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TWISTYSMOBILE PRIVACY POLICY
Effective as of November 6, 2009 (the “Effective Date”)
Your privacy is very important to us. TwistysMobile (“Twistys”) has created this privacy statement in order to demonstrate our commitment to your privacy. This Privacy Policy (the “Policy”)
explains what information we collect about you and what we do with
it. We want you to fully understand our privacy practices and
therefore, in addition to this Policy, we have created a Privacy
Contact whom you can contact with any questions or concerns (see
below). We reserve the right to modify this Policy at any time,
and we will notify you of any material changes to the Policy by posting
the modified Policy at www.TwistysMobile.com/privacy.html
and changing the Effective Date at the top. We encourage you to check
this page periodically for any changes. This Policy is
incorporated into, and subject to, the terms of Twistys’ Terms and
Conditions of Subscription. By using or navigating Twistys’ web
site, located at www.TwistysMobile.com (the “Web Site”),
you acknowledge that you have read, understand and agree to be bound by
this Policy or any modified Policy as posted. If you do not agree to
these terms, please do not use or visit the Web Site.
What information do we collect?
We do not collect personally identifiable information except where you
specifically provide us with such information. We may collect
your full name, e-mail address, street address and telephone number. We
may also collect credit card information from you. We generally collect
this personal information on our registration and order forms when you
sign up to receive products or services from our Web Site and to access
our member’s area.
We collect aggregate technical information (such as IP addresses,
screen resolution, browser language, etc.) and anonymous demographic
information (such as your postal or zip code, the web site that you
came from, etc.) during your usage of the Web Site.
What do we do with the information we collect?
We use personal information and other demographic or profile
information you provide to us to: fulfill your orders or requests;
attempt to prevent fraudulent transactions; verify your age, and;
contact you when necessary. Your personal information is NEVER
shared with advertisers and market researchers.
Whenever possible, we use non-identifiable information (i.e. IP
addresses and anonymous demographic information) rather than personal
information. Non-identifiable information is used to tailor your
experiences on our Web Site by showing content in which we think you
will be interested and displaying content according to your
preferences. We may use aggregate data to analyze user behaviour and
characteristics in order to measure interest in and use of the various
areas of our Web Site. We also use the information collected to
evaluate and improve our services and analyze traffic to our Web Site.
Personal information collected on our Web Site is stored and processed
in the United States and by using our Web Site, you consent to any such
transfer of information outside of your country. It is important
for you to note that the laws on holding data in the United States may
be less stringent than the laws of your country, but Twistys intends to
adhere to the principles set forth in this Policy.
Do we share the information we collect with third parties?
We NEVER sell, provide or otherwise transfer your personally
identifiable information to any arm-length third parties for any
reason. Twistys is opposed to spam mail activities and does not
participate in such mailings, nor do we release or authorize the use of
membership data for such purposes. We may transfer information
between Twistys affiliates.
We may use statistical analysis of aggregate information to inform
advertisers of aggregate user demographics and behaviour, as well as
the number of users that have been exposed to or clicked on their
advertising banners. We will provide only aggregate data from
these analyses to third parties.
We may share information we
collect with third party service providers to manage certain aspects of
the services we provide, such as maintaining our servers and processing
or fulfilling orders for products and services you purchase through the
Web Site. We ensure that the third party service providers that
we share your information with have privacy policies in place
substantially similar to our own.
We may also disclose your information in special cases if required to
do so by law, court order or other governmental authority or when we
believe in good faith that disclosing this information is otherwise
necessary or advisable, including, for instance, to identify, contact,
or bring legal action against someone who may be causing injury to or
interfering with the rights or property of Twistys, the Web Site,
another user or anyone else that could be harmed by such activities
(ie. for identify theft or fraud).
How long do we retain information?
We retain personal information for such period of time as we feel is
necessary to ensure that you have a reasonable opportunity to access
the information. If you no longer consent to us retaining your
personal information, you can contact us and request that it be removed
at: support@twistysmobile.com.
