Privacy Policies
Effective date: July 1st, 2018
Hosting : OVH, Roubaix, France
Website Editor : Max Kroher – Twistex SAS, France
Webmaster : Marc Ringrave – Frametonic.com
Pictures : Mostly belong to Max Kroher Consulting / Twistex . Otherwise Shutterstock
Twistex places the highest priority on protecting the integrity of your data, whether about you, your company, your transactions, your products or your service. We collect and process your personal data always in accordance with all applicable laws and regulations.
This Website Data Protection Statement (the “Statement”) describes collection and processing of personal data in connection with your use of Twistex SAS website (the “Site”, any public internet page of Twistex SAS).
Most of the pages on the Site are provided mainly for information purposes and generally we do not, automatically or otherwise, collect or process any personal data (i.e. any data identifying you directly or indirectly such as your name, address or email address) about you as you visit our Site. However, we may collect and process your personal data e.g.:
- When it is provided by you in connection of any specific function of our Site. Examples of such special functions include submitting a feedback form or Quote Enquiriy as well as registering to our commercial services; and
- Through use of cookies (as explained below) if you use our services as a registered user.
- If we collect and process your personal data, we will inform you about it explicitly and in detail. Please visit our Data Protection Pages for further information.
- From time to time, Twistex SAS may place information on your computer which allows Twistex SAS to recognize your computer. This information is commonly known as a “cookie”. Information we collect by using cookies is in anonymous form except when we use cookies with our registered and therefore identified users.
- Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites are separate from our Sites and do not operate under this Statement, but have their own privacy policies, data protection statements or similar announcements/devices. We do not accept any responsibility or liability for these policies, statements and announcements/devices or the lack of them or your use of such websites. Please check these policies, statements and announcements/devices before you submit any personal data to these websites.
Changes to this statement
From time to time, Twistex SAS may change or amend this Statement. In addition, Twistex SAS may modify or revoke access to the Site at any time with or without notice. It is the recommendation of Twistex SAS that you revisit this Statement periodically to review any changes to this Statement.
Contact us
If you want to contact Twistex SAS in data protection related matters, please send us an e-mail by visiting our contact page.
Data protection and GRPD
Twistex SAS appreciates your privacy and places the highest importance on protecting the integrity of your data, whether about you, your company, your transactions, your products or your services. This section of our site is intended to provide you with information about personal data processing and data protection in Twistex SAS.
We arrange and process the personal data we collect in the course of our business activities in several different data files. Before further continuing your activities with Twistex SAS, we recommend you to familiarize yourself with Twistex SAS data protection information. You can find the data protection information relevant to you by navigating to subpages depending on your role in relation to Twistex SAS.
Privacy Statement
Who We Are
At Twistex we are dedicated to preserving the trust and confidence of the visitors to our website; and our advertisers. We will never sell, trade or rent Your contact information with any other business for the purpose of marketing. Within this Privacy Policy we will provide You with details on when and why we collect Your personal information, how we will use it, the limited conditions under which we may disclose it to others and how we will keep it secure. The collection of Personal Data will always be in line with the General Data Protection Regulation (GDPR).
Our Trading and Correspondence address is at:
Max Kroher
1 Bld Saint -Michel
75005 Paris
France
Data Collection
twistex.com undertakes to collect Your Data by means that are:
Fair
Legal
Transparent
If You visit twistex.com’s web-site , Your web-browser automatically discloses, and twistex.com’s web-server automatically logs, the following information:
The date and time
The IP address from which You issued the request
The type of browser and operating system You are using
The URL of any page that referred You to the pageThe URL You requested, and whether Your request was successfulThis data may or may not be sufficient to identify You.
Any additional Personal Data that You provide, e.g. in a web-form , may also be logged via our database and/or in the form of an email notification.
Name
Company Name
Telephone Number
Your Location (Country
Your Company resides in)Email Address
This data may or may not be sufficient to identify You.
Any additional data that Your web-browser automatically provides may also be logged. This will be the case, for example, if Your browser has previously been requested to store data on Your computer in ‘Cookies’ (further details provided below) and submits them each time You request a web-page within a domain (such as twistex.com).
This data may or may not be sufficient to identify You.
In general, You can browse our website without providing us with any personal information. We use various products (namely Google Analytics) to collect and analyse traffic to our website, to better understand our visitors; and to offer insight in how we can continually improve. We only collect anonymous statistics, and therefore we do not tie a specific IP address to a specific visit.
Notifications (further information regarding this provided below).
Subject to the qualifications immediately below, twistex.com undertakes to collect Your Data from You and not from other parties. This undertaking is qualified as follows:
Where twistex.com collects Your Data from sources other than You, it undertakes:
To do so only by legal means; andTo declare to You what sources it uses, and under what circumstances.
twistex.com undertakes to declare the purpose of collection in a manner which is clear and meaningful.
