Effective Date: August 14, 2020
This policy explains what information we collect when you use twola.com Limited’s (Here after will be referring the same as twola.com) sites, services, mobile applications, products, and content (“Services”). It also has information about how we store, use, transfer and delete that information. Our aim is not just to comply with privacy law and also earn your trust.
Information We Collect & How We Use It
In order to give you the best possible usage experience of twola.com, we collect information from your interactions with our network. Some of this information, you actively tell us (such as your email address, which we use to track your account or communicate with you). Other information, we collect based on actions you take while using twola.com, such as what pages you access and your interactions with our product features (like Buy, Sell, and Auction services). This information includes records of those interactions, your Internet Protocol address, information about your device (such as device or browser type), and referral information.
We use this information to:
Provide, test, improve, promote and personalize twola.com Services
Fight spam and other forms of abuse
Generate aggregate, non-identifying information about how people use twola.com Services
When you create your twola.com account, and authenticate with a third-party service (like Twitter, Facebook, Google or LinkedIn) we may collect, store, and periodically update information associated with that third-party account. We will never publish through your third-party account without your permission.
twola.com won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you. We may share your account information with third parties in some circumstances, including:
With your consent.
To a service provider or partner who meets our data protection standards.
With academic or non-profit researchers, with aggregation, anonymization, or pseudonymization.
When we have a good faith belief it is required by law, such as pursuant to a summon or other legal process.
If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others. We will object to requests for information about users of our services that we believe are improper.
twola.com uses third-party vendors and hosting partners, such as DigitalOcean / Amazon, for hardware, software, networking, storage, and related technology we need to run twola.com. We maintain two types of logs: server logs and event logs. By using twola.com Services, you authorize twola.com to transfer, store, and use your information in the United Kingdom and any other country where we operate.
Tracking & Cookies
We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log you in, remember your preferences (such as default language), evaluate email effectiveness, allow our paywall and meter to function, and personalize content and other information.
twola.com complies with the “Do Not Track” (“DNT”) standard recommended by the World Wide Web Consortium. For logged-out users browsing with DNT enabled, twola.com's analytics will not receive data about you, but we will do some first-party tracking in order to customize content and provide data to third-party service providers that enable twola.com Services to work. When you use twola.com while logged-in to your account, we cannot comply with DNT. Here’s some more information about twola.com's Do Not Track policy.
Modifying or Deleting Your Personal Information
If you have a twola.com account, you can access, modify or export your personal information, or want to delete your twola.com account, please Send us your request, including your twola.com username.
To protect information from accidental or malicious destruction, we may maintain residual copies for a brief time period. But, if you delete your account, your information and content will be unrecoverable after that time. twola.com may preserve and maintain copies of your information when required to do so by law.
We use encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.
Email from twola.com
Sometimes we’ll send you emails about your account, service changes or new policies. You can’t opt out of this type of “transactional” email (unless you delete your account). But, you can opt out of non-administrative emails such as digests, newsletters, and activity notifications through your account’s “Settings” page. When your interact with an email sent from twola.com (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction. We won’t email you to ask for your password or other account information. If you receive such an email, please send it to us so we can investigate.
Changes to this Policy
twola.com may periodically update this Policy. We’ll notify you about significant changes to it. The most current version of the policy will always be here and we will archive former versions of the policy here.
We welcome feedback about this policy at Legal@ twola.com.com. We will certainly consider your feedback to make this policy better.
Data Protection Statement for European Union Users
Description of Processing Activity
twola.com collects and stores personal information about its users to customize their usage experience and enable personalized distribution of content. It shares minimal data with its service providers.
Purposes of Processing
Provide, test, promote, and improve the services
Gather usage statistics of services
Provide customized usage experience
Publish and distribute user-provided content
Provide access to paid content
Fight spam, fraud, and other abuse of services
Where twola.com collects and stores personal data about non-users, it does so under performance of contract obligations with users who use the services to publish digital product details on the web site hosted by twola.com. In such cases, users authoring such content containing personal data of third parties are responsible for that content. twola.com will consider related complaints in compliance with the General Data Protection Regulation’s rights of the data subject, as well as rights of expression and access to information.
Public Nature of Personal Data
Logged-in users may choose to interact publicly with the twola.com Services in the form of sharing a digital product links into social media like Facebook, twitter, or following other user accounts, or writing into product description message. Where such personal data may reveal special category protected data, it is processed on the basis that it is manifestly made public by the user. Additional information on potential consequences of such processing can be found below. If you do not agree to this public usage, do not create an account or use these features of twola.com Services.
Categories of Personal Data Collected
Logged out users
Browsing history of the twola.com sites
Logged in users:
Email address (non-public)
Session activity (security)
Linked social media accounts (optional)
Browsing history (on twola.com network only)
Network interactions (recommends, follows, etc.)
Posts, responses, or series published by user
Billing information and history
Bank account or other payment account information for payments
Business information, if applicable
Categories of Recipients
twola.com shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:
Hosting, Storage, & Other Infrastructure
Communication & Support
Search engines will index user profiles, public interactions, and any user-generated content. Users may also share links to your content on social media.
twola.com provides Services in conjunction with several payment processors, including: PayPal and Escrow.com, through which users may pay for twola.com memberships , product purchases or receive payment based on participation in our seller program. Those companies acting as payment processors may collect and store personal data related to your billing information and history in order to provide their services, and may collect and store personal data and business data to prevent fraud and other abuse
When you delete your twola.com account, twola.com deletes your personal data as outlined in this document. However, to delete your payment or billing information, you will need to do so with your payment provider, as twola.com only has minimal secure access to those records as needed to provide the services.
Existence of Automated Decision-making
twola.com collects and stores personal data about its users to customize the service offerings. This includes automated decision-making to promote content tailored to the preferences and interests indicated by the user, and to their browsing history and network interactions.
twola.com also filters content for the purposes of fighting and preventing spam, fraud, and other forms of abuse.
Potential Consequences of Processing
By creating an account on twola.com, users may make certain personal data about themselves public and accessible to others on their profile and through network interactions. This may in some cases constitute special category protected data which is considered manifestly made public by the user. Due to the public nature of information posted to twola.com, it may be possible for third parties to derive identifying personal data from products listed for sale, whether by reading, inference, supplemental research, or automated extraction and analysis.
Users are free to use their real name and information, or a pseudonym of their choosing, for their account. Users may also choose to use the service without posting data or engaging in network interactions. However, if you do not agree with and accept the risks of such usage, you may not use the services.
By using twola.com Services, you authorize twola.com to transfer, store, and use your information in the United Kingdom and any other country where we operate. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement.
twola.com retains personal data associated with your account for the lifetime of your account. If you would like to delete your personal information, you can delete your account at any time. Deleted account profile pages will yield an error 404 “file not found” page, immediately upon initiating deletion, and will become unrecoverable in our system after a period of fourteen days. It may take several additional days for your personal data to be de-indexed from search engines, depending on those search engines’ practices, over which twola.com may have limited or no control. To delete your payment or billing information, you will need to do so with your payment provider, as twola.com only has minimal secure access to those records as needed to provide the services.