Publ. March 10th 2023

We are committed to provide You with high-quality services and to respect Your privacy highly. This Privacy Policy describes Our policies and procedures on collecting, using, and disclosing Your information when You use Our websites, programs or services.

ThinkFit is a mobile and web-based tool that enables you to better manage your health and wellbeing. In this policy, “ThinkFit” refers to the products and services provided by tHe Holistic experiment LLC and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership and under the name of “ThinKFit”. We may also refer to ThinkFit as “We” or “Us”.


1.1. Please read this privacy policy carefully before using Our Platform.

1.2. Definitions and Agreement to Context

  • “Affiliate” means any program offered under the Service by another Third Party or Partner.
  • “ThinkFit” (referred to as either “We,” “Us,” or “Our” in this Privacy Policy and agreement) refers to ThinkFit, which is owned by tHe Holistic experiment LLC.
  • “Device” means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
  • “Feedback” means feedback, innovations, or suggestions sent by You regarding our Service’s attributes, performance, or features.
  • “Operator” for the purposes of the Refund Policy means ThinkFit or its associates, and its respective officers, directors, employees and agents.
  • “Partners” mean any related parties that we share Your information with. These Partners can, and both use and hold Your personal information. They may have their own independent Privacy Policies and Terms of Service that are unique to those Partners.
  • “Program” means the software program provided by Us and downloaded by You on any electronic Device, named
  • “Service” (also referred to as “Services”) means the Programs or the Website or both, as well as any services provided, offered, referred to or from Us, in partnership with other third-parties, as arranged for by or from Us via phone, email, text, or any via other communication method and whether the service is offline or online.
  • “Terms”mean the terms of this Privacy Policy and agreement that We follow regarding the privacy of, and of Our use & storage of, Your information.
  • “Third-party Social Media Service” means any services or Content (including data, information, products, or services) provided by a third-party that may be displayed, included, or made available by the Service or Programs We provide.
  • “Site” (also referred to as “Website”) refers to Our website accessible from
  • ThinkFit Store” (also referred to as “Store”) refers to Our website accessible from
  • “You” (also referred to as “Your”) means the individual accessing or using the Site and Service, or the Company, or other legal entity on behalf of which such individual is accessing or using the Site and Service, as applicable.
  • “ThinkFit Academy” (also referred to as “Academy”) refers to Our website accessible from

1.3. Scope

  • 1.3.1. This privacy policy covers:
    • i. visitors to our Website and Store such as You; and
    • ii. Registered users of the Site and Store such as You, as the case may be.
  • 1.3.2. As a visitor to, or Registered user of, the Site or Store, You may provide Your personal information to Us to obtain Our services from Our Site or Store.


  • 2.1. We collect Your personal information to maximize high-quality service delivery to You, to provide You with any additional or special information about Our services, and take reasonable steps to protect Your personal information.
  • 2.2.We may collect the following kinds of information when You, Your colleagues, agents, representatives, or other users, access the Service:
      • i. Your contact information, such as your first and last name
      • ii. your profile picture or its URL
      • iii. your user ID number, which is linked to publicly available information such as name, profile photo, groups you belong to, events you are attending, challenges you are participating in and actions you choose to share.
      • iv. the login e-mail you provided at the time you registered
      • v. your physical location and that of your access devices
      • vi. your gender
      • vii. your birthdate
      • viii. your wellness objectives
      • ix. Other information about type of employment, working hours

    You represent and warrant that You have sought the consent of any individual whose information You provide to us.

  • 2.3. We may collect personal information about You from the information You provide to us when You fill out an Application or other forms on our Site, a Program, over the phone or in person. We may also receive, and also share, personal information about You, from and with third-party services such as Third-party Social Media Services and others. Lastly, we may also collect personal information from individuals whose identity You share with Us as described in this policy.
  • 2.4. Our servers also collect information from You, such as Your domain name, websites You visit, and Internet Protocol address. This information is not personally identifiable. However, when You respond to questions or communicate with us, Your personal information may be collected.
  • 2.5. If you use ThinkFit Services on your mobile telephone or other mobile device, including iPads and tablets, We collect your mobile device identifier and IP Address. In certain Services We will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, country, and any other information you choose to provide, such as user name, character name or e-mail address.
  • 2.6. If a third party is not paying for the service on your behalf, We will collect the billing and financial information necessary to process your charges for ThinkFit Services which require payment, which may include your postal and e-mail addresses. ThinkFit may also receive the billing and payment information that you provide when your purchase is processed by another party, such as Paypal. Our Terms of Service explain our policies and terms relevant to our charges and billing practices. Please note that establishing an account with a third party payment processor, like Paypal, may also be subject to additional policies.
  • 2.7. When you access our websites or use our Services, We collect (i) certain technical information about your mobile device or computer system, including IP Address and mobile device ID; and (ii) usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files (“Log Files”), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number(s). For more information on how We utilize cookies and other tracking technologies please review the “Cookies and Automated Information Collection” portion of Section 3 (“How We Collect Information About You”).
  • 2.8. To the extent that you are accessing the Service while domiciled outside of the United States, you acknowledge that the Personal Information you are providing Us is collected and stored in the United States and therefore consent to the transfer of information to and storage of the information outside of your domiciled country and in the United States.


