provide. You can decide how much information you want to share with us in those communications.
Cookies and Similar Technologies	The Site uses cookies and similar technologies as described in the “Cookies and Similar Technologies” section of this Policy.
Usage Information	When you visit the Site, we automatically collect information from your browser and your device, including the date and time of your visit, data about which pages you visit, data about the length of time you spend on pages within the Site, which website linked you to our Site, search terms that you’ve used to find the Site, and your Internet Protocol (IP) address, device identifier, device type, operating system, language preferences, time zone setting, browser type and version, and browser plug-in types and versions.

Cookies and Similar Technologies

What are first and third-party cookies? A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your device and remain there until they expire at the end of your browsing session. “Persistent” cookies remain stored on your device until they expire or are deleted by you. Local shared objects (or “Flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

What are “similar technologies”? In addition to cookies, there are other data collection technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

What cookies and similar technologies are in use on the Site and why do we use them? The Site uses cookies and similar technologies to improve Site functionality, to measure and track how you interact with the Site, to perform analytics, to market to you, to track ad-driven activity, and to otherwise tailor our communications with you.

Cookies currently in use. The Site is hosted on Squarespace, which sets cookies that are needed for the Site to work and to protect it from abuse (for example, cookies named crumb, ss_cvr, and ss_cvt). The Site also uses Google Analytics, which sets cookies (for example, cookies whose names begin with _ga) to count visits and help us understand how the Site is used. The Roundtable website at roundtable-app.com does not set cookies of its own. Both websites load fonts from third-party font services (Adobe Fonts and Google Fonts), which receive your browser’s request, including your IP address, when the fonts load. We do not currently use a cookie management widget; you can manage cookies through your browser settings as described below.

Other third-party technologies. Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices about cookies and similar technologies. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Site’s functionality. In addition, adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. The links below provide additional information about how to disable cookies or manage the cookie settings:

• Google Chrome
• Firefox
• Microsoft Edge
• Safari for Mac and iPhone

You can learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.

How Do We Collect Personal Information? We collect personal information when you visit the Site, when you provide it to us, when you communicate with us, and when you give us your permission. Personal information can be received in any manner, including in-person discussions, telephone conversations, and electronic or other written communications. We may also observe or infer it from the information you provide to us and/or the way you interact with us.

Is Personal Information Required? You may choose not to provide us with personal information, but you will not be able to access portions of the Site that require personal information.

How Do We Use Personal Information? To the extent permitted by applicable law, we use personal information for the following purposes:

• Operate and improve our operations, business, services, and the Site
• Provide you with services, content, and functionality
• Improve our services and develop new services
• Honor and enforce our terms of service and contracts
• Manage, maintain, and improve our relationship with you
• Communicate with you and respond to your feedback, requests, questions, or inquiries
• Register you for our email lists and send you periodic messages
• Engage with you on social media
• Enable you to share comments, questions, and answers
• Ensure the privacy and security of our Site and services
• Maintain our databases and back-ups, including records of our communications with you
• Support and improve the Site, including evaluations of functionality and features
• Analyze use of the Site and our services and prepare aggregate traffic information
• Recognize your device and remember your preferences and interactions
• Provide you with a more personal and interactive experience on the Site
• Determine and track user interests, trends, needs, and preferences
• General operational purposes, including procurement, financial and fiscal management, risk and compliance management, and reporting
• Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transactions
• Obtain and maintain insurance coverage, manage risks, and obtain professional advice
• Detect, investigate, and take steps to prevent fraud, illegal activities, and loss
• Accomplish any other purpose (a) that is related or ancillary to any of the purposes described in this Policy, (b) that is described to you when you provide the information or to which you consent, or (c) for which we have a legal basis under applicable law
• Comply with applicable laws
• Comply with civil, governmental, regulatory, and legal inquiries, investigations, warrants, subpoenas, orders, summonses, and other process
• Cooperate with law enforcement agencies
• Establish, exercise, and defend legal rights or claims
• Create, use, retain, and disclose de-identified or aggregated data
• Any other purpose with your consent

No Profiling. We do not use personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the individual. Under Maryland law, “profiling” means automated processing performed on personal information to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, demographic characteristics, personal preferences, interests, reliability, behavior, location, or movements.

