Privacy Policy

This Privacy Statement explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information, by the Twimbit family of applications (“Twimbit”) in connection with the Twimbit services.

Contacting Us

Your data controller depends on your country of membership, and will be listed in your membership or payment confirmation email. If you have general questions about your account, this Privacy Statement, or our use of your personal information, cookies or similar technologies, please mail us at [email protected]. Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

Collection of Information

We receive and store information about you such as:

• Information you provide to us: We collect information you provide to us which includes:

• Your name, email address, address or postal code, payment method(s), and telephone number. In certain countries, we collect a government identification number for purposes such as billing and tax compliance. We collect this information in a number of ways, including when you enter it while signing-up for our service, interact with our customer service, or participate in surveys or marketing promotions.
• Information when you choose to provide ratings, content preferences, account settings (including preferences set in the “Account” section of our website), or otherwise provide information to us through our service or elsewhere.

• Information we collect automatically: We collect information about you and your use of our service and your interactions with us. Information regarding your network, network devices, and your computer or other devices you might use to access our services.

This information includes:

• your activity on the twimbit service, such as title selections, content you have consumed, and search queries;
• your interactions with our emails and texts, and with our messages through push and online messaging channels;
• details of your interactions with our support service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
• resettable device identifiers, which will be for the purpose of advertising only if applicable. (see the “Cookies” section below for more information);
  
• device and software characteristics (such as type and configuration), connection information including type (wifi, cellular), statistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information;
• Information collected via the use of cookies, web beacons and other technologies
  

• Information from partners:
  

We may collect information from other companies with whom you have a relationship (“Partners”). These Partners might include (depending on what services you use), such as payment methods, voice technologies. The information Partners provide us varies depending on the nature of the Partner services, and may include:

• search queries and commands applicable to twimbit that you make through Partner devices or voice assistant platforms
• service activation information such as your email address or other contact information
  
• IP addresses, device IDs or other unique identifiers, as well as associated pre-paid promotion, billing and user interface information, that support user authentication, the twimbit service registration experience, Partner payment processing, and the presentation of twimbit content to you through portions of the Partner user interface such as for events.

• Information from other sources:
  

We also obtain information from other sources. We protect this information according to the practices described in this Privacy Statement, plus any additional restrictions imposed by the source of the data. These sources vary over time, but could include:

• service providers that help us determine a location based on your IP address in order to customize our service and for other uses consistent with this Privacy Statement
• security service providers who provide us with information to secure our systems, prevent fraud and help us protect the security of twimbit accounts
  
• payment service providers who provide us with payment or balance information, or updates to that information, based on their relationship with you;
  
• online and offline data providers, from which we obtain aggregated demographic, interest based and online advertising related data as applicable
  
• publicly-available sources such as publicly available posts on social media platforms and information available through public databases associating IP addresses with internet service providers (ISPs)
  

• Use of Information
  

We use information to create and personalize our content and services and marketing efforts, to manage member referrals, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use such information to:

• determine your general geographic location, provide localized content, provide you with customized and personalized recommendations for content we think will be of interest to you
• coordinate with Partners on making the twimbit service available to members and providing information to non-members about the availability of the twimbit service, based on the specific relationship you have with the Partner
  
• secure our systems, prevent fraud and help us protect the security of twimbit accounts
  
• prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our terms (such as determining whether and for which twimbit signup offers you are eligible and determining whether a particular device is permitted to use the account consistent with our Terms of Use)
  
• analyze and understand our audience, improve our service (including our user interface experiences and service performance) and optimize content selection, recommendation algorithms and delivery
  
• communicate with you concerning our service so that we can send you updates about twimbit, details about new features and content available on twimbit, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message, online messaging channels, and matched identifier communications (described below). Please see the “Your Choices” section of this Privacy Statement to learn how to set or change your communications preferences.
  

• Disclosure of Information
  

We disclose your information for certain purposes and to third parties, as described below:

• The Twimbit family of companies: We share your information among the twimbit family of companies (Twimbit Pte Lte, Twimbit Research India Pvt. Ltd.) as needed for: data processing and storage; providing you with access to our services; providing customer support; making decisions about service improvements; content development; and for other purposes described in the Use of Information section of this Privacy Statement.
  
• Service Providers: We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to manage events, advertising, communications, security, infrastructure and IT services, to customize, personalize and optimize our content service, to process credit card transactions or other payment methods, to provide bank account or balance information, to provide customer service, to analyze and enhance data (including data about users’ interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services).
  
• Partners: As described above, you may have a relationship with one or more of our Partners, in which case we may share certain information with them in order to coordinate with them on providing the twimbit service to members and providing information about the availability of the twimbit service. For example, depending on what Partner services you use, we may share information:
  

• in order to facilitate Partner pre-paid promotions or collection of payment for the twimbit service for distribution to us
  
• with Partners who operate voice assistant platforms that allow you to interact with our service using voice commands
  
• so that content and features available in the twimbit service can be suggested to you in the Partner’s user interface. For members, these suggestions are part of the twimbit service and may include customized and personalized consumption recommendations.
  

• Promotional offers: We may offer joint promotions or programs, such as industry events, that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
  
• Protection of Twimbit and others: Twimbit and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of twimbit, its users or the public, as required or permitted by law.
  
• Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.
  

Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection.

You may also choose to disclose your information in the following ways:

• certain portions of our service may contain a tool which gives you the option to share information by email, text message and social or other sharing applications, using the clients and applications on your smart device.
• social plugins and similar technologies allow you to share information.
  

Social plugins and social applications are operated by the social networks themselves, and are subject to their terms of use and privacy policies.

• Essential cookies: These cookies are strictly necessary to provide our website or online service. For example, we and our Service Providers may use these cookies to authenticate and identify our members when they use our websites and applications so we can provide our service to them. They also help us to enforce our Terms of Use, prevent fraud and maintain the security of our service.
• Performance and functionality cookies: These cookies help us to customize and enhance your online experience with Twimbit. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during member sign up). We also use these cookies to collect information (such as popular pages, conversion rates, consumption patterns, bounce rates and other information) about our visitors’ use of the Twimbit service so that we can enhance and personalize our website and service and conduct market research. Deletion of these types of cookies may result in limited functionality of our service.
• Advertising cookies and resettable device identifiers: These cookies and resettable device identifiers use information about your use of this and other websites and apps, your response to ads and emails, and to deliver ads that are more relevant to you and for analytics and optimization purposes. These types of ads are called “interest-based advertising.” The advertising cookies associated with our service belong to our Service Providers.