ThinkingData Privacy Policy

Last Updated: [September 3rd, 2025]

This privacy policy (“Privacy Policy”) applies to your access and use of our proprietary ThinkingEngine web-based platform that provides data analytics relating to computer games (“Platform”)  and the website located at www.thinkingdata.io (the “Site”) made available by ThinkingData, Inc. (“ThinkingData,” “us” or “our” throughout this Privacy Policy), as well as any of its subdomains and any services, tools or features offered through the Platform or the Site (collectively, the “Services”). This Privacy Policy describes how ThinkingData collects, uses and discloses information that we obtain about you.

By using the Services and/or by clicking a box indicating your acceptance of this Privacy Policy, you agree to the terms of this Privacy Policy, and that your personal information will be handled as described in this Privacy Policy, and consent to the privacy practices described in this Privacy Policy. If you do not agree with our policies and practices as described in this Privacy Policy, do not use the Services.  In addition, you agree that any disputes or claims relating to this Privacy Policy will be subject to the limitations of liability, dispute resolution and other provisions in our Alpha Tester Agreement and any other agreement between ThinkingData and you governing your access to or use of the Services.

If the individual accepting this Privacy Policy is accepting on his or her own behalf, such individual shall be referred to throughout this Privacy Policy as “you” or “Customer.” If the individual accepting this Agreement is accepting on behalf of a company or other legal entity, such individual hereby represents and warrants that they have the authority to bind such entity to this Privacy Policy, in which case the terms “you” or “Customer” as used throughout this Privacy Policy shall refer to such entity. If the individual accepting this Privacy Policy does not have such authority or does not agree with the terms of this Privacy Policy, such individual must not accept this Privacy Policy and may not use the Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. This Privacy Policy only applies to information collected on or through the Services and is not intended to fully describe the privacy policies of ThinkingData. This Privacy Policy does not apply to information collected offline. It also does not apply to information collected by or provided to any third party, including any web form, application or other content (including advertising) that may link to or be accessible from or through the Services, or any information (including Personal Information as defined below) that a Customer inputs into the Services relating to persons other than Customer and that were collected by Customer, such as game play or game player data (“Game Data”).  In such a case, Customer’s privacy policy applies to the use of such information and Game Data and any inquiries regarding such information and Game Data should be directed to the Customer.

Types of Personal Information; Methods of Collection

We collect several types of information from and about users of the Services directly from you when you provide it to us or third parties authorized to share such information with us, as well as automatically through your use of the Services.

When you use the Services, we may collect or you may provide us with information, including Personal Information. “Personal Information” means information by which you may be personally identified, including your name, e-mail address, mailing address, mobile phone number, and social media profile information. You may directly provide us with your Personal Information in the following ways:

• Website Forms. You may provide us with your Personal Information by filling out forms on the Site or a third-party website. Such information you provide may include your name, email address, mailing address and telephone number. Such information may be used to contact you about the Services. 
• Account Registration. You may provide us with your Personal Information in connection with the account registration process. Such information you provide may include your name, company, title, email address, mailing address, telephone number, social media information, username and password. Such information may be used to establish your account to use the Services.
• Email Communications or Newsletters. You may provide us with your name and email address in order to receive newsletters or other communications. We may collect information from you through records and copies of correspondence with you, including email address. You may opt-out of these marketing communications at any time as described below.

• Feedback. You may provide us with your Personal Information (including contact information) when you provide feedback about our Services, including during live feedback sessions via video or audio-conferencing platforms, which may be recorded by ThinkingData and you hereby consent to such recording.

Automatically Collected Information

When you visit the Site, we may automatically receive and record certain information from your computer, web browser and/or mobile device and your interactions with the Site, including without limitation log data, your domain, IP address, or other device address or ID, web browser and/or device type, operating system, hardware and software settings and configurations, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Site (“Automatically Collected Information”).   

Device Related Information

We may collect the following information, including Personal Information, from devices and users of our SDK:

The Personal Information collected under the basic functions refers to the Personal Information collected by the preset attributes of our SDK.  The Personal Information collected under the extended functions refers to the personal information collected by our SDK using additional plugins.

