Privacy Notice – Twikit Applications
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, analyzing, 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 Hessenplein 2, 2000 Antwerpen, Belgium (RLE Antwerp 0500.986.687).
If you have any questions about this Notice, please contact us by email at firstname.lastname@example.org. If you wish to contact our local offices, please refer to our Contact page for details.
What personal data do we process and how do 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 DataInformation we collect when you register, such as:NameE-MailClient ID||You may give us information about you using our services||Twikit LiveTwikit CreateTwikFitAdmin Portal||Enroll you in the ServicesDisplay your user avatar to meeting participants.Provide you with support…||ContractLegitimate Interests|
|Telemetry DataTechnical 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 LiveTwikit CreateTwikFitAdmin Portal||Provide supportMaintain the security of our infrastructure and Services…||ContractLegitimate interestsProtect vital interestsLegal compliance|
|Support Datainformation that has been provided by a user contacting the support||Directly from you||Twikit LiveTwikit CreateTwikFitAdmin Portal||Respond to requests for support||ContractLegitimate Interests|
|Biometric DataScan 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.
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 that the European Commission has determined provides an adequate level of protection for personal information; or
- Implement appropriate safeguards, which will be assessed on a country-by-country basis, to protect your personal information, including transferring it in accordance with applicable transfer mechanisms, including the European Commission’s standard contractual clauses
The data we store can be divided into 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 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.
How we share data
We only share personal data with companies, organizations, or individuals when one of the following circumstances applies:
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 processors, and service providers 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 processes, including from law enforcement or other government agencies.
- enforce applicable Terms of Service
We take technical and organizational security measures to protect your personal data which we store and process in our company against manipulation, loss of confidentiality, destruction, and access by unauthorized persons. Our company’s security measures are continuously improved in line with technological developments.
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 to 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 email@example.com or by mail at the following address: Hessenplein 2, 2000 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