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Radyushin Pty Ltd (trading as “Power Thesaurus”, in this document can be referred as “Power Thesaurus”, “we,” “us,” or “our”) respects your privacy and is committed to being transparent about the tracking technologies we use. This Privacy & Cookie Policy describes our practices concerning the personal information collected through our website powerthesaurus.org and any related Power Thesaurus products and services including the Power Thesaurus, Power Thesaurus Free, Power Thesaurus Pro mobile apps, Power Thesaurus Browser extensions, Power Thesaurus add-ons (provision of the Sites and related products and services, collectively the “Services.”) and explains why explains how cookies, web beacons, pixel tags, clear gifs, and other similar files or technologies may be used to collect and store the information automatically collected about your computer, device, and Service usage and how you can control the use of these technologies. If you do not accept the use of cookies, please disable them as described in the Cookie Controls. Introduction Your privacy is important to us. We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes Power Thesaurus’s policies and practices regarding its collection and use of your personal data through our free, ad-supported www.powerthesaurus.org website and related mobile application services and any software provided on or in connection with these services (the Services), and sets forth your privacy rights. For our EU users and visitors, we actively have been working towards compliance with the EU’s General Data Protection Regulation (GDPR), and plan to further update our cookie notices and implement consent management tools for users located in the EU as soon as possible. In the meantime, if you have concerns, please contact our data protection officer at dpo@powerthesaurus.org. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies. The Services may provide links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. Our Services are intended for general audiences over the age of 16 years old. We do not knowingly collect information from children under the age of 16 years old. Your privacy choices You have choices when it comes to the privacy practices described in this Privacy & Cookie Policy, including your choices related to: Targeted Advertising. See Web Browser Controls and Third Party Advertising Controls Website Analytics. See Web Browser Controls and Google Analytics Controls Information we collect We collect information about you from a variety of sources, including from you directly providing it to us (e.g., when you open an account or contact us), from cookies and other tracking technologies that automatically collect information in the course of your use of the Services (skip to Cookies and Other Trackers) and from various third parties and public sources. You can use some of the Services without directly providing any information, but if you do not provide certain information or limit the operation of some cookies, you may not be able to use some of the Services we offer. Information we collect that you provide to us Power Thesaurus protects the identity of visitors to the Services by limiting the collection of personally identifiable information. Personal information provided by you to us will not be posted or published by us, and will be shared with third parties only as provided herein. You can enjoy many of our Services and their special features without giving us your personal information. Access to the general content on our Sites does not require you to provide us any personal (e.g., name, date of birth), contact (e.g., email address, phone number) and/or account (username and password) information. You may provide personal information to us, if you choose to: create or update your account subscribe for paid PRO Membership on our website, apps, extensions sign up for one of our newsletters submit a help request, feedback, report, send us an email, a customer services inquiry or other inquiry to us, or fill in any other forms for the purposes of receiving our Services; Payments and subscriptions on our website We collect information related to subscription management including billing date, status of subscription, status of individual payments, payment amount, date/time of payment. We do not collect financial information from you (such as your payment card number, expiration date or security code). All subscription payments to us are handled via a third party, Paddle Ltd (https://paddle.com). Paddle's Privacy Notice: https://paddle.com/privacy-buyers/. Payments and subscriptions on apps Our mobile applications on iOS and Google Android Play Store include subscription services, which necessitate the collection of specific information related to the management of these subscriptions. This information includes details such as the billing date, subscription status, individual payment statuses, payment amounts, and date/time of payments. We do not collect financial information from you (such as your payment card number, expiration date or security code). All app subscription payments to us are handled via a third party, Apple (https://apple.com) or Google (https://google.com). Apple Privacy Policy: https://www.apple.com/legal/privacy/en-ww/. Google Privacy Policy: https://policies.google.com/privacy. Purposes for processing personal data provided directly by you As explained above, Power Thesaurus processes your data to provide you with the products and services you have requested or purchased from us, including special features, e-newsletters and other content. Sometimes we use third-party providers to facilitate the delivery of the services described above, and these third-party providers may be supplied with or have access to your personal information for the sole purpose of providing services to you on our behalf. We also use your data for legitimate business purposes that enable us to refine our products and services to better tailor them to your needs and communicate with