Twyxter
 

PRIVACY POLICY

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?

Where and when is information collected on the Twyxter Services (including through the use of cookies and action tags)?

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?

What choices do I have regarding the collection, disclosure and distribution of personally identifiable information?

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.

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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.

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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.

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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.

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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.

Sale of Business.

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.

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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.

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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.

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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.

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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.

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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.

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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:

privacy@twyxter.com.

By postal mail or courier:

Customer Care – Privacy Policy
Twyxter, Inc.
P.O. Box 207
Weston , MA 02493-1000 USA

BY USING THE TWYXTER SERV ICE S, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE THE TWYXTER SERV ICE S. YOUR CONTINUED USE OF THE TWYXTER SERV ICE S FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY WILL MEAN THAT YOU ACCEPT THOSE CHANGES.

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Copyright 2012 Twyxter, Inc. All rights reserved. Twyxter is a trademark of Twyxter, Inc.