Privacy Statement

Thrive Labs B.V.
May 2023



This privacy statement applies to the processing of personal data (“Personal Data”) by Thrive Labs B.V. (collectively referred to as “Thrive Labs”, or “we”, “our”, and “us”). We are a provider of online courses and educational content.

All Personal Data provided by you to Thrive Labs will be processed by Thrive Labs in accordance with this Privacy Statement, the EU General Data Protection Regulation (Regulation EU 2016/679) (the “GDPR”) and all other applicable laws regarding Personal Data protection.

The purpose of this Privacy Statement is to inform you on (i) how Thrive Labs uses and protects your Personal Data and (ii) your rights in relation to your Personal Data.

This Privacy Statement was created on 29 May 2023. Thrive Labs reserves the right to update this Privacy Statement from time to time. We recommend you to regularly check our website (“Thrive Labs Website”) and this Privacy Statement. If we change things in this Privacy Statement that are important to you, we will of course also let you know in other ways (e.g. via email or via a communication tool available in your account).


When is this Privacy Statement Applicable?

This Privacy Statement is applicable to the processing by Thrive Labs of your Personal Data. There is one exception: the Thrive Labs Website may, from time to time, contain links to and from the website or services of third parties. If you follow a link to any of these websites, kindly note that these websites have their own privacy statements and that Thrive Labs does not accept any responsibility or liability for these statements or websites. Please consult these privacy statements before transferring any Personal Data.


When does Thrive Labs obtain Personal Data and which Data does it concern?

We collect Personal Data at various times, for example when you:

• create an account via the Thrive Labs Website
• pay for your products (subscriptions, courses etc.)
• contact our customer service and advisors
• sign up for our newsletter

This concerns the following Personal Data:

Personal Data you have provided to us yourself:

You provide us with Personal Data when you create an account via the Thrive Labs Website. These include email address and login details. You also provide Personal Data yourself when you talk to our consultants or call or email our customer service.

Automatically generated data

To make the Thrive Labs Website work properly, we also collect automatically generated information. This includes your IP address, the browser you use and its version number, internet provider, date and time, and other pages visited before or after the visit (Uniform Resource Locators clickstream).


For what Purposes and on what Legal Basis does Thrive Labs use your Personal Data?

Thrive Labs uses Personal Data for one or more of the following purposes:

• to grant you access to the Thrive Labs Website and our online products (courses, videos, communities etc.)
• to optimise the quality of our products and digital content
• to prepare user statistics
• for marketing and communication activities
• to send and collect invoices
• to detect, prevent and investigate any attacks made against the Thrive Labs Website

Under the GDPR, Thrive Labs may only process Personal Data if there is a so-called legal basis for doing so: a "processing purpose". Thrive Labs only processes Personal Data on the basis of the legal grounds listed below, including a brief explanation of for the sake of clarity.

Thrive Labs uses Personal Data on the basis of one of the following legal grounds:

• for the proper execution of an agreement: When you create an account and buy a product, you enter into an agreement with Thrive Labs. Our general terms and conditions also apply to that agreement. To be able to execute that agreement, and for example to ensure that you can (continue to) access our online content, we process your Personal Data you have provided us with.
• on the basis of your consent: When you create an account on the Thrive Labs Website, you give us permission to process Personal Data you provide to us. You can withdraw this consent at any time. For your rights, see also Clause 9 below.
• to comply with legal obligations we are subject to: In some cases, we are obliged to share information we have at our disposal. This may include your Personal Data. An example of such a situation is an investigation carried out by an authority; and
• on the basis of our legitimate interests: In some cases, we feel that Thrive Labs' "legitimate" interest justifies processing your Personal Data. Examples include our marketing emails and the security of the Thrive Labs Website.

Thrive Labs will not use your Personal Data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorised by law to do so.


How does Thrive Labs secure your Personal Data?

Thrive Labs takes appropriate technical and organizational measures to protect your Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, and against all other unlawful forms of processing. Examples of such measures are the implementation of a IT infrastructure according to the applicable information security standards. We have also made agreements on this with subcontractors and other service providers.



We use cookies on the Thrive Labs Website. A cookie is a small text file that the Thrive Labs Website stores on your computer or mobile device when you visit the site. The information stored therein can be sent back to our servers during your next visit. If you want to read exactly which cookies the Thrive Labs Website uses, click here for our detailed cookie statement.


Does Thrive Labs share your Personal Data with Third Parties?

Thrive Labs will share your Personal Data with third parties only to the extent that it is necessary to properly execute agreement with you and in accordance with the objectives listed above.

Thrive Labs may transfer your Personal Data to the following categories of recipients:

• service providers (for example payment service providers, providers of online community tools, IT support providers and cloud computing providers);
• regulators, tax authorities or investigative agencies (if we believe we are required to share your Personal Data by law or regulation);

Such recipients may be located outside the European Economic Area (the “EEA”). Unless otherwise notified to you, any transfers of your Personal Data to recipients located outside the EEA will be based on an adequacy decision or are governed by the standard contractual data protection clauses as set forth in clauses 45 and 46 of the GDPR.


How long will Thrive Labs retain your Personal Data?

Thrive Labs does not retain Personal Data provided for longer than necessary for the purposes set out in this Privacy Statement or than is required by law or regulation. For example, if you request us to delete your account, we will also delete any Personal Data you have provided to us.


What are your Rights?

As set forth in the GDPR, you have the right to request from Thrive Labs access to and correction, deletion or export of your Personal Data or restriction of the processing of your Personal Data or to object to the processing of your Personal Data, as well as the right to data portability.

Where Thrive Labs processes your Personal Data on the basis of your consent you have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing based on consent before its withdrawal.

If you believe that your rights have been violated and/or if you believe that Thrive Labs does not comply with applicable data protection laws, you have the right to file a complaint with a supervisory authority such as the Dutch Autoriteit Persoonsgegevens. We nevertheless kindly ask you to file your complaint firstly with us by means of the contact details below.

Should you have any questions regarding the processing of your Personal Data, including the exercise of your rights, please contact Thrive Labs by email using the contact details provided below.