Privacy Policy
Date of Last Revision: February 22, 2024
At twineSTUDIO, LLC™ (“twineSTUDIO”, “We” or “Our”), we are committed to protecting the privacy and security of the personal data (“Personal Data”) we collect. We recognize that our client companies, operators and/or sponsors (collectively as “Client” or “Clients”) and our visitors and users (collectively as “User” or “Users”) who access our website, mobile applications, platform and other services (collectively as “Service” or “Services”), value their privacy. This privacy policy (“Privacy Policy”) applies to all the Services offered by twineSTUDIO and outlines our practices regarding the collection, use and sharing of that Personal Data.
Independent Software Vendor (ISV)
twineSTUDIO acts as an Independent Software Vendor (“ISV”). As an ISV, twineSTUDIO develops and provides a software platform that enables our Clients to engage with their customers effectively. Part of our service involves the collection, processing, and management of Personal Data. This data collection is integral to facilitating communication between our Clients and their customers.
In our role as an ISV, twineSTUDIO is committed to the highest standards of privacy and data security. We implement measures to protect the personal information entrusted to us and ensure that our client companies adhere to these standards. Our Privacy Policy reflects our dedication to safeguarding user data and providing clear, concise information about our data collection practices and users' rights concerning their personal information.
Personal Data Collection and Usage
At twineSTUDIO, we gather Personal Data directly from you when you engage with our Services. This engagement can include actions like subscribing to our communications (via text or email) or creating a user account. The information we collect typically includes your name, phone number and email address, among other details, to ensure we can provide you with a tailored and meaningful experience on our platform.
You may receive from us a variety of communications, including marketing and promotional messages, product updates, essential platform notifications and general account information. These communications are designed to keep you informed and engaged with our latest offerings and platform enhancements.
Personal Data may be shared with our Clients who utilize our ISV platform when you have expressly opted into receiving their marketing and promotional communications. It's important to note that once you opt into communications with our Clients, their Privacy Policies and Terms and Conditions will apply. We encourage you to review these policies to understand how your information is handled.
We are committed to ensuring that all communications are in line with your expressed preferences and consent.
Please note that we will never sell, rent or disclose your personal information to third parties without explicit consent, except as mandated by law or during business transactions, such as mergers or acquisitions, which is outlined later in this Privacy Policy.
Account Registration and Personal Information Use
twineSTUDIO does not require that you register in order to access its Services. However, to engage with certain interactive aspects of our Services — like submitting, viewing, and sharing photos, managing prints, or placing orders — you'll be asked to create a User account and provide some Personal Data. This step is essential for us to deliver these specific services effectively and ensure a personalized and secure experience.
Public Sharing
Please be aware that when you share Personal Data, comments, or any other content on our Website or Services, such as comment pages or blog forums, this information becomes accessible to the public. Your account name is visible to other users whenever you post messages or comments through our Website and Services. Consequently, any content you share in these public forums is considered published content and is not protected as Personal Data under this Privacy Policy.
It's important to remember that information shared in public areas of our Services can be seen by individuals and organizations not affiliated with twineSTUDIO. This publicly shared information may be used by others to contact you without our control. We urge you to exercise caution and consider the privacy implications before posting any Personal Data or other sensitive information in public forums.
We encourage you to think carefully about your privacy when interacting in public spaces on our platform and to use the privacy settings and tools we provide to manage your shared content. If you have concerns about the information you have shared publicly and wish to remove it, please contact us at feedback@twine.it for assistance.
Social Networking Sites
From time to time you may access or interact with our services via other social networking websites and services (“SNSs”) like Facebook®, X® (formerly Twitter®) or others. If you choose to provide your information directly to a third-party SNSs, your information will be governed by the policies of those other SNSs. We don’t exercise control over third-party SNSs. These other services may place their own cookies or other files on your computer, solicit Personal Data from you and/or follow different rules regarding the use of the information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
Compliance with Legal Obligations and Law Enforcement Requests
We reserve the right to disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, or legal process served to twineSTUDIO. We may share Personal Data if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or as otherwise required by law.
