ThinkAhead Privacy Policy

Updated September 18, 2021

In addition to this Privacy Policy, we provide data and privacy information embedded in our products and certain features that ask to use your personal information.

You will be given an opportunity to review this product-specific information before using these features.

What Is Personal Data at ThinkAhead?

At ThinkAhead, we believe strongly in fundamental privacy rights — and that those fundamental rights should not differ depending on where you live in the world. That’s why we treat any data that relates to an identified or identifiable individual or that is linked or linkable to them by ThinkAhead as “personal data,” no matter where the individual lives. This means that data that directly identifies you — such as your name — is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you — such as the username or avatar associated with you— is personal data. Aggregated data is considered non-personal data for the purposes of this Privacy Policy.

This Privacy Policy covers how ThinkAhead, or an ThinkAhead-affiliated company handles personal data whether you interact with us on our websites, through ThinkAhead apps (such as ThinkAhead UnivMo Wallet), or in person (including by phone or by email). ThinkAhead may also link to third parties services. ThinkAhead’s Privacy Policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

Your Privacy Rights at ThinkAhead

At ThinkAhead, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We have provided these rights to our global customer base and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from ThinkAhead. ThinkAhead does not sell your data including as “sale” is defined in Nevada.

There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and ThinkAhead is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for antifraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical.

If you live in California, if you cannot access ThinkAhead’s Privacy page, you or your authorized agent can make a request at by calling 1-702-945-2858.

Personal Data ThinkAhead Collects from You

At ThinkAhead, we believe that you can have great products and great privacy. This means that we strive to collect only the personal data that we need.

When you create an ThinkAhead account, purchase and/or activate a service, connect to our services, contact us (including by social media), participate in an online survey, or otherwise interact with ThinkAhead, we may collect a variety of information, including:

• Account Information. Your ThinkAhead account and related account details, including email address, devices, account status, and age

• Device Information. Data from which your device could be identified, such as device serial number, or about your device, such as browser type

• Contact Information. Data such as name, email address, physical address, phone number, or other contact information

• Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information

• Transaction Information. Data about purchases of ThinkAhead products and services or transactions facilitated by ThinkAhead, including purchases on ThinkAhead platforms

• Fraud Prevention Information. Data used to help identify and prevent fraud, including a device trust score

• Usage Data. Data about your activity on and use of our offerings, such as app and services, including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data

• Location Information. Precise location only to support services that require such data for validation of an action

• Financial Information. Details including salary, income, and assets information where collected, and information related to ThinkAhead-branded financial offerings

• Government ID Data. In certain jurisdictions, we may ask for a government-issued ID in limited circumstances, including when setting up a financial account and activating your device, for the purpose of extending credit, managing reservations, or as required by law

• Other Information You Provide to Us. Details such as the content of your communications with ThinkAhead, including interactions with customer support and contacts through social media channels

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

Personal Data ThinkAhead Receives from Other Sources

ThinkAhead may receive personal data about you from other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources.

• Individuals. ThinkAhead may collect data about you from other individuals — for example, if that individual has sent you a product or gift card, invited you to participate in an ThinkAhead service or forum, or shared content with you.

• At Your Direction. You may direct other individuals or third parties to share data with ThinkAhead. For example, you may direct your mobile carrier to share data about your carrier account with ThinkAhead for account activation, or for your loyalty program to share information about your participation so that you can earn rewards for ThinkAhead purchases.

• ThinkAhead Partners. We may also validate the information you provide — for example, when creating an ThinkAhead account, with a third party for security, and for fraud-prevention purposes.

ThinkAhead’s Use of Personal Data

ThinkAhead uses personal data to power our services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.

ThinkAhead uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance, ThinkAhead may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.

• Power Our Services. ThinkAhead collects personal data necessary to power our services, which may include personal data collected to personalize or improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting.

• Process Your Transactions. To process transactions, ThinkAhead must collect data such as your name, purchase, and payment information.

• Communicate with You. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with ThinkAhead, you may not opt out of receiving these important notices.

• Security and Fraud Prevention. To protect individuals, employees, and ThinkAhead and for loss prevention and to prevent fraud, including to protect individuals, employees, and ThinkAhead for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.

• Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.

ThinkAhead does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review.

ThinkAhead retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

ThinkAhead’s Sharing of Personal Data

ThinkAhead may share personal data with service providers who act on our behalf, our partners, or others at your direction. Further, ThinkAhead does not share personal data with third parties for their own marketing purposes.

• Service Providers. ThinkAhead may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering products to customers. ThinkAhead service providers are obligated to handle personal data consistent with this Privacy Policy and according to our instructions. They cannot use the personal data we share for their own purposes and must delete or return the personal data once they've fulfilled our request.

• Partners. At times, ThinkAhead may partner with third parties to provide services or other offerings. For example, ThinkAhead financial offerings like ThinkAhead UnivMo Wallet and ThinkAhead Finance are offered by ThinkAhead and our partners. ThinkAhead requires its partners to protect your personal data.

• Others. ThinkAhead may share personal data with others at your direction or with your consent, such as when we share information with your carrier to activate your account. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

Protection of Personal Data at ThinkAhead

At ThinkAhead, we believe that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure.

Cookies and Other Technologies

ThinkAhead’s websites, online services, interactive applications, and advertisements may use cookies. This technology helps us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.

• Communications Cookies. These cookies are used to enable network traffic to and from ThinkAhead’s systems, including by helping us detect any errors.

• Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our websites in the proper format and language, to authenticate and verify your transactions, and to preserve the contents of your Bag when shopping online at ThinkAhead.com.

• Other Cookies. These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of advertisements and web searches. ThinkAhead also uses these cookies to remember choices you make while browsing, so we can provide you with a customized experience.

If you prefer that ThinkAhead not use cookies, you may disable their use. Certain features of the ThinkAhead website may not be available if all cookies are disabled.

In addition to cookies, ThinkAhead uses other technologies that help us achieve similar objectives.

In some email messages ThinkAhead sends to you, we provide a “click-through URL” that links you to content on the ThinkAhead website. When you click one of these URLs, they pass through a separate server before arriving at the destination page on our website. We track this click-through to help us determine interest in particular topics and measure whether we are communicating with you effectively. If you prefer not to be tracked in this way, you should not click graphic or text links in email messages.

ThinkAhead generally treats data we collect using these cookies and similar technologies as nonpersonal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data in those regions. In addition, ThinkAhead sometimes combines nonpersonal data collected from these technologies with other personal data ThinkAhead holds. When we combine data in this way, we treat the combined data as personal data for purposes of this Privacy Policy.

Transfer of Personal Data Between Countries

ThinkAhead products and offerings connect you to the world. To make that possible, your personal data may be transferred to or accessed by entities around the world. ThinkAhead complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be.

Our Companywide Commitment to Your Privacy

To make sure your personal data is secure, we communicate our privacy and security guidelines to ThinkAhead employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have questions about ThinkAhead’s Privacy Policy or privacy practices, would like to contact our Data Protection Officer, or would like to submit a complaint, you can contact us via phone at 702-945-2858. You can also ask us questions about how to submit a privacy complaint.

Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person, we will take steps to address that with you or that other person.

When there is a material change to this Privacy Policy, we’ll post a notice on this website at least a week in advance of doing so and contact you directly about the change if we have your data on file.