The following are required or optional permissions for use of Android devices on our Platform:

The following are required or optional permissions for use of iOS devices on our Platform:

The following are required or optional permissions for use of HarmonyOS on our Platform:

In addition, third parties such as advertising networks, analytics providers and widget providers may collect information about your online activities over time and across different websites when you access or use our Site. Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers.  You may, however, disable certain tracking as discussed in this section (e.g., by declining cookies), but such disabling may impair use of the Site. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies Information

When you use the Site, we may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device, to track information about your use of the Site, help analyze our web page flow, customize our content, measure promotional effectiveness, and promote trust and safety. We have restricted the use of non-essential cookies on the Site. You may choose whether to accept, reject or select only certain cookies to be deployed during your use of the Site through the cookie banner on the homepage of the Site.

You are always free to decline our cookies upon visiting the Site, although doing so may interfere with your ability to use the Site or certain features of the Site. To decline the use of cookies on the Site, except for cookies that are necessary to the operation of the Site, please select “Decline All” on the cookie banner on the Site’s homepage. You may also customize the use of cookies on the Site by selecting the “Manage Cookies” option on the cookie banner on the Site’s homepage.

In addition, we, our service providers and others sometimes use data-gathering mechanisms on the Site, including without limitation “web beacons”, “clear GIFs”, “pixels” and/or “tags” (“Tracking Technologies”). These perform statistical and administrative functions, such as measuring site and page traffic, verifying advertising paths, better understanding user interests and activity, gathering related information (such as information relating to a particular browser, device or IP address), and positioning images, and typically do so without detracting from your online experience. 

We generally use the following types of cookies and Tracking Technologies on our Site:

Strictly Necessary Cookies: These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.    You can set your browser to block or alert you about these cookies, but some parts of the Site or Services will not then work.

Functional Cookies: These cookies enable the Site to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages.    If you do not allow these cookies then some or all of these services may not function properly.

Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They help us to know which pages are the most and least popular and see how visitors move around the Site.  All information these cookies collect is aggregated. If you do not allow these cookies we will not know when you have visited our Site, and will not be able to monitor its performance.  One of the services we use for these purposes is Google Analytics.  To opt-out of Google Analytics and find out more about their privacy practices, see https://tools.google.com/dlpage/gaoptout.

Targeting Cookies:  These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.    They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. These cookies may collect information your online activities over time and across different Internet websites or online services when you use our Site and Services.

By accessing and using our Site and Services, you consent to use of cookies and Tracking Technologies and our sharing of information collected through cookies and Tracking Technologies with third parties for data analytics, site performance and advertising purposes, including targeted advertising.

Uses of Personal Information

We use your information, including Personal Information, for the following purposes:

• We use your Personal Information to establish your account to use the Services as well as to establish and maintain the accounts of your authorized users in connection with the Services.
• We use information about your use of the Services to understand and analyze the usage trends and preferences of our users, to improve the Services and to improve fraud detection and information security.
• We may use your e-mail address or other Personal Information to contact you for administrative purposes such as customer service and/or to send you our newsletters or other promotional materials. Generally, you can opt-out of receiving promotional communications by following unsubscribe links provided in the messages, or by contacting us directly at [privacy@thinkingdata.io].  Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse and analytics.
• We may use information collected from cookies or Automatically Collected Information through the Site to: (a) personalize our Services; (b) better understand how users access and use our Services; (c) monitor and analyze the effectiveness of the Services; (d) monitor aggregate usage metrics such as total number of visitors and pages viewed; and (e) perform research and analytics, including to analyze and report on usage and performance of the Services.
• We may use your Personal Information to: (a) detect, investigate, and prevent activities on our Services that conflict with applicable terms of service, including any terms or conditions applicable to the use of the Platform, could be fraudulent or violate copyright or other rules, or that may be otherwise illegal, (b) comply with legal requirements, (c) defend or exercise legal claims, (d) respond to legal process or law enforcement or governmental investigations or requests, and (e) protect our rights and the rights and safety of our users and others.