Business Transactions
In the event of significant business changes, including mergers, acquisitions, or asset sales, it's possible that your Personal Data may be transferred as part of our assets. In such circumstances, we will inform you via email about the transfer and any changes to the ownership or control of your data, ensuring transparency and continuity in the protection of your privacy.
Children's Online Privacy Protection Act (COPPA)
At twineSTUDIO, we take the privacy of children very seriously. In compliance with the Children's Online Privacy Protection Act (COPPA), we do not knowingly collect, use, or disclose personal information from children under the age of 13 without obtaining prior parental consent. Our Services are not designed to attract children under 13, and we request that children under 13 not provide any personal information through our Services.
International Users
For users accessing our Services from outside the United States, including the European Union, Asia, or any other region with data protection laws and regulations that may differ from those in the United States, please be aware of the following:
By continuing to use our Services, which are governed by U.S. law, our Privacy Policy, and our Terms of Service, you acknowledge and consent to the transfer of your Personal Data to the United States. This consent is necessary for us to provide you with access to our Services and to perform the contracts we may have with you.
We are committed to ensuring that your Personal Data is protected and handled in accordance with applicable laws and standards, regardless of where it is processed. We take appropriate measures to ensure that any transfer of Personal Data from countries outside the United States is carried out in compliance with relevant data protection regulations, safeguarding your privacy rights and providing an adequate level of data protection.
Your consent to the transfer of your Personal Data to the United States is essential for us to provide you with our Services. However, we understand the importance of privacy and data protection rights. If you have any concerns or questions about how your Personal Data is handled, please contact us at feedback@twine.it. We are dedicated to transparency and are here to address any inquiries or requests regarding your data.
GDRP Compliance
twineSTUDIO is dedicated to the protection of personal data and privacy in line with the General Data Protection Regulation (GDPR) to safeguard the rights of European Union (EU) citizens. Our approach to data processing is built on transparency, legality, and security, respecting the following principles:
Lawful Processing: We only process personal data with clear consent, to fulfill contractual obligations, or based on legitimate interests that do not infringe on individual rights.
User Rights: Under GDPR, individuals have rights to access, rectify, erase, restrict processing of their data, data portability, object to processing and not be subject to automated decision-making including profiling.
Data Security: We adopt stringent security measures to protect data against unauthorized access or breaches. In the rare event of a breach, we commit to promptly informing affected individuals and the appropriate authorities.
International Data Transfer: We ensure any transfer of data outside the EU complies with GDPR through mechanisms like Standard Contractual Clauses, maintaining data protection standards.
For any inquiries or to exercise GDPR rights, please reach out to us at feedback@twine.it.
User Rights and Choices
As a user of twineSTUDIO, you are empowered with several rights regarding your Personal Data. These rights allow you to access, correct, or request the deletion of your Personal Data at any point. We are committed to ensuring that you have full control over your information and how it's used.
If you wish to stop receiving marketing messages from us, you can do so by following the unsubscribe instructions provided in any marketing communication you receive, or by contacting us directly at feedback@twine.it. We aim to make this process as straightforward as possible to ensure your preferences are respected.
Should you decide to have your Personal Data removed from our Service, you have two options: send us an email at feedback@twine.it or use the “Delete My Account” feature in twineSNAP. Following your request, we will permanently delete all Personal Data associated with your account from our database. You will receive a final confirmation email at your registered email address confirming the removal of your Personal Data.
Contact Details for Privacy Concerns
Your privacy is of utmost importance to us at twineSTUDIO. Should you have any questions, concerns, or require clarification about our privacy practices, including how your Personal Data is handled, please do not hesitate to contact us.
For all privacy-related concerns, please email us directly at feedback@twine.it. We are committed to responding promptly and effectively to your queries and concerns about your privacy rights and how we manage your data.
Changes and Updates
We may update this privacy policy from time to time to reflect changes in our practices. We will notify users of any significant changes through our website or direct communication.