Privacy Policy
Thryv Therapeutics Inc. (“Thryv” or “we”) respects your privacy and is committed to protecting your personal information.
This Privacy Policy (the “Policy“) describes our privacy practices, the types of Personal Information we may receive or collect from you and how we use, disclose, store and secure it, so that you can make informed choices.
This Policy applies to our website, and other interactions that you may have with us (e.g., inquiries, support service, etc.) (taken together, our “Website”). For clarity, this Policy does not apply to the use or collection by Thryv of Personal Information provided to Thryv by third parties as a result of your participation in clinical studies. If you are concerned by this type of collection, please refer to Thryv’s clinical study consent form for the applicable study.
Additionally, we wish to draw your attention to the fact that the rights and obligations described in this Policy do not cover third-party websites that may be linked to or mentioned on our Website. These third-party websites have their own privacy policies, and we encourage you to read them carefully.
We ask that you read this Policy carefully to understand our policies and practices regarding the collection, processing and storage of Personal Information, or any other information in order to give us your informed consent where appropriate. If you do not consent to this Policy, then you may not use the Website.
Furthermore, in order to protect your Personal Information, we have put in place policies, practices and procedures relating to the management of the Personal Information we hold.
These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as complaint handling, information security and data governance at Thryv. They also provide the framework for the implementation of Privacy Impact Assessments (as defined in applicable laws), where required, as well as the prevention of and response to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer (as defined below).
1. What is Personal Information?
For the Purposes (as defined below) of this Policy, “Personal Information” means any information about an identifiable individual, including information that can be used alone or in combination with other information to identify, contact or locate a single individual.
2. What Personal Information Do We Collect About you?
The Personal Information we collect may include, but is not limited to:
To the extent that you provide them to us, your contact details such as your first and last name, given name, title, postal address, zip code, email address, phone number, and/or similar details to identify you, or to correspond with you.
Information related to your use of the Website, such as your IP address, information concerning your browser, or the device used.
Technical information about your use of the Website, such as dates of use of the Website, web browser type and version, time zone settings, system used, as well as information about your internet connection, equipment used to access the Website, and certain details about your usage.
Technical information that may help Thryv approximate your location. For example, Thryv may use an IP address received from your device to approximate your location. Thryv may also collect location information from devices in accordance with the consent process provided by your device.
Technical information about your interactions with the Website such as pages visited, clickstreams to, through and from the Website, times of your interactions, content searched for, page response times, Website errors, duration of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to leave the page.
Any Personal information provided during your interaction with us, including with our teams, support or other employee to provide you with information or assist you with your use of the Website, access to our services or information about our activities.
Thryv may receive Personal Information when submitted to our Website or in other ways, such as if you participate in a contest, activity or event, apply for a job, enroll in a program hosted by Thryv, interact with our social media accounts or otherwise communicate with us.
Any other Personal Information you have provided to us.
If you provide Thryv with the Personal Information of another individual, you acknowledge that you have obtained all appropriate and necessary consents from that individual to authorize us to collect, use and store that Personal Information for the Purposes and in the manner set out in the present Policy.
3. How Do We Collect Your Personal Information?
Thryv needs to collect and process some of your Personal Information in order for you to use our Website.
When we collect your Personal Information, we ensure that we collect only the information necessary to fulfill one of our Purposes, which has been previously disclosed to you, for example, in this Policy. We use Personal Information in accordance with the privacy laws applicable to our business.
3.1. Direct interactions
As a general rule and as required by applicable privacy laws, we collect the Personal Information we need directly from you on the basis of your voluntary consent, for example when you fill a form on the Website, when you communicate with us or when you use the Website. For more information about the collection of information through cookies, we invite you to read the section “How do we use cookies?”.
3.2. With your consent
We generally collect your Personal Information with your consent, unless applicable law provides an exception to this principle (for example, to comply with our legal obligations, when necessary to establish, exercise or defend a legal claim or proceeding).