you about other products and services offered by Power Thesaurus, such storage of IP address and date/time for new entry submissions. In addition, we may disclose your personal information in special legal circumstances. For instance, such information may be used where it is necessary to protect our copyright or intellectual property rights, or if the law requires us to do so. You can update your personal information and change your marketing preferences at any time by sending an email to privacy@powerthesaurus.org. Information we collect via automated technologies and interactions. As you interact with the Services, we may collect information via automated means about your computer or mobile device, your preference settings, your location and your activities, including: IP address of your computer; Unique mobile device identifier; Technical information about your computer or mobile device such as type of device, mobile device ID number, screen resolution, web browser information and operating system or platform; Your preferences and settings (time zone, language, etc.); Internet provider or mobile carrier name; The URL of the last webpage you visited before visiting the Site; Information about your activity on the Services (e.g., your search queries, mis-formatted DNS entries, search results selected, clicks, pages viewed, search history, comments); If you are using a mobile device, your mobile device’s geographic location (specific geographic location if you’ve enabled collection of that information, or general geographic location automatically); and If you installed an Application, we may also collect information about that Application (e.g. the specific release date and distribution source of your Application, a unique Application ID, Application partner ID, the ads you click on, and information contained in error log files or cookies, aggregate query or click data and erroneous domain name system requests). How we use your information We may use your information for the following purposes: Identification and authentication: We use your identification information to verify your identity when you access and use our Services and to ensure the security of your personal information. This is so we can comply with our contractual obligations to you. Provide the Services: We process your personal information to provide the Services you have requested. This is so we can comply with our contractual obligations to you. Improving our Services: We analyze information about how you use our Services to provide an improved experience for our customers of all our Services, including product testing and site analytics. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Services and improve them. Compensating our partners: We process your personal information for purposes of calculating compensation to be paid to our third party product/service providers and distributors and to analyze usage across products, services and distribution partner/channel. It is in our legitimate interest to appropriately determine amounts to be paid to our partners and inform our product roadmap and distribution strategy. Communicating with you: We may use your personal information when we communicate with you, for example if we are providing information about changes to the terms and conditions or if you contact us with questions. It is in our legitimate interest that we are able to provide you with appropriate responses and provide you with notices about our Services. Marketing: We may use your personal information to deliver relevant advertisements to you and measure the effectiveness of the advertising we serve to you. It is in our legitimate interest to provide more relevant and interesting advertising messages and inform our marketing strategy. We may use automated decision-making to deliver tailored advertisements based on your personal information. Where necessary, we will obtain your consent before sending such marketing messages. Messaging: to send you welcome, informational, educational, marketing and promotional messages, account updates, transactions and other information about our products, services and relevant topics that may be of interest to you, including information sent by, or on behalf of, our business partners. Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our Terms of Service. Complying with our obligations: We may process your personal information to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law. Customizing your experience: When you use the Services, we may use your personal information to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests. We may use automated decision-making to customize your experience based on your personal information. We may also aggregate and de-identify your information in such a way that you may not reasonably be re-identified by us or any other company, and may use this information for any other purpose. How do we share your information We share user information with others for various reasons. What information we make available to other companies depends on the nature of our relationships with them. Service Providers: We may share your information with vendors who provide services on our behalf such as voice transcription, email messaging, customer service, trouble shooting, survey providers, video players. Contests/Sweepstakes Partners: When you sign up to participate in a contest or sweepstakes, your information may be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers, operators, or sponsors’ privacy policies or practices. Group Companies: We may share your information with our affiliates for security, internal reporting and regulatory compliance. Fraud prevention: We may disclose your information when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others. Law enforcement purposes and public safety: If requested or required by government authorities, such as law enforcement authorities, courts, or regulators, or otherwise to comply with the law, we may disclose any information we have about our users. We may disclose information collected about you in order to exercise or protect legal rights or defend against legal claims. