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THOUGHTSPOT® PRIVACY STATEMENT

 

Effective as of March 26, 2020

ThoughtSpot, Inc. and its subsidiaries (collectively “ThoughtSpot”, “we” or
“us”) is committed to protecting your privacy and providing you with a positive
experience on our websites and in using our products and services.

This Privacy Statement only covers our privacy practices with respect to the
collection, use, and disclosure of Personal Information obtained: (i) through
the ThoughtSpot websites that link to this Privacy Statement ("Website"); (ii)
in connection with your purchase and use of our software products (“Solutions”)
and related support and professional services (“Services”); and (iii) in
connection with events hosted by us where we collect information from
registrants and attendees (“Events”). This Privacy Statement does not cover any
data stored in the ThoughtSpot Solution.

For the purposes of this Privacy Statement:

 * “Customer” means the entity that purchases our Solution or Service.
 * “Mobile Applications” means applications downloaded to a mobile device by an
   authorized user of our Solutions.
 * “Partner” means an entity that sells ThoughtSpot Solutions and Services or
   provides services or technology to ThoughtSpot Customers on behalf of
   ThoughtSpot.
 * “Personal Information” means information about an identified or identifiable
   natural person.



If you have any questions or concerns about our use of your Personal
Information, please contact us using the contact details provided at the bottom
of this Privacy Statement.

COLLECTION OF YOUR PERSONAL INFORMATION

The types of Personal Information we collect will depend upon your interactions
with ThoughtSpot. We may collect information directly from you when you use our
Websites and purchase or use our Solutions and Services. We may also collect
information from trusted third-party sources and engage third parties to collect
Personal Information to assist us. The types of information we collect from you
may include the following:

 * Contact Information and User Credentials. Name, employer, title, email
   address, physical address, phone number, and other contact information.
 * Payment and Billing Information. Credit card number, banking information and
   billing and shipping addresses.
 * Demographic Information.On occasion, ThoughtSpot may collect other
   demographic information, such as gender, race, ethnicity, veteran status and
   age.
 * Event Information.  Registration information related to your attendance at
   Events, including travel and contact information, scheduling information,
   food preferences or allergies and accessibility requests.
 * Search Queries. The search text submitted by users of the Solutions when
   using our natural language processing functionality, SearchIQ.
 * Online Identifiers. Internet protocol address or location data when you
   access the Website or Mobile Applications (as defined below).
 * Device Information and Usage. Device settings, attributes, identifiers, and
   interactions when you access the Website or Mobile Applications.
 * Employment Application Information. Employment history, employment status,
   education and other background information in connection with an application
   for employment with ThoughtSpot.

In some instances, ThoughtSpot and the third parties we engage may automatically
collect data through cookies, web logs, web beacons, and other similar
applications. For detailed information, please see our Cookies Policy.

USES OF YOUR PERSONAL INFORMATION

We may use your Personal Information for the purposes of operating our business,
delivering, improving, and customizing our Websites, selling our Solutions and
Services, sending marketing and other communications related to our business,
and for other legitimate purposes permitted by applicable law. Some of the ways
we may use Personal Information include:

 * To understand you and your preferences to enhance your Website experience;
 * To send our Customers and Partners ThoughtSpot-related information, including
   confirmations, account verification, invoices, technical notices, updates,
   security alerts, and support and administrative messages;
 * To communicate with you about promotions, upcoming events, and news about
   products and services offered by ThoughtSpot and our selected Partners;
 * To link or combine information about you with other Personal Information we
   get from third parties, to help understand your needs and provide you with
   better and more personalized Website experience;
 * To enforce our terms and conditions or protect our business, Partners, or
   users;
 * To operate, maintain, and provide to you the features and functionality of
   the Website;
 * In connection with your application for employment with ThoughtSpot;
 * To register you for Events you sign up for with us and populate profiles for
   you in our records;
 * To communicate with you about Events or contact you for marketing purposes,
   in accordance with your marketing preferences;
 * For industry analysis, benchmarking, analytics, marketing, and other business
   purposes;
 * To operate and improve our Solutions and Services; or
 * To provide our Services.

We may also use information we collect about our Customers and Partners for
billing and contracting purposes.

If you are from the European Economic Area (“EEA”), our legal basis for
collecting and using the Personal Information described above will depend on the
Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only where we
have your consent to do so, where we need the Personal Information to perform a
contract with you, or where the processing is in our legitimate interests and
not overridden by your data protection interests or fundamental rights and
freedoms. In some cases, we may also have a legal obligation to collect Personal
Information from you.

