1. Who we are
1.1. We are TWISPER INTERNATIONAL SA located at Rte des Jeunes 4, 1227 Geneva, Switzerland.
1.2. This Privacy Policy sets out how we collect and use your personal information when you use by visiting our site and registering your account on the TWISPER.com, the TWISPER mobile and online products and services (“Services”) and the choices available to you in connection with our use of your personal information (the Privacy Policy). This Privacy Policy should be read alongside, and in addition to, our Terms and conditions (accessible online at https://twisper.com) (Terms) and our Cookie Policy (accessible online too). In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.
2. This Privacy Policy
2.1. By making available the Services we, acting reasonably and in good faith, believe that you:
a) have all necessary rights to register on and use the Services;
b) provide true information about yourself to the extent necessary for use of the Services;
c) understand that by the posting your personal information where it is accessible by other users of the Services you have manifestly made this information public, and this information may become available to other Service users, may be copied and disseminated by them;
d) are aware of and accept this Privacy Policy.
2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfil our obligations to you.
3. Information we collect about you
3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Services, we will improve, develop and implement new features to our Services, and enhance the available Services functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organize, extract, compare, use, and supplement your data. We will also receive and pass this data, and our automatically processed analyses of this data internally as set out in the table below and section 4 of this Privacy Policy.
3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.
3.2.1 Location Data
Purpose: We use your location data in order to manage and administer the Services provided to you. We use this data to enable us to fulfil our obligations to you as part of the Services (e.g. in cases where you request restoration of your account). We also use this information in order to provide you with recommendations we think you may be interested in.
Legal Basis: Consent, Legitimate Interests
3.2.2 Data provided while registering in the Services
Data you provide for registering in the Services: your name or data obtained via third parties – your social network name, surname and email (Facebook, Google).
Purpose: We import this information into your profile. We use this information in order to manage and administer the Services provided to you. We use this data to enable us to fulfil our obligations to you as part of the Services (e.g. in cases where you request restoration of your account).
Legal Basis: Legitimate interests,Performance of our contract with you
3.2.3 Documents used to verify your identity
Where necessary, a copy of your identity or another document containing your name, surname, photograph, number of the principal identity document of you or your representative, payment details and another additional data, that you may provide us, including through our support service. We may take additional verification steps where we consider reasonable in order to verify your account.
Purpose: We use this data in order to identify you, verify your account and prevent abuse of your or other persons’ rights. For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us.
Legal Basis: Legitimate interests, Performance of our contract with you
3.2.4 Additional data received while accessing the Services
Additional data received when you access the Services, including information regarding technical devices, technical interaction with the Service such as your IP-address, time of registration in the Service, device model and operating system used, your installed apps, type of a browser, your Internet provider and/or phone network operator, network type, screen resolution, RAM size.
Purpose: We use your data for internal review in order to constantly improve the content of our Services and web pages, optimizing your user experience, to understand any errors you may encounter when using the Services, to notify you of changes to the Services and to personalize the use of our Services. We may also use this data in order to tailor and improve the information that are presented to you to and measure the effectiveness of our TWISPER campaigns.
Legal Basis: Legitimate Interests
3.2.5 Information received with the use of cookies
Information that is automatically received at the time of access to the Site with the use of cookies.
Purpose: Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for. We use this information in order to tailor and improve the information that are presented on the Site and measure the effectiveness of these campaigns.
Legal Basis: Consent
3.2.6 Information created while using the Services
Information that is created by you while using the Services (e.g. information that you post as comments).
Purpose: We use this information in order to manage and administer the Services including providing our services to you.
Legal Basis: Legitimate interests, Performance of our contract with you
3.2.7 Information created while placing support requests
Information that is created by you while placing requests to our Services support.
Purpose: We use this information in order to verify your identity and to fulfill your support request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.
Legal Basis: Legitimate interests, Performance of our contract with you
3.2.8 Information created while placing support requests
Purpose: By syncing your contacts, you will be able to find people you already know on TWISPER. We upload and store your contacts on our server to improve your experience in TWISPER application by suggesting new connections from people you already know.
Legal Basis: Legitimate interests, Performance of our contract with you
3.3. Our legitimate interests include
(1) maintaining and administrating the Services;
(2) providing the Services to you;
(3) improving the content of the Services;
(4) processing of the data that was manifestly made public by you where it is accessible by other users of the Services;
(5) ensuring your account is adequately protected; and
(6) compliance with any contractual, legal or regulatory obligations under any applicable law.
3.4. As part of maintaining and administrating the Services we use the information to analyze user activity and ensure that rules and terms of use for the Services are not violated.
3.5. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims. We will not delete personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.
3.6. You may withdraw your consent the collection of location data by amending your privacy settings on your device.
3.7. Please note, if you do not want us to process sensitive and special categories of data about you, you should take care not to post this information or share this data when using the Services. Once you have provided this data it will be accessible by other Service users and it becomes difficult for us to remove this data.
3.8. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services.
3.9. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
4. Data sharing
4.1. Your name, surname and comments can be available to all of the Service users. We take technical and organizational measures to ensure that your data is safe. Please note that by posting your personal information you have manifestly made this information public where it is accessible by other user of the Services, and this may become available to other Service users and be copied and/or disseminated by such users.
