Privacy Policy
Last Update: February , 2024
Twibolt and its associated entities are deeply committed to safeguarding the privacy of their users. Please carefully review this Privacy Policy (referred to as the “Policy”) to comprehend how Twibolt manages personal information. This Policy delineates the procedures through which Twibolt processes the personal information of users and other individuals browsing the Site (“users”) in connection with the Site and additional services offered by Twibolt, along with privacy practices pertinent to affiliates, influencers, and other collaborators.
By utilizing or navigating www.twibolt.com, the Twibolt mobile app, or any affiliated sites, applications, services, and products, or any website under Twibolt's operation linked to this policy (collectively, the “Site”), and by registering for a Twibolt account or participating in our affiliate, influencer, or analogous programs, you acknowledge that you have thoroughly read and comprehended this Policy. The Policy is subject to periodic updates; any alterations will be promptly posted on the Site. We will also take additional measures, as required by applicable law, including notifying you about substantial changes. The effectiveness of alterations to this Policy is determined by the "Last Updated" date. We strongly advise checking the Policy periodically for any modifications.
1. The Short Version
• Information We Collect: We collect information directly from you when you register, use the site, complete forms, or participate in programs. Additionally, we automatically collect data during your site usage and may receive information from third-party vendors.
• Legal Basis: We process personal information based on lawful grounds as detailed in applicable laws.
• Use of Information: We use personal information for service provision, security, site operation, fulfilling obligations, improving services, ensuring marketplace integrity, preventing fraud, direct marketing, and complying with laws.
• Data Retention: Personal information is kept for the duration necessary to fulfill its purpose, with potential longer retention in specific cases.
• Children: The site is for users 18 years or older. Minors 13-18 can use the site through a parent/guardian's account, but those under 13 are not permitted.
• Sharing with Third Parties: Personal information is shared with third parties for site operation, service provision, legal obligations, and fraud prevention.
• Data Processing Location: Personal information may be processed by third parties in different jurisdictions, including the United States and Israel.
• Cookies: We use cookies and similar technologies for enhancing user experience, providing services, analyzing performance, and marketing.
• Do Not Track (DNT): The site does not respond to Do Not Track signals.
• External Links: Third-party sites linked from Twibolt are not under our control, and their data practices are not subject to this policy.
• Security: Measures are implemented to secure the site and personal information against unauthorized access or misuse.
• EU, EEA, and UK Users: Specific provisions and rights apply to users in these regions, as detailed in the long version of the policy.
• US Residents: Residents have specific privacy rights, subject to exceptions outlined in the detailed policy.
• Updating Personal Information: Users can update their information through account profile settings, and inaccuracies can be reported for correction.
• Contact Us: Users can exercise their rights by opening a Customer Relations ticket, contacting privacy@twibolt.com, or, for Twibolt Workspace users, reaching out to workspace-support@twibolt.com. Additional details about applicable rights are available in the long version of the policy.
2. Information We Collect
2.1 Information You Provide:
When you engage with Twibolt, we collect various forms of personal information that you willingly provide during your interactions with the Site. This includes, but is not limited to:
• Contact Information: Valid email address, phone number, and physical address.
• Account Details: Login information, username, and profile details (name, picture, education, profession, expertise).
• Transactional Information: Details about gigs, orders, purchases, transactions, ratings, and reviews.
• Payment Information: Payment method, credit card number, taxpayer information, and forms (e.g., W-9 Forms, DAC-7 Forms).
• Identity Verification: Copies of government-issued ID, passport, or driver's license.
• Social Network Information: Details about linked accounts and communication on other social networks.
• User-Generated Content: Information included in content created by users.
• Additional Authentication: Information required for identity verification, as detailed in our Help Center.
2.2 Information We Collect Automatically:
As you navigate the Site, we automatically collect information to enhance your experience and improve our services. This includes:
• Usage Information: Details about transactions, communications, searches, page visits, scrolls, clicks, and other actions on the Site.
• Device Information: Geo-location, IP address, device type, operating system, session duration, language, currency, and keyboard settings.
• Web Log Information: URLs of viewed or engaged web pages.
• Cookie and Similar Technologies: Information related to the use of cookies and similar technologies.
• Impression Reporting: User Global Unique Identifier, HTTP request data, user agent, IP, host, URL, country/continent, browser info, and device/operating system/version.
2.3 Information We Receive from Third Parties:
We may receive information from third-party vendors, commercially available sources, and third-party services you connect to your Twibolt account. This includes:
• Enrichment Service Providers: Data to supplement the information we collect, including fraud and security warnings.
• Third-Party Service Integration: Information from services like Google, Facebook, or LinkedIn when you link, connect, or log in.
• Google Workspace Integration: Details of contacts from your Google Workspace directory with your permission.