Cookies
Cookies are usually small text files, given ID tags that are stored on Your computer’s browser directory or program data subfolders. Cookies are created when You use Your browser to visit a website that uses Cookies, to keep track of Your movements within the site, help You resume where You left off, remember Your registered login, theme selection, preferences, and other customisation functions. The website can store a corresponding file (with the same ID tag) to the one they set in Your browser, and in this file, they can track and keep information on Your movements within the site and any information You may have voluntarily given; while visiting the website; such as an email address.
Cookies are often indispensable for websites that have huge databases, need logins, have customisable themes or other advanced features.
Cookies usually don’t contain much information except for the URL of the website that created the Cookie, the duration of the Cookie’s abilities and effects, and a random number. Due to the little amount of information a Cookie contains, it usually cannot be used to reveal Your identity or personally identifying information.
Standard Uses for Browser Cookies
Website servers set Cookies to help authenticate the user, if the user logs in to a secure area of the website. Login information is stored in a Cookie, so the user can enter and leave the website without having to re-enter the same authentication information over and over.
Session Cookies are also used by the server to store information about user page activities, so users can easily pick up where they left off on the server’s pages. By default, web pages really don’t have any ‘memory’. Cookies tell the server what pages to show the user, so the user doesn’t have to remember or start navigating the site all over again. Cookies act as a sort of “bookmark” within the site.
Cookies are NOT viruses. Cookies use a plain text format. They are not compiled pieces of code, so they cannot be executed nor are they self-executing. Accordingly, they cannot make copies of themselves and spread to other networks to execute and replicate again. Since they cannot perform these functions, they fall outside the standard virus definition.
References:
AllAboutCookies.org – http://www.allaboutcookies.org
Mailing List (Newsletter)
As part of the registration process in order to receive our monthly e-newsletter, we collect Personal Data including Email Address, First Name, Surname (Last Name) and Country. Additional information which can be provided is Company Name.
We store this data securely within our database and we never sell, rent or trade our email lists with any other organisation. We will use Your email address for the purpose of sending You our e-newsletter/s which You have requested to receive. You can opt out or update Your preferences of future mailings at any time, by using the ‘Unsubscribe’ link provided on the e-newsletter, within Your Subscription Management Centre; or by using our ‘Contact’ form via the website. We gather statistics in relation to clicks and email opening, using industry standard technologies to help us monitor and improve (where possible).
The Email Address and ‘Categories of Interest’ are stored securely within our database for review/report purposes only. Once the notification period selected has lapsed, data is automatically removed from the Reports page. Similarly, if an unsubscribe request is made prior to the notification period ending, the data will be removed automatically.
Date Security
twistex.com undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion. Access to the database is via a secure login, which only key employees are privy to.
twistex.com undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level appropriate with its sensitivity. Access to the database is via a secure login, which only key employees are privy to.
twistex.com undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by twistex.com’s staff-members and contractors. These include:
Training for staff in relation to privacy
Access Control – To limit access to Your Data to those staff and contractors who have legitimate reasons to access it
Reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour
Declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
Clear communication of policies and sanctions
Data Use
Use refers to the application of Your Data by any part of twistex.com, or any staff-member or contractor of twistex.com in the course of their work. twistex.com undertakes to use Your Data only for:
The purposes for which it was collected
Such other purpose as are subsequently agreed between twistex.com and You
Such additional purposes as may be required by law . In these circumstances, twistex.com will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
Such additional purposes as are unauthorised by law (in particular to protect twistex.com’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil Your undertakings to twistex.com or have committed a breach of the criminal law)
twistex.com undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.
twistex.com undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose , e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
Data Disclosure
Disclosure refers to making Your Data available to any party other than twistex.com and You. The term disclosure may include many different conditions of data transfer, including sharing and giving. twistex.com undertakes to disclose Your Data only under the following circumstances:
In the course of business being conducted between You and twistex.com, where disclosure is necessary to a contractor, such as a transport company. Where Your Data is disclosed in this way, twistex.com undertakes to ensure the contractor’s actions are compliant with these Terms
In other circumstances that are directly implied by the purpose agreed between You and twistex.com at the time of data collection or subsequently. Where Your Data is disclosed in this way, twistex.com undertakes to ensure the contractor’s actions are compliant with these Terms
With Your consent, or at Your request
Where required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena. In these circumstances, twistex.com will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law
Where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where twistex.com believes on reasonable grounds that the disclosure of Your Data will materially assist in the protection of the life of health of some person), provided that twistex.com will apply due diligence to ensure that the exercise of the permission is justifiable
In all cases, twistex.com undertakes to disclose only such of Your Data as is necessary in the particular circumstances.
