We at Twik Technologies Ltd. ("Twik" "us", "we", or "our") recognize and respect the importance of maintaining the privacy of our Customers and their End Users. This Privacy Notice describes the types of information we collect from you when you visit our website ("Site") and/or use our Services. This Privacy Notice also explains how we collect, process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at legacy.twik.io/terms ("Terms"). "You" means any adult user of the Site or Services and/or an End User of our Customer(s).
Twik is the data controller in respect of certain of the processing activities outlined in this Privacy Notice. Our registered office is Sderot Rothschild 3, Tel Aviv Israel 6688106 and our registration number is 515778611. When we process information in the context of providing Services to our customers ("Customers") including with regard to each Customer's End Users, the applicable Customer serves as a controller with respect to such Customer's End User Personal Data (as defined below). Our co-controllers are listed below.
Our representative in the European Union is Surezki Limited, address: 21 Engineer Ln. Gibraltar GX11 1AA, Gibraltar, phone number: +34-762-378-672. Our Data Protection Officer ("DPO") is Mr. Yossi Gadol, contact details avilable at Rothschild Blvd 3, Tel Aviv-Yaffo, Israel, +972546791902, and firstname.lastname@example.org.
"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
Visitors of the Site
We collect information from you when you choose to visit our Site. We also collect Personal Data when you request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason. In addition, when you visit the Site, certain information may be automatically gathered about your computer or mobile device, such as operating system, device ID, and, subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any information regarding your viewing and browsing history on the Site.
In order to use our Services as a Customer, you will be required to register and provide us with certain Personal Data, such as your name, email address, and phone number, the company you work for and your job title, and payment details. It is clarified that payment details are provided to third party payment processors and are not stored and/or processed by Twik. If you use the Services by logging in through a third-party login service (such as Facebook or Google), we may also receive Personal Data about you as provided by such third-party login service. Please check such third-party’s policies in order to understand what information we receive.
It is your voluntary decision whether to provide us with any such Personal Data, but if you refuse to provide such information we may not be able to register you to the Site and/or provide you with the Services.
If you are an End User of our Customer(s), we will collect Personal Data as they direct. For more information about any such collection, please refer to the Privacy Notice of the applicable Customer.
At the Customer's direction we may collect your interests, age, browser type, device ID, gender, geo-location, household income, language, network speed, operating system, weather, whether you are a new or returning visitor, social networks, URL from which you are referred, weighted-funnel targeting, whether you have an adblocker, pages viewed per session, average session duration and frequency, schedule, converted/non-converted user, any targeting by competitors. We collect this information through fingerprint technology that check whether you are connected to social media and websites you may have visited. We do not, however, access information stored in cookies. We assign a unique identifier to information collected from individual devices, as collected through our proprietary technology.
A Customer may also instruct us to connect the information we collect with other Personal Information it may have about you and/or with additional Personal Data collected by us about you, at Customer’s direction.
We and any of our trusted third-party subcontractors and service providers use the Personal Data we collect from and about you for any of the following purposes: (1) to provide the Site and/or Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to provide you with customized content, targeted offers, and advertising on the Site, on other third-party sites or apps you may visit, or via e-mail, based upon your history and usage of the Services and the content on our Site; (5) if you are a Customer, to contact you with informational newsletters and promotional materials relating to our Site and Services; (6) to review the usage and operations of our Site and Services; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services; (9) to provide customer support; and (10) to satisfy our legitimate interests, while at all times ensuring that your rights and freedoms are not affected.
By analyzing all information we receive, including all information concerning visitors to the Site, we may compile statistical information across a variety of platforms and users ("Statistical Information"). Statistical Information helps understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
We may use your Personal Data as required or permitted by any applicable law.
Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to our Customers, including responding to inquiries or requests, contacting and communicating with you and providing customer support. When you make a purchase, use our Services or engage in any other transaction with us, we may also process your Personal Data to perform that contract.
Processing for the purposes of developing new and enhancing our products and Services, for analytics and usage analysis, for the marketing of our products and services, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue. In conducting such processing activities, we balance these legitimate interests against the rights and interests of our users. If you would like more information regarding how we make such determinations, please contact us through the contact information specified below.
Please note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your Personal Data. Please contact us if you would like details about the specific legal grounds on which we are relying to process your Personal Data.
We share your information, including Personal Data, as follows:
When we act as a processor on behalf of our Customers, we will share Personal Data of End Users with the applicable Customer.
