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Information for individuals who are or were a visitor to a ThinkOnward website and/or user of the ThinkOnward digital application.
ThinkOnward is part of the Shell group of companies. As such, this Privacy Policy aligns with the standards and practices adopted across Shell entities and reflects our commitment to safeguarding personal data in accordance with applicable laws and Shell’s global privacy principles. This notice sets out what personal information we collect, for what purposes and your rights in this respect.
What does this Privacy Notice cover?
This Privacy Notice provides information regarding the processing of your personal data when in connection with our offerings, such as using services and/or purchasing products from ThinkOnward LLC part of Shell group companies (“ThinkOnward” or “we”) whether as a customer, platform subscriber, and/or a visitor to the ThinkOnward website ('Website' or 'ThinkOnward Website').
This Privacy Notice explains what personal data are processed about you; why we are processing your personal data and for which purposes; for how long we hold your personal data for; how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.
We may collect and process your personal information when you use services or purchase products from, or interacting with, ThinkOnward, including as: (i) a customer; (ii) a visitor to a ThinkOnward website (“ThinkOnward Website”); (iii) a user of a ThinkOnward Application (“ThinkOnward App); or (v) as a participant in a sweepstake, contest, promotion or competition offered by ThinkOnward, either alone or with a third party (“Promotion”).
Personal information we collect
Personal information is information that identifies, relates to, or could be linked, directly or indirectly, with you. We collect your personal information, including information about you as a ThinkOnward customer, user of ThinkOnward Apps and/or visitor to a ThinkOnward Website or ThinkOnward administered social media page (“ThinkOnward Social Media Page”). Below outlines the categories of personal information we may have collected in the preceding 12 months:
Identifiers, including your name, contact information, gender, and attributes you provide, date of birth, and phone
Financial information provided by you
Commercial information, including payment details and purchase history
Internet or other similar network activity, including IP address, log information, browser type and preferences, location information, purchase history, online identifiers, and details of your interaction with ThinkOnward Websites or ads
Social media profile information
Audio and electronic information including customer service recordings, event photos, and security footage
Inferences derived from personal information to create a profile about your individual preferences or characteristics
Precise geolocation data obtained through your device location, when you permit such collection
From time to time, we may collect sensitive personal information, including precise geolocation, as detailed above and defined under applicable data protection laws. You have the right to limit our collection and use of your sensitive personal information.
In most cases, you are in control of the information you choose to provide to us; however, in some cases, your choice not to provide some information may impact your ability to interact fully with a ThinkOnward product, service, program, website, or application.
ThinkOnward does not knowingly collect, use, process, or disclose the personal information of children under 16 years old without parental consent.
From what sources do we collect your personal information?
Information that you provide to us – You may choose to provide personal information, including your name, contact details, or other personal details, when creating an account or interacting with ThinkOnward or to receive communications or marketing offers from us. If you choose to create a ThinkOnward user account, a personal profile may be created for you to use and navigate across ThinkOnward services.
Information gathered through external sources - We may collect information about you from publicly available sources or through third parties including, but not limited to data brokers and advertising partners. This may include information about your interests, behaviors, and purchases.
Information gathered through social media pages - When you communicate with us through a ThinkOnward Social Media Page (for example, when you comment on, share or react to a post, upload media, send a personal message, or subscribe to a ThinkOnward Social Media Page), we may receive personal information from your profile.
Why do we process your personal information?
We process personal information covered by this Privacy Notice for the following purposes:
performing activities related to your participation in any of the ThinkOnward offerings, such as bounties, challenges, project assignments or accelerator incubation programs;
managing relationships and marketing such as maintaining and promoting contact with you;
account management including account verification (that is, ensuring that only you or someone you have authorized can access your account and information);
user support and development of our offerings;
performance of and analysis of market surveys and marketing strategies;
promotions and contests offered to ThinkOnward subscribers, including offering you digital rewards to recognize you as a valued member of the ThinkOnward community;
health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of ThinkOnward and staff, authentication of individual status and access rights;
legal and/or regulatory compliance - including compliance with legal or regulatory requirements and performing necessary screening to meet such requirements;
or for a secondary purpose where it is closely related, such as:
storing, deleting or anonymizing your personal data;
audits, investigations, dispute resolution or insurance purposes, litigation or defense of claims; or
statistical, historical or scientific research.