When We Disclose Information

We may share your information, including Personal Information, as follows:

• We may share your information, including Personal Information, where you have provided consent as described at the time of consent.
• We may disclose the Personal Information we collect from you to fulfill the purpose for which you provide it or for any other purpose disclosed by us when you provide the information.
• We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing the Site and Services to you; however, if we do so, their use and disclosure of your Personal Information will be maintained by such affiliates and subsidiaries in accordance with this Privacy Policy.
• We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to take precautions against liability; to protect ThinkingData from fraudulent, abusive, or unlawful uses or activity; to protect the security or integrity of the Services; to investigate and defend ourselves against any third party claims or allegations or to enforce agreements or exercise legal claims; to assist government enforcement agencies, such as  in response to law enforcement or other government request; or to comply with state and federal laws, in response to a court order, judicial or other legal process or government subpoena or warrant.
• We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Privacy Policy or any applicable terms of service, including any terms or conditions applicable to the use of the Platform, or as evidence in litigation in which we are involved.
• We may disclose the information we collect from you to third party vendors, service providers, contractors, or agents who perform functions on our behalf, including the provision of the Site or Services.

• We may disclose the Personal Information we collect from you to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ThinkingData’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held ThinkingData about our Services or users is among the assets transferred.  This includes  disclosing Personal Information to professional advisors (e.g. bankers, lawyers, accountants) and potential buyers and vendors in connection with the sale, disposal or acquisition by use of our business or assets.

We will not sell or share (as such terms are commonly defined by applicable US privacy and data protection laws) Personal Information with third parties without your consent or disclose your Personal Information to third parties for their Direct Marketing Purposes.

You may decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionalities of the Services.

Your Rights

You may have certain rights to your Personal Information depending on where you reside.   We describe the rights that individuals may have under various state laws in the United States.

California Privacy Notice

We provide this California Privacy Notice under the California Consumer Privacy Act (“CCPA”).   This notice applies only to personal information that we collect in our capacity as a business and not personal information that we process as a service provider to our customers.

Notice at Collection

We collect the following categories of personal information for the follow purposes:

• Identifiers such as name, address, email address, phone number, general contact information, company name, payment information, internet protocol (IP) address, and device identifiers.  We collect this information to provide and improve the Services, communicate with you, for marketing and promotion, processing job applications and other purposes described in the section entitled Uses of Personal Information.
• Personal information described in California Civil Code Section 1798.80(e) such as the identifiers listed above.  We collect this information to provide and improve the Services, communicate with you, for marketing and promotion, processing job applications and other purposes described in the section entitled Uses of Personal Information.
• Commercial information such as the products and services you have purchased, and credit card and other payment information. We collect this information to provide and improve the Services, processing transactions and other purposes described in the section entitled Uses of Personal Information.
• Characteristics of Protected Classifications such as gender, age, race, disability status, sexual orientation, gender identity, military/veteran status, marital status, national origin, and medical information that you provide in connection with a job application or some other interaction with us.  We collect this information only as necessary in connection with processing of job applications or in compliance with applicable law or legal obligations.
• Internet or other electronic network activity information such as browsing history, search history, and information regarding a consumer’s interaction with an internet website application or advertisement.  We collect this information to provide and improve the Services, for marketing and promotion and other purposes described in the section entitled Uses of Personal Information.
• Professional or employment-related information such as information provided when an applicant applies for a job with us online.  We collect this information only as necessary in connection with processing of job applications or in compliance with applicable law or legal obligations.
• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 C.F.R. Part 99) when an applicant applies for a job with us online.  We collect this information only as necessary in connection with processing of job applications or in compliance with applicable law or legal obligations.
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not sell personal information or share personal information for cross-context behavioral advertising or sell or share personal information of children under 16.  We also do not collect, use or disclose sensitive personal information for purposes of inferring characteristics about you.

Your California  Privacy Rights

If you are a resident of California, you may have the following rights with respect to your personal information:

(i) Right to Know

You may have the right to request that we disclose personal information that we have collected, sold, or shared about you, including:

• The categories of personal information;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting, selling, or sharing personal information;
• The categories of third parties to whom we disclose personal information; and
• The specific pieces of information we have collected about you.

(ii) Right to Correction

You may have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

(iii) Right to Deletion

You may have a right to request that we delete any personal information about you that we have collected directly from you, subject to certain exceptions.

(iv) Right to Opt-Out of Sale/Sharing

We do not offer a right to opt-out of the sale or sharing of your personal information because, within the meaning of the CCPA, we do not sell or share and have not sold or share personal information identified in the above categories to any third party.

(v) Right to Limit Use and Disclosure of Sensitive Personal Information

We do not offer a right to limit the use or disclosure of sensitive personal information because, within the meaning of the CCPA, we do not use sensitive personal information for inferring characteristics.