3.3. Other permissible legal basis, such as the performance of our contracts
As permitted by applicable privacy laws, Thryv may collect Personal Information without your express consent, for example, to comply with obligations under applicable laws, or to fulfill our agreements.
3.4. Refusing and withdrawing your consent
You have the right, if you wish, to refuse the processing of your Personal Information. You may also, at any time, and subject to reasonable notice and any applicable legal or contractual restrictions, withdraw your consent (if any) to the processing of your Personal Information in our possession by contacting us. You should be aware, however, that if you choose not to provide us with your Personal Information, this may prevent you, for example, from using the Website or some of its features, or otherwise prevent us from providing you with relevant support or information, as some of this information might be essential to such Purpose. You can contact us as indicated in the “How to Contact Us” section for any questions relating to this subject.
4. Why Do We Collect and Use Your Personal Information?
4.1. For specific and limited purposes
Thryv generally collects your Personal Information for the purposes listed below (collectively, the “Purposes”).
a) To provide you with the Website and its features
We collect and use your Personal Information to enable you to access the Website, including the information you might be able to access through it. Specifically, we use your Personal Information to:
Provide, update, maintain and protect our Website and business. This includes use to prevent or address errors, security or technical issues, analyze and monitor usage, trends and other activities, or at a user’s request.
Determine your eligibility to the Website, its features or certain information, and authenticate yourself.
Process and classify information about you.
Provide you with relevant information and help you navigate the Website.
Personalize your use and experience of the Website.
Communicate with you regarding the Website and to respond to your inquiries about the Website or our products and services in general.
b) For the administration of our business
We may use your Personal Information for purposes relating to our business and the proper management of our administration. As a general principle, we use Personal Information based on our legitimate interests in operating our Website and business. Specifically, we may use your Personal Information as follows:
To carry out our obligations and enforce our rights under any contract we may have with you, or to comply with legal requirements.
To meet our business objectives, such as developing new products and services, improving or modifying our products and services.
To send you administrative information, for example, information about our services and changes to our terms, conditions and policies.
For audit, surveillance and fraud prevention purposes.
To ensure the security of the Website.
c) To give you the support you need
We may use your Personal Information to respond to your requests for assistance, support or information in connection with the Website or our services. Specifically, we may use your Personal Information as follows:
To respond to your requests for information, assistance and support.
To answer your questions, queries, comments or complaints.
To provide you with personalized assistance based on your previous requests.
d) For study, research, marketing and statistical purposes
We may use your Personal Information for study, research, marketing and statistical purposes, including to improve the Website, our products or services, our marketing or our customer relationships and experiences. Specifically, we may use your Personal Information as follows:
To keep you informed of our new offers.
To send you communications that we think may be of interest to you, such as newsletters, event, one-time promotional e-mails, direct mailings, business contacts or newsletters.
For data analysis purposes, including the identification of usage trends, and to determine the effectiveness of our promotional campaigns and commercial activities.
To conduct research to determine how to improve the Website, certain services or develop new ones.
e) To comply with or act under any applicable law or regulation
We may use your Personal Information as required by applicable law, legal process, or regulation or to ensure that we can comply with any legal requests under applicable law or regulation, which includes, but is not limited to:
Respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence.
To protect our operations and legitimate interests or those of our subsidiaries.
To enable us to pursue available remedies or limit the damages we may suffer, etc.
4.2. To send you messages
We may use your Personal Information to communicate with you in several ways (sending newsletters, e-mail messages, chat messages, support tickets, news, updates, written communications, etc.) (collectively, the “Messages”), including:
To inform you of new product or service releases, new partnerships and other key information about our business.
To inform you of changes to any products or services we offer or provide through it.
To provide you with useful information and other information about trends and best practices in our field and other relevant topics in connection with our services.
You may choose not to receive Messages in the manner indicated in the “Contact Us” section or through the unsubscribe link included in Messages. However, Thryv may continue to send you Messages to critical technical issues related to the Website (as applicable).
