PRIVACY POLICY 

Twinverse Oy, doing business as Twinverse (“Twinverse”, “we”, “us”, or “our”), provides services through its website and various terminal device applications (“Apps”). This privacy policy applies to personal information we obtain from individuals through our website, Apps and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services”).

We use Personal Information only for providing and improving the Services. By using the Services, you agree to the collection and use of information in accordance with this policy.

  1. COLLECTED INFORMATION

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when registering at the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

Publicly Available Personal Information. We collect first name, last name; name and information regarding the organization you represent; business email; business phone number; email addresses; phone numbers; and other similar data. 

Personal Information Provided by You. We collect app usage; and other similar data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information collected through our Apps

If you use our Apps, we may also collect the following information:

  • Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, sensors, and other features.
  • Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
  1. USAGE OF THE INFORMATION

We use personal information collected via our Services or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. 
  • Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services or Apps.
  • Request Feedback. We may use your information to request feedback and to contact you about your use of our Services or Apps.
  • To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.                     
  • To deliver services to you. We may use your information to provide you with the requested service.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience.
  1. SHARING OF THE INFORMATION

We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

ï  Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

ï  Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services or Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. 

ï  Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

  1. USAGE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

  1. USAGE OF GOOGLE MAPS AND APPLE MAPS

Our website and mobile applications use Google Maps and Apple Maps APIs. You may find the Google Maps APIs Terms of Service here and Apple Maps APIs Terms of Service here. Google’s Privacy Policy can be found from this link. and Apple’s Privacy Policy from this link.

By using our Maps API Implementation, you agree to be bound either by Google’s Terms of Service or Apple’s Terms of Service depending on which version of the application you are using. You agree to allow us to obtain or cache your location.

  1. INFORMATION STORAGE TIME

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

  1. INFORMATION SECURITY

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services or Apps is at your own risk. You should only access the services within a secure environment.

  1. YOUR PRIVACY RIGHTS

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please contact us through the contact form on our website. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you have questions or comments about your privacy rights, you may contact us through the contact form on our website.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

    ■  Contact us through the contact form on our website. 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us through the contact form on our website. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

    ■  Contact us through the contact form on our website. 

  1. DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when we believe you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that we become aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information we will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

  1. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

  1. UPDATES TO THIS POLICY

We may update this privacy policy from time to time. The updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

  1. CONTACTING US ABOUT THIS POLICY

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Ismo Olkkonen, by email at ismo.olkkonen (at) twinverse.eu, or by post to:

Twinverse Oy 

Ismo Olkkonen

Vanhan-Mankkaan tie 16 C 10

Espoo 02180 

Finland

  1. REVIEWING, UPDATING AND DELETING YOUR PERSONAL DATA

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request through the contact form on our website.