Privacy Policy

The policy was last updated on 01 May 2019

WE TAKE THE PRIVACY OF OUR CUSTOMERS VERY SERIOUSLY. THIS PAGE SETS OUT OUR POLICIES REGARDING YOUR PRIVACY AND THE INFORMATION WE COLLECT IN ORDER TO DELIVER THE SERVICE. This explains what information is gathered about you, what we use that information for, and who we give that information to. It also sets out your rights in relation to your information, how long we keep it and who you can contact for more information. Although you do not have to provide any of your personal information to us, if we ask you to do so and you refuse, we may be unable to provide you with the information, goods or services you want from us. Although you need to set up an account using your Twitter username and password, we do not have access to these details, nor do we store them. The personal information we collect and store is the minimum we need in order to send out the Twilerts and bill you for any subscriptions you have. If you believe we have collected excessive information about you, please contact us [email protected] to raise any concerns you may have. We also collect anonymous information about what pages consumers access or visit, using Google Analytics. This information is used purely for us to understand who our customer are and improve our services and the ways in which we provide information about our services to new and existing customers. Any information we have is never shared with anyone outside and never will be unless:

• it is necessary to share information as required by law, or
• we sell either Twilert itself is sold to a third party, in which case, details would be transferred to them. We would inform you of any changes to our Privacy Policy were this to happen.

1. The way we gather and use information

In order to use the Services, you will need a Twitter account and be required to authorize Twilert Staging to use your Twitter account. Twilert will not have access to your Twitter password, nor will it be able to post on your behalf or access your direct messages. You are free to revoke Twilert’s access at any time from the Applications tab of your Settings page on Twitter.com If you decide to take up one of our subscription packages, we will then ask you for your name and billing details, along with your credit card. We do not store these details and use a third party trusted payment handler based in the USA called Recurly. Recurly meets and exceeds all industry-standard payment security practices. You can read more about their security set up here https://recurly.com/security

2. Security of personal information

We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorised persons are provided access to personally identifiable information we have collected, and such individuals have agreed to maintain the confidentiality of this information. Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.

3. Sharing personal information

We may transfer, share or disclose the personal data we collect from you to third parties (other organizations or individuals) for:

• The purposes for which the information has been submitted
• The purposes listed above under ‘The way we gather and use personal information’
• The administration and maintenance of our website and/or
• Other internal or administrative purposes

We also may transfer share or disclose personal data to third party service providers of website hosting and management, data analysis, data backup, security and storage services. These third party providers may use their own third party subcontractors that have access to personal data (sub-processors). It is our policy to use only third party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by us, and to flow those same obligations down to their sub-processors.

Other disclosures

We may also disclose personal information to third parties under the following circumstances:

• When explicitly requested by you
• When required to deliver goods or services requested by you
• When required to facilitate our conferences or events that you have asked to attend which are hosted by a third party
• As otherwise set out in this privacy policy.

We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation. The third parties we may transfer share or disclose the personal data we collect from you to are:

4. Retention of personal information

We will retain your personal information only for as long as we need it, given the purposes for which it was collected, or as required to do so by law. Normally, this means we will retain your personal information for five years. In the case that you request the complete deletion of data, we will commit to deleting any associated data with your account within 30 business days.

5. Marketing

Where we are legally required to obtain your consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so. If you opt into any subscriptions you will receive emails known as newsletters. If you want to unsubscribe from any subscriptions, you should look for and follow the instructions we will provide in the relevant communications to you. If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honour your request.

6. Rights in relation to your information

You have certain rights in relation to the personal information we hold about you. In particular, you have the right to: Request a copy of the personal information we hold about you;

• Ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
• Ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
• Object to our processing of your personal information; and/or
• Withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).

If you would like to exercise these rights or understand if these rights apply to you, please contact us at [email protected].

7. Automated decision making

We will not use your personal information for automated decision making or profiling.

8. Children

We understand the importance of protecting children’s privacy and we never knowingly collect personal information about individuals under the age of 13. We adhere to laws regarding marketing to children.

9. Our website

We do not intend to collect special category (also known as sensitive) personal information through our website (unless we are legally required to do so). Examples of special category information are a race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records. We ask that you do not provide us with a special category of personal information when using our website.

11. Cookies

A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site’s computers and stored on your computer’s hard drive. We use cookies to record current session information, but do not require permanent cookies.

12. Third party vendors for storing data

Twilert uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run our services.

13. Contact us

If you have any questions or complaints about the way your personal information is processed by us, or would like to exercise one of your rights set out above, please contact us by on [email protected]. We may update this Privacy Notice at any time by publishing an updated version here. So that you know when we make changes to this Privacy Statement, we will amend the revision date at the top of this page. The new modified or amended Privacy notice will apply from that revision date. Therefore, we encourage you to review this Privacy notice periodically to be informed about how we are protecting your information.