Twine Data Privacy StatementPrivacy Statement Effective Date as of January 21, 2015
This Twine Data Business Privacy Statement describes the Company’s privacy practices for Mobile Contact Information listed in the Twine Data Directory, and other Mobile Contact Information which may be provided through Twine Data Services.
Description of the Twine Data Directory and Services
The purpose of the Twine Data Directory and Services is to maintain and provide up-to-date mobile contact information. The Twine Data Directory contains Mobile Contact Information from a variety of sources. Most Twine Data Directory information comes from Twine Data Members. However, individuals may add their own Mobile Contact Information to the Twine Data Directory, and the Company may supplement the Twine Data Directory with publicly available information or with information from trusted data providers who are legally authorized to provide such information.
The Twine Data Services also allow Customers to add Social Identifications to their existing U.S. business contact records. The Customer submits its business contact records to the Twine Data Services and the Twine Data Services retrieve and attach publicly available Social Identifications published in connection with the Mobile Contact Information submitted by the Customer. Such Social Identifications are not displayed in the Twine Data Directory but are only provided directly to Customers in relation to their existing U.S. business contact records.
The Company may notify individuals when their Mobile Contact Information is added to the Twine Data Directory via email to permit them the opportunity to opt out of being listed in the Twine Data Directory. Also, at any time, individuals can check to see if they are listed in the Twine Data Directory and opt out by clicking on “Are You in Twine Data?”
Information Provided by the Buyers of Twine Data
From time to time, buyers of Twine Data will want to provide specific information on their users to see if there is a match within the Twine data set. Twine will use this data only to provide matches to the buyer, and will not provide this data to any other third party.
Definitions Relating to the Twine Data Directory
- “Mobile Contact Information” includes an individual’s mobile advertising ID, hashed & anonymized email, and hashed & anonymized mobile phone number. The email may be a work email address or personal address (or multiple email addresses associated with an individual) that is listed in the Twine Data Directory.
- “Twine Data Members” are companies who register to use the Twine Data Services and add (and maintain) records in the Twine Data Directory.
- “Social Identifications” are social handles or unique identifiers used to identify an individual’s online activities on social media channels.
Collection of Mobile Contact Information and Company Information
The Twine Data Directory contains Mobile Contact Information obtained from a variety of sources, including Twine Data Members, the individuals themselves, third party data providers, and publicly available sources.
When new Mobile Contact Information is added to the Twine Data Directory, the Company may send such individuals an email notification that provides an overview of the Twine Data Services, the types of information included and maintained in the Twine Data Directory, how the Twine Data Directory is used, and instructions on how to be removed from the Twine Data Directory.
Individuals may choose to have their Mobile Contact Information removed from the Twine Data Directory. Individuals may opt out of the Twine Data Directory by responding to the email notifying them that they have been added to the Twine Data Directory and/or by following the instructions at “Are You in Twine Data?
The Company may notify individuals that their Mobile Contact Information has been added to the Twine Data Directory and may be used by third parties. The Company offers such individuals the opportunity to opt out of having their Mobile Contact Information available in the Twine Data Directory by clicking on “Are You in Twine Data?“.
At any time, individuals may see if their Mobile Contact Information is listed in the Twine Data Directory and the contents of such Mobile Contact Information by clicking on “Are You in Twine Data?“. Additionally, individuals may request an update or removal of their Mobile Contact Information in the Twine Data Directory by clicking on the same link.
The Company uses reasonable security controls to protect Mobile Contact Information from loss, misuse, and unauthorized access.
The Company limits Mobile Contact Information available in the Twine Data Directory to information typically used to register an app on a mobile device. Other Mobile Contact Information which is provided solely to Customers in connection with their existing U.S. contact records through the Twine Data Services is publicly available information published in connection with an individual’s Mobile Contact Information.
Third Party Advertisers
Individuals may contact the Direct Marketing Association regarding the Company’s compliance with this Mobile Contact Information Privacy Statement:
Direct Marketing Association
1615 L St, NW Ste 1100
Washington, DC 20036-5624
Questions regarding this Twine Data Mobile Contact Information Privacy Statement or the information practices of the Company may be directed to the Company by contacting Twine Data or mailing Twine Data Privacy Office, 1340 East 6th St #103, Los Angeles, CA 90021.