Twine Data Privacy Statement

Privacy Statement Effective Date as of May 1, 2018

This Twine Data Business Privacy Statement describes the Company’s privacy practices for Mobile Information listed in the Twine Data Directory, and other Mobile 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 information. The Twine Data Directory contains Mobile Information from a variety of sources. Most Twine Data Directory information comes from Twine Data Members. However, individuals may add their own Mobile 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.

At any time, individuals can check to see if they are listed in the Twine Data Directory by clicking on “Are You in Twine Data?”  They may use this link to get a list of the information available about them in the Twine Data Directory and to opt out if they choose.

Information Provided by the Licensors of Twine Data

From time to time, licensors of Twine Data will to provide specific information on their users to see if there is a match within the Twine Data Directory. Twine will use this data only to provide matches to the licensor, and will not provide this data to any other third party.

Definitions Relating to the Twine Data Directory

  • “Mobile Information” includes a mobile advertising ID and one or more descriptive elements, which may include:
    • A hashed and anonymized email address.  The email address 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
    • GPS-derived location information relating to app usage
    • Demographic data such as age, gender, or language preference
    • Information about app ownership and usage
    • Mobile device characteristics, including Bluetooth connections associated with a device
  • “Twine Data Members” are companies who register to use the Twine Data Services and add (and maintain) records in the Twine Data Directory.

Collection of Mobile Information and Company Information

The Twine Data Directory contains Mobile Information obtained from a variety of sources, including Twine Data Members, the individuals themselves, third party data providers, and publicly available sources.

 

Choice

Individuals may choose to have their Mobile Information removed from the Twine Data Directory. Individuals may opt out of the Twine Data Directory by following the instructions at “Are You in Twine Data?

 

Access

At any time, individuals may see if their Mobile Information is listed in the Twine Data Directory and the contents of such Mobile Information by clicking on “Are You in Twine Data?“. Additionally, individuals may request an update or removal of their Mobile Information in the Twine Data Directory by clicking on the same link.

Security

The Company uses reasonable security controls to protect Mobile Information from loss, misuse, and unauthorized access.

 

Third Party Advertisers

We partner with third-party advertising companies who serve ads to individuals based on their data in the Twine Data Directory . These companies may use this information in order to provide advertisements about goods and services of interest to individuals. Third party advertiser use of cookies is subject to their own privacy policies, not the Twine Data privacy policy. The DAA and NAI offer consumer choice programs that allow individuals to opt-out of certain interest-based advertising. See http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/ for more information.

Enforcement

Individuals may contact the Direct Marketing Association regarding the Company’s compliance with this Mobile Information Privacy Statement:

Direct Marketing Association
1615 L St, NW Ste 1100
Washington, DC 20036-5624
http://www.the-dma.org

Contact

Questions regarding this Twine Data Mobile 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, 800 Wilshire Blvd #200, Los Angeles, CA  90017.