Twikit applications

Privacy notice

1.General

This notice explains how Twikit („we“, „us“ „company“) processes your personal data, when you (each a “User”, “you”, “your”) use our services.

To “process” or “processing” means any use of personal data including, transferring, collecting, recording, storing, using, analysing, combining, disclosing or deleting it. “Personal Data” shall be considered as information that is personally identifiable and obtained in connection with providing our service to you.

 

Responsible for processing:

Twikit NV, with registered office at Uitbreidingstraat 60 – 62, 2600 Antwerpen, Belgium (RLE Antwerp 0500.986.687).

E-mail: privacy@twikit.com

If you have any questions about this Notice, please contact us by email at privacy@twikit.com. If you wish to contact our local offices, please refer to our Contact page for details.

 

2.What personal data do we process and how we use it?

The table below describes Twikit’s processing of personal data as a data controller.

Types of personal Data How we get it Twikit Application What we do with it Legal Basis
Account User Data

Information we collect when you register, such as:

-Name

-E-Mail..

-Client ID

 

You may give us information about you using our services ·Twikit Live

·Twikit Create

·TwikFit

·Admin Portal

·Enroll you in the Services

·Display your user avatar to meeting participants.

·Provide you with support

·…

 

·Contract

·Legitimate Interests

 

Telemetry Data

Technical information from software or system hosting the service, such as:

 

·Feature Usage Data: information about if and how Service features were used.

·Performance Data: metrics related to how the Services perform.

·Service Logs: information on system events and states.

 

 

Automatically through use of the services

 

·Twikit Live

·Twikit Create

·TwikFit

·Admin Portal

·Provide support

·Maintain the security of our infrastructure and Services

·…

 

·Contract

·Legitimate interests

·Protect vital interests

·Legal compliance

 

Support Data

information that has been provided by a user contacting the support

 

Directly from you ·Twikit Live

·Twikit Create

·TwikFit

·Admin Portal

·Respond to requests for support

·

·Contract

·Legitimate Interests

Biometric Data

Scan data provided for the sole purpose of creating a design or recreating a design based on an older scan in TwikFit

Directly from you ·TwikFit ·To create a design or recreate a design ·Explicit consent

For the avoidance of doubt, this table does not cover other Customer Content provided by you, including any personal data about you, that may be contained in Customer Content, through free field forms etc..

3.Transfer, storage and removal of data

We use the services of Amazon AWS. If you are a resident of the European Economic Area (EEA), your data is stored in Ireland. If you are a resident of the USA, or Canada your data is stored in California, United States.

If your personal data is transferred outside of the EEA, we will:

  • Process it in a territory which the European Commission has determined provides an adequate level of protection for personal information; or
  • Implement appropriate safeguards, which will be assess on a country-by-country basis, to protect your personal information, including transferring it in accordance with applicable transfer mechanism, including the European Commission’s standard contractual clauses 

The data we store can be divided in three categories:

  • Non-personal data: all data processed that is not personally identifiable such as order value, amount of units,…
  • Personal data: such as Name, E-Mail. This data that can be used to identify a natural person.
  • sensitive data provided by the user, like medical 3D scan data.

We will retain personal data for as long as required to provide our service, unless a longer retention period is required by applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide our services to you (for example, for as long as you have an account with us or keep using our services);
  • Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Customers can delete their own accounts.

 

4.How we share data

We only share personal data with companies, organizations or individuals when one of the following circumstances applies:

With Consent
We may share personal data with companies, organizations, individuals outside and others when we have consent from an individual (as applicable).

For business purposes
We provide personal data to vendors and services providers to help us provide the Services. Examples include, carriers, payment processor, and service provider for managing customer support tickets. Twikit contractually prohibits such vendors from using the personal data for any reason other than to provide the contracted-for services and Twikit contractually requires its vendors to comply with all appropriate privacy and security requirements.

For legal reasons
We share personal data with companies, organizations or individuals if we believe that access, use, preservation or disclosure of the information is reasonably necessary to:

  • meet any applicable law or respond to valid legal process, including from law enforcement or other government agencies.
  • enforce applicable Terms of Service

 

5.Data security

We take technical and organisational security measures to protect your personal data which we store and process in our company against manipulation, loss of confidentiality, destruction and access by unauthorised persons. Our company’s security measures are continuously improved in line with technological developments.

6.Your Rights

What are your rights as a data subject?
We want to guarantee a safe and lawful processing of Personal Data and we assure you that your Personal Data will be processed in a straightforward and lawful way. This implies that the Personal Data will only be processed for the aforementioned, explicitly stated, and legal purpose. We furthermore assure that the Personal Data will always be processed in an adequate, relevant and non-excessive manner.

Your right for information and access
If you have questions or suggestions with regard to the processing of your Personal Data, provided you are able to prove your identity, you have the right to request information concerning the processing. We will then provide you with access to your Personal Data that we process as well as the source of these Personal Data.

Your right of rectification or erasure
You have the right to have your Personal Data rectified, erased or amended, free of charge, and to correct inaccuracies, in the event that your Personal Data is incomplete or incorrect, or is being processed in an unlawful manner. You have the right to request the erasure of incorrect data or data that is not relevant in such a manner.

You have the right to have your Personal Data erased without undue delay, free of charge, unless the Personal Data has to remain stored in accordance with a legal provision. The erasure is predominantly related to visibility, which entails the possibility that the erased Personal Data will remain stored temporarily. However, we will take any and all reasonable measures to erase all your Personal Data as fully and extensively as possible.

Your right of transferability of Personal Data You have the right to request your Personal Data in a structured format.

Your right to object or restrict the processing You can, at all times, object to the processing of your Personal Data, or request to restrict the processing of your Personal Data.

These rights may be exercised by contacting us through privacy@twikit.com or by mail on the following address: Uitbreidingstraat 60 – 62, 2600 Antwerpen.

Your right to Data Portability Within the limits set forth in the Privacy Legislation, you may request the portability of your Personal Data, i.e. by obtaining that the Personal Data you have provided to Twikit will be returned to you or transferred to someone else of your choice, in a structured, commonly used and machine-readable format.

Your option to file a complaint with the competent authority
If you are not satisfied with the way we process your Personal Data, please let us know using the above communication means and we will investigate your concern.

You may also file a complaint to the competent data protection authority with the following contact details:

De Gegevensbechermingsautoriteit – / Autorité de protection des données

Rue de la Presse 35, 1000 Bruxelles

02 274 48 00 or 02 274 48 79/ Fax: 02 274 48 35

https://www.gegevensbeschermingsautoriteit.be

https://www.autoriteprotectiondonnees.be

https://www.dataprotectionauthority.be