• Third-Party Integrations: Information from integrated third-party systems, tools, or products based on your permissions.
• Invitations to Twibolt: Limited information if you are invited by another user, used for collaboration and referral purposes.
2.4 Data Combination:
We may combine your personal information with data collected automatically or obtained from other companies for the purposes outlined in this Policy.
3. Our Legal Basis for Using Your Personal Information
The processing of your personal information is justified based on legal grounds, including:
• Consent: You have provided consent for specific purposes.
• Contractual Necessity: Processing necessary to perform or enter into a contract with you.
• Legal Obligations: Processing required to comply with relevant legal or regulatory obligations.
• Legitimate Interests: Processing necessary to support our legitimate business interests, subject to your rights and interests.
4. How Do We Use The Information Collected
We use your personal information for the following purposes:
• Service Provision: To provide quality service, operate the Site, develop, improve, and personalize our services.
• Marketplace Integrity: To ensure a safe and secure marketplace, prevent fraud, and maintain marketplace integrity.
• Contact: To contact you as requested, approved, or permitted according to this Policy.
• Promotion and Advertising: To promote the Site, our services, and the Twibolt marketplace.
• Business Records: To maintain appropriate business records and comply with legal requests and regulations.
4.1 Direct Marketing:
We use your personal information for direct marketing communications about products, services, or promotions that may be of interest. This may include email, post, SMS, telephone, or targeted online advertisements. You have the right to opt out at any time by following the opt-out link or contacting optout@twibolt.com.
4.2 reCAPTCHA:
This Site is protected by reCAPTCHA, and Google's Privacy Policy and Terms of Service apply. The use of reCAPTCHA is necessary to prevent fraud and misuse of the Site by automated machines. To learn more, refer to Google's privacy policy.
5. How Long Do We Keep Personal Information?
At Twibolt, we adhere to a general principle of retaining personal information only for the duration necessary to fulfill the purpose for which it was collected. However, certain circumstances may warrant the retention of personal information for extended periods, including:
• Operational Necessity: We retain personal information for as long as necessary and relevant for our operations, ensuring an accurate record of your interactions in case of complaints or challenges.
• Closed Accounts: Personal information from closed accounts is retained to comply with applicable laws, prevent fraud, collect owed fees, resolve disputes, troubleshoot problems, assist investigations, and take other actions permitted by law.
• Legal and Statutory Obligations: We may retain personal information to comply with statutory or other obligations imposed on Twibolt or when necessary to preserve evidence within statutes of limitation.
6. Children
Twibolt is intended for users who are 18 years of age or older and legally eligible to form binding contracts. Minors under 18 and at least 13 years old may use the Site with an account owned by a parent or legal guardian, with appropriate permission. Users under 13 are prohibited from using the Site. If we learn of any personal information collected from a child under 13, we will promptly delete it. Parents and guardians should supervise their children's online activities. For concerns related to children's information, contact us at privacy@twibolt.com.
7. Sharing Personal Information with Third Parties
Twibolt may share your personal information with various entities for specified purposes, including but not limited to:
• Other Users and Site Visitors: Certain information, such as usernames, country, and activity details, is made public when you register. Shared information includes photos, portfolios, gig information, ratings, reviews, and other data voluntarily added to your profile.
• Users with Whom You Interact: Information may be shared to facilitate interactions, such as sharing certain details with sellers to ensure their services align with your needs.
• Service Providers: Personal information is shared with service providers for business operations, including hosting, billing, fraud detection, analytics, cybersecurity, and marketing services. We ensure third parties adhere to privacy and security standards.
• Legal Compliance: Information may be shared with law enforcement, regulatory authorities, or other parties to comply with legal obligations, respond to subpoenas, court orders, or investigations, and protect against fraud or security breaches.
• Payments and Fraud Detection: Personal information is shared with payment processors, fraud detection agencies, and similar third parties to facilitate payments and protect against fraud and unauthorized transactions.
• Social Media Partners: Limited personal information may be shared with social media platforms and marketing partners for promotional purposes.
• Corporate Affiliates: Personal information is shared with corporate affiliates to operate business activities, prevent fraud, and promote services.
• Corporate Transactions: In the event of a business transition, such as a merger, sale, or acquisition, personal information may be disclosed to prospective buyers.
8. Where We Process Your Personal Information
Some personal information may be stored or processed by third-party suppliers and data processors, possibly located in jurisdictions with different data protection laws. Appropriate safeguards, such as EU standard contractual clauses, are implemented for data transfers outside the European Economic Area (EEA).
9. Cookies
Twibolt utilizes cookies and similar technologies to enhance user experience, provide services, analyze website performance, and for marketing purposes. The types of cookies used are categorized as essential, analytics, and marketing cookies. For detailed information and control over cookies, refer to our Cookie Policy.
