Last updated: Mar 06, 2023
Twist Solutions Ltd. (“Twist”, “we”, “our” or “us”) develops and operates a HaaS solution ("Platform"). We also operate the website https://www.twist.eco/, its subdomains and its related features (“Website”, and collectively with the Platform – the “Services”).
Specifically, our Policy addresses the following –
What types of data we collect
Why we process your Personal Data, and under what legal bases
With whom we share your data
Transfer of data outside the EU
How we protect your data
Updates to this Policy
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Policy at any time.
You are not legally required to provide us with any Personal Data (as defined below), but without it we will not be able to provide you with the full range or with the best experience of using our Services.
1. What types of data we collect
We collect two types of data from you: Personal Data ("Personal Data") and non-Personal Data. Personal Data means any information which may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (e.g. the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out how and when we collect those types of data from you.
1.1. Account Information. When you sign up to our Services, we collect your full name, email address, company's name, company's address, and billing information.
1.2. Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include IP address, unique identifiers (e.g. MAC address) as well as other information which relates to your activity in the Services.
1.3. Communication Information. When you send us an email or contact us via the support in our Platform or Website, we collect the Personal Data you provide us. This may include your name, email address and any other information you choose to provide.
2. Tracking technologies
There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Another method of managing your Tracking Technology preferences is changing your browser settings to send a “Do-Not-Track” signal. In such a case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Website may not work properly or effectively if you delete or disable cookies.
3. Why we process your Personal Data, and under what legal bases
This section explains for what purposes we use your Personal Data and outlines the legal bases that underlies our usage.
Provision of our Services; support. We use your Personal Data, such as your name, and email address, for consumer services purposes. This includes, for example, responding to your inquiries
The legal bases for processing this data are the performance of our contractual towards you; your consent (for example, when you provide Personal Data); compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.
Transactions. We collect from our third-party payment processors certain non-financial Personal Data related to the purchase, such as your name, billing address, e-mail address and the items purchased, in order to fulfil your transactions and for our accounting purposes.
The legal bases for processing this data are the performance of our contractual obligations; and compliance with legal obligations to which we are subject
Improve our Services. We collect and analyse information about you and your usage of our Services to improve the usability and effectiveness of our Services
The legal bases for processing this data are our legitimate interests, in this case – providing and improving our Services
Marketing. We may use certain contact information, such as your email address, to deliver marketing communications (e.g. new features, events and promotions).
The legal basis for processing this data is your consent (when required).
Compliance with applicable laws.
We may be required to collect, retain, or share your Personal Data, under applicable laws.
4. With whom we share your data
We may share your Personal Data as described below:
Affiliated companies: we may share Personal Data internally within our family of companies, for the purposes described in this Policy.
Payment processors: we share your payment information with third party payment processors, for the purpose of facilitating your payments when using our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf.
Service providers: we work with service providers that work on our behalf that may need access to certain personal data in order to provide their services to us. These companies include those we have hired to provide various services, such as cloud storage vendors.
Compliance with laws and law enforcement entities: we may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal,unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. We will only disclose the minimum amount of Personal Data that is required for compliance with such legal requirements.
Auditors and advisers: we may share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for the purpose of ensuring our compliance with regulatory requirements and industry standards.
Mergers and acquisitions: we may share your data if we enter into a business transaction such as a merger, acquisition, reorganisation, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.
5. Your rights
This section addresses the specific rights applying to residents of the EU or residents of other jurisdictions that grant the below rights.
You may request to:
Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
Request rectification of your Personal Data that is in our control.
Request erasure of your Personal Data.
Object to the processing of Personal Data by us.
Request to restrict processing of your Personal Data by us.
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Users, including those outside the EU, are welcome to contact us for any questions or requests through our contact details below.
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time via the following email address: firstname.lastname@example.org. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
6. Transfer of data outside the EU
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred 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. Some countries outside the European Economic Area (EEA) are recognised by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information.
7. How we protect your data
We have implemented administrative, technical, and physical safeguards to help prevent unauthorised access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.
Our Services are only eligible to individuals who are the greater of eighteen (18) years of age or the age of legal majority in their jurisdiction ("Applicable Age"). We do not knowingly collect or solicit Personal Data from anyone under the Applicable Age. By accessing, using or interacting with our Services, you certify to us that you are not under the Applicable Age. In the event that we learn that we have collected Personal Data from an individual under the Applicable Age without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Applicable Age, then please contact us through the contact details available below.
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
10. Updates to this Policy
We reserve the right to change this Policy at any time. The most current version will always be posted on our Website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
11. Controlling Version
12. Contact Us
If you have any further questions, please contact us by email at: email@example.com.
Twist Solutions Ltd.