Effective: 08 April 2022
Introduction
We are Twirl Technologies Ltd (“Twirl”), a British registered company with a registered address at Senna Building, Gorsuch Pl,London E2 8JF , United Kingdom provides a content generation service (“Service”) more fully described on the website usetwirl.com (“Website”)
This Privacy Policy explains what personal information Twirl collects about you and why, what we do with that information, how we share it, and how we handle the content you place in our products and services. For the purposed of this Privacy Policy, "Personal Information" means is any information related to an identifiable individual or that may be used to identify an individual. Please read the following carefully to understand our practices regarding Personal Information, including Personal Information of visitors to our Website, our customers (“Customers”) and creators who submit content to us ("Creators") .
Changes to our Privacy Policy
We may change this Privacy Policy from time to time. We encourage you to review this Privacy Policy each time you use our Website or our Services to see if the policy has been changed, as indicated by the “Effective Date” set out above. We may at our discretion choose to highlight the fact that we made material changes by posting a notice on our Website and/or by sending you a notice (if we have your contact details), as appropriate.
Information you provide us
You may give us Personal Information by:
* Using our service as a Customer of ours. Where you are our Customer or are an employee of our Customer you may provide us with Personal Information. The type of information collected includes your name; company name; business address; email address; phone number; username; password; business tax number and basic site information i.e. URL/Channel/Impression Traffic etc.
* Corresponding with us by phone, e-mail or otherwise. We ask you to disclose only as much information as is necessary to provide you with our products or services or to submit a question/suggestion/comment in relation to our Website or our services or products.
* Applying to work with us. The type of information you may provide in your CV, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). We ask that you do not disclose sensitive personal information (e.g. gender, height, weight, medical information, religion, philosophical or political beliefs, financial data) in your application.
* Supplying us with goods or services, whether as a creator or otherwise. Suppliers such as creators may provide us with information which may include a contact name; email address; business address; and telephone number.
Mobile Terms of Service
Last updated: Aug. 31, 2022
The Twirl mobile message service (the "Service") is operated by Twirl (“Twirl”, “we”, or “us”). Your use of the Service constitutes your agreement to these terms and conditions (“Mobile Terms”). We may modify or cancel the Service or any of its features without notice. To the extent permitted by applicable law, we may also modify these Mobile Terms at any time and your continued use of the Service following the effective date of any such changes shall constitute your acceptance of such changes.
By consenting to Twirl’s SMS/text messaging service, you agree to receive recurring SMS/text messages from and on behalf of Twirl through your wireless provider to the mobile number you provided, even if your mobile number is registered on any state or federal Do Not Call list. Text messages may be sent using an automatic telephone dialing system or other technology. Service-related messages may include updates, alerts, and information (e.g., order updates, account alerts, etc.). Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders).
You understand that you do not have to sign up for this program in order to make any purchases, and your consent is not a condition of any purchase with Twirl. Your participation in this program is completely voluntary.
We do not charge for the Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message frequency varies. Message and data rates may apply. Check your mobile plan and contact your wireless provider for details. You are solely responsible for all charges related to SMS/text messages, including charges from your wireless provider.
You may opt-out of the Service at any time. Text the single keyword command STOP to +18335120376 or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other Twirl mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.
For Service support or assistance, text HELP to +18335120376 or email hello@usetwirl.com.
We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages.
The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. If you get a new mobile number, you will need to sign up for the program with your new number.
To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the Service, any errors in such information, and/or any action you may or may not take in reliance on the information or Service.
We respect your right to privacy.
Information we collect from your use of Twirl Service
Twirl may also collect certain information from visitors to and customers of the Website, such as Internet addresses. This information is logged to help diagnose technical problems, to administer our Website and in order to constantly improve the quality of the Services. We may also track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
Our third-party partners also employ clear gifs (a.k.a. Web Beacons/Web Bugs), images, and scripts that help them better manage content on our Website. We do not tie the information gathered to our Customers' or End Users' Personal Information.
