Privacy Policy

Last updated: 2026-06-20

Data Controller

ThinkUp is operated by Unixal SAS, a simplified joint-stock company (société par actions simplifiée) incorporated in France.

Unixal SAS

  • 10 rue Sainte-Odile, 67530 Bœrsch, France
  • SIREN: 811 116 920
  • SIRET: 811 116 920 00018
  • RCS Saverne: 811 116 920 R.C.S. Saverne
  • TVA intracommunautaire: FR42811116920
  • Capital social: 1 000 €
  • Directeur de la publication: Julien Stoeffler
  • Contact: contact@thinkup.com
  • Hébergeur: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA

What Data We Collect

Data You Provide

We do not require you to create an account. We collect the following data when you use ThinkUp:

  • Coupon interaction data: when you reveal a coupon code or click a deal link, we record that an interaction occurred. This is used to rank trending coupons and display vote counts.
  • Vote data: if you vote on a coupon (worked / didn't work), we store that vote anonymously tied to your browser session. No account is required.
  • Contact enquiries: if you email us at contact@thinkup.com, we retain your email address and message for the duration needed to respond.

Data We Collect Automatically

When you visit ThinkUp, our infrastructure and analytics tools collect:

  • IP address and approximate location (country-level, detected client-side via /cdn-cgi/trace, used for consent geo-gating)
  • Browser and device information (user agent, screen size, browser language), collected by Google Analytics 4
  • Page views and session data (pages visited, time on page, referrer URL), collected by Google Analytics 4
  • Ad click attribution: if you arrive via a Google Ads campaign, a first-party attribution cookie (ctid) links your Google Click ID (gclid) to your session so we can measure whether paid traffic converted. See our Cookie Policy for details.

Legal Basis for Processing (GDPR)

We process personal data on the following legal bases:

  • Legitimate interests (Article 6(1)(f) GDPR): operating the site, detecting abuse, and improving functionality. We have assessed that this processing is proportionate and does not override your fundamental rights.
  • Consent (Article 6(1)(a) GDPR): analytics and advertising tracking, where required by applicable law (EEA/UK users). You can withdraw consent at any time via the cookie banner or our Cookie Policy.
  • Legal obligation (Article 6(1)(c) GDPR): retaining records where required by French law.

Third-Party Processors

Processor Purpose Location Safeguard
Google LLC (Google Analytics 4) Analytics — page views, sessions USA EU Standard Contractual Clauses
Google LLC (Google Ads) Conversion tracking, remarketing USA EU Standard Contractual Clauses
Cloudflare, Inc. CDN, DDoS protection, bot management USA EU Standard Contractual Clauses

Consent Mode and EEA/UK Geo-Gating

We implement Google Consent Mode v2. Your browser detects your country client-side via a request to /cdn-cgi/trace (a Cloudflare endpoint). If your IP address resolves to a country in the European Economic Area (EEA) or the United Kingdom, consent for analytics and advertising cookies defaults to denied until you accept via the cookie banner. For all other visitors (currently primarily United States), consent defaults to granted because GDPR does not apply to those users.

You can change your preferences at any time by clicking the "Cookie preferences" link in the footer.

Cookies

Please see our Cookie Policy for a full list of cookies and storage items we use, including their purpose, category, and duration.

Data Retention

  • Analytics data: retained for 14 months in Google Analytics (the minimum configurable retention period), then automatically deleted.
  • Attribution cookies: the ctid cookie expires at the end of the browser session unless configured otherwise.
  • Contact emails: retained for up to 12 months after the last interaction, then deleted.
  • Vote data: stored indefinitely in aggregate (vote counts per coupon), not linked to identifiable individuals.

Your Rights (GDPR)

If you are located in the EEA or the UK, you have the following rights under the GDPR:

  • Right of access (Article 15): you may request a copy of the personal data we hold about you.
  • Right to rectification (Article 16): you may ask us to correct inaccurate data.
  • Right to erasure (Article 17): you may ask us to delete your personal data where we no longer have a legitimate reason to hold it.
  • Right to restriction (Article 18): you may ask us to restrict processing while a dispute is resolved.
  • Right to object (Article 21): you may object to processing based on legitimate interests.
  • Right to withdraw consent (Article 7(3)): where processing is based on consent, you may withdraw it at any time. This does not affect the lawfulness of processing before withdrawal.
  • Right to lodge a complaint: you may lodge a complaint with the French data protection authority (CNIL) at www.cnil.fr or with the supervisory authority in your EU member state.

To exercise your rights, contact us at contact@thinkup.com. We will respond within 30 days.

Children

ThinkUp is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

Changes to This Policy

We may update this Privacy Policy from time to time. We will update the "Last updated" date at the top of this page when we do. Continued use of ThinkUp after an update constitutes acceptance of the revised policy.

Contact

Questions about this Privacy Policy? Contact us at contact@thinkup.com.

Unixal SAS, 10 rue Sainte-Odile, 67530 Bœrsch, France.