Where the processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent. You can opt-out of receiving direct marketing communications at any time by following the instructions set out in each marketing communication or by contacting us.
How we use your personal information
We may process your personal information to:
provide our products and deliver our services, and otherwise manage our relationship with you.
analyze which products and services may be of interest to you and send you personalized marketing communications or offer you promotions and contests,
enable account management including account verification,
support our customer service and development of our products and services,
perform and analyze market surveys and marketing strategies or conduct statistical, historical, marketing, or scientific research,
detect or prevent fraud,
facilitate audits, investigations, dispute resolution or litigation, or insurance claims or other legal or regulatory compliance, or
enable a merger or acquisition, or similar corporate transaction.
Additionally, specific uses of your personal information are as follows:
Chatrooms- Our chat functionalities may collect personal information you submit to these chats to provide, improve, or develop the functionality and to better respond to your and other customers’ future interactions. By choosing to use these technologies, you understand and agree that ThinkOnward and our third-party service providers may use the information you provide in the chat for quality and training purposes, and to respond to your inquires.
Email Tracking- We may use online activity information collected, such as when you open emails from us, for marketing and data analytics purposes. This information may also be shared with certain third parties, as described below.
Personal Profiles- Depending on the nature of your engagement with ThinkOnward, we may combine information provided by you, gathered from third party sources to create a personal profile for you. This enables you to interact with different ThinkOnward products and services more seamlessly and to develop and provide tailored services and products for your specific interests. We may also use and share with certain third parties, as described below, your profile to identify individuals who have similar interests to you.
Social Media- If you interact with ThinkOnward through social media, your personal information may be visible to ThinkOnward and other visitors depending on your privacy settings on the social media platform. You can change your settings or delete any information through the platform. ThinkOnward reserves the right to access and aggregate information provided by you through its ThinkOnward Social Media Page for statistics and analytics. For more information on how your personal information is processed on those social media platforms, including any targeted advertising that you may receive, please refer to the social media platform's privacy settings and disclosures. Please contact ThinkOnward at support@thinkonward.com if you have specific questions related to your personal information on a ThinkOnward Social Media Page.
Disclosure of your personal information
Certain content related to ThinkOnward services are publicly accessible. For example, Achievement Badges, Leaderboards and Discussion forums related to Challenges are publicly accessible. Any information that you voluntarily choose to include in your public profile page or in a forum posting will also be available to the public.
Otherwise, your personal data is exclusively processed for the purposes referred to in Section 6 above and will only be shared on a strict need to know basis with:
Authorized agents, licensees, service providers, external auditors and/or subcontractors of ThinkOnward;
A competent public authority, government, regulatory, supervisory, investigative or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which ThinkOnward is subject to or as permitted by applicable law; or
Any person to whom ThinkOnward proposes to transfer any of its rights and/or duties.
As necessary or appropriate to enforce our terms and conditions, and to protect our rights, privacy, safety or property, or that of our affiliates, you, or others,
With data brokers for the purpose of data enrichment, audience matching, profiling, and look-alike audience modelling.
We may also share personal information with third party advertising partners for the purposes of serving offline personalized advertising, lookalike advertising, and suppression advertising. We may also disclose de-identified, aggregate, or anonymous information about ThinkOnward Website visitors and ThinkOnward App users, with service providers, contractors, or sub-contractors involved in advertising or marketing.
Transfers of your personal data to other countries
Where your personal data have been transferred to companies within the Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Shell group and for Shell companies in the European Union, European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of Shell Binding Corporate Rules at https://www.shell.com/privacy.html or by contacting privacy-office-SI@shell.com.
Security of your personal information
We have implemented technical, administrative, and physical safeguards designed to protect your personal information and our systems from unauthorized access and improper use. When we disclose your personal information, we have administrative and contractual measures with the recipient designed to ensure that the personal information is processed only for the stated purposes and that adequate levels of protection are in place to safeguard your personal information. These measures include Shell's Binding Corporate Rules for sharing among the Shell group of companies, which can be found at https://www.shell.us/privacy.html or by contacting privacy-office-SI@shell.com.