Do we save any correspondence that you send to us?
Yes. If you send us correspondence, including e-mails and faxes, we may
retain such information in the records of your account. We may
also retain customer service correspondence and other correspondence
from Twistys to you. We may retain these records in order to
measure and improve our customer service, and investigate potential
fraud and violation of Twistys Terms and Conditions of
Subscription. We may, over time, delete these records if
permitted by law.
Is the information submitted in public forums confidential?
No. The Web Site may offer chat rooms, forums, message boards and/or
news groups to our users. IT IS IMPORTANT TO REMEMBER THAT ANY
INFORMATION DISCLOSED IN THESE AREAS BECOMES PUBLIC INFORMATION.
Accordingly, you should exercise extreme caution when deciding to
disclose your personal information and you do so at your own risk.
Do we use cookies?
Yes. Cookies are pieces of information (actually, alphanumeric
identifiers) generated by web servers and stored in your computer for
future access. Cookies cannot view or retrieve data from other
cookies, nor can they capture files or data stored on your
computer. We use cookie technology to enhance your online
experience by making it easier for you to navigate through our Web Site
or make a feature work better. We also use cookies to track
affiliates that refer you to our Web Site. These particular
cookies are saved on your computer for 30 days and collect no data from
you. Generally, cookies can be disabled. The “help” portion
of the toolbar on most browsers will tell you how to prevent your
browser from accepting new cookies, how to have the browser notify you
when you receive a new cookie, or how to disable cookies altogether.
If you would like to use the Web Site, you may do so without
accepting cookies. However, you should understand that if you
choose not to accept cookies, some areas of the Web Site may not
function properly or optimally and you will not be permitted to access
certain secured areas of the Web Site.
Do we use web beacons?
Yes. The Web Site may contain electronic images known as "web beacons"
or single-pixel gifs that allow us to count visitors to our Web Site
and collect aggregate data. Web beacons collect limited information
including cookie number, time and date of a page view and a description
of the page on which the web beacon resides.
Is the Web Site secure?
We are committed to maintaining the security of your information and
have measures in place to protect against the loss, misuse and
alteration of the information under our control. We employ the
latest and most secure techniques available for protecting our systems
from intrusion by unauthorized individuals, and we are constantly
upgrading our security as better methods become available. Our data
center utilizes state-of-the-art physical security measures to prevent
unauthorized access to the facility. In addition, all information
is stored in a secure location behind a firewall and other
sophisticated security systems with limited (need-to-know)
administrative access. It is “IP protected” and only accessible
by authorized Twistys employees using a certified IP address. All
Twistys employees who have access to, or are associated with, the
processing of personal information are contractually obligated to
respect the confidentiality of your information and abide by the
privacy standards we have established. Although we use industry
standard practices to protect your privacy, we do not promise, and you
should not expect, that your personal information or private
communications will always remain private.
Does this Policy apply to linked web sites other than the Web Site?
No. The Web Site contains links to other Internet web sites. By
clicking on a third party advertising banner or other link, you will be
redirected off the Web Site and to such third party web site.
Furthermore, we may permit third parties to offer subscription and/or
registration-based services through our Web Site. We are not
responsible for the privacy policies of such web sites. You should make
sure that you read and understand the privacy policies of the third
party web sites and direct any concerns regarding external links to the
third party web site administrator or webmaster prior to providing any
personally identifiable information.
How do you unsubscribe?
We sometimes email you in order to provide targeted marketing from our
Web Site and related services. All emails you receive from us
will include specific instructions on how to unsubscribe and you may
unsubscribe at any time. Additionally, we give you the following
options for removing your information from our database:
(1) send an email to support@twistysmobile.com;
(2) select the opt-out link at the bottom of any Twistys email and follow the instructions provided;
(3) send conventional mail to the following address:
Customer Service
TwistysMobile
xxxxxx
Can we update/correct your information?
Yes. You may correct or update your personal information by writing to our Privacy Contact by email at support@twistysmobile.com
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