Privacy Policy

Last updated: September 11, 2018

Communication Labs Ltd (“us”, “we”, or “our”) operates the Thrive Matters website and mobile application(s) (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service. You can also find the version of this document at We will not use or share your information with anyone except as described in this Privacy Policy.

Communication Labs provides a personal development application called Thrive Matters. Thrive Matters is designed to help you identify your personality traits and character strengths and to determine group or team characteristics that may include your traits. Communication Labs assumes by your answers to the questions provided in Thrive Matters, that you understand these responses will be used to derive outputs to you and the organization that has invited you to connect and complete the questions.

You can read our Terms of Service at

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Communication Labs Ltd of Albuquerque NM, USA.

Information Collection and Use

Communication Labs collects two types of information: Personal information, which means information that can be used to uniquely identify and contact you; and non-personal information, which does not provide direct association with you.

When you register to use Thrive Matters we collect the following:

  • Your sign-in data (which includes: your name, email address and password), which we use to identify you so you have exclusive access to your account.
  • Your demographic information, which we use for our research. Your demographic information is non-personal. Your age is used to help provide guidance on content relevance provided to you in the application.
  • Your answers to our questionnaires, which will allow us to create a customized profile for you. Your answers to our questionnaire are non-personal but we link the answers to your account details which is used to support the profile. Traits from your profile may be included in collective/group analysis if you accepted to join as part of an organization. If surveys are provided and you have accepted to be part of an organization, then your responses may be provided to the organization.
  • Any data which is used for research will be anonymized.
  • Device information. We may collect information about the device or any computer you may use to download or stream a copy of the Thrive Matters application on your device, including, where available, the device’s or computer’s unique device identifiers, operating system, browser type and mobile network information as well as the device’s telephone number, for system administration. We may associate device information with your sign-in data and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
  • Log information. When you use Thrive Matters, we may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, internet service provider (ISP), clickstream data, browser type and language, viewed and exit pages and date or time stamps.
  • If you connect using our mobile application, we may request to send you push notifications regarding your account or Services. If you wish to opt-out from receiving these types of communications, you may turn them off using your device’s settings.

If you contact us for customer service, we may also collect any information you give us. We use this information to identify you as a customer and help improve our service.

When you use Thrive Matters for further personal development, we collect non-personal information on your usage and responses. We use this information to provide you with personalized feedback.

Disclosing Information

We will not sell, rent or give any of your personal information to third parties, with the following exceptions:

  • If we need to in order to provide a product or service you have requested.
  • If you have explicitly given us permission to do so.
  • If you have been provided access to this application by an organization and they have requested access to specific personal information that has been disclosed to you.

And except from the following circumstances:

  • If we are responding to a subpoena, court order, or legal process, or to establish or exercise our legal rights or to defend ourselves against legal claims.
  • If we have to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.
  • If we are acquired by or merged with another company.
  • If with an affiliate who has agreed to honor this privacy policy. Affiliates include any parent company and any subsidiaries, joint venture partners or other companies that we control or under common control with us.

Thrive Matters may allow you to share your profile on other platforms from time to time. If you do this, or if you share your information publicly in any other way, the information becomes publicly accessible and is no longer covered by this privacy policy. Remember that putting personal information online where it is publicly accessible means third parties can collect it and use it to send you unsolicited messages or for any other purposes.  Please share your information carefully.

Access, Correction, Deletion

If you wish to access or amend any personal data we hold about you, or to request that we delete any information about you that we have obtained, you may contact us in the “Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.

You may update or correct your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while changes you make will be reflected in active databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we reasonably believe that we have a legitimate reason to do so.

Privacy Shield

This Privacy Policy describes how Communication Labs Ltd and its subsidiaries and affiliates (Communication Labs) collect, use, and disclose certain personally identifiable information we receive from the European Union. This Privacy Policy applies to the following US affiliated entities: Communication Labs Ltd and NeuroEdge Health Ltd.

Communication Labs complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Communication Labs has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit The Federal Trade Commission has investigatory and enforcement authority over Communication Labs’ compliance with the Privacy Shield Framework.

In compliance with the Privacy Shield Principles, Communication Labs commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Communication Labs at Under certain conditions, more fully described on the Privacy Shield website (, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Communication Labs has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. Communication Labs also complies with the Privacy Shield Principles for onward transfers of personal data from the EU, including the onward transfer liability provisions.


The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

International Transfer

Your information, including Personal Information, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Only persons age 18 or older have permission to access our Service. Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Controls for Do-Not-Track features

Most browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your browsing activities monitored and collected. No standard technology for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or other mechanism that automatically communicates your choice not to be tracked.

Changes to This Privacy Policy

This Privacy Policy is effective as of September 11, 2018 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. You waive any right to receive specific notice of each change or modification.

Contact Us

If you have any questions about this Privacy Policy, please contact us.