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Sale or merger of our business: We may transfer your information to a third party if we or any of our affiliates are involved in a corporate restructuring (e.g., a sale, merger, or other transfer of assets). Advertisers and advertising networks: Advertisers and advertising networks place ads on our Sites. These companies may collect information, such as your computer’s IP address, browser information, mobile device ID, and search queries, as you use our Site and Services. They also may use cookies and other technologies to collect this information when you use our Service as described below (Cookie & other Trackers). We require all third parties to respect your privacy and to treat your information in accordance with the law. We only permit third parties to process your personal data for specified purposes and in accordance with our agreements with them. We do not sell or trade your information to third parties, but we share with others who can help us achieve the Power Thesaurus vision. That can be other Power Thesaurus companies, service providers or business partners. We’re all committed to keep your information safe and secure. How we share information with Google We use Google Analytics to analyze the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html. We may at some point publish Google AdSense, Google Ad Manager or Google AdX interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behavior on our website and on other websites across the web using the DART cookie. You can view, delete or add interest categories associated with your browser using Google’s Ads Preference Manager, available at: https://www.google.com/ads/preferences/. To read more about the way Google uses the information please use the following link: https://policies.google.com/technologies/partner-sites You can opt out of the AdSense partner network cookie at: https://www.google.com/privacy/ads/ or by using the NAI’s (Network Advertising Initiative’s) multi-cookie opt-out mechanism at: https://www.networkadvertising.org/managing/opt_out.asp However, these opt-out mechanisms use cookies, and if you clear the cookies from your browser, your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you should use the Google browser plug-in available at: https://www.google.com/ads/preferences/plugin. Mobile device location Information When you use one of our location-enabled services (for example, when you access Services from a mobile device), we may need to collect and process information about your specific GPS location (including the latitude, longitude or altitude of your mobile device) and the time the location information was recorded, and we may use that information to customize the Services with location-based information, advertising, and features. Some of these services require us to associate location data with your device ID and other information we hold about you. Cookies and other trackers Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. A pixel tag (also called a web beacon or clear GIF) is a tiny graphic with a unique identifier, embedded invisibly on a webpage (or an online ad or email) that links web pages to particular web servers and their cookies, and may be used for a variety of purposes, such as counting the number of visitors to the Sites, analyzing how users navigate around the Sites, assessing what content or ads are viewed or clicked on by our visitors. Some ad companies and game developers use “flash cookies” for ads and games that use Flash media technology. We use the term “cookies” in this policy to refer to cookies and all such similar technologies. Cookies are widely used in order to make websites work, or to work more efficiently, as well as to provide information to the owners of the site. We use these technologies to let you navigate between pages efficiently, remember your preferences, track your use of the Services and generally improve your experience. Ad companies we work with place cookies on your computer to track your activities across various sites so that they can display ads on our Sites and third party websites that are more relevant to you and your interests. Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are ‘permanent cookies’, meaning that they survive after your browser is closed. They can be used by websites to recognize your computer when you open your browser and browse the Internet again. There are two broad categories of cookies: First party cookies, served directly by us to your computer or mobile device. Third party cookies, which are served by a third party on our behalf. We use third party cookies for functionality, performance / analytics, advertising and social media purposes. How do we use cookies We use cookies to: track traffic flow and patterns of travel in connection with our Services; understand the total number of visitors to our sites on an ongoing basis and the types of internet browsers (e.g. Chrome, Safari or Edge), operating systems (e.g. Windows or Mac OS), and screen resolutions used by our visitors; monitor and analyze the performance of our Services and to continually improve them; customize and enhance your online experience, including your search history, search suggestions and popular terms; and enable our and third-party advertising both on and off our Sites. Third parties whose products or services are accessible or advertised through the Services, including social networking services, may also use cookies or similar tools, and we advise you to check their privacy policies for information about their cookies and other practices. We do not control the practices of such partners and their privacy policies govern their interactions with you. We encourage you to read their privacy policies. What types of cookies do we use The types of cookies used by us and our partners in connection with the Services can be classified into one of the 4 categories below. We’ve set out some further information about each category, and the purposes of the cookies we and third parties set below: Strictly necessary cookies. