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Privacy Policy

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Theia Group, Incorporated Online Privacy Policy

Last modified: October 2019

Theia Group, Incorporated and its affiliates and subsidiaries (collectively, “we,” “our,” or “us”) are committed to protecting the privacy of our website users. This policy describes our information collection and use practices when you visit the Theia Website www.theiagroupinc.com or any website, mobile application or online service that links to this policy (collectively, the “Website”).

This policy applies to information we collect:

  • on the Website; or
  • in e-mail, instant messages, and other electronic messages between you and the Website.

This policy does not apply to information collected by third parties, including through any third party applications or content that the Website may link to or by us offline or through any other means, including from clients or others.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By accessing or using the Website, you agree to this privacy policy. This policy may change from time to time (see Changes to our Privacy Policy below).

Information We Collect

Information You Provide Us

The information we collect on or through our Website that is provided by you includes:

  • Information that you provide by filling in forms on our Website. This includes information provided when contacting us, or requesting further services, such as your personal details (e.g. name), contact details (e.g. phone number, e-mail address, or postal address)
  • Records and copies of your correspondence (including e-mail addresses), if you contact us.

Information We Collect Automatically

We may automatically collect information from your computer through server logs and third party applications. This includes for example:

  • Information such as internet protocol address, your general geographic location, your browser type, your operating system, the pages you view on the Website, the pages you view immediately before and after you access the Website, and the search terms you enter on the Website. As explained below we also collect information through cookies and similar technologies.

Cookies and Similar Technologies

As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment and activities.

We or third parties operating on the Website may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not respond to web browser “do not track” signals or other similar mechanisms. However, if you do not wish for us to collect information about you through automatic data collection technologies, you may set your browser to refuse cookies. Some parts of the Website, however, may not be accessible or may not function or function as expected as a result.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Click Tracking. Click tracking is a tool used to determine and record what a user clicks on while browsing through the Website. Our Website may use click tracking to conduct market research and software testing.
  • Web Beacons. Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Information We Collect via Third Parties

We or third parties collect some personal information via the Website. This includes:

Google Analytics (Google, Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.

Information collected: IP address, general location.

Mailing List (MailChimp or other email service providers)

When you sign up to receive e-mail from us, your e-mail address will be added to the contact list of those who may receive e-mail messages containing information of commercial or promotional nature concerning this Website. Your e-mail address might also be added to this list as a result of signing up to this Website. You may remove yourself from the mailing list at any time by clicking the Unsubscribe link in the footer of any newsletter, or you can send us an e-mail to be manually removed from the list.

Information collected: e-mail address, first name, and last name.

Collection from other Third Parties

We may also append offline information we possess or obtain about you from third party data sources with information we have collected about you online.

How We Use Your Information

We use information that we collect about you or that you provide to us:

  • To present the Website and its contents to you. It is in our legitimate business interests to use the information provided to us for this purpose.
  • To provide you with information that you request from us. It is in our legitimate business interests to use the information provided to us for this purpose.
  • To notify you about changes to our Website or any products or services we offer or provide though it. It is in our legitimate business interests to use the information provided to us for this purpose.
  • To deliver marketing communications, promotional materials, or advertisements that may be of interest to you. It is in our legitimate business interests to use the information provided to us for this purpose.
  • To customize your experience when using the Website, such as by providing interactive or personalized elements on the Website and providing you with content based on your interests. It is in our legitimate business interests to use the information provided to us for this purpose.
  • To generate and analyze statistics about your use of the Website. It is in our legitimate business interests to use the information provided to us for this purpose
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. This is so we can comply with our contractual obligations to you or in furtherance of entering into a contract with you.
  • To detect, prevent, and respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Website. It is in our legitimate business interests to use the information provided to us for this purpose.
  • In any other way we may describe when you provide the information. It is in our legitimate business interests to use the information provided to us for this purpose.
  • For any other purpose with your consent. It is in our legitimate business interests to use the information provided to us for this purpose.