Data Retention and Destruction
Subject to the qualifications immediately below, twistex.com undertakes:
To retain Your Data only as long as is consistent with its purpose; and
To destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered
This undertaking is qualified as follows:
Your Data may be retained in twistex.com’s logs, backups and audit trails within short-term retention cycles that are devised to protect the company’s operations. In such cases, Your Data will be destroyed in accordance with those cycles
Your Data when an account is marked as ‘Disabled’ will be retained indefinitely for the purpose of archiving (as detailed above); unless a request is made to remove the data, upon which it will be destroyed.
Your Data for the purpose of review/reference will be retained in the form of email notifications once generated (Machine Enquiry, Newsletter Registration, Blocked Enquiries, Wanted Advert, Blocked Wanted Advert, Acceptance of Free Trial / Paid Deal, Potential/New Member Requests, Direct Message (Contact Form).
Your Data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, twistex.com: • Will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law; and • Will only retain Your Data while that provision is current, and will then destroy Your Data
Your Data may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect twistex.com’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil Your undertakings to twistex.com or have committed a breach of the criminal law). In these circumstances, twistex.com will only retain Your Data while that situation is current, and will then destroy Your Data
Access by You to Your Personal Data
twistex.com undertakes to provide You with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, twistex.com undertakes to enable access:
Conveniently
Without unreasonable delay; and
Without cost
twistex.com undertakes to establish and operate identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical.
You can have access to the following information:
The purpose of processing
The Personal Data concernedThe recipients to whom the Personal Data have or will be disclosed
The right to request rectification or erasure of Personal Data (subject to such data being removed will not create a potential adverse effect to the operation of twistex.com (as detailed above (namely the Ban List))
Where Personal Data is not collected from You, any available information as to the source (e.g. for the protection of twistex.com’s financial interests)
In the event that You dispute some aspect of Your Data, twistex.com undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.
You undertake:
Not to seek access for frivolous purposes, or unreasonably frequently;
To accept that deletion of some data may not be consistent with the provision of particular services by twistex.com to You
Information About Data Handling Practices
twistex.com undertakes to make information available to You about the manner in which twistex.com handles Your data:
In general terms, in a readily accessible manner; and
In more specific terms, on request
Where Your Data is disclosed to a contractor, twistex.com undertakes to make information available to You on request about the manner in which twistex.com’s contractors handle Your data.
twistex.com undertakes to ensure that the information provided is meaningful, and addresses Your concerns.
You undertake:
Not to seek such information for frivolous purposes, or unreasonably frequently; and
To accept that the disclosure of excessive detail may harm the security of Your Data and twistex.com’s business processes, and may harm twistex.com’s commercial interests
Handling of Enquiries, General Concerns and Complaints
If You have enquiries, general concerns, or complaints about these Terms, or about how twistex.com handles Your Data:
To communicate them in the first instance:
To twistex.com only
In sufficient detail
Through a channel made available by twistex.com for that purpose (Contact Form / Direct Email, Postal Address, Telephone)
twistex.com undertakes:
To provide one or more channels for communications to twistex.com, which are convenient to users (highlighted above)
To promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication and the date and time it was registered
To promptly provide a response to the communication, in an appropriate and meaningful manner
You further undertake to not pursue twistex.com through any Regulator or the media (including Social Media):
Until and unless twistex.com has had a reasonable opportunity to respond to the initial communication; and
while twistex.com and You remain conducting a meaningful dialogue about the matter
Enforcement
twistex.com declares that its undertakings in these Terms are intended to create legal obligations , and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.
You undertake to seek enforcement only in a jurisdiction that is relevant to the transactions that have taken place between You and twistex.com, in particular the jurisdiction in which You live or in which You performed the relevant acts, and the jurisdiction in which twistex.com is domiciled or performed the relevant acts.
Not to materially change these Terms in a manner that reduces the protections for Your Data
To take all possible steps to prevent any company that acquires this company or any of its relevant assets from materially changing the Terms applicable to Your Data in a manner that reduces the protections for Your Data;
Where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to make the updated policy readily available at any time via twistex.com.;
To maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.
Definitions
twistex.com means Twistex SAS including www.twistex.com
Your Data / Personal Data means data that is capable of being associated with You, whether or not it includes an explicit identifier such as Your Name or Email Address. In particular it encompasses all data that twistex.com is capable of correlating with You, using such means as server-logs and cookie-contents.
Your Data does not refer to data that can no longer be associated with You. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.
Consent means Your concurrence with an action to be taken by twistex.com. Consent may be express or implicit, but in either case must be informed and freely-given.