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies some services cannot be provided. Functional cookies. These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to sorting, text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. Performance cookies. These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. Tracking cookies. These cookies record your visit to our website, the pages you have visited, the material you have downloaded and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interest and to provide information to our sales team. We will also provide this information to third parties for these purposes. Social Media Cookies. Third parties that make their applications available through/on our Sites may set their own cookies in order to track the performance of their applications or customize those applications for you. For example, when you share an article using a social media sharing button on our Sites (e.g., Facebook, Twitter, or Instagram), the social network that has created the button will record that you have done this. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. Some pages of our website may also contain embedded content, such as video content from YouTube, and these sites may set their own cookies. Cookie controls You can control your cookie settings as explained below. We may disclose your opt-out choices to third parties so that they can honor your preferences in accordance with applicable laws. Web Browser Controls. Most browsers allow you to change your cookie settings. Users can usually set their browsers to block all third-party cookies (which are those set by third-party companies collecting information on websites operated by other companies), block all cookies (including first-party cookies such as the ones We uses to collect search activity information about its users), or block specific cookies. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details. Cookie settings in Chrome Cookie settings in Safari web and iOS Cookie settings in Microsoft Edge Cookie settings in Firefox We note that an optional browser setting known as Do Not Track allows you to express your preferences regarding tracking by advertisers and other third-parties. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. Flash Cookie Controls. You can manage the use of Flash technologies with the Flash management tools available at Adobe’s website. Web-Beacons. You can usually prevent the operation of web-beacons by changing your web-browser cookie settings and your ad choices, or for those in emails, by switching off images in your email client or viewing emails using only the “text” display (rather than “HTML” display”). See the “Help” section of your email client for instructions. Please see the All About Cookies website for further information about managing your options. Mobile Apps. With respect to our mobile apps, you can stop all collection of information via an app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. Google products including Analytics, AdWords, AdSense, Ad Manager. To see an overview of privacy at Google and how to opt out of certain Google practices, visit https://www.google.com/intl/en/policies/privacy. You can prevent your data from being collected by Google Analytics by downloading the Google Analytics Opt-out Browser Add-on. Opting-out is generally done by the third party dropping a cookie on your browser indicating your intent to opt-out. If you get a new device, install a new browser, erase, or otherwise alter the third party’s browser cookie file, you may clear the opt-out cookie and no longer be subject to its opt-out. Third Party Advertising Controls. You may exercise choices regarding certain third party advertising cookies through the following organizations: Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You exercise the DAA choices regarding Interest-based Advertising here. You can also download the DAA AppChoices app for control over how information about your interests is used for in-app advertising on your mobile device here. European Interactive Digital Advertising Alliance (“EDAA”). To learn more about the EDAA and your opt out options, see Your Online Choices. Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain Interest/behavioral/targeted -based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest/behavioral/targeted -based ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Power Thesaurus is not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs. Promotional Communications. You can opt-out of receiving certain promotional communications (e-mails and push notifications) from us at any time by (i) for e-mails, following the instructions as provided in e-mails to click on the unsubscribe link; and (ii) for push notifications or in-app messages, adjusting the permissions in your mobile device. Please note it may be possible to disable some (but not all) cookies through your device or browser settings, but doing so may interfere with certain functionality on the Services. Business transfers As we continue to develop our business, we might sell or buy subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). Also, in the unlikely event that Power Thesaurus, or substantially all of its assets are acquired, customer information will be one of the transferred assets, and will remain subject to our Privacy Policy. Account Deletion & Data Erasure You can delete your Power Thesaurus account at any time. Once you do, we stop processing your personal data for that account and begin permanent erasure according to the timelines below. If you are unable to access your account, you can request deletion by email. How to delete your account (self-service): Log in at https://www.powerthesaurus.org Tap your avatar icon in the upper-right corner Open Account Settings Click Delete account, then confirm If you have an active subscription, cancel it first before proceeding with