  • 3.1 Where it is in our legitimate interest to do so, We may use Your personal information:
    • i. to create your user accounts and allow you to use our Services
    • ii. to suggest connections with other ThinkFit users
    • iii. to enable user-to-user communications
    • iv. to prevent fraud or potentially illegal activities, and enforce our Terms of Service
    • v. to deliver and target resources
    • vi. To provide You with details about our products and services by email, text, phone and through other communication methods;
    • vii. to develop and improve Our services and products;
    • viii. to update Our records;
    • ix. to carry out checks required by applicable regulation or regulatory guidance;
    • x. to improve Our relationship with You by making the Website available to You in a User-friendly way, and to identify the products and services which You may be interested in;
    • xi. for customer service, including answering questions and responding to Feedback and complaints;
    • xii. for any other specific purposes in relation to Your activities via the Site or in any form of communication or access to our Services;
    • xiii. Where You have given Us consent, we shall provide You with information about any new products, services, events, promotions, and other information which we think will be of interest to You. You can withdraw Your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal and with a reasonable time thereafter for systems to get updated. You can update Your details or change Your privacy preferences by contacting us via the details given in the “Contact Us” section.
  • 3.2. We use Your email address to communicate with You. Upon Your consent, we may direct electronic email communication to You about Our services or market new services. We may also ask to seek Your feedback on the services we offer. You have an option to opt-out of such electronic communication. Lastly, we may track Your email activity to check the effectiveness of the communication.


  • 4.1. We may provide Your personal information to other companies for:
      • 4.1.1. Their general marketing purposes, upon Your consent.
      • 4.1.2. To perform services on our behalf, including payment processing, data analysis, e-mail delivery, hosting services, customer service and to assist Us in our marketing efforts.

    However, we may aggregate anonymized information based on Your personal information and disclose this to advertisers and other third parties. Besides, we direct all such third-party service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on ThinkFit’s behalf.

  • 4.2. We may disclose Your personal information to third parties where it is in our legitimate interest to do so, including the following reasons:
    • 4.2.1. we may share Your information with analytics and search engine providers that assist us in the improvement and optimization of our Site;
    • 4.2.2. we may disclose Your personal information on request to the police or any other regulator or government authority to fulfill our regulatory responsibilities, to help prevent or detect fraud or any other type of crime, or for any other reasonable purpose;
    • 4.2.3. Save as set out in this privacy policy; we will not sell or disclose Your data to any third party;
    • 4.2.4. We may share Your information in the event of a merger, acquisition, or sale of our assets. We shall communicate with You in the event of such a change. We may assign your contract to another party, and You agree that we can provide them with Your information, for such purposes and you would be notified of any such assignment.
    • 4.2.5. Some of the third parties who may require Your information belong to territories or countries other than the United States. The third-parties are subjected to all relevant laws in their jurisdictions pertaining to the information we share with them.


  • 5.1. We may store your information as long as we keep it completely anonymous. We acknowledge that there can be no chance that you can be traced from the data we have stored.
  • 5.2 We shall hold for the shortest amount of time possible. Accordingly, we shall wipe the data if it becomes obsolete or unnecessary.


  • 6.1. We use cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and improve and analyze Our Website.
  • 6.2. You can instruct Your browser to refuse all Cookies or to indicate when a cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Programs or Site.
  • 6.3. Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your Device (personal computer or mobile device as examples) when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
    We use both session and persistent cookies for the purposes set out below:
    • We use both session and persistent cookies for the purposes set out below:

      These Cookies are essential to provide You with services available through the Website and enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user Accounts. Without these Cookies, the services You have asked for cannot be provided, and We only use these Cookies to give You those services.

    • ii. Cookies Policy / Notice Acceptance Cookies

      These Cookies identify if users have accepted the use of cookies on the Website.

    • iii. Functionality Cookies

      These cookies allow us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these cookies is to provide You with more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

    • iv. Tracking and Performance Cookies

      These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify You as an individual visitor. This is because the data collected is typically linked to a pseudonymous identifier associated with the Device You use to access the Website. We may also use these cookies to test new advertisements, pages, features, or new functionality of the Website to see how our users react to them.

  • 6.4. Analytics
    • 6.4.1. We may use third-party Service providers to monitor and analyze the use of our Website.
    • 6.4.2. One such service provider is Google. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Program and Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network.
    • 6.4.3. You can opt-out of having made Your activity on the Program and Site available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
    • You may opt-out of certain Google Analytics features through Your mobile Device settings, such as Your Device advertising settings, or by following the instructions provided by Google in their Privacy Policy:
    • 6.4.5. For more information on Google’s privacy practices, please visit the Google Privacy & Terms web page:


  • 7.1. Our Programs and Site may contain links to other websites 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.