Cookies on the Website
When you interact with the Website we strive to make that experience easy and meaningful. When you come to our Website, our web server sends a cookie to your computer. Cookies are files that web browsers place on a computer's hard drive and are used to tell us whether customers and visitors have visited the Website previously. If you click on a link to a third-party Website, such third party may also transmit cookies to you.
Standing alone, cookies do not identify you personally. They merely recognize your browser. Unless you choose to identify yourself to Twirl, either by responding to a promotional offer, opening an account, or registering for a free trial, you remain anonymous to Twirl. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you've closed your browser or turned off your computer. They include such information as a unique identifier for your browser.
Twirl uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Twirl to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you've logged in and are required in order to use the Twirl application. Twirl uses persistent cookies that only Twirl can read and use, to identify the fact that you are an Twirl customer or prior Twirl Website visitor (whatever the case may be). We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. Users who disable their web browsers ability to accept cookies will be able to browse our Website but will not be able to successfully use our Services. End Users may be able to limit cookies used by their browsers and third parties by updating settings at: http://www.aboutads.info/choices and http://www.youronlinechoices.eu.
How we use information we collect
We collect the Personal Information described above in order to provide our Services to our Customers and their End Users, to market our products and services, to improve our Website and to recruit staff.
We will use the information we collect in the following ways:
Customers
* To fulfill our obligations arising from our contract with you i.e. to provide you with our Services;
* To set your company up as a customer on our systems.
* To liaise with you about projects that we are undertaking with you.
* To deliver information about our products and services, where you have subscribed to receive same.
* To ensure payment of our invoices.
Website users
* To administer and improve our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
* As part of our efforts to keep our Website safe and secure.
* To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
* To make suggestions and recommendations to you and other users of our Website about services that may interest you or them;
creators and Suppliers
* To fulfill our obligations arising from our contract with you, and to allow you to fulfil your contractual obligation to us, such as by accessing the Services as a creator or Content Provider (as defined in our Terms of Service for creators);
* To liaise with you about projects that you are undertaking for us.
* To manage your delivery of your services to us
Who we share your information with
We may share your Personal Information with our selected business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. For example, these business partners may include our web hosting provider and our IT service providers.
We use a number of sub processors and service providers to both assist us in providing the Website and Services and in addition, we may disclose your Personal Information to third parties:
* In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.
* If we or substantially all of our assets are acquired by a third party, in which case information held by us about our Customers and their End Users will be one of the transferred assets.
* If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Data Storage
Data Locality
For information about the adequate security safeguards that have been put in place for data based in the United States of America, you can reach out to hello@usetwirl.com
Data Retention
The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.
Automated decision making & profiling
We use automated decision-making/profiling in the administration of the employment or contractual relationship. Twirl uses automated decision making when deciding on the correct answer to serve based on a customer question. The exact logic of the automated decision may change based on the machine learning model employed.
Your data rights
You have the following rights in respect of your Personal Information:
* The right to access the Personal Information we hold about you.
* The right to require us to rectify any inaccurate Personal Information about you without undue delay.
As a customer of Twirl, you have the following rights:
* The right to have us erase any Personal Information we hold about you in circumstances such as where it is no longer necessary for us to hold the Personal Information or, in some circumstances, if you have withdrawn your consent to the processing.
* The right to object to us processing Personal Information about you such as processing for profiling or direct marketing.
* The right to ask us to provide your Personal Information to you in a portable format or, where technically feasible, for us to port that Personal Information to another provider provided it does not result in a disclosure of Personal Information relating to other people.
* The right to request a restriction of the processing of your Personal Information.
* The right to address a challenge concerning the personal information handling policies and practices at Twirl.
Where our processing of your Personal Information is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful. You may exercise any of the above rights by contacting hello@usetwirl.com Where Twirl is acting as the Data Processor, End Users should contact the Data Controller, i.e. the entity with which End User has a relationship, to exercise these rights.
If you are a resident of the European Union, you may also lodge a complaint with your local privacy commissioner or other Supervisory Authority with respect to our processing of your Personal Information. The local Supervisory Authority in each European country can be found here.
Contact Us
Our Data Protection Team can be reached at hello@usetwirl.com.
