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European Regional Privacy Notice

Effective May 8, 2026

This European Regional Privacy Notice (this “Notice”) supplements Thrivania's Privacy Policy and contains additional information for Members and Visitors located in the European Economic Area (EEA), Switzerland, and the United Kingdom. If there is a discrepancy between the Privacy Policy and this Notice, the information in this Notice will apply to you.

Data Controller

Thrivania is the data controller of your personal data. When we refer to “Thrivania” in this Notice, we mean the entity responsible for processing your data in accordance with the General Data Protection Regulation (GDPR) and applicable local data protection laws.

Legal Bases for Processing Your Personal Data

Thrivania only processes your personal data when we have a valid legal basis. We set out below each of the legal bases we rely on, why and how we use your data.

To Perform Our Contract With You

Thrivania processes personal data when it is necessary to perform our contract (the User Agreement) with our Members. This includes:

  • • Allowing Members to register for and manage access to their Thrivania account
  • • Providing core Services including AI-powered job matching, co-founder matching, and profile generation
  • • Facilitating messaging and communications between Members
  • • Processing job applications and managing recruitment workflows
  • • Administering challenges and skills assessments

Consent

Thrivania processes personal data when Members give us consent. Where we rely on consent, you can withdraw your consent at any time through your account settings, however this will not affect our use of your data up to that point. Consent-based processing includes:

  • • Displaying your profile information to other Members and Visitors (based on your visibility settings)
  • • Opting into the Co-Founder Hub and sharing your founder profile
  • • Receiving marketing communications and promotional emails
  • • AI-assisted profile generation through our onboarding conversation
  • • Using non-essential cookies for analytics and preferences

Legitimate Interest

In some cases, we process your personal data based on our legitimate interests, provided that these interests are not overridden by your rights and freedoms. We have considered whether these interests are outweighed by your rights and have concluded, based on the limited impact of the processing and the controls we offer, that we can proceed. Legitimate interest processing includes:

  • • Safety and security: Detecting and preventing fraud, abuse, and violations of our User Agreement
  • • Personalisation: Customizing your feed, job recommendations, and content based on your profile and activity
  • • Research and development: Improving our AI matching algorithms, conducting platform analytics, and developing new features
  • • Business administration: Quality control, consolidated reporting, and customer service
  • • Direct marketing: Sending relevant product recommendations and platform updates (you can always opt out)

You have the right to object to processing based on legitimate interests. See “Your Rights” below.

Compliance with Legal Obligations

Thrivania processes information to comply with legal obligations, such as preserving or disclosing certain information to adhere to valid legal requests from law enforcement agencies, courts, or regulators, or to comply with financial, tax, or consumer protection laws.

How You Can Control Your Data

Under GDPR and applicable local laws, you have the following rights regarding your personal data. You can exercise these rights through your account settings or by contacting us.

Access Your Data

Download a copy of your personal data at any time from your account settings. We provide your data in a structured, machine-readable format (JSON).

Correct and Rectify

Update or correct your information directly through your profile or settings. If there is data you cannot edit yourself, contact us to request corrections.

Delete Your Data

Request deletion of your personal data or close your account entirely. Most profile data can be deleted through your account settings.

Restrict Processing

Request that processing of your data is restricted if the data is inaccurate or if you believe processing is unlawful.

Object to Processing

Object to processing based on legitimate interests or public interest. For direct marketing, you always have the right to object and we will stop.

Data Portability

Receive your data in a structured, commonly used format and transfer it to another controller. Download your data anytime from settings.

Withdraw Consent

Where we process data based on consent, you can withdraw it at any time through your settings. Withdrawal does not affect prior processing.

Lodge a Complaint

If you have concerns about our data practices, you have the right to lodge a complaint with your local supervisory authority.

Data Sharing with Third Parties

In addition to Section 3 of our Privacy Policy, we provide the following additional information about how Thrivania shares data:

Service Providers

Thrivania shares data with third-party service providers and processors, including cloud infrastructure providers (Google Cloud Platform), AI services (Microsoft Azure OpenAI), authentication providers, analytics services, and email delivery services. These providers have access to your information only as necessary to perform their functions and are bound by data processing agreements.

Employers and Co-Founders

When you apply for a position or participate in co-founder matching, certain profile data is shared with relevant parties as described in our Privacy Policy and subject to your visibility settings.

Special Category Data

Thrivania does not encourage you to provide data that includes genetic, biometric, or health data, or data revealing racial and ethnic origin, political opinions, religious or ideological convictions, or trade union membership (“Special Category Data”) when using our Services. Where you voluntarily provide such data (for example, in your profile or content), we process it on the basis of your explicit consent or where such data has been manifestly made public by you.

Data Retention

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. If you close your account, we will generally delete or anonymize your data within 30 days, except where we need to retain data to:

  • • Comply with legal obligations (e.g., tax, financial, or regulatory requirements)
  • • Resolve disputes and enforce our agreements
  • • Address suspended accounts due to harmful or illegal activity
  • • Support ongoing or potential legal proceedings

Transfers of Your Data Outside the EEA and UK

Thrivania may transfer personal data outside of the EEA and the UK as part of its Services. For example, Thrivania stores personal data on servers located in the United States. Thrivania will always use a lawful transfer mechanism, including:

  • • Standard Contractual Clauses (SCCs): European Commission-approved contractual commitments between companies that ensure your data receives equivalent protection.
  • • Adequacy Decisions: Transfers to countries that the European Commission has determined provide an adequate level of data protection.
  • • Derogations: Where appropriate, derogations permitted by law (e.g., transfers necessary for the performance of a contract).

Contacting Your Supervisory Authority

If you have a concern or complaint about the use of your personal data that you feel has not been addressed by us, you always have the right to raise a concern with the supervisory authority in your jurisdiction. A list of EEA data protection authorities is available at edpb.europa.eu. UK residents can contact the Information Commissioner's Office (ICO) at ico.org.uk.

Contact Us

If you have questions about this Notice or wish to exercise your rights:

Online: Contact form

Email: privacy@thrivania.com