You can edit your communication preferences at any time. See Controlling Your
Personal Information below.

SHARING YOUR PERSONAL INFORMATION

We may share your Personal Information with third parties for the purposes of
operating our business, selling, delivering and improving our Solutions and
Services, sending marketing and other communications related to our business,
and for other legitimate purposes permitted by applicable law or otherwise with
your consent.

We may share Personal Information in the following ways:

 * Within ThoughtSpot and any of our global subsidiaries. These companies will
   use your Personal Information in the same way as we can under this Privacy
   Statement.
 * With third party vendors, consultants and other service providers that
   perform services on our behalf. Examples include, but are not limited to:
   processing of orders and credit card transactions, hosting websites, hosting
   Event registration, assisting with sales-related efforts or post-sales
   support, recruitment and human resources, and providing Services.
 * In connection with, or during negotiations of, any merger, sale of company
   assets, consolidation or restructuring, financing, or acquisition of all or a
   portion of our business by or to another company.
 * In response to a request for information by a competent authority if we
   believe disclosure is in accordance with, or is otherwise required by, any
   applicable law, regulation or legal process.
 * With law enforcement officials, government authorities, or other third
   parties as necessary to comply with legal process or meet national security
   requirements; protect the rights, property, or safety of ThoughtSpot, its
   business partners, you, or others; or as otherwise required by applicable
   law.
 * In aggregated, anonymized, or de-identified form which cannot reasonably be
   used to identify you.

We do not sell Personal Information nor do we rent or trade Personal Information
collected through the Website with third parties for their promotional purposes.

MOBILE APPLICATIONS

We may obtain additional information through Mobile Applications that you
download to your mobile device (“Device”). “Mobile Applications” means
applications downloaded by an authorized user of our mobile software application
to a mobile device. Mobile Applications we provide may obtain, collect or access
information from your Device in connection with your use of the Solutions, and
are designed to interoperate with the Solutions; for instance, to provide you
with access to information within the Solutions.

In order to provide and operate the Mobile Applications, we need certain
information from you. For example, we ask you to provide some Personal
Information, such as login credentials to access and use the Solutions through
the Mobile Applications. We may only be able to collect or access this
information if the Device settings allow it, so you should always review our
Mobile Applications settings under the Device settings menu to determine the
access restrictions for the Mobile Applications. The Mobile Applications also
provide location information to us by way of the internet protocol addresses
from which you access the Mobile Applications.

Our Mobile Applications may also provide us with information regarding your
Device, such as the Device model, manufacturer, and operating system. We may
also collect Device event information, such as error logs and crashes related to
our Mobile Applications, which allows us to provide a better experience to you.
In addition, we may use information collected by our Mobile Applications to
enforce our rights arising from contracts we enter into with you.

In addition, to provide this Mobile Application, we work with our group
companies and certain partners and service providers who may have access to your
information.

SECURITY OF YOUR PERSONAL INFORMATION

We implement physical, administrative, and technical safeguards designed to
protect your Personal Information from unauthorized access, use, or disclosure.
We also contractually require that our service providers protect such
information from unauthorized access, use, and disclosure. However, you should
know that no company, including ThoughtSpot, can fully eliminate security risks
associated with Personal Information. Further, the Internet cannot be guaranteed
to be 100% secure, and we cannot ensure or warrant the security of any Personal
Information you provide to us.

RETENTION OF YOUR PERSONAL INFORMATION

We will retain your Personal Information as needed to fulfill the purposes for
which it was collected. We will retain and use your Personal Information as
necessary to comply with our business requirements, legal obligations, resolve
disputes, protect our assets, and enforce our agreements. When we have no
ongoing legitimate business need to process your Personal Information, we will
either delete it, anonymize it or securely store your Personal Information and
isolate it from any further processing until deletion is possible.

CONTROLLING YOUR PERSONAL INFORMATION

Our marketing emails permit you to "opt-out" of or “unsubscribe” from receiving
further marketing emails. Certain jurisdictions, for example the EEA and
California, provide their residents certain privacy rights under applicable law,
including, as applicable, the right to object to or restrict the processing of
Personal Information, to transfer Personal Information (data portability), or to
request that we correct any inaccuracies or otherwise update your Personal
Information.

You may contact us to exercise your rights using the contact details in the
section titled “How to Contact Us” below. We will respond to such requests in
accordance with the requirements of applicable data protection laws. Please note
that in order to fulfil your request, we may need you to provide certain
information to verify your identity.