4.3. For any other purposes compatible with the Purposes or to which you have consented
With your express consent, we may use your Personal Information for any other purpose consistent with the Purposes.
If we wish to use your Personal Information for a purpose not mentioned above and for which you have not consented, we will ensure that we seek appropriate consent from you or inform you of the change, where permitted by law.
5. How Do We Share or Disclose Your Personal Information?
Your Personal Information will not be sold to third parties.
We share your Personal Information with third parties to fulfill our purposes and respond to requirements or requests made under applicable laws. Thryv may also share Personal Information with its corporate affiliates, parents, and/or subsidiaries.
Most of the time, you have already consented to such sharing, for example by accepting this Policy through your use of the Website. Sometimes, applicable laws also allow us to share your Personal Information with third parties without your consent, in specific cases.
Specifically, we may need to share your Personal Information, sometimes without your consent:
5.1. With our employees
In the course of their work, our employees may need to access your Personal Information, for example, when you contact us or request assistance. Their access is limited to what is necessary for the performance of their duties.
5.2. With service providers
Thryv may share your Personal Information with its service providers to enable the provision of the Website, such as hosting service providers, authentication service providers, or cybersecurity service providers.
Our service providers may have access to your Personal Information for a limited time in connection with these activities. Where Thryv uses third parties to process any Personal Information, we implement reasonable contractual and technical safeguards to ensure that these third parties keep all Personal Information they process strictly confidential.
Please note that these third parties may be located outside of your geographic location (province, territory or country). In such cases, Thryv takes commercially reasonable steps, as described below in the section “Where is your Personal Information hosted and transferred?”.
5.3. Where required by applicable law, to enforce our rights, prevent fraud and for safety
We may also share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with the law; (ii) comply with an order of a competent judicial authority in any jurisdiction; (iii) comply with legal process served on Thryv; (iv) protect and defend the rights or property of Thryv; (v) enforce or verify your compliance with any agreement you have entered into with Thryv, if any; (vi) prevent fraud or other illegal activity perpetrated through the Website; or (vii) act in urgent circumstances to protect the personal safety of users of the Website or the general public.
5.4. During a commercial transaction
We may need to share your Personal Information without your consent in the event of a merger, acquisition or sale of all or part of the business, for example, as part of a due diligence review. In such a case, we limit sharing to what is necessary to assess the feasibility or advisability of the transaction.
5.5. For other purposes, with your consent
Where you have expressly consented, your Personal Information may be shared with other third parties. For example, there may be specific cases where additional conditions apply and through these, we make it clear that specific third parties are processing your Personal Information.
6. Third-Party Services and Platforms
We may sometimes include links on the Website to third-party sites or services that we do not control. If you click on one of these links, you will be directed to sites that we do not control. Please read the privacy policies of those sites, applications or platforms that may collect Personal Information to understand their privacy policies and Personal Information collection practices.
7. Where is Your Personal Information Hosted and Transferred?
Your Personal Information may be disclosed and stored outside your province, state, territory or country of residence.
Our business partners and service providers may be located in Canada, in the United States or elsewhere in the world. Please be aware that we have contractual agreements with these third parties and suppliers to ensure that your Personal Information is handled in accordance with the laws applicable to us. Where required by applicable law or where considered relevant by us to ensure the safety of Personal Information, we conduct Privacy Impact Assessments prior to any transfer of Personal Information to another jurisdiction (e.g., outside Quebec for Quebec residents).
We endeavour to limit access to Personal Information by such third parties to that which is necessary to perform the tasks entrusted to them. Please be aware that we also strive to establish contractual agreements with these agents and service providers to ensure the confidentiality and security of your Personal Information. This may include the implementation of robust and effective security measures.
In addition, Thryv will ensure that your Personal Information is adequately protected by appropriate technical, organizational or other legal means. If you would like more information about these security measures, please contact us as indicated in the “How to Contact Us” section.