  • 8.1. The security of Your Personal Data is important to us but remember that no transmission method over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, we cannot guarantee its absolute security.
  • 8.1. We secure your personal information from unauthorized access, use, or disclosure. We use the following methods for this purpose:
    – SSL Protocol
  • 8.3. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
  • 8.4. Accordingly, we strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
  • 8.5. We restrict access to the information obtained from our websites and web pages to our employees, agents, Affiliates, Partners and contractors. We maintain physical, electronic, and procedural safeguards designed to protect personal information to the extent reasonably possible.


  • 9.1. You may request us to identify the personal information we have collected and kept in our servers. To make such a request, contact us through our email provided below.
  • You may contact us to cancel, withdraw, or restrict the amount and type of information we collect and keep. You may send an e-mail to . Place “Delete My Account” in the subject line and include your first name, last name, e-mail address and user ID number for the third-party site from which you access our Services (if applicable) in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example, those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content on the Service, We may not be able to delete it. Accordingly, We may keep on using some of Your personal information even after Your withdrawal of the information is necessary to run Your Account or fulfill legal obligations. We may also stop providing services that we would only give if we had the information You have withdrawn.
  • 9.3. When you install our apps on your mobile device you can choose to receive push notifications. You can turn off push notifications by visiting the “options” or “settings” page within the relevant Service. You may also receive local notifications. You can turn off local notifications by visiting the “options” or “settings” page within the relevant Service. We may e-mail or communicate with you from time to time if We need to provide you with information or if We need to request information from you with respect to a transaction initiated by you or for other legitimate non-marketing reasons.


  • 10.1. We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
  • 10.2. We will let You know via email or a prominent notice on Our Programs and Site (as applicable) before or when the change becomes effective.
  • 10.3. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are significant when they are posted on this page.


  • The relationship between the parties is governed exclusively by Italian law under exclusion of the UN Convention on Contracts for the International Sale of Goods (CISG). In relation to business transactions with consumers within the European Union, the law of the consumer’s place of residence may also be applicable where such law contains consumer law provisions that it is mandatory to apply. If you do not have a place of general jurisdiction in Italy or in another EU Member State, or if you have moved your permanent place of residence to a country outside the EU after these General Terms and Conditions of Business have entered into effect, or if your permanent place of residence or usual place of residence at the time the complaint is filed is not known, then the exclusive place of jurisdiction for all disputes arising from this contract will be our place of business.


  • For users in the European Union. We hereby confirm that We are in full compliance with Our respective obligations under the General Data Protection Regulation, (GDPR) (EU) 2016/679. Each Party will, if applicable, notify the other Party in a timely manner in the event of a data breach that involves the other Party’s data.


  • For Canadian users. “Personal Information” shall have the meaning attributed to such term within the provisions of PART 1 of the Personal Information and Electronic Documents Act of Canada (“PIPEDA”) and any successor legislation and any legislation of similar effect in Canada. We hereby confirm that We are in full compliance of Our respective obligations under PIPEDA, and other applicable subsequent legislations.


  • For users within the United States. We hereby confirm that We are in full compliance of Our respective obligations under any applicable privacy standards and requirements of any Federal or state law, as may be amended from time to time.


  • For Australian users. The Australian Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles (APPs) regulates the handling of personal information about individuals. We hereby confirm that We are in full compliance of Our respective obligations under the mentioned laws, as may be amended from time to time.


Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children, we take steps to remove that information from our servers.


  • For users in California. The California Consumer Privacy Act (CCPA) was enacted to give consumers more control over the personal information that businesses collect about them. The California Online Privacy Protection Act, (CalOPPA), was drafted to protect the privacy rights and personal data of California residents. We hereby confirm that We are in full compliance of Our respective obligations under the mentioned laws, as may be amended from time to time. For more information about protecting your privacy, you may wish to visit: If you have questions about this policy, please contact us at


  • 18.1. Severability
    • If any term in this Policy is held to be unenforceable or invalid, such provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law, and the remaining provisions will continue in full force and effect.
  • 18.2. Waiver
    • Except as provided herein, the failure to exercise a right or to require performance of an obligation under this Policy shall not affect a party’s ability to exercise such right or require such performance at any time thereafter, nor shall be the waiver of a breach constitute a waiver of any subsequent breach.


  • The Terms in this Privacy P olicy, the Refund Policy, together with the Terms of Service, constitute the entire agreement between You and Us and Our Affiliates and Partners (to the extent of the information We have in relation to Your account from those Partners) with respect to, but not limited to, the Site, Services, and all information, and supersede all previous written or oral agreements between You and Us with respect to, but not limited to, the Site and Services.


  • If We decide to make material changes to our Privacy Policy, We will notify you and other users by placing a notice on the Website or app or by sending you a notice to the e-mail address We have on file for you. We may supplement this process by placing notices in our Services. You should periodically check our Site and this privacy page for updates.


  • Users in certain jurisdictions have a right to access personal information held about themselves. Your right of access can be exercised in accordance with applicable law. Please submit any requests for access to your personal data in writing to


  • If You have any questions about the provisions in this Privacy Policy, please send an e-mail to All other inquiries should be directed to ThinkFit’s Feedback Page or
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