4.2. Sometimes we may also need to share your data with a third-party in order to provide our Services to you or to administer the Services,
5. Privacy settings
5.1. The Services may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third-party services and you should ensure you review the relevant third-party’s privacy statement which will govern your data privacy rights.
5.2. We bear no liability for the actions of third parties which, as the result of your use of the internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.
5.3. We bear no liability for the consequences of use of the information which, due to the Services nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Site.
6. International Transfers
6.1. We may transfer and maintain on our servers or databases some of your personal information outside Switzerland or European community.
6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected).
7. Retention Periods
7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
7.2. You may request to remove your personal data on our Services by contacting the Service support.
7.3. We may remove your personal data on your account, or the information you post as provided by the Terms.
8. Your Rights
8.1. You have the following rights, in certain circumstances, in relation to your personal information:
a) Right to access your personal information.
b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
c) Right to restrict the use of your personal information.
d) Right to request that your personal information is erased.
e) Right to object to processing of your personal information.
f) Right to data portability (in certain specific circumstances).
g) Right not to be subject to an automated decision.
h) Right to lodge a complaint with a supervisory authority.
8.2. If you would like to exercise these rights, please contact Support Service via email support@twisper.com or send your request to us, in writing to TWISPER INTERNATIONAL SA, Rte des Jeunes 4, 1227 Geneva, Switzerland. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.
9. Security Measures
9.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
9.2. Access to the Services is authorized using by the relevant social network your login and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties, and we recommend you take measures to ensure this information is kept confidential.
10. Changes to this Policy
10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation archive. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.
11. Contact Us
11.1. If you have any questions, please send your inquiries to Service support via support@twisper.com or in writing to TWISPER INTERNATIONAL SA, Rte des Jeunes 4, 1227 Geneva, Switzerland. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.
11.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
Cookie Policy
This document is posted by TWISPER INTERNATIONAL SA (registered at Rte des Jeunes 4, 1227 Geneva, Switzerland), hereinafter named “we”, “our” or “us”, to assist our website users with knowing our cookies policy. We believe in being clear and open about how we collect and use data related to you. In the spirit of transparency, this policy provides detailed information about how and when we use cookies.
1. How we use cookies, tags and similar technologies
1.1. Please review this Cookie Policy carefully. This policy describes our information practices relating to using our website TWISPER.com and all of our online products and services (together “website”).
1.2. This Cookie Policy should be read together with the terms and conditions posted elsewhere on our website, including our Privacy Policy and our website terms and conditions.
2. Cookies
2.1. A cookie is a small text file which includes a unique identifier that is sent by a web server to your computer, mobile phone or any other internet enabled device when you visit a website or mobile app. Cookies are widely used to make sites work efficiently and to collect information about users’ online preferences. For simplicity, this Policy refers to cookies, but we may use other similar technologies in the same way.
3. How do we use cookies?
3.1. We use cookies to record session information and provide our services to you. We use this information to make decisions about ways to improve the services we offer you by making browsing easier, providing a more personalised service, tailoring the recommendations and advertising that you see on our site, and our own analysis which helps us develop and improve our site.
3.2. We use all or some of the following categories of cookies on our website:
(a) Essential cookies. These cookies are essential for parts of our website to operate. They enable you to move around our website and allow us to recognise you within our website so that we can provide you with the service that you have asked for such as remembering your sign-in details.
(b) Functionality cookies. These cookies help us customise our site content based on your preferences. They remember choices you make, your language and the country you visit our website from. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
(c) Performance cookies. These cookies collect information on how you use our website in order to help us improve areas such as navigation and to help us fix technical issues or errors. For example, we use these cookies to help us understand how you arrive at our website, browse or use our website and highlight areas where we can improve. The information stored by these cookies never shows personal details from which your identity can be established.
3.3. We may engage third-party providers such as Google Analytics or CloudFlare to act on our behalf to ensure safe browsing, enrich user experience, track and analyse your usage of our website through the use of cookies, pixel tags / web beacons, and similar technologies. These third parties collect, and share with us, usage information about visits to our website, measure and research the effectiveness of our campaigns, track page usage, help us target our recommendations, and track use of our recommendations and advices.
4. How do I reject cookies?
4.1. At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable any cookies, please consult your browser’s ‘Help’ or ‘Support’ section. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.
4.2. Please consult the following links for information on cookie management and blocking according to your browser:
(а) Explorer: http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11.
(b) Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(c) Chrome: https://support.google.com/chrome/answer/95647?hl=en
(d) Safari: https://support.apple.com/kb/PH19214?locale=en_GB 4.3.
You can opt out of third-party tracking networks using these tools: Click here to opt out of Google Analytics
4.4. You can find general information and opt-out resources at youronlinechoices.eu.
5. Changes to this Policy
5.1. From time to time, we may change and/or update this Cookie Policy. If this Cookie Policy changes in any way, we will post an updated version on this page. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such. Any changes to this Cookie Policy will go into effect on posting to this page.
6. Contact Details
6.1. If you have any comments or questions about this policy and our use of cookies please contact us at support@twisper.com or TWISPER INTERNATIONAL SA, Rte des Jeunes 4, 1227 Geneva, Switzerland.