8. Retention of Personal Information
Personal Information will be retained only as long as necessary for the fulfillment of the Purposes, in accordance with our internal document retention policies, to comply with applicable legal, tax or regulatory requirements, or until you request us to destroy it. At the end of this period, we will destroy, delete or anonymize such Personal Information securely in accordance with relevant legal, regulatory and contractual requirements.
In determining the appropriate retention period for your Personal Information, we take into account the amount, nature and sensitivity of the Personal Information, the potential risk of harm arising from unauthorized use or disclosure of your Personal Information, the Purposes for which we process your Personal Information and the possibility of achieving those Purposes by other means, as well as applicable legal, regulatory, tax, accounting or other requirements. As stated above, in certain circumstances, we may anonymize your Personal Information (so that it can no longer be associated with you) pursuant to applicable laws, including for study, research or statistical purposes, and only for serious and legitimate purposes, in which case we may use it indefinitely without further notice.
If you wish to obtain more information on this subject or otherwise request the deletion of your Personal Information under this Policy, we invite you to contact us.
9. Protection of Your Personal Information
9.1 With necessary and appropriate measures
Security is critical to Thryv’s mission, and we take security of data seriously. Thryv uses industry-standard technical and organizational measures to protect Personal Information from loss, misuse, and unauthorized access or disclosure.
As such, Thryv has implemented security measures to protect your Personal Information. The standard security measures we use depend on the type of information collected. However, and while Thryv uses electronic, physical and procedural safeguards to protect your Personal Information, we encourage you to use caution when using the Internet as it incorporates an inherent risk.
Your Personal Information is hosted by our service providers who are committed to using industry-standard security measures to preserve the integrity and confidentiality of your Personal Information.
Our employees and providers are informed of the confidential nature of the Personal Information collected and are made aware of the appropriate security measures to prevent unauthorized access to Personal Information.
We maintain our Website and all associated data with technical, administrative and physical safeguards to protect you against loss, unauthorized access, destruction, misuse, alteration and improper disclosure of your Personal Information. These safeguards vary according to the sensitivity of the data in our possession and are based on the best industry standards. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
If you have any questions about the security of your interaction with us, or if you believe that your Personal Information has been provided to us without your consent, please contact us as described in the “How to Contact Us” section.
9.2 Children’s privacy
To the extent prohibited by applicable law, Thryv does not allow use of our Website by anyone younger than 16 years old. If we learn that anyone younger than 16 has unlawfully provided Personal Information, we will take steps to delete such Personal information.
If a parent or guardian discovers that his or her minor child has provided us with Personal Information without our having obtained the appropriate consent, such parent or guardian has the right, upon request, to inspect the Personal Information provided by the child and/or to require that it be deleted from our files. In this case, we ask the child’s parent or guardian to contact us at the coordinates indicated in the section “How to contact us”.
10. How Do We Use Cookies?
A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet or other device when you use your browser to visit an online service. Other tracking technologies, such as web beacons, tracking pixels, or tokens, may be used for similar purposes. In this Policy, all such tracking technologies are collectively referred to as “Cookie(s)”. Any Personal Information collected using Cookies by or on behalf of Thryv (if applicable) is treated with the same level of confidentiality as any other Personal Information held by Thryv.
10.1. Essential Cookies
These Cookies are necessary for the operation of the Website and provide basic functions and may include maintaining your session and preventing security threats. We cannot disable these Cookies in our systems without affecting the operation of the Website. However, if you wish, you can block or delete them by changing your browser settings and forcing all Cookies on the Website to be blocked.
10.2. Non-Essential Cookies
Non-essential Cookies provide certain non-essential functionalities on our Website for functional, analytical or advertising purposes. We will ask for your consent before using these Cookies.
Functionality Cookies (also known as “preference cookies”): These Cookies are not essential to the provision of our Website. They enable us to personalize and improve the user experience. For example, if you have consented to their use, these Cookies will store your communication preferences or provide the integration of content such as videos.