deletion. If you cannot access your account: If you can’t log in, please send an email from the same address linked to your account to team@powerthesaurus.org with the subject “Delete my account”. Include any details that can help us locate your account (for example, your account usage, approximate last login date). For security reasons, we’ll reply to confirm the request and ensure you can receive messages at that address before proceeding with deletion. We may request additional details to verify your identity before completing the deletion. What we delete (and when): Account data (name, email, username, profile image, settings) — removed from active systems within 7 days, logs within 30 days, and encrypted backups within 90 days. Usage and device data (searches, votes, clicks, IPs, browser or app details) — deleted or irreversibly de-identified within 30 days. User contributions (for example, public votes or submissions) — deleted or anonymized so they are no longer linked to you. Customer-support records — deleted or minimized after 180 days, unless retained longer for security, fraud-prevention, or legal reasons. Payment and subscription metadata — retained only as required for accounting, tax, or fraud-prevention purposes for up to 7 years. This action immediately signs you out of all sessions and schedules your account for deletion. Deletion timelines reflect normal retention and backup schedules. After backups cycle out, the data becomes unrecoverable. Where immediate deletion is technically or legally constrained, we isolate the data and cease processing it except for required retention. Your EU Rights Based on the GDPR you may have rights available to you in respect of your Personal Information, such as: To obtain a copy of your Personal Information together with information about how and on what basis that Personal Information is processed; To rectify inaccurate Personal Information (including the right to have incomplete Personal Information completed); To delete your Personal Information (where it is no longer necessary in relation to the purposes for which it was collected or processed). We strive to anonymize your Personal Information within 30 days after your deletion request; To restrict processing of your Personal Information under certain circumstances. To port your Personal Information in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of an agreement with you; To withdraw your consent to our processing of your Personal Information (where that processing is based on your consent); To obtain, or see a copy of the appropriate safeguards under which your Personal Information is transferred to a third country or international organization outside of the European Economic Area; To lodge a complaint with your local supervisory authority for data protection. In addition to the above rights, you have the right to object, on grounds relating to your particular situation, at any time to any processing of your Personal Information which we have justified on the basis of a legitimate interest, including profiling (as opposed to your consent) or to perform a contract with you. You also have the right to object at any time to any processing of your Personal Information for marketing or promotional purposes, including profiling for marketing or promotional purposes. In relation to all of these rights or if you have any questions about this Privacy Statement, please send an email to dpo@powerthesaurus.org. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, especially if your request is manifestly unfounded or excessive. We will endeavor to respond to your request within all applicable timeframes. Your California Privacy Rights This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or "CCPA". We do not sell the Personal Information we collect to third parties for money or any other consideration, as that term is generally understood. However, the CCPA’s definition of "sale" is very broad and might be construed to include the following: Situations where browsing data is sent to referral advertisers - when you click on an ad that sends you to our website, we send a hashed identifier to the referring site so they can receive credit for the referral. We, along with millions of other sites, use these services. While we limit the information sent to what is needed to properly record the referral, the fact that you clicked on the link and visited Revinate may be added to your profile by the ad publisher. You have the right to opt out of this by sending us a request as described below. Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any "sales" that may be occurring, and to not be discriminated against for exercising these rights. California consumers may make a request pursuant to their rights under the CCPA by send us an email to dpo@powerthesaurus.org. Contact us If you have any questions or concerns about this Privacy & Cookie Policy or the manner in which your information is processed or would like to submit a request to us, please contact: Power Thesaurus 2633 Gold Coast Highway, Broadbeach, QLD 4218 Australia privacy@powerthesaurus.org EU representative Concerning Article 27(2)(a) of the GDPR, a representative is not required when a company is processing EU personal data, if: personal data is only processed occasionally processing does not include large-scale processing of special categories of personal data or personal data relating to criminal convictions and offences and processing is unlikely to result in a risk to the rights and freedoms of data subjects. We believe that the above mentioned exceptions are applicable for Power Thesaurus and there is no real need or legal requirement to appoint EU Representative for Power Thesaurus. Data protection officer If you have questions or concerns regarding the way in which your personal information, collected in the EEA, is processed or transferred, please contact our Data Protection Officer at: Alexander Radyushin Data Protection Officer 2633 Gold Coast Highway, Broadbeach, QLD 4218 Australia dpo@powerthesaurus.org