Last
modified November 1, 2012
We
at Twyxter, Inc. (“Twyxter,” “we,” “us,” or “our”) are fully
committed to the responsible use of your personal information and the
protection of your privacy. This privacy policy describes how we handle your
personal information and applies to all the products and services we offer on
the Twyxter web site, websites that are identified as operated by Twyxter or
other services we may make available from time to time (referred to
collectively in this Privacy Policy as the “Twyxter Services”). We
pledge that we will take reasonable steps to ensure that your personal
information will only be used in ways that are in compliance with this Privacy
Policy. This Privacy Policy does not pertain to any information that is
publicly available on or through the Twyxter Services.
This
Privacy Policy serves to notify you of the following:
What information about me is collected when using the Twyxter
Services?
Does Twyxter collect information from children under 13 years of age?
What does Twyxter do with the information it collects?
When does Twyxter disclose information to third parties?
Does this privacy policy apply when I link to other web sites?
Is the information collected when using the Twyxter Services secure?
Can I update or correct my personally identifiable information?
How will I know if there are any changes to this privacy policy?
Who do I contact if I have any privacy questions?
If you have
questions regarding this Privacy Policy, please contact our Customer Care team
by e-mail at privacy@twyxter.com.
WHAT
INFORMATION ABOUT ME IS COLLECTED WHEN USING THE TWYXTER SERVICES?
Depending
on your use of the Twyxter Services, we collect both Personal Information and
Non-Identifiable Information that you submit to us voluntarily through the
Twyxter Services. Certain aspects of the Twyxter Services may be accessed by
non-registered users (“Visitors”). If you become a registered user (“User”) of
the Twyxter Services, we will collect information that you submit in the
process of creating or editing your User account and User profile. For example,
our registration and login process may require you to provide us with your
name, a valid email address and a password of your choice. If you access the
Twyxter Services through a mobile device, we may also collect your mobile phone
number as part of your registration information. When you personalize your
profile and use the features of the Twyxter Services, we will collect any
information you voluntarily provide, and we may also request optional
information to support your use of the Twyxter Services, including such
Non-Identifiable Information as your gender and other demographic information.
We also collect information from Users in the form of the content that you
choose to submit during your use of the Twyxter Services.
Personally
Identifiable Information
Personally
identifiable information is information that identifies you or can be used to
identify or contact you. Such information may include information such as your
name, address, email address, and telephone number. We will request personally
identifiable information from you when you register to use the Twyxter
Services. In all of these cases, we will collect personally identifiable
information from you only if you voluntarily submit the information to us.
Unless you give us permission to do so, we will not sell, share, license, trade
or rent your personally identifiable information other than as specified in
this Privacy Policy.
Non-Personally
Identifiable Information
Non-personally
identifiable information is information that by itself cannot be used to identify or contact you, such as demographic information
(like age, profession or gender). Non-personally identifiable information may
also include Visitor and User IP addresses, browser types, domain names, and
other anonymous statistical data involving the use of the Twyxter Services.
WHERE
AND WHEN IS INFORMATION COLLECTED ON THE TWYXTER SERVICES?
Using the Twyxter Services.
Visitors
who wish to subscribe to communications related to the Twyxter Services (“Subscribers”) must “opt-in” to receive
such communications. If you “opt-in” and elect to subscribe to such
communications, you will be required to provide us with certain information,
such as your name and email address, in order for us to communicate with you.
In
order to access certain aspects of the Twyxter Services and/or upload content
to the Twyxter Services, you must first complete certain steps to become a User
with permission to access certain secure areas of the Twyxter Services. During
these steps, you will be required to provide us with information (including
personally identifiable information) such as name, company, department, postal
address, email address and phone number. This information is necessary for our
provision of the Twyxter Services and is also used to help us understand who
uses the Twyxter Services, to improve the Twyxter Services, and/or to contact Users
about the Twyxter Services.
In
their use of the Twyxter Services, Users may be permitted to submit, publish,
post, and display various types of content, including data, text, information,
profiles, pictures, graphic images, audio and video clips, links and other such
content (collectively “User Content”).