(vi) Right to Non-Discrimination for Exercise of a California Privacy Right

You may have a right to not receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights

Please see the section entitled How to Exercise Rights for information on making a request under the CCPA.

California Shine the Light Privacy Rights: We do not disclose your personal information to unaffiliated third parties for those third parties’ direct marketing purposes unless you affirmatively agree to such disclosure.

Other State Privacy Rights

Residents of certain other US States may have rights relating to the collection, use, disclosure, and other processing of their personal information, subject to applicable legal exceptions and requirements. The exact scope of these rights may vary by state and will depend on whether we are acting as a controller subject to those laws.

Right to Know/Access

You may have the right to know what personal information we have collected about you, including the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, “selling,” or “sharing” personal information or processing for “targeted advertising,” the categories of third parties to whom we disclose personal information, the categories of personal information disclosed to third parties, and the specific pieces of personal information we have collected about you in a usable format.

Right to Data Portability.

You may have the right to access your personal information in a portable format.

Right to Delete

You may have the right to request that we delete the personal information we have collected from or about you, subject to certain exceptions.

Right to Correct

You may have the right to request that we correct inaccurate personal information that we maintain about you.

Right to Opt Out of Targeted Advertising, Sale, or Sharing of Personal Information

You may have the right to “opt out” of “targeted advertising” and the “sale” or “sharing” of your personal information. As noted above we do not sell or share personal information for targeted advertising as defined by applicable law.

Right to Request Categories of Third Parties

You may have the right to request a list of the categories of third parties to which we have disclosed your personal information.

Right to Appeal

Certain states permit you the right to appeal a decision we have made in connection with your privacy rights request.

Right to Request Specific List of Third Parties

You may have the right to request a list of the specific third parties to which we have disclosed personal information.

Right to Non-Discrimination

You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise your rights. However, the exercising of the rights described below may result in a different price, rate, or quality/level of product or service where that difference is reasonably related to the impact the right has on our relationship with you or is otherwise permitted by law.

How to Exercise Rights

You can make a request to exercise any rights you may have with respect to your personal information be emailing us at [privacy@thinkingdata.io].  As required and to the extent permitted under applicable law, we take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information sufficient to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative and to describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may limit our response to your exercise of the above rights as permitted under applicable law.

Under certain laws, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent. We may refuse a request if the agent does not provide adequate proof of their authorization.

Third-Party Links

The Services may contain links to third party websites and applications. Any access to and use of such linked websites or applications is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third-party websites or applications. We are not responsible for the information practices of such third parties. Please read such third parties’ privacy policies to understand their privacy practices.

Data Security

We have implemented measures designed to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration and destruction; however, no security measures are perfect or impenetrable, so we cannot ensure or warrant the security of any information you transmit to us through the Services, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of any of our safeguards. We are not responsible for circumvention of any privacy settings or security measures contained in the Services.

Data Retention

We retain personal information as long as it is reasonably necessary and relevant for our operations or for providing Services, and/or to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, or enforce any applicable terms of service or other agreements.

Visitors from Outside the United States

The Services are controlled and operated by ThinkingData in the United States, which may have fewer protections than your jurisdiction of residence. If you choose to access the Services from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary to allow you to use the Services.

Children’s Privacy

The Services are not intended for children under 16 years of age. We do not knowingly collect information from persons under 16 years of age, and no part of the Services are directed to persons under 16 years of age. If you are under 16 years of age, do not use or access the Services at any time or in any manner. If we learn that information has been collected through the Services from persons under 16 years of age and without verifiable parental consent, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided us with information, please alert us at [privacy@thinkingdata.io] to request that we delete the information from our systems.

Changes to Our Privacy Policy

This Privacy Policy is current as of the “Last Updated” date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. If we make any changes to this Privacy Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will post a banner notification on the Site’s main webpage and will update the “Last Updated” date to reflect these changes.  If you continue to use the Services after we have made changes to the Privacy Policy, you are deemed to have accepted such changes. If you do not agree to such changes, you should discontinue use of our Services.

Our Contact Information

Please contact us with any questions or comments about this Privacy Policy, your Personal Information, our use and disclosure practices, your communication preferences or your consent choices by e-mail at [privacy@thinkingdata.io].