Performance Cookies (also known as “statistical cookies” or “analytical cookies”): These Cookies are not essential to the provision of our Website. If you have consented to their use, we use Performance Cookies to understand how you interact with our Website, to produce location reports and to have analytical reports on Website errors. Our partners may also use this type of Cookie to analyze your use of our Website and provide us with information about it. These Cookies are intended for statistical purposes only.
10.3 Deactivation of Cookies
With the exception of strictly necessary Cookies, we will only place Cookies on your device with your consent, and these Cookies will be retained for a maximum period of thirteen (13) months from the time they are installed on your device. At the end of this period, your consent will again be required. You can also manage your Cookies by changing the settings on your browser or device. For details on how to configure your browser, please consult the help center for Chrome, Safari, Firefox, Internet Explorer, Edge or Opera. However, if you choose to refuse Cookies, certain pages or sections of our Website may not be displayed correctly or certain functionalities may no longer be available. You may also continue to receive advertising, but it will no longer be as tailored to your nee.
11. Your Rights
You may review, correct, update, modify or delete the Personal Information you have provided to us through the Website. Simply contact us and we will assist you.
You can also exercise your rights listed above by sending a written request to our Privacy Officer. He or she will be happy to assist you in any way he or she can.
For your protection, we may need to verify your identity before processing your request. Depending on the applicable laws, we will inform you of the procedure to follow, the processing time and the information required, if any. We aim to respond to requests promptly, usually within thirty (30) days.
11.1. Access to and correction of Personal Information
Depending on your situation, it is important that the Personal Information we hold about you is accurate and up-to-date. Please keep us informed of any changes to your Personal Information. By law, you have the right to request access to and correction of the Personal Information we hold about you.
You may view and modify Personal Information by contacting us. If you wish to consult, verify, correct or withdraw your consent to the use of your Personal Information, you may do so by contacting us as provided in the Policy.
We may ask you for specific information to help us confirm your identity and right of access, and to provide you with the Personal Information we hold about you or to make the changes you request. Applicable law may permit or require us to refuse to provide you with access to some or all of the Personal Information we hold about you, or we may have destroyed, erased or made anonymous your Personal Information in accordance with our record-keeping obligations and practices. If we are unable to provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions such as:
Information protected by solicitor-client privilege.
Information that is part of a formal dispute resolution process.
Information about another person that would reveal his or her Personal Information or confidential business information.
Legal record information: subject to applicable legal limitations, you have the right to access your legal record as it is available to us through the platforms. If you request a copy of your legal record, it will be provided to you for a reasonable fee. You may request access to your legal record by contacting us. Access to your legal record will also be denied if disclosure is likely to have a material adverse effect on your physical, mental or emotional health in the opinion of a professional, or to reveal personal information about a third party or the existence of such information and disclosure may seriously harm that third party, unless the third party consents or in the event of an emergency threatening the life, health or safety of the person concerned. We use reasonable means to ensure that the information in your legal record is accurate. If you find any inaccuracies, you may request that a note be made on the record indicating the inaccurate information.
We may refuse a request to amend Personal Information if we believe that the amendment would violate a law or legal requirement or would render the Personal Information incorrect.
If you are concerned about our response or wish to correct the Personal Information provided, you may contact us as provided in this Policy.
11.2. Withdrawal of consent
Where you have given your consent to the collection, use and disclosure of your Personal Information, you may have the legal right to withdraw your consent in certain circumstances. To withdraw your consent, if applicable, contact us as set out in this Policy. Please note that if you access your consent, we may not be able to provide you with a particular feature or service and/or you may no longer be able to access the Website. We will explain the consequences at that time to assist you in your decision.
11.3. Right to de-index
The right to de-index allows you to request that Thryv cease disseminating your Personal Information or de-index any hyperlink attached to your name providing access to Personal Information if such dissemination causes you harm or contravenes the law or a court order.
