Effective date: 26th of January, 2023
Twiso, Inc, a Delaware corporation (“Twiso” and “we” / “us”) respects your privacy. This notice describes the types of Personal Information (as defined below) we may collect or that you may provide when you interact with our websites and software (collectively, the “Application”); and our practices for collecting, using, maintaining, protecting, and disclosing Personal Information. In this notice, “Personal Information” means any information that identifies or relates to a reasonably identifiable individual. Please read the notice carefully.
The following terms have the meanings ascribed:
- “Cookies” means small sets of data stored in the User’s device.
- “Data” means all information provided by any User or obtained by the Application about a User
- “Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Information, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is Twiso.
- “Data Processor” or a “Service Provider” means the natural or legal person, public authority, agency or other body which processes Personal Information on behalf of the Controller, as described in this notice.
- “Data Subject” means the natural person to whom the Personal Information refers.
- “Service(s)” means the services provided by this Application as described on our website at twiso.co.
- “Usage Data” means information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
- “User” means the individual using this Application who, unless otherwise specified, coincides with the Data Subject. Users are also referred to individually throughout these terms as “you”.
Types of Data We Collect & How We Collect It
The types of Personal Data this Application collects, by itself or through third parties, includes Cookies, Usage Data, address, email addresses, names and phone numbers. (Further detail concerning each type of Personal Information collected is provided below in the Section entitled “Detailed Information Concerning the Processing of Data.”) We collect this Personal Information directly from you when you provide it to us or automatically when you use the Application.
Information You Provide to Us
When you register with or use the Application, we may ask you provide the following data that may, alone or in combination with other information, constitute Personal Information
- Name, postal address, email address, telephone number, and any other identifier by which you may be contacted online or offline; and
- company or employer name.
Additionally we may collect:
- information that you provide by filling in forms in the Application (such as when you register or subscribe, when you post information, or when you request Services);
- records and copies of your correspondence (, if you contact us
- your responses to surveys that we might ask you to complete for research and development purposes;
- details of transactions you carry out through the Application and of the fulfillment of your orders, including financial information you may be required to provide before placing an order through the Application;
- search queries within the Application; and
- files you upload to the Application
When you access or use the Application, it may use technology to automatically collect the following Data that may, alone or in combination with other information, constitute Personal Information:
- Usage Data, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Application;
- Data about your device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number;
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
- Cookies. A cookie is a small file placed on your device. You can adjust your cookie settings within your browser. However, if you do so, you may be unable to access certain parts of our Application.
How We Use Personal Information About You
We use Data that we collect about you or that you provide to us, including any Personal Information, to:
- Provide you with the Application and its contents, and any other information, products or services that you request from us.
- Fulfill any other purpose for which you provide it.
- Give you notices about your account or subscription, including expiration and renewal notices.
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- Notify you when Application updates are available, and of changes to any products or services we offer or provide through it.
The Usage Data we collect helps us to improve our Application and to deliver a better and more personalized experience by enabling us to:
- Estimate our audience size and usage patterns.
- Store Data about your preferences, allowing us to customize our Application according to your individual interests.
Security and Methods of Processing
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of Personal Information. The processing of Personal Information is carried out using computers and systems, following organizational procedures and modes strictly related to the purposes indicated. In some cases, Personal Information about you may be accessible to employees and other service providers involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). An updated list of these parties may be requested from Twiso at any time.
Despite our efforts to store Personal Information in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent malicious third-parties from illegally obtaining access to Personal Information. We do not warrant or represent that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.
Legal Basis of Processing
We may process Personal Information relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes; provided, that, in certain jurisdictions (other than the European Union) Twiso may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases;
- Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation to which Twiso is subject;
- Processing is necessary for the purposes of the legitimate interests pursued by Twiso or by a third party.
Should you desire that we clarify the specific legal basis that applies to particular processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract, please contact us at the email address provided in the Contact Us section below.
Transfers of Personal Information
Twiso is based in the United States of America. If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, this means that we may transfer Personal Information outside of the EEA, the United Kingdom, or Switzerland. Such transfers are made using adequate safeguards, such as the EU Standard Contractual Clauses for Controller-to-Controller and Controller-to-Processor Transfers.
Personal Information shall be processed and stored for as long as required by the purpose for which it has been collected.
- Personal Information collected for purposes related to the performance of a contract between Twiso and the User shall be retained until such contract has been fully performed and for a period of up to four years thereafter (or such longer time as is necessary to enforce or protect our interests or as required by law).