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy to unaffiliated third parties under the following circumstances:

  • To contractors, service providers, and business partners. We may share your personal information with our contractors, service providers, and business partners that perform marketing services and other business operations for us or with whom we partner for a business purpose, such as a joint offering. For example, we may use service providers to optimize our services, send newsletters, support e-mail services, and analyze information.
  • To asset purchasers or potential purchasers. We may share your information with a buyer, potential transactional partner, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Theia Group, Incorporated’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Theia Group, Incorporated about our Website users is becomes part of a new or acquiring entity or is among the assets transferred.
  • Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties when we believe this is necessary to comply with any court order, law or legal process, including to respond to any government or regulatory request, or to otherwise protect our rights or the rights of any third party.

We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction.

The Website also may contain third-party links. You acknowledge and agree that we are not responsible for the collection and use of your information by such third parties that are not under our control. We encourage you to review the privacy policies of each website you visit.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the information you provide to us. We have created certain mechanisms to provide you with the following control over your information:

  • Tracking Technologies. For purposes of advertising and other behavioral tracking, our systems recognize “do not track” signals from your browser. However, the Website may still utilize cookies even if you have enabled Do Not Track in your browser, in order to track session data that is critical to the Website's functionality, such as verifying a user's identity. Visit https://www.allaboutdnt.com for more information about Do Not Track functionality.
  • E-mails. If you receive a commercial e-mail from us, you will have the opportunity to opt-out of the e-mail through an opt-out or unsubscribe option at the bottom of the e-mail.

Data Security and Storage

We and our partners have implemented administrative, technical, and physical measures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our Website, submitted by you, information gathered about you, or information stored by us. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. Moreover, we are not responsible for the security of information you transmit to the Website over networks that we do not control, including the internet and wireless networks.

We will keep your personal information for as long as necessary for legitimate business purposes, including to comply with legal requirements and to investigate or defend potential legal claims.

Where Information is Processed

Information collected through the Website will be processed in and subject to the laws of the United States, which, if you are not located in the United States, may not provide the same level of protection for your personal information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries. By using the Website, you consent to such transfer to, and processing in, the United States and these other countries.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

Children Under the Age of 13

The Website is intended for adults 18 years of age and older and is thus not intended for children under 13 years of age. No one under age 13 may provide any information to or post any information on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not (i) use or provide any information on the Website or on or through any of its features, (ii) register on the Website, (iii) use any of the interactive or public comment features of the Website, or (iv) provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If you believe we might have any information from or about a child under 13, please contact us at legal@theiagroupinc.com.

Your California Privacy Rights

If you reside in California and have provided your personally identifiable information to us, you may request information once per calendar year about our disclosures of certain categories of your personally identifiable information to third parties for their direct marketing purposes. Such requests must be submitted to us via e-mail at the following e-mail address: admin@theiagroupinc.com.

Other Rights of Users

Under certain laws, if applicable depending on where you reside, you may exercise certain rights regarding your personal information. These may include the right to:

  • Withdraw your consent.
  • Object to processing of your personal information.
  • Access your personal information.
  • Rectify the information we hold about you.
  • Restrict the processing of your personal information.
  • Erase your personal information.
  • Receive your personal information in a usable electronic format and transmit it to a third party (right to data portability).
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Please note that we will likely require additional information from you in order to honor your requests.

If you would like to discuss or exercise such rights, please contact us at the address listed below.

Changes to Our Privacy Policy

Occasionally we may, in our discretion, make changes to the Privacy Policy. When we make changes to the Privacy Policy, we’ll post a new Privacy Policy on this page. If we make any revisions that materially change the ways in which we use or share the information previously collected from you through the Website, we will provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Website or by sending you an e-mail. Your continued use of the Website after the changes have been made will constitute your acceptance of the changes.

You may request a copy of this privacy notice from us using the contact details set out below. We may modify or update this privacy notice from time to time. You will be able to see when we last updated the privacy notice because we will include a revision date. Changes and additions to this privacy notice are effective from the date on which they are posted.

How to Contact Us

You may contact us with questions or comments about this privacy policy at the address listed below.

Owner and Data Controller

Theia Group, Incorporated is, where applicable, the controller responsible for the personal information we collect and process. If you have questions or concerns regarding the way in which your personal information has been used, please contact:


Theia Group, Incorporated 1455 Pennsylvania Avenue, Suite 600 Washington, DC 20004

Effective: October 1, 2019