Effective as of December 14, 2018
1. About Twine’s Services
Twine works with trusted app publishers and other business partners that generate information about mobile device and app ownership and usage (“Providers”). We also work with agencies, brands, and other companies that use mobile data for mobile ad targeting, ad and audience analytics, and other purposes (“Customers”).
The purpose of the Twine Services is to maintain and provide up-to-date mobile device and other information for Twine and its Customers. The Twine Data Directory contains mobile data received from our Providers, and Twine may supplement the Twine Data Directory with publicly available information from time to time.
2. What Data Twine Collects
Data that We Collect on the Twine Website
Contact Information: When you use our Website, you may provide us with your name, address, phone number, and email when you set up an account with us and you may provide your name, title, company, email, address, and/or phone number when you sign up for an event with us online or download content from our site.
Browsing Activity on our Website: We may also collect data about your browsing activity on the Twine Website, for example which pages you visited and when, what items were clicked on a page, how much time was spent on a page, or whether you downloaded any materials posted on the Website.
Device and Browser Information: We may also collect technical information about the device or browser you use to access our Website, for example your device's IP address, the operating system, and (in the case of mobile devices) your device type and mobile device's unique identifier such as the Apple IDFA or Android Advertising ID.
Data that We Collect When Rendering the Twine Services
In rendering the Twine Services, we may collect mobile information obtained from a variety of sources, including Providers, the individuals that use mobile devices, third party data providers, and publicly available sources. The data that we collect in providing the Twine Services may include mobile advertising identifiers such as IDFA and Google AdID, location data, device and hardware data, application install data, and other types of user-level data. The data may also include standard health-related categories such as the ownership of a health and fitness app or a medical app.
3. How Twine Uses the Data We Collect
Our Providers, business partners, and Customers provide information on their users to see if there is a match within the Twine data set or the Twine Data Directory. Twine will use this data to provide matches of emails or mobile ad IDs to the Customer. The Twine Services include engaging in cross-device linking.
From time to time users of our Website will provide their contact information and post inquiries via the Website. We use this data to respond to the inquiries or information provided by users of our Website.
4. Data Sharing
We may disclose information that we have collected about you via the Twine Website or through the Twine Services:
With our Customers: We work with agencies, brands, and other companies that use mobile data for various advertising services such as mobile ad targeting, ad and audience analytics.
With Our Service Providers: We contract with service providers and suppliers to help us run our business operations (for example, website and data hosting), as well as billing, collections, IT and tech, customer and operational support.
In Connection with a Financing or Sale of Our Business: If a third party invests in or acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the transaction).
We may also use or share your information with third parties when we believe that doing so is necessary for any of the following:
In Connection with Legal Proceedings: When we are under a legal obligation to do so, for example, to comply with a binding order of a court, or where disclosure is necessary to exercise, establish, or defend the legal rights of Twine, our Customers, business partners or any other third party.
To Comply with Legal Processes: To satisfy in good faith any applicable law, legal process, law enforcement, or governmental request, such as to respond to a subpoena or similar process.
To Protect Ourselves or Others: To prevent or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to Twine’s property or the property or physical safety of any person or third party.
5. Cookies and Related Technology
If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Website may not operate correctly.
6. Your Choices and Opting Out
We recognize that your online and mobile privacy is important to you, so we offer the following ways to give you control over the data that we collect from you.
You Can Find Out if You are In the Twine Data Directory. At any time, individuals may see if their mobile information is listed in the Twine Data Directory and the contents of their mobile information by clicking on “Are You in Twine Data?”.
You May Request Updates or Removal of Your Personal Information. At any time you may request an update or removal of your mobile information in the Twine Data Directory by sending an email request to opt out to firstname.lastname@example.org or by following the instructions at “Are You in Twine Data?”.
We will need your email address OR your mobile ad ID to look for your information in our system. If we find your information we will inform you by email, at which time you can choose to block your data from further use by Twine. We will also send our partners notice of your opt out so that they may process it in their own systems. We will retain your mobile ad ID and your email in our system to ensure that your data is not re-ingested in the future.
Note that if you give us an email address, we will opt you out on all devices connected to that email address. If you give us a mobile ad ID, we will opt you out only on the device with that particular mobile ad ID.
Note the following when using the opt-out mechanisms below: If you use multiple devices we will opt out those devices that we have linked to the email address or the mobile device ID that you provide when opting out. Since we may not have all your browsers or devices connected back to your user, you may need to execute this opt-out on each browser or device.
Other companies’ opt-outs may function differently than our opt-out mechanism. To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the instructions below, for iOS and Android devices:
On an Apple device, go to Settings / Privacy / Advertising. You can turn on “Limit Ad Tracking”, which will prevent advertisers from collecting your mobile ad identifier. You can also reset your ad identifier, which will disconnect your mobile device from any information previously connected.
On an Android device, go to Settings / Google / Ads. You can turn on “Opt out of Ads Personalization”, which will prevent the use of your mobile ad ID for advertising.
7. Additional Rights for California Residents
In addition, under California Civil Code Sections 1798.83-1798.84, California residents may contact Twine at email@example.com to opt out of disclosure to third parties for such third parties’ direct marketing purposes.
Some Internet browsers allow users to send a “Do Not Track” signal to websites you visit. Twine does not respond to this signal at the present time.
8. Data Retention
For identifiable data that we hold on behalf of our Providers and Customers (e.g., their lists of hashed emails, location data, mobile ad IDs, and other identifiable data) that we received in providing the Twine Services, we retain it for up to 15 years from the most recent date of receipt or until we receive a request to delete it.
9. Security Measures
Twine uses reasonable security controls to protect mobile information from loss, misuse, and unauthorized access. However, no security control is one hundred percent secure, and thus, Twine cannot guarantee the absolute security of your information.
11. Contact Twine
Twine Data, Inc.
c/o Twine Data Privacy Office
555 W 5th St, 35th Floor
Los Angeles, CA 90013