- Personal Information collected for the purposes of Twiso’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Twiso by contacting Twiso.
- Twiso may be allowed to retain Personal Information for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Twiso may be obligated to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
- Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Detailed Information Concerning the Processing of Personal Information
Personal Information is collected for the following purposes and using the following Data Processors/Service Providers:
The services contained in this section enable Twiso to monitor and analyze web traffic and can be used to keep track of User behavior.
- measure and analyze traffic and browsing activity on our site;
- show advertisements for our products and/or services to you on third-party site(s);
- and collect emails for direct marketing purposes.
Amplitude is a web application analysis service.
Amplitude utilizes the Data collected to track and examine the use of this Application to prepare reports on its activities.
Personal Data collected: Page URLs, IP addresses, browser fingerprint, operating system, device type, visitor country.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Information is stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.): Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.
Google (Alphabet Inc.): Google is a groupware and infrastructure service provided by Alphabet Inc.
- Personal Data collected: email, video transcriptions, analytics data
Zoom (Zoom Video Communications, Inc.): Zoom is a video conferencin solution provided by Zoom Video Communications, Inc.
- Twiso utilizes the data collected to track user meetings and meeting configuration (e.g. if a recording is enabled)
- Zoom data collected: meetings, recordings, user profiles (only userId)
- Personal data collected: meeting recordings
Source code management
This type of service makes it possible to manage source code for the twiso.co application. The Personal Data processed depends on the information provided by the User.
Certain Rights of Users
Users may have certain rights regarding Personal Information about them processed by Twiso in particular jurisdictions, depending on whether Twiso is subject to the jurisdictional reach of the applicable laws, such as:
- the right to withdraw consent where they have previously given their consent to the processing of Personal Information about them;
- the right to object to the processing of Personal Information about them if the processing is carried out on a legal basis other than consent;
- the right to learn if Personal Information about them is being processed by Twiso, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Personal Information undergoing processing;
- the right to verify the accuracy of Personal Information and ask for it to be updated or corrected;
- the right to restrict the processing of Personal Information about them;
- the right to have Personal Information deleted or otherwise removed;
- the right to receive Personal Information about them in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller of Personal Information without any hindrance; and
- the right to bring a claim before a competent data protection authority.
Details About the Right to Object to Processing
Where Personal Information is processed for the purposes of the legitimate interests pursued by Twiso, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users may opt-out of the use by Twiso of Personal Information for marketing purposes at any time by providing notice to Twiso at email@example.com without providing any justification.
How to Exercise These Rights
Any requests to exercise User rights can be directed to Twsio through the contact details provided in this notice. These requests can be exercised free of charge and will be addressed by Twiso as early as possible and in any event no later than within 30 calendar days.
Disclosure of Personal Information
We may disclose Data that does not identify any individual without restriction. In addition, we may disclose Personal Information that we collect or you provide:
- To our subsidiaries and affiliates. To contractors, service providers (as described above in “Detailed Information Concerning the Processing of Personal Information”), and other third parties we use to support our business solely for purposes of providing such services and for no other purpose.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Twiso about our Application users is among the assets transferred. To fulfill the purpose for which you provide it. For any other purpose disclosed by us when you provide the Personal Information. With your consent.To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce our rights arising from any contracts entered into between you and us, including the Application Terms of Service, and for billing and collection.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our employees, our customers or others.
Your California Privacy Rights
California Civil Code Section 1798.83 permits users of our Application that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email or write us at the Contact Information provided below. In the last 12 months, we have not sold Personal Information collected in and through the Application. Consequently, we do not have a Do Not Sell My Info-functionality on the Application.
You have a right not to be treated in a discriminatory manner for the exercise of your California privacy rights.
The Application is not intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that Personal Information. If you believe we might have any information from or about a child under 13, please contact us at the email in the Contact Us section below.
Additional Information About Data Collection and Processing
Providing & Requesting Additional Information
In addition to the information contained in this notice, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Information upon request.
System Logs & Maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (system logs) and use other Personal Information (such as the IP Address) for this purpose.
“Do Not Track”
This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies. Users may follow the instructions provided on the subsequently linked initiatives by the EDAA (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. Twiso thus recommends that Users make use of these resources in addition to the information provided in this document.
We reserve the right to make changes to this privacy notice at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to us. Please check this page often, referring to the date of the last modification listed on the top of this page. Should the changes affect processing activities performed on the basis of the User’s consent, we will collect new consent from the User, where required, and, if not given, further use of the Application may not be possible.