10. Do Not Track
Twibolt does not honor Do Not Track (DNT) browser requests but provides options to opt out of receiving cookies, as explained in our Cookie Policy.
11. External Links
Links to third-party sites on Twibolt are not under our control, and data provided or used by those third parties is not subject to this Policy. Users should review the privacy policies of each visited site. This Policy applies solely to personal information collected by Twibolt. When tagging the Site on social networks, submissions are subject to the terms of use and privacy policy of the respective social network.
12. Security
At Twibolt, the security of our Site, services, and personal information is paramount. We employ technical and organizational measures to safeguard against unauthorized access, loss, misuse, alteration, destruction, or damage. These measures include industry-standard technologies and internal procedures. We maintain a PCI DSS (Payment Card Industry Data Security Standards) certification for credit card payments and contractually ensure that third parties processing your personal information adhere to strict confidentiality and integrity standards.
While we implement robust security measures, the transmission of data over the internet is not entirely secure. Despite our best efforts, we cannot guarantee the security of data transmitted to the Site. Upon receiving your data, we employ strict procedures and security features to prevent unauthorized access.
Users who register on the Site are obligated to keep their passwords confidential and refrain from disclosing them to third parties. Additional details about our data security practices can be provided upon request.
13. Specific Provisions for EU, EEA, and UK Users
This section applies to users in the EU, EEA, or UK. Twibolt, as the Controller under the GDPR, provides the following rights:
• Information Access: You have the right to obtain information about how and on what basis your personal information is processed and obtain a copy.
• Rectification: You can rectify inaccurate personal information.
• Erasure: In limited circumstances, you can request the erasure of your personal information.
• Restriction of Processing: You may restrict the processing of your personal information under certain conditions.
• Objection to Automated Processing: You can object to decisions based solely on automated processing.
• Data Portability: You can request a copy of your data in a structured, machine-readable format.
• Access to Safeguards: You have the right to obtain a copy of or access safeguards for the transfer of your personal information outside the EEA.
To exercise these rights, contact us through the "Contact Us" section. You also have the right to lodge a complaint with a supervisory authority for data protection.
We may ask for additional data to verify your identity and may charge a fee where permitted by law. Certain personal information may be retained for record-keeping, accounting, and fraud prevention purposes.
14. Specific Provisions for US Residents
This section applies to US residents. In the last twelve months, Twibolt has collected various categories of personal information, including identifiers, characteristics of protected classifications, commercial information, internet or electronic network activity information, and inferences drawn from such information.
You have the following rights:
• Access: Request access to personal information collected in the past 12 months.
• Deletion: Request deletion of personal information under certain circumstances.
• Correction: Correct personal information you provided.
• Opt-Out of Sale: Opt-out of the sale of personal information.
• Opt-Out of Targeted Advertisement: Opt-out of targeted advertising.
• Non-Discrimination: Not be discriminated against for exercising your rights.
• Authorized Agent: Submit requests via an authorized agent, subject to specific requirements.
To make requests, open a Customer Relations ticket or contact us at privacy@twibolt.com. For Twibolt Workspace users, contact us at workspace-support@twibolt.com. We will verify requests using associated account information and may require government identification.
15. Updating Personal Information
At Twibolt, we prioritize the accuracy and currency of the personal information we collect. To ensure that your information is correct and up-to-date, we offer you the ability to update it through your account profile settings. If you believe that any of your information is incorrect or inaccurate, please notify us immediately. We will promptly investigate the matter and rectify any inaccuracies as needed or provide you with avenues to update or delete the information – unless retention is required for legitimate business or legal reasons. When initiating updates to your personal information, identity verification will be requested for security purposes.
You can conveniently review and modify your personal information by logging into the Site and accessing your account profile page.
In cases where you wish to delete your User Generated Content (“UGC”), as defined in the Twibolt Terms of Service, from the Site, please be aware that copies of your UGC may persist in cached and archived pages or might have been copied or stored by other Site users. The appropriate access and use of information, including UGC, are governed by our Terms of Service.
If you encounter difficulties in deleting your personal information, please reach out to Twibolt's Customer Support. We are committed to making reasonable efforts to delete such information in accordance with applicable privacy laws.
16. Contact Us
To exercise any of your rights regarding your personal information, we kindly request that you open a Customer Relations ticket. Please provide all relevant details to ensure proper handling of your ticket. We will process your requests in accordance with local laws and our established policies and procedures. Alternatively, you may reach out to us via email at privacy@twibolt.com or through postal mail at Twibolt Ltd., 8 New York.
If you have any questions or comments regarding this Policy, please email our team at privacy@twibolt.com, and we will make every effort to respond within a reasonable timeframe.