This policy applies to all products built and maintained by Threadway Ltd. That includes the Threadway app (all versions), Threadway Send, and the Threadway Handbook, whether delivered within a web browser, desktop application, mobile application, or another format.
This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Threadway). We refer collectively to these categories of individuals as "you" throughout this policy.
If you are a customer’s end user and you have questions about how your information is collected and processed through the services, please contact the organization who has provided your information to us for more information.
Our guiding principle is to collect only what we need. Here’s what that means in practice:
When you sign up for a Threadway product, we ask for identifying information such as your name, email address, and a company name. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We sometimes also give you the option to add a profile picture that displays in our products.
We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.
If you sign up for a paid Threadway product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit Threadway servers. We store a record of the payment transaction for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.
For most of our products, we log the full IP address used to sign up a product account and retain that for use in mitigating future signup spam. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active.
We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active. The web analytics we use are described further in the Advertising and Cookies section.
We may use CAPTCHA across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your Threadway, the CAPTCHA service evaluates various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides Threadway with the spam score results; we do not have access to the evaluated information.
We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics.
A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off.
When you email Threadway with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.
We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.
To provide products or services you’ve requested. We use some third-party subprocessors to help run our applications and provide the Services to you. You can view the third-party subprocessors below.
We may also access your data if required in order to respond to legal process (see "When required under applicable law" below).
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.
Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.
When required under applicable law. Threadway is a UK company and all data infrastructure is located in either the UK or the EU.
Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if UK law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside the UK if compelled by the UK government through procedures outlined in a mutual legal assistance treaty or agreement. It is Threadway’s policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.
We do not disclose preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period.
If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.
Finally, if Threadway is acquired by or merges with another company we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.
At Threadway, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:
Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.
In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at team@threadway.com. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.
In Threadway, project data is immutable which means copies of data is kept even if it is deleted. To have a particular piece of information removed, contact team@Threadway.com to have the information redacted. Information will generally be redacted within 30 days.
If you choose to cancel your account, your account will become immediately inaccessible and removed within 60 days. As information is stored within projects, not as per-account information this information will be retained until the project itself is deleted.
We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.
Our products and other web properties are operated in primarily in the UK and partly in the EU. If you are located elsewhere, any information you provide to use will be transferred and stored in the UK and/or the EU. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.
If you have questions or comments about this notice, you mmay contact our Data Protection Office (DPO) by email at team@threadway.com, or contact us by post at:
Threadway Ltd
Data Protection Officer
120 Aldersgate Street
London, EC1A 4JQ
United Kingdom
We use third-party subprocessors, such as cloud computing providers and customer support software, to run Threadway (the service). Each of the third-party subprocessors we use are subject to GDPR and the Data Processing Addenda for each are linked below.