Last updated: Sep 13th, 2021
TABLE OF CONTENTS
- What Information Do We Collect?
- How Do We Use the Information We Collect?
- Do We Share Your Personal Information?
- How Do We Secure Your Personal Information?
- Your Choices Regarding Information
- Links to Third Party Websites
- How We Respond To Do Not Track signals
- Children Under 16
- DMCA Notice
- Users Outside of the United States
- Contact Us
What Information Do We Collect?
We collect information, including Personal Information, only where we have a lawful basis. Lawful bases on which we rely include your consent where you have given it, contract where processing is necessary for us to perform our obligations pursuant to a contract with you, and legitimate interests of our business such as operating and providing the Site and Service to you.
We collect, store, and use the following categories of information, which includes Personal Information:
Information you give us:
- Your name, email address, country, telephone number, physical address and any other information you share when you create an account on our Site or otherwise access our Service, including your user name and password.
- Your responses to surveys that we may ask you to complete for research purposes or to help direct Twic activities.
- Other information you voluntarily submit, which may include content and Personal Information, including your profession, gender, date of birth, your profile picture, etc.
- Any information you share when you contact us.
Information we get from your use of the Site and/or Service:
- Details of how you use the Site and/or Service.
- Your internet protocol address (i.e., IP address), internet service provider or carrier name, and, if you access the Site or Service from a mobile application, your unique mobile device ID number and non-email authentication.
- Details of financial transactions you participate in on the Site and/or Service, including the amount, currency, and method of payment.
- Browser and device information and information collected through Tracking Technologies (defined below), such as cookies, pixel tags, and other technologies.
- If you use our Site and/or Service from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location. Not applicable in the APAC region.
How Do We Use The Information We Collect?
We use the information we collect for a variety of purposes, including to improve the Site and/or Service, optimize our technology and algorithms, and refine and customize our offerings and user experience, experience of our users.
In particular, we use the information we collect to:
- Verify your identity and eligibility for the Service, administer the Site and provide the Service, enable you to use its features, and improve the overall user experience.
- Communicate with you through email or via push notifications to your mobile device so that we can provide you with information regarding your account, updates about us, our work, and our community, and make it easier for you to share such information about us with your social networks.
- Send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
- Respond to comments and questions and provide technical support and customer support.
- Analyze how users use the Site and Service using tools like Google Analytics, Mixpanel and other tools to help us understand traffic patterns and know if there are problems with the Site and/or Service.
- Create targeted advertising to promote the Site and Service and engage our users.
- Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
- Link or combine user information with other Personal Information.
- Compare information for accuracy, update our records, and verify it with third parties.
Do We Share Your Personal Information?
We do not rent, sell, or share your Personal Information with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide you with the Service or any specific service you have requested or authorized. We currently do not share personal data with third parties for their direct marketing purposes without your consent.
To help us do our work, we may provide limited access to some of your Personal Information to the following third parties:
- Collaborating Organizations: Sometimes we collaborate closely with other groups to further our mission. In these cases, we may share your name, contact information and other details you provided when making an account with our partners.
- Service Providers: We work with a wide range of third parties who provide services on our behalf, notably website hosting service providers, bulk email and SMS services, database administrators, cloud computing services, advertising services, data analysts, application service providers, and other non-governmental organizations. We do not authorize them to use or disclose your Personal Information except in connection with providing their services.
We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Site and/or Service; and to protect Twic's rights or property. In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes.
We will also share Personal Information with companies, organizations or individuals outside of Twic if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Information is reasonably necessary to (1) detect or protect against fraud or security issues, to enforce our Terms of Service, (2) meet any enforceable government request, (3) defend against legal claims, or protect against harm our legal rights or safety, or that of our staff and/or users.
We, or third parties we do business with, may use certain technologies to automatically collect log files and other information about your usage of, and the devices you use to access, the Site and the Service (“Tracking Technologies”). For example, we may use Tracking Technologies like cookies, log files, web beacons, session replay scripts, or similar technologies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety.
You may delete and block all cookies from our Site and/or Service, but parts of the Site and/or Service will not work. We want to be open about our cookie use.
Web beacons may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow. Our third-party advertising service providers may also use web beacons to recognize you when you visit the Site or access the Service and to help determine how you found the Site and/or Service. If you would like more information about this and to know your choices about not having this information used by these companies, please visit: the Digital Advertising Alliance’s website, http://www.aboutads.info/, or the Network Advertising Initiative’s website, http://networkadvertising.org/consumer/opt_out.asp.
How Do We Secure Your Personal Information?
We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. The safety and security of your Personal Information also depends on you. You are solely responsible for keeping your membership details confidential, including any access credentials like passwords or mobile device PINs.
Your Rights Regarding Your Personal Information
You have certain rights with respect to the use of Personal Information on our Site and/or Service:
Changing or Deleting Your Personal Data.
All users may review, update, correct or delete the Personal Information furnished by a user in their user account (including any imported contacts) by contacting us at firstname.lastname@example.org, or by editing their profile via the Site. If you completely delete all of your Personal Information, then your user account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Delete or Correct Your Content.
You may access, correct, amend, or delete Content by accessing your user account (including any imported contacts). You control all Content you upload. Content that you delete (including Content containing Personal Information) may be retained in archived or backup copies in order to enable you to use certain features like revision history and base snapshots. For instructions on how to permanently delete Content from your account, please contact us at email@example.com. Please note that permanent deletion of Content through this process will impair or disable those features with respect to that Content.
Delete or Correct Personal Information
You may access, correct, amend, or delete Personal Information we have about you by logging into your account and navigating to your account page or by emailing us at firstname.lastname@example.org. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you wish to cancel your account, you may do so through your account page. If you do, personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law.
Download or Access Personal Information.
You can ask us for a copy of your Personal Information, as well as information about its processing, and can ask for a copy of your Personal Information (including in machine readable form) by emailing us at email@example.com.
Opting Out of Email Communications.
If at any time you would like to unsubscribe from our email list, you may do so by following the link in the marketing communications we send to you or by contacting us at firstname.lastname@example.org.
We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Twic features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions by clicking "Unsubscribe" (or similar opt-out language) in those communications. You can also contact us at email@example.com to opt out.
Links to Third Party Websites
By using the Site and Service, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third party websites.
How We Respond to Do Not Track Signals
Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.
Children Under 16
The Service is not directed to individuals who are under age of sixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at firstname.lastname@example.org and the information will be deleted.
A Note to Users Outside the United States
Twic is based in the United States. Your Personal Information may be collected, transferred to, stored and otherwise processed in any country where we have facilities or in which we engage service providers, in particular the United States. By using the Site and/or Service you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. If you are located in the European Economic Area (“EEA”), we may transfer your Personal Information to countries which have been found to provide adequate protection by the EU Commission, use contractual protections for the transfer of Personal Information, transfer Personal Information to recipients who have certified to the Privacy Shield or adopted Binding Corporate Rules, or otherwise transfer your Personal Information as permitted by applicable law. For more information about how we transfer Personal Information outside of the EEA, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us as specified below
If you have any questions about this Policy, your Personal Information, or the Site and/or Service, you can contact email@example.com or by emailing us at the below address:
c/o Data Protection Officer
47000 Warm Springs Blvd., Suite 1-170
Fremont, CA 94539
Please contact us if you have any complaints or concerns with respect to your privacy. If you believe we are unable to assist you, you have the right to lodge a complaint with a supervisory authority in the relevant jurisdiction. However, we are committed to working with you to resolve any complaint or concern you may have with respect to your privacy.