Cookies and similar online tracking technologies
We may use cookies, web beacons, and similar technologies that collect and store personal information when you visit a ThinkOnward Website, use a ThinkOnward App, or other interact with us through a digital platform, including your device information, IP address, and usage activity. We may use this information to improve your experience, remember your preferences, and to serve you personal advertisements. We also enable the use of advertising and social media cookies on ThinkOnward Websites; these technologies may track your online activity across third-party digital platforms that are not affiliated with ThinkOnward. With such technologies, third parties may use your personal information for their own purposes or to display ThinkOnward advertisements to you on sites and services that ThinkOnward does not operate. This is commonly referred to as targeted advertising or “selling” and “sharing” under certain consumer privacy laws.
You can control and manage your cookies preferences, including those related to online targeted advertisements, by adjusting your browser settings or by managing your consent in the cookie settings of the ThinkOnward website. For more information, please refer to the ThinkOnward Cookie Policy at https://thinkonward.com/cookie-policy. Please note that disabling these technologies may impact your use and functionality on the ThinkOnward Websites.
Your Rights and Choices
Depending on your jurisdiction of residence, you may have the right to:
Obtain confirmation that we maintain certain personal information relating to you and verify the content, origin, and accuracy of the personal information we hold about you,
Access your personal information,
Request the correction of your personal information,
Request deletion or portability of your personal information,
Opt-out of Selling, Sharing, and Targeted Advertising,
Only have your sensitive personal information, as defined in applicable law, processed with your consent,
Residents of California may request information concerning the categories of personal information (if any) we disclose to third parties or affiliates for their direct marketing purposes.
Should you choose to exercise any of your rights as detailed above, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.
Some of these rights, include the right to correct or delete your information, may be available through self-service on your ThinkOnward account profile or by following the instructions on communications received (e.g., using the "Unsubscribe" button). You may also use an opt-out preference signal to opt-out of the online sale/sharing of your personal information. We honor Global Privacy Control (GPC) in jurisdictions where the GPC signal is recognized as valid request to opt-out.
Otherwise, you may submit a request by emailing us at support@thinkonward.com.
The request must provide sufficiently detailed information for verification and to locate the personal information subject to the request. We may not be able to respond to your request if we cannot verify your identity or authority to make the request. If we need to request further information from you to verify your identity, we will only use that personal information for the purposes of identifying you or that you have authorized the request. In some states, you can designate an authorized agent to make a request on your behalf.
We will comply with your request as soon as reasonably practicable and as required by applicable law.
If you wish to opt out of targeted advertising, you can follow the instructions above in addition to the instructions under ‘Cookies and similar online tracking technologies’. Your request to opt-out of targeted advertising may be linked to your browser identifier, and as such you may have to opt-out on additional browsers or devices you use to access our websites, apps, and services. Please note that opting out of sales, sharing, and targeted advertising may not prevent all promotions and advertisements from being displayed to you, including those that do not rely on targeted advertising techniques, and may limit your ability to receive certain promotions and advertisements.
Retaining your Personal Information. We retain your personal information for only as long as necessary to fulfill the purposes for collection and use outlined above, or as otherwise required or permitted by applicable law. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. For example, we may also still need to send you service updates and notifications where such updates and/or notifications are necessary for the proper functioning of the ThinkOnward Apps or other services that you use or allowed by applicable law.
Appeals. In certain states, if we refuse to act on a request, you may appeal our decision within a reasonable period by contacting us as outlined below and specifying you wish to appeal. We will review and respond to your appeal within the timeframe required by applicable law and will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the appropriate regulatory authority for your state.
Who can you contact if you have a question, concern or complaint about your personal information?
If you have any issues, questions, or complaints regarding the processing of your personal information or this Notice, please contact us at support@thinkonward.com. You may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands - Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, privacy-office-SI@shell.com.
If you would like to receive this Notice in an alternative format (for example, in larger print) please email us at support@thinkonward.com.
Without prejudice to the abovementioned rights or any additional rights you may have under applicable law, you may also lodge a complaint about ThinkOnward's handling of your personal information with the Dutch Data Protection Authority ("DPA"), which serves as the lead supervisory authority for the Shell group of companies. The Dutch DPA's address is Hoge Nieuwstraat 8, 2514 EL The Hague, Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.
Changes to this Notice
We reserve the right to update this Notice periodically and without notice, for example, when a new category of personal information is collected and used and upon changes/enactment of data protection and privacy laws. You are advised to regularly review this Notice and the last updated date for changes. This Notice was last updated in September 2025.