11.4. Right to data portability
Depending on applicable laws to you, you may request that Thryv provide you with computerized Personal Information in its possession in the form of an intelligible written transcript in a structured and commonly used technological format. Alternatively, you may simply ask Thryv to confirm the existence of your Personal Information. You may request that such Personal Information be disclosed to any person or organization authorized by law to collect such information.
Thryv will only send you the Personal Information it has collected from you and may exclude certain Personal Information under applicable law (such as Personal Information it has created or inferred about you). Thryv also reserves the right to refuse any such request if it raises serious difficulties under applicable law.
11.5. Other rights and how to exercise them
Depending on applicable law, you may have other rights with respect to your Personal Information that are not otherwise listed above. This may include:
Request the deletion of your Personal Information.
To obtain additional information, for example on the categories of third parties to whom we communicate your Personal Information.
To withdraw your consent at any time, if we have collected and processed your Personal Information with your consent. Withdrawal of your consent will not affect the lawfulness of the processing we carried out prior to your withdrawal, nor the processing of your Personal Information carried out on the basis of legitimate processing grounds other than consent.
File a complaint with the appropriate authority, such as a privacy commissioner or the Commission d’accès à l’information.
We invite you to write to us with this request and to provide us with the relevant information about that right to enable us to assess its implementation.
To exercise any of your rights (to the extent that they are available), please contact us as indicated in the “How to Contact Us” section.
You may file a complaint with Thryv’s Privacy Officer if you are dissatisfied with our handling of your Personal Information or compliance with this Policy.
You are also entitled by law to lodge a complaint with a privacy commissioner or any other competent supervisory authority for the protection of personal information.
12. Your California Privacy Rights
This section provides additional details about the Personal Information Thryv collects about California consumers and the rights afforded to them under the California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CCPA”.
For more details about the personal information Thryv has collected over the last 12 months, including the categories of sources, please see the “What Personal Information do we collect about you?” section above. Thryv collects this information for the business and commercial purposes described in the “Why do we collect and use your Personal Information?” section above. Thryv shares this information with the categories of third parties described in the “How do we share or disclose your Personal Information?” section above. Subject to certain limitations, the CCPA also provides California consumers the right to request to know more details about the categories or specific pieces of personal information Thryv collects (including how Thryv uses and disclose this information), to delete their Personal Information, correct their Personal Information that may be occurring, and to not be discriminated against for exercising these rights. Please also note that Thryv does not collect sensitive personal information through the Website as defined under the CCPA.
As described in the section “How Do We Use Cookies?”, we have incorporated Cookies from certain third parties into our Website. These Cookies allow those third parties to receive information about your activity on our Website that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Website or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” or “share” of information, to which you have the right to opt out. You can opt out of these activities by following the instructions in this section.
We may “sell” or share your Personal Information to the following categories of third parties:
Ad Networks
Analytics providers
Marketing providers
Over the past 12 months, we may have “sold” the following categories of your Personal Information to categories of third parties listed above:
Log data regarding your use of the Website, device information or other information regarding your interaction with the Website.
Cookie Information.
We have “sold” or shared the foregoing categories of Personal Information for the following business or commercial purposes:
Improving the Website or our business activities, including testing, research, internal analytics and product development.
Showing you advertisements, including interest-based or online behavioral advertising.
You have the right to opt-out of the “sale” or sharing of your Personal Information. You can opt-out using the following methods:
Accessing your Cookie settings in your browser as described above.
By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Information for at least 12 months.
If we collect sensitive Personal Information, including precise geolocation data, you have the right to limit its use and disclosure to that which is necessary to provide you with access to the website or for certain permitted business purposes.
We do not use geolocation data to infer characteristics about you, and we do not disclose geolocation data to third parties for their own purposes without your express permission.
To limit the use or disclosure of your geolocation data, you may:
Adjust your mobile or browser settings to prevent geolocation tracking.
Email us at with the subject line: “Limit Use – Geolocation”.
To our knowledge, we do not sell the Personal Information of minors under 16 years of age.