Business Partners, Service Providers, Affiliates, and Subcontractors
We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who use such information to: (1) help us provide you with the Site and/or Services; (2) aid in their understanding of how users are using our Site and/or Services; (3) provide to you customized content, targeted offers, and advertising on the Site, on other third-party sites or apps you may visit, or via e-mail, based upon your history and usage of the Services and the content on our Site.
Such service providers, business partners, affiliates, and subcontractors include:
When you use the Site and/or Services, we also disclose your Personal Data to additional third parties, which act as co-controllers with respect to the collection of your Personal Data. The details and contact information of such controllers are as set forth below:
We may transfer our databases containing your Personal Data if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Data, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) to protect the rights, property or safety of third parties; (iii) when required by law, regulation subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Data as specified herein by emailing us at email@example.com.
Other Uses or Transfer of Your Information
We allow you to use our Site and Services in connection with third-party services, sites, and/or mobile applications. If you use our Site and/or Services with or through such third-parties, we may receive information (including Personal Data) about you from those third parties. Please note that when you use third-parties outside of our Site and/or Services, their own terms and privacy policies will govern your use of those services.
We use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own, as set forth above and send them information we receive (including Personal Data). We conduct such international transfers for the purposes set forth above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country.
Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us through the contact information listed below if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
You hereby consent to such international transfer described above.
We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it, including by implementing the below:
Safeguards - The physical, electronic, and procedural safeguard we employ to protect your data include secure servers, firewalls, antivirus and TSL encryption of data.
Access Control - We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.
Internal Policies - We maintain and regularly review and update our privacy related and information security policies.
Personnel - We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
Encryption - We encrypt the data in transit using secure TSL protocols.
Database Backup – Our databases are backed up on a periodic basis for certain data and which are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity and are tested regularly to ensure availability, and are accessed only by authorized personnel.
However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
If you are a Customer or visitor to the Site, you have certain rights in relation to the Personal Data that we or our co-controllers hold about you, as detailed below. If you are an End User of one of our Customers, you have certain rights relating to the Personal Data held by applicable Customer (serving as a controller) or held by us on such Customer's behalf. For any requests by End Users to exercise such rights with respect to information held by the applicable Customer or by us on its behalf, please contact the applicable Customer directly. For any requests to exercise such rights with respect to information held by our co-controllers, please contact the applicable co-controller directly. If you wish for us to notify all co-controllers, please specify that when you contact us in order to exercise any of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
Subject to applicable law, we retain information as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice. We may also retain your information in an anonymized form. In addition, retention by any of our processors may vary, in accordance with the processor's retention policy.
To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether those purposes can be achieved through other means, as well as applicable legal requirements.
Please contact us through the contact information listed below if you would like details regarding the retention periods for different types of your Personal Data.
Fingerprinting on Behalf of Customers
When we collect Personal Data from our Customers' End Users, we use fingerprint technology to do so. Fingerprint technology allows us to identify certain characteristics about user’s behavior and preferences online. We use this technology at our Customers' request and direction and based upon the End User’s consent as obtained by the relevant Customer, if and as applicable in accordance with applicable law. If an End User would like to opt-out of the use of fingerprints, he or she can do so at the following link: legacy.twik.io/privacy/opt-out
Visitors to Twik's Site
What are Cookies?
A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.
We may use the terms "cookies" to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.
By changing your device settings, you can prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier. Typically, you can find the ad identifier settings under "privacy" or "ads" in your device's settings, although settings may vary from device to device.
Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisement you do see will be less relevant to your interests.
Third Party Cookies and/or Similar Technologies
Google Analytics, Google DoubleClick, Facebook, Inc.
All use of third-party applications or services is at your own risk and subject to such third party's privacy policies.
Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You will be given the opportunity to unsubscribe from commercial messages and stop receiving future communication from us by following the UNSUBSCRIBE link in any such email or message, by emailing us at firstname.lastname@example.org, as well as through your account settings. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may cancel your account.
We do not knowingly collect personally-identifiable information from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
When visiting this Site, you shall be asked to accept the terms of this Privacy Notice. If you do not agree with the terms hereof, please do not use the Site. We may update this Privacy Notice from time to time – in which case, we shall notify you of such changes. We will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.
If you have any comments or questions about this privacy notice, or if you wish for us to amend or delete your Personal Data, or exercise any other of your legal rights, please contact us at email@example.com.
Last updated: December 2018