Inasmuch as such User Content is submitted and published within the Twyxter
Services, it will be visible to other registered and non-registered users who
have access to that aspect of the Twyxter Services. To enable us to deliver the
full benefits of the Twyxter Services and to insure that the Twyxter Services
are being used in accordance with the associated Twyxter Terms of Use, we will
also collect and retain detailed information about each User, including but not
limited to their Account information, their usage of the Twyxter Services,
their User Content and their communications and interactions with other Users
(collectively “User Data”).
Log
Files, Cookies and Action Tags.
We also collect non-personally identifiable
information passively using Internet “log files,” “cookies” and “action tags.”
“Log
files” record data such as Visitor and User IP addresses, browser types, domain
names, and other anonymous statistical data involving the use of the Twyxter
Services. This information may be used to analyze trends, to administer the
Twyxter Services, to monitor the use of the Twyxter Services, and to gather
general demographic information. We may link this information to personally
identifiable information for these and other purposes such as personalizing
your experience on the Twyxter Services and evaluating the Twyxter Services in
general.
"Cookies"
are pieces of information that a website transfers to your computer's hard disk
for record-keeping purposes. Cookies in
and of themselves do not personally identify users, although they do identify a
user's computer. You may be able to set
your web browser to refuse Cookies, which in turn may affect your ability to
access and use the Twyxter Services.
"Action
tags," also known as web beacons or gif tags, are a web technology used to
help track web site usage information, such as how many times a specific page
has been viewed. Action tags are invisible to you, and any portion of the
Twyxter Services, including email sent by us or on our behalf, may contain
action tags.
By
using cookies and action tags together, we are able to gain valuable
information to improve the Twyxter Services and measure the effectiveness of
our various communications and marketing campaigns. We do not disclose any of
your personally identifiable information to our advertising partners.
Finally,
you should be aware that other third parties may also use their own cookies or
action tags when you link to their web sites or services on or from the Twyxter
Services. This Privacy Policy does not govern the use of such cookies or action
tags by third-party web sites or services.
DOES
TWYXTER COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?
We are committed to protecting the privacy of
children. The Twyxter Services is not designed for or directed to children
under the age of 13. We do not collect personally identifiable information from
any person we actually know is under the age of 13.
WHAT
DOES TWYXTER DO WITH THE INFORMATION IT COLLECTS?
In
general, both the Personal Information and Non-Identifiable Information you
submit to us is used to provide you access to the Twyxter Services, to process
your transactions and interactions when using the Twyxter Services, to help us
understand who uses the Twyxter Services, to improve the Twyxter Services, to
contact you for customer service or for market research purposes, to better tailor
the features, performance, and support of the Twyxter Services, and to offer
you additional information, opportunities, promotions and functionality from us
or our partners. For example, we may use and display your full name and email
address when you send an email notification to another User through the Twyxter
Services.
If
you register to become a User, we may use your information to send you a
welcoming email that may confirm your user name and password. If you “opt-in”
and become a User of the Twyxter Services, become a Subscriber or request
information from Twyxter, we may contact you in conjunction with your use of
the Twyxter Services, send you electronic newsletters, contact you about
Twyxter’s products, services, information and news that may be of interest to
you, and provide you with targeted feedback. We may also contact you about
voluntarily participating in surveys or other research to help us to meet the
needs of Visitors and Users of the Twyxter Services and to better understand
the needs of the markets we serve. If you no longer desire to receive some or
all of these communications, we will provide you with the option to change your
preferences. Note that, if you have registered as a User of the Twyxter
Services, you will not be able to stop certain types of communications unless
you choose to cancel your User Account, in which event you will no longer be
able to enjoy the access privileges and functionality that we grant to Users.