These choices do not apply to service notifications or other required
communications that are considered part of the Solutions or Services, which you
may receive periodically unless you stop using or cancel the Solution or
Services in accordance with its terms and conditions. Moreover, certain Personal
Information may be exempt from such requests in certain circumstances, which may
include circumstances where we need to keep processing your Personal Information
for our legitimate interests or to comply with a legal obligation.

Event registrants and attendees may update their user profiles for Events we
host by logging into the applicable event website or registration page.

COOKIES AND WEB BEACONS

Like many websites, ThoughtSpot uses automatic data collection tools, such as
cookies, embedded web links, and web beacons. “Cookies” are small text files
that we and others may place in users' computer browsers to store their
preferences. "Web beacons" or “pixel tags” are small pieces of code placed on a
web page or within the body of an email to monitor the behavior and collect data
about the users viewing a web page or viewing or opening an email.

While ThoughtSpot attempts to honor do not track (“DNT”) instructions we receive
from a user’s browser, we cannot guarantee that ThoughtSpot will always respond
to such signals, in part, because of the lack of common industry standard for
DNT technology. We continue to monitor developments in DNT technology and stay
apprised of DNT industry standards as they evolve.

For more information about the cookies and related technology we use on our
Websites, please refer to our Cookie Policy.

INTERNATIONAL DATA TRANSFER

ThoughtSpot stores and processes any information collected in in: (i) any
country where we have facilities, (ii) any country in which we engage service
providers; or (iii) any country where Events are held. A list of ThoughtSpot
global offices is available here.

If you are a user from the EEA, we will protect your Personal Information when
it is transferred outside of the EEA by:

 * Processing it in a territory which the European Commission has determined
   provides an adequate level of protection for Personal Information; or
 * Otherwise implementing appropriate safeguards to protect your Personal
   Information, including through the use of Standard Contractual Clauses or
   another lawful transfer mechanism approved by the European Commission.

If you require further information about our international transfers of Personal
Information, please contact us using the contact details in the section titled
“How to Contact Us” below.

CALIFORNIA PRIVACY DISCLOSURES

The California Consumer Privacy Act (“CCPA”) requires businesses to provide
additional disclosures of California consumer rights relating to the sharing of,
access to, and deletion of Personal Information that is collected. We may share
Personal Information with third parties or allow them to collect Personal
Information as described in this Privacy Statement. We may share or disclose the
Personal Information listed in the section above titled “Collection of Your
Personal Information” our business purposes.

California consumers have a right to request information about the collection of
your Personal Information, and access to and deletion of your Personal
Information under the CCPA. We do not sell the Personal Information of
California consumers and do not discriminate in response to privacy rights
requests.

If you are a California consumer and you or your authorized agent would like to
exercise your privacy rights, please contact us using the contact details in the
section titled “How to Contact Us” below. We may need to verify your identity
and place of residence before completing your rights request.

GENERAL

Linked Websites

We may provide links to other third-party websites and services that are outside
our control and not covered by this Privacy Statement. We encourage you to
review the privacy statements posted on those websites (and all websites) you
visit.

Forums and Chat Rooms

We offer you the ability to post information and exchange ideas through our
websites and other services such as ThoughtSpot Community.

If you participate in the ThoughtSpot Community or other discussion forum or
chat room on a ThoughtSpot Website, you should be aware that the information you
provide there (i.e. your public profile) will be made broadly available to
others, and could be used to contact you, send you unsolicited messages, or for
purposes neither ThoughtSpot nor you have control over. ThoughtSpot will not be
responsible in the event that you disclose Personal Information in your posts,
through our public services or during any other communication with other Website
users.

Children's Privacy

ThoughtSpot does not knowingly collect Personal Information from children
without appropriate parental or guardian consent. If you believe that we may
have collected Personal Information from someone under the applicable age of
consent in your country without proper consent, please let us know using the
methods described in the How to Contact Us section and we will take appropriate
measures to investigate and address the issue promptly.

Changes to this Privacy Statement

ThoughtSpot may modify or update this Privacy Statement from time to time to
reflect the changes in our business and practices, and so you should review this
page periodically. When we change the Privacy Statement in a material manner we
will let you know and update the ‘effective date’ at the top of this page.

How to Contact Us

If you have any questions about this Privacy Statement or our privacy practices,
please email us at privacy@thoughtspot.com,
call us at (800) 508-7008, or write to us at:

ThoughtSpot, Inc.
Attn: General Counsel
910 Hermosa Court
Sunnyvale, CA 94085

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