Twine Solutions Ltd. is dedicated to respect your privacy and to protect the personal data you are sharing with us. In general, you can use our website [without needing to provide us with any personal data] (other than cookies, as described in our Cookie Policy). This privacy policy describes the way we collect and use your personal data when you decide to hand it over to us or when we do need such personal data to provide the services that you requested from us, for instance when you subscribe to our mailing lists or when you contact us in order to receive information on our website.

Personal data or personal information is any information about you by which you can be identified. This can include information such as your name, date of birth, email address, postal address, phone number, mobile number, gender, occupation, industry, personal interests, and other information when it is needed in order to provide you with a service you requested.

Twine Solutions Ltd. (in this privacy policy: “Twine”, “our”, “we” or “us”) is in charge of your personal data processing.

What is our legal basis for processing your personal data?

Performance of a commercial engagement with you

We process your personal data in order to enable us to perform our future or existing commercial engagement towards you.

Your consent

We process your personal data for promotional purposes (including via direct mailing and targeted advertising) only if you have given your specific, separate, free, unbundled and informed consent to the processing activity.

Legitimate interests

We process your personal data to further our legitimate interests, such as developing, improving, securing, and analyzing statistics.

How do we use the information we collect?

We use the information we collect for the following purposes:

Providing our clients with customer support and answering their inquiries

We may collect and store your personal data when you subscribe to our newsletter or when you submit us inquiries regarding our website. Such information may only be used to contact you in order to respond to your inquiry and process your request.

Promotional purposes

We may also collect and store your personal data when you subscribe to our email lists or when you contact us, in order to provide you with information and promotional literature in which, in our opinion, you may be interested. However, such personal data collect and storage may only occur if you gave us your explicit, free and informed consent to do so. In addition, we will not add you to our mailing lists without getting your consent first. You may opt in to such mailing lists at any time in order to receive information and promotional materials.

Cookies and pixel tags

When you visit our site, we may also collect cookies and pixel tags subject to our Cookie Policy. You can always disable cookies by browser settings or otherwise, as set forth in our Cookie Policy.

Providing and improving our website and services

Your personal data (such as IP addresses, web server logs, cookies, pixel tags and web beacons) may be collected and stored when you submit inquiries with respect to our website or when you browse the website, in order to maintain, protect, and improve this website or our services, for our internal records and for statistical purposes such as analysing the performance of our website and the way you use it (as set forth in our Cookie Policy).

Do we share your personal data?

We will not share your personally identifiable data with anyone else for their own marketing purposes unless we first provide clear notice to you and have your permission to do this.
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.

Twine’s Offices and subsidiaries

We may share your personal data with other Twine’s offices or subsidiaries which are all subject to this privacy policy or to other protective confidentiality and data transfer agreements.

Upon your consent

We may share your personal data if we have your consent to do so.

Authorized third parties

We may share your personal data with third parties working on behalf of Twine in order to provide you with promotional or informational materials or services such as customer service. Such authorized third parties are only given access to the information which is necessary for them to provide you with the aforementioned services, and any other use of your personal information is strictly forbidden to them.

Mergers and Acquisitions

If we decide to sell, merge or otherwise reorganize Twine or any Twine’s affiliate, this may involve us disclosing personal data to prospective or actual purchasers and their advisers.

Service providers and subcontractors

We contract with companies which help us with parts of our business operations and we may share your personal data with them in order for them to provide services to us only for the purposes set forth in this privacy policy.

Twine defense of legitimate interest

We may share your personal data when such disclosure is necessary to prevent illegal and fraudulent uses of our services, to respond to third party claims, to defend ourselves against any complaint or security threat, to assist in fraud prevention or investigation or to execute a corporate audit.

Mandatory disclosure

We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties. We may also disclose and otherwise process your personal data in urgent circumstances, to protect the public, our website or personal safety.

What are your protections when your personal information is transferred across international borders?

For the above purposes, your personal data may be transferred across international borders, including to countries outside the European Economic Area (EEA) or the European Union (EU) in which laws are less protective than in the EEA or EU. When your personal data is being transferred to such countries, we ensure that adequate protection for your personal data is provided by using standard contractual clauses approved by the European Commission. A copy of such contractual clauses may be accessed at:
http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.

What steps are taken to safeguard personal data?

We have implemented appropriate technical, physical and organizational controls to protect your personal data, taking into consideration, the state of art, the costs of implementation, the scope, context, purposes and risk represented by the processing and the nature of the data being protected. Although we will do our best to protect your personal data, we cannot guarantee the security of the personal data you transmit to us and we strongly recommend you to take all the necessary precautions and steps in order to protect your personal data when you surf on the web.

How long do we retain your personal data?

We endeavour to only collect personal data that are necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary for such purposes. Therefore, your personal data is erased as soon as it is no longer necessary, except if our legitimate interest implies that we retain such personal data for a longer period of time or if we are required to do so by any applicable law. Once anonymized, we may retain data for longer periods

What are end users rights?

If you reside in the EU or in the EEA, you may contact us at any time and:

  • Request rectification of your personal information;
  • Request erasure of your personal information, which may involve however that Twine will not be able to process your requests or provide you any requested services;
  • Request a copy of your personal information from our record;
  • Request to restrict the processing of your personal information if you estimate that such information is inaccurate for instance; or
  • Request the termination of use of your personal information.

You may unsubscribe from direct marketing messages by following the opt out instructions which are provided in the message.

What is our responsibility regarding third party sites’ privacy practices you can find on our website?

Our website may contain links to third party sites to which we do not share your personal data. Such site may be permitted to use our logo but they are not maintained or operated by us and we are not responsible for their privacy practices. Such third party sites have their own privacy policy which you should always read before following their link in order to determine how they will handle any data they collect from you. In addition, you may find on our website some services based on content tools and third party application such as Google Analytics Such third parties may be provided with certain types of information when you use such third party applications and tools on our website, which are based on their own privacy statements.

Privacy inquiries

Twine is responsible for your personal information processing and you shall address any of your requests to exercise your rights as stated above to marketing@twine-s.com
If you are located within the EU or the EEA, you have the right to lodge a complaint about our data collection and processing activities with the supervisory authority concerned.

Changes to this privacy policy

Twine may from time to time change this policy. However, if this policy is changed materially regarding the way we use your personal data we will make that information available by posting a notice on this website.