In
addition, if you identify yourself to us by sending us an email with questions
or comments, we may use your information (including personally identifiable
information) to respond to your questions or comments, and we may file your
questions or comments for future reference. We may also use the information collected
to send you important service announcements and updates regarding the Twyxter
Services or, if you are a Subscriber or User, about your account status. As
long as you are registered as a User, you will not be able to unsubscribe from
these service announcements and updates as they contain important information
relevant to your use of the Twyxter Services.
If
you provide feedback to us, we may use and disclose such feedback for any
purpose, provided we do not associate such feedback with your Personal
Information. We will collect any information contained in such feedback and
will treat the Personal Information in it in accordance with this Privacy
Policy.
We
may also use the information gathered on the Twyxter Services to perform
statistical analysis of Visitor and User behavior or to evaluate and improve
our Twyxter Services. We may link some of this information to personally
identifiable information for internal purposes only or to improve your
experience with the Twyxter Services.
WHEN
DOES TWYXTER DISCLOSE INFORMATION TO THIRD PARTIES?
Except
as set forth in this Privacy Policy or as specifically authorized by you, we
will not disclose any information we gather from you on the Twyxter Services.
Laws and Legal Rights.
We
may disclose your information (including personally identifiable information)
if we believe in good faith that we are required to do so in order to comply
with an applicable statute, regulation, rule or law, a subpoena, a search
warrant, a court or regulatory order, or other valid legal process, or that we
should do so when we have reason to believe that disclosing this information is
necessary to protect the safety and/or security of our Users, Twyxter or the
general public.
Third
Parties Generally.
We
may provide to third parties information about you that does not allow you to
be identified or contacted, including where such information is combined with
similar information of other Visitors and Users of the Twyxter Services. For
example, we might inform third parties regarding the number of unique users who
visit the Twyxter Services or the demographic breakdown of Users of the Twyxter
Services. The third parties to which we may provide this information may
include potential or actual providers of advertising products or services
(including vendors and web site tracking services), commercial partners,
sponsors, licensees, researchers and other similar parties.
Sponsoring Organizations.
Twyxter
has relationships with various companies, organizations and other entities that
provide Twyxter with some consideration in exchange for granting certain
individuals and groups of individuals access to
non-public areas of the Twyxter Services. In service to such companies,
organizations and other entities (collectively “Sponsors”) we offer the privileges of becoming Users of the Twyxter
Services to specific individuals and groups of individuals who have
specifically been designated by their sponsoring organization. If your ability
to use of certain aspects of the Twyxter Services has been provided to you
expressly in conjunction with a Sponsor, we may from time to time provide all
or some of your User Data to your Sponsor. In general, any User Data that we
provide to your Sponsor will be aggregated with similar information collected
from other non-registered and registered users who are also associated with
your Sponsor. From time to time and at our sole discretion, we may also share
your specific User Data with your Sponsor in a detailed, or non-aggregated,
form. Typically, we will only share this individual level User Data with your
Sponsor when we believe it is in the best interest of the Sponsor’s other
registered Users and/or when it is needed by your Sponsor to insure that they
can properly administer the Account privileges that are provided at their
discretion and through their role as Sponsor.
Outside Contractors.
We
may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide
specific services and products related to the Twyxter Services, such as hosting
and maintaining the Twyxter Services, and developing applications for the
Twyxter Services and e-mail services. In the course of providing products or
services to us, these Outside Contractors may sometimes have limited access to
information collected on the Twyxter Services, including your personally
identifiable information. We also require that these contractors
(1) protect the privacy of your personally identifiable information
consistent with this Privacy Policy, and (2) not use or disclose your
personally identifiable information for any purpose other than providing us
with the products or services for which we contracted.
We
reserve the right to transfer information to a third party in the event of a
sale, merger or other transfer of all or substantially all of the assets of
Twyxter, Inc. provided that the third party agrees to adhere to the terms of
this Privacy Policy.
Affiliates.
We
may disclose information (including personally identifiable information) about
you to our Affiliates. For purposes of this Privacy Policy, "Affiliates" means any person or
entity which directly or indirectly controls, is controlled by or is under
common control with Twyxter, Inc., whether by ownership or otherwise. Any
information relating to you that we provide to our Affiliates will be treated
by those Affiliates in accordance with the terms of this Privacy Policy.
