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.
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.
We receive and store information about you such as:
This information includes:
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:
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:
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:
We disclose your information for certain purposes and to third parties, as described below:
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:
You will not be allowed to share access to your account with others: You have the option to use seamless account login through the twimbit app. If you use that feature, those devices will remain signed into your account unless you later log out of those devices.
Interest-Based Ads. Interest-based ads are online ads that are tailored to your likely interests based on your use of various apps and websites across the Internet. If you are using a browser, then cookies and web beacons can be used to collect information to help determine your likely interests. If you are using a mobile device, tablet, or streaming media device that includes a resettable device identifier, then that identifier can be used to help determine your likely interests. Please see the “Cookies and Internet Advertising” section (below).
Matched Identifier Communications. Some third-party sites and apps allow us to reach our users with online promotions about our titles and services by sending a privacy protective identifier to the third party. A privacy protective identifier means we convert the original information (such as an email address or phone number) into a value to keep the original information from being revealed. The third party compares the privacy protective identifier to identifiers in its database and there will be a match only if you have used the same identifier (such as an email address) with twimbit and the third party. If there is a match, twimbit can then choose whether or not to send a given promotional communication to you on that third party site or app, and can optimize and better measure the effectiveness of online advertising. You can opt out in the “Account” section of our website.
You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also request that we delete personal information that we hold about you.
When you visit the “Settings” portion of our website, where you have the ability to access and update a broad range of information about your account, including your contact information, your twimbit payment information, and various related information about your account. You must be signed in to access the “Settings” section.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please also see the “Your Choices” section of this Privacy Statement for additional choices regarding your information.
We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Statement.
We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.
We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. Your continued use of the twimbit service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Statement, you may cancel your use of the twimbit service. To see when this Privacy Statement was last updated, please see the “Last Updated” section below.
Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We use other technologies such as browser storage and plugins (e.g., HTML5, IndexedDB, LocalStorage and WebSQL). Like cookies, these other technologies may store small amounts of data on your device. Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. In many cases, declining cookies will impair the effectiveness of web beacons associated with those cookies.
If you use the twimbit app on a mobile device, tablet, or streaming media device, we may collect a resettable device identifier from your device. Resettable device identifiers (also known as advertising identifiers) are similar to cookies and are found on many mobile devices and tablets (for example, the “Identifier for Advertisers” (or IDFA) on Apple iOS devices and the “Google Advertising ID” on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant and for analytics and optimization purposes.
We use these types of technologies for various reasons, like making it easy to access our services by remembering you when you return; to provide, analyze, understand and enhance the use of our services; to enforce our terms, prevent fraud; to improve site performance, monitor visitor traffic and actions on our site; and to deliver and tailor our marketing or advertising, and to understand interactions with our emails, marketing, and online ads on third party sites.
In connection with our use of these technologies, some of the websites and apps where we advertise, as well as advertising technology companies that we use to purchase, deliver, optimize, and/or measure our advertisements (collectively “Advertising Partners”), may receive limited information from us as part of our campaign targeting, measurement, and optimization (e.g., steps completed in sign-up and site visit or app open/install information).
Common uses of this type of information are to judge the effectiveness of and optimize campaigns, to see when someone who saw an ad later signed up for our service. Another common use is to make sure we do not serve ads trying to get individuals to sign up for the twimbit service if they are already a twimbit member.
Twimbit uses contractual and technical measures designed to prevent Advertising Partners from accessing information regarding specific title/content selections you make, URLs you land on, or content you have consumed on our site.
How can I exercise choice regarding these technologies?
To exercise choice regarding cookies
For more information about cookies set through our website, as well as other types of online tracking (including the collection of information by third parties about your online activities over time and across third-party web sites or online services for online interest based advertising), and to exercise choices regarding them please contact us. At this time, we do not respond to web browser “do not track” signals.
To exercise choice regarding resettable device identifiers
To opt out of interest-based ads from twimbit in connection with a resettable device identifier on a mobile device, tablet, or streaming media devices, please configure the appropriate setting on your device (usually found under “privacy” or “ads” in your device’s settings). You may still see twimbit ads on your device, but they will not be tailored to your likely interests.
To exercise choice using self-regulatory program resources
Twimbit supports the following self-regulatory programs, which provide additional privacy choices for interest-based advertising:
· In the US: Digital Advertising Alliance (DAA)
To exercise choice regarding other technologies
There are a number of ways to exercise choice regarding technologies that are similar to cookies, such as browser storage and plugins (e.g., HTML5, IndexedDB, LocalStorage and WebSQL). For example, many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser’s help function or support area to learn more. Other technologies, may be cleared from within the application.
Last Updated: Aug, 2023