No Sales of Personal Information. We do not sell personal information to third parties as defined under applicable law.

Targeted Advertising. We do not use personal information of consumers for purposes of targeted advertising as defined under applicable law. We may, however, use certain website technologies to serve advertisements to individuals acting in a commercial or employment context.

How Do We Disclose Personal Information? To the extent permitted by applicable law, we disclose personal information to the categories of third parties listed below for the purposes described below. To the extent required by law, we will only disclose personal information where the recipient has provided written assurances that it will protect any personal information disclosed to it in accordance with applicable law.

Category	Description
Affiliates	We disclose all categories of personal information described in this Policy with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.
Parties to Corporate Transactions	In the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our organization or some or all of our assets, we will disclose all categories of personal information described in this Policy in connection with such transaction.
Courts, Law Enforcement, Regulators, and Fulfilling Legal Obligations	We will disclose all categories of personal information described in this Policy in response to subpoenas, warrants, court orders or other legal process, and to comply with relevant laws. We also disclose such personal information in order to establish and exercise our legal rights, to pursue claims, to defend against claims, and to investigate, prevent, and take action regarding possible illegal activities, suspected fraud, safety of person or property, and/or violations of contract.
Service Providers and Advisors	We disclose all categories of personal information described in this Policy to our contractors, service providers, insurers, and professional advisors (including attorneys, accountants, consultants, and auditors) that need access to information to provide services on our behalf or to perform functions for us. Among other things, recipients help us to administer the Site; support our operations; provide technical support; send communications to you; and assist with other legitimate purposes permitted by law.
Disclosures with Your Consent or at Your Direction	We will disclose your information to fulfill the purposes for which it was collected, the purposes for which you provided it, and the purposes disclosed to you when you provided the information. We may ask if you would like us to share your information with third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent. We will also disclose your information to those third parties to whom you direct.
De-Identified and Aggregated Data	We may disclose aggregated information, anonymous data, and/or de-identified data that does not identify any specific individual, where permitted under applicable law.

How Long Do We Keep Personal Information?

We keep personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements.

We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

We may retain and use anonymous, de-identified, or aggregated information for as long as is permitted under applicable law. We will also maintain records of certain requests submitted under applicable privacy laws and how we responded to such requests for as long as is required by law.

How Do We Protect Personal Information?

We have adopted security measures that are designed to protect the personal information under our control. From time to time, we review our security procedures and consider appropriate technologies and methods.

But, no security system is perfect, and no data transmission is 100% secure. Although we strive to protect personal information, we cannot guarantee or warrant the security of any information transmitted to or from the Site. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

Your Rights and Choices

Except as otherwise stated, please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor requests when we are required to do so under applicable law.

Email Preferences. We may send you emails about our Site and services. If you do not want to continue receiving emails from us, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails, if applicable, or by emailing us at contact@thrivingcitiesgroup.com. Please provide your name and contact information in your request, and we will respond to your request in accordance with applicable law.

Updating Your Personal Information. Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please let us know via the “Contact Us” details provided at the end of this Policy.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

Rights for Residents of Certain States. Residents of certain states who are acting in a consumer capacity may have the following rights relating to their personal information under their state’s consumer data protection laws. However, these rights do not apply in all circumstances or to all information, and we honor these rights where required under applicable law.

Rights to Confirmation and Access. Certain states’ residents have the right to confirm whether we process their personal information and, if we do, to access such personal information.

Right to Correct. Certain states’ residents have the right to correct inaccuracies in their personal information, taking into account the nature of the personal information and the purposes for which we process the personal information.

Right to Delete. Certain states’ residents have the right to request the deletion of certain personal information collected or maintained by us. However, we are not required to honor a deletion request where retention of the personal information is required by law.

Right to a Copy. If the processing of personal information is done by automatic means, certain state’s residents have the right to obtain a copy of their personal information in a portable and, where technically feasible, readily usable format that allows them to easily transmit the data to another controller without hindrance.