California consumers may make all other requests to access, correct, or delete pursuant to their rights under the CCPA by contacting our Privacy Officer as detailed below.
Thryv will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
13. Your Virginia Privacy Rights
Subject to certain limitations, the Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia consumers the right to request to access personal information we collect about you, correct inaccuracies in your Personal Information, to request a portable copy of your Personal Information, and to delete your Personal Information. You also have the right opt-out from the processing your Personal Information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, which Thryv does not do. You also have the right to opt out of targeted advertising and selling (as such terms are defined under the VCDPA), however, Thryv does not participate in selling of your Personal Information. To opt out from targeted advertising, please:
Accessing your Cookie settings in your browser as described above.
By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the VCDPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.
If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request.
If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
Thryv will honor the exercise rights or appeals of decisions of Virginia residents requested via email or letter to our Privacy Officer.
14. Additional Information for residents of Colorado, Connecticut, Utah, Texas, and Oregon
Residents of Colorado, Connecticut, Utah, Texas, and Oregon have certain rights regarding their Personal Information under applicable state privacy laws. These rights include:
The right to confirm whether we process your Personal Information.
The right to access Personal Information we have collected about you.
The right to correct inaccuracies in your Personal Information.
The right to delete Personal Information we have collected from or about you.
The right to opt out of targeted advertising or profiling and the sale of Personal Information.
The right to data portability, i.e., to obtain a copy of your Personal Information in a usable format.
These rights may be subject to specific limitations or requirements. You may exercise these rights by contacting our Privacy Officer.
To appeal a refusal of your request, you may submit a request for reconsideration by contacting us at the same contact information above with the subject line: “Appeal – Privacy Request Denial”.
Residents of Colorado, Connecticut, Utah, Texas, and Oregon also have the right to opt out of the processing of their sensitive Personal Information, including precise geolocation data.
If we collect precise geolocation data through your use of our Website, we will seek your consent before collecting such data where required, including through this Policy or through specific request in your browser. You may also withdraw your consent or opt out at any time using the following methods:
Disable location tracking via your browser or mobile device settings.
Email us with the subject line: “Opt-Out – Geolocation”.
Use the privacy settings within our application to disable geolocation data sharing (if applicable).
Please note that disabling geolocation features may affect your ability to use certain location-based functionalities of our Website, if any.
15. How to Contact Us?
Our senior executives have delegated the management of the privacy program to the Privacy Officer. His/her duties consist of managing and monitoring Thryv’s internal personal information management program. It is the Privacy Officer who approves and implements privacy policies and procedures, ensures their proper functioning and reports to Thryv senior management on the effectiveness of the program.
It is also the responsibility of the Privacy Officer to provide you with the necessary support in the event of a question, complaint or request relating to the protection of Personal Information.
If you have any questions about any aspect of this Policy, wish to send a comment, lodge a complaint or exercise any of the rights available to you under applicable law, please do so by contacting our Privacy Officer as follows:
Privacy Office, Thryv Therapeutics Inc.
Address: 999 boul. De Maisonneuve Ouest, Montreal, Quebec, H3A 3L4
Email: privacy@thryvtrx.com
Your request may be granted or denied by Thryv in accordance with applicable laws. Thryv will take prompt corrective action upon becoming aware of any breach of this Policy. Thryv shall not be liable for any indirect, incidental, consequential or punitive damages related to this Policy. You may at any time file a complaint with the appropriate authority if you believe that Thryv is not handling your Personal Information in a manner consistent with this Policy or applicable law.
15. Modifications and Updates to the Policy
We revise the Policy annually to comply with applicable laws and our operations. If we update this Policy in a material way, we will notify you by sending you a notice either on our Website or by e-mail. However, the posting of a new version of the Policy on our Website or your continued use of the Website will suffice as notice and consent to the Policy changes.
Of all translated versions of this Policy, the French version shall prevail in the event of differences.
Date: June 1, 2024