DOES
THIS PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEB SITES?
Our
web sites may contain links to other web sites not owned or operated by
Twyxter. However, please be aware that we are not responsible for the privacy
practices of such web sites. We encourage you to be aware when the Twyxter
Services link to other web sites and to read the privacy policies or statements
of each and every web site. This Privacy Policy applies solely to information
collected by the Twyxter Services.
IS THE
INFORMATION COLLECTED WHEN USING THE TWYXTER SERVICES
SECURE?
The
information we collect when using the Twyxter Services is stored in secure
operating environments that are not made generally available to the
public. Unfortunately, no data
transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot ensure the security of
any information you provide, and you do so at your own risk. Once we receive your transmission, we will
make reasonable efforts to ensure its security on our systems.
WHAT CHOICES DO I HAVE REGARDING THE COLLECTION, DISCLOSURE
AND DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION?
Except
as otherwise described in this Privacy Policy, we will only use personally
identifiable information for the purposes described above or as otherwise
disclosed at the time we request such information from you. You must
"opt-in" and give us permission to use your personally identifiable
information for any other purpose. For example, we may have an "opt-in"
mechanism so that those who become Subscribers or Users must give us permission
to send them marketing materials and our electronic
newsletter or to send them notifications that are associated with their usage
of the Services. You may also change your preference and "opt-out" of
receiving such communications by changing that option by following the
directions provided in association with the communication, or by privacy@twyxter.com.
Note that, if you are registered as a User of the Twyxter Services, you will
not be able to stop certain types of communications unless you choose to cancel
your User Account, in which event you will no longer be able to enjoy the
access privileges and functionality that we grant to Users.
CAN I
UPDATE OR CORRECT MY PERSONALLY IDENTIFIABLE INFORMATION?
You
have the right to request the restriction of certain uses and disclosures of
personally identifiable information as follows. You can contact us in order to
(1) update or correct your personally identifiable information,
(2) change your preferences with respect to communications and other
information you receive from us, or (3) delete the personally identifiable
information maintained about you on our systems (subject to the following
paragraph), by contacting privacy@twyxter.com.
Such updates, corrections, changes and deletions will not have an effect on
other information that we maintain, or information that we have provided to
third-parties in accordance with this Privacy Policy prior to such update,
correction, change or deletion.
You
should be aware that it is not technologically possible to remove each and
every record of the information you have provided to us from our system. The
need to back-up our systems to protect information from inadvertent loss means
that a copy of your personally identifiable information may exist in a
non-erasable form that will be difficult or impossible for us to locate. We
promise that promptly after receiving your request, all personally identifiable
information stored in databases we actively use and other readily searchable
media will be updated, corrected, changed or deleted, as appropriate, as soon
as reasonably practicable.
HOW
WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?
You
should be aware that we may revise this Privacy Policy at any time and that
such revisions may result in additional uses or disclosures of your personally
identifiable information. We will make an effort to update this web page with
any changes to this Privacy Policy and you are encouraged to review this
Privacy Policy frequently so that you may stay up to date about what
information we collect, how we use it, and under circumstances, if any, we
disclose it (the date of the most recent revision to this Privacy Policy will
appear at the beginning or end of this Privacy Policy). We may also make
non-significant changes to this Privacy Policy that generally will not affect our
use of your personally identifiable information. If you do not agree to the
terms of this Privacy Policy, you should not use the Twyxter Services.
WHO DO
I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
If
you have any questions or comments about our Privacy Policy or feel that we are
not abiding by the terms of our posted Privacy Policy, please contact Customer
Care in any of the following ways:
By e-mail:
By postal mail
or courier:
Customer Care –
Privacy Policy
Twyxter, Inc.
BY
USING THE TWYXTER SERV
Copyright 2012 Twyxter, Inc. All rights reserved. Twyxter is a trademark of Twyxter, Inc.