Right to Information about Disclosures. Certain states’ residents have the right to obtain a list of the categories of third parties to which we have disclosed their personal information or a list of the categories of third parties to which we have disclosed any consumer’s personal information if we do not maintain this information in a format specific to the individual.

Right to Opt-Out. Certain states’ residents have the right to opt-out of the processing of personal information for purposes of targeted advertising, sales of personal information, and profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the individual. You may submit a request to opt-out of targeted advertising based on your personal information using the Submission Process identified below or by broadcasting an opt-out preference signal on the browsers and/or browser extensions that support such a signal.

Submission Process. You may submit a request to exercise one of the above rights, and/or to revoke any consent that you previously provided, by email to contact@thrivingcitiesgroup.com or via our submission form.

Authorized Agents. Certain states’ residents may designate an individual to serve as their authorized agent (including by an Internet link or a browser setting, browser extension, global device setting, or other similar technology) and act on their behalf to opt out of the processing of their personal information for one or more of the purposes described above. Such authorized agents may submit requests to exercise the right to opt-out as described above using the methods identified in this Policy. In addition, a parent, guardian, or conservator may exercise any right listed above on behalf of the individual(s) under their care.

Authentication Process. We are required to verify the identities of those who submit requests to exercise certain of the above rights. As a part of this process, you will be required to provide your name, email address, mailing address, and/or telephone number. If you use an authorized agent to submit a request, we may also require the authorized agent to provide proof that you gave the agent permission to submit the request. If we cannot authenticate a request, we will provide notice to the individual that we cannot authenticate the request until the individual provides additional information reasonably necessary to authenticate the individual and their request.

Appeals. Certain states’ residents have the right to appeal a refusal to take action on a request within a reasonable time after your receipt of the decision. You may submit an appeal to a decision on your request by email to contact@thrivingcitiesgroup.com or via our submission form. We will inform you of any action taken or not taken in response to the appeal, along with a written explanation of the reasons for the decision.

Excessive Requests. If requests are manifestly unfounded, excessive, technically infeasible, or repetitive, we may either (1) charge a reasonable fee to cover the administrative costs of complying with the request, or (2) decline to act on the request.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the above rights. We do not discriminate against individuals for exercising their rights under applicable law.

Nevada Residents. Nevada residents may submit a verified request to us at contact@thrivingcitiesgroup.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.

Third-party Sites

This Policy only applies to our Site. It does not apply to any websites, applications, or services provided by third parties.

The Site may include links to, and content from, third parties. These links are to external resources and third parties that have their own privacy policies and with which we may have no relationship. It may not always be clear which links are to external, third-party resources. If you click on a third-party link, you will be redirected away from the Site. You can check the URL to confirm whether you have left the Site.

We cannot and do not (1) guarantee the privacy or security practices of third parties or any content provided by third parties; (2) control third parties’ collection or use of your information; or (3) endorse any third-party information, products, services, applications, or websites.

Any information provided by you or collected from you by a third party will be governed by that party’s privacy policy and terms of use. You should review their privacy policy and terms of use carefully.

Children

Our Site and services are not directed to children under the age of 13, and we do not knowingly collect information online from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or provide any information to us online. If we learn that we have collected or received personal information from a child under the age of 13 online without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it. If you believe we have received any information from a child under the age of 13 online, please contact us using the “Contact Us” details provided at the end of this Policy.

For more information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission’s website.

Updates and Changes to this Policy

We may update this Policy from time to time. If we change this Policy, we will post the revised version on our Site. Any changes, updates, and modifications will be effective immediately upon posting. If we make material changes, we may also notify you through a notice on the Site’s homepage and/or we may send you an email regarding the updates.

You should read this Policy carefully before using the Site, and you should review it from time to time so that you are aware of its current terms. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to any changes and to our collection, use, and sharing of your information according to the then-current Policy. If you do not agree with this Policy, you should not use the Site.

Contact Us

If you have any questions or concerns about this Policy or wish to exercise your rights, please contact us using the information below, and we will do our best to assist you.

Mail: Thriving Cities Group
PO Box 226
Elkton, Virginia 22827
Email: contact@thrivingcitiesgroup.com