Twine Data Privacy Policy

Effective as of December 14, 2018

We have prepared this Data Privacy Policy for Twine Data, Inc. (“Twine”) to explain how, why, and when we collect personal data from you on the Twine website and through services we provide on behalf of and for various partners as described below.

This Data Privacy Policy describes our data privacy practices related to personal information that we collect through our Website at http://twinedata.com/ (the “Website”) and is used to provide information to Website users, Customers (as defined below) and business partners about our services, including the Twine Data Directory (collectively, the “Twine Services”).

The personal information collected via the Twine Services and via the Website is subject to this Privacy Policy (the “Privacy Policy”). Please note that this Privacy Policy does not apply to the collection, use, manipulation, storage, destruction, disclosure, and/or processing of any information by third parties, which information is subject to the privacy policy of that particular third party.

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.

The personal data provided to us by third parties may be subject to the privacy policy of the entity collecting the data from the individual and not to this Privacy Policy. See Section 6 below for information about your choices and opting out of the collection of your personal data.

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

We use cookies or similar technologies to analyze trends, administer our Website, to track our users’ movement around the Website, and to gather demographic information about our user base as a whole. The technology used to collect information automatically about Twine users may include the following:

Cookies. We use cookies on our Website. Cookies are small files that are stored on your computer or other device by your web browser. A cookie allows a website to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect information about your use of the Website during your current session and over time (including the pages you view and the files you download), your computer or device’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website you visited prior to accessing our Website and the link you use to leave the Website.

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 privacy@twinedata.com 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.

How to Limit Collection of Mobile Data. If you wish to limit data from being collected from your mobile device in the future, you can limit ad tracking on your device. The instructions below are current as of the most recent update of this Privacy Policy but are subject to change at any time by device manufacturers. The NAI maintains a guide showing how to opt out on a variety of mobile devices: http://www.networkadvertising.org/mobile-choice.

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 privacy@twinedata.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.

10.  Changes to this Privacy Policy

Changes to this Privacy Policy will be posted on this page. If we make a material change to our privacy practices, we will provide notice on our Website or by other means as appropriate. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

11.  Contact Twine

If you have any questions regarding our Privacy Policy or our privacy practices, or about Twine generally, you can contact us by email at privacy@twinedata.com or via regular mail at the following address:


Twine Data, Inc.

c/o Twine Data Privacy Office

555 W 5th St, 35th Floor

Los Angeles, CA 90013