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  • Privacy Policy

    Last updated: September 18, 2021

    This Privacy Policy (this "Policy") describes the ways TWDX Infrastructure, LLC ("TWDX Infrastructure", "us", "our" or "we") collect, store, use, and manage the information, including personal information, and data that you (hereinafter referred as "you" or "user(s)") provide or we collect in connection with our web site (the "Site") or any TWDX Infrastructure application provided on a mobile platform (for example, iOS and Android) or on social media (collectively, the "Service(s)").

    Please note that the scope of this Policy is limited to information and data collected or received by TWDX Infrastructure through your use of the Service. TWDX Infrastructure is not responsible for the actions of third party people or companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.

    By using the Service, you are expressing your agreement to this Policy and the processing of your information and data, including your personal information, in the manner provided in this Policy.

    IF YOU DO NOT AGREE TO THESE TERMS, PLEASE DO NOT USE THE SERVICE.

    If you have any questions or concerns, please contact us with the information provided in the Contact Information of Data Controller section of this Policy.

  • Information and data we collect

    Here are some example of information and data we may collect from you:

    •  Data that are collected automatically (such as IP Address, your device's operating system, browser type and language);
    •  Identifiers that are used to identify your mobile device such as your unique device ID (persistent/non-persistent), hardware type, medial access control ("MAC") address;
    •  Profile information that you volunteer (such as name, email address, profile photo, gender, age or birthday, links to profiles on other social networking websites);
    •  Employment information (such as name, email address, phone number, resume).
  • Tracking technologies

    We and our marketing and outsourcing partners, affiliates, or analytics service providers use technologies such as cookies, beacons, scripts, and tags to identify a user's computer/device and to store information about your visit. Information contained in a cookie may be linked to your personal information, such as your user ID, for purposes such as improving the quality of our Service, tailoring recommendations to your interests, and making the Service easier to use. You can disable cookies at any time, although you may not be able to access or use features of the Service.

  • Other collection practices

    The Service may include Social Media features, such as the Facebook Like button and Widgets, such as the Share this button. These Features may collect your IP address, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are hosted by a third party. Your interactions with these Features are governed by the privacy policy of the company providing it.

    TWDX Infrastructure may offer you the opportunity to invite your contacts from a social media or networking service so that those contacts can be located in TWDX Infrastructure apps and/or you can invite them to join you in TWDX Infrastructure apps. Such contact information will be used only for the purpose of sending communications to the addressee. You or the third party may contact us to request the removal of this information from our database to the extent TWDX Infrastructure stores any of this information.

  • How we use the data we collect

    TWDX Infrastructure's first goals in using information are to provide the Service to you, improve our Service, contact you, conduct marketing and research and create reports for internal use. We store information on servers located in the United States via our own infrastructure and third parties (such as Amazon Web Services), and may store information on servers and equipment in other countries.

    We use information collected through our Service for purposes described in this Policy or disclosed to you in connection with our Service. For example, we may use your information to:

    •  Allow you to use our apps;
    •  Identify and suggest connections with other TWDX Infrastructure users;
    •  Operate and improve our Service;
    •  Understand you and your preferences to enhance your experience and enjoyment using our Service;
    •  Respond to your comments and questions and provide customer service;
    •  Provide and deliver products and services you request;
    •  Deliver advertising and marketing and promotional information to you;
    •  Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services.
  • Website services

    While you are browsing our website, your computer's operating system, Internet Protocol (IP) address, access times, browser type and language and referring Web site addresses may be logged automatically. We may use this information to monitor, develop and analyze your use of the Service.

  • Third party services

    Our Service may contain third party tracking and data collection and analytics tools from our service providers, examples of which include Google Analytics. Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze user and device related data and information on our behalf. The third parties may have access to and collect data and information about you, such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), IP address, application usage, access and session times, applications present on the device or in use at a particular time on the device, and your viewing of and interactions with advertising, for the purpose of providing their services, including, for example, enabling, providing and delivering advertising as described in further detail below.

    The privacy policies of our service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.

    We may provide links to third party applications, services or websites from our Services (including advertising that may link to a third party). You understand that when you click on these links any data which you provide afterwards is subject to that third party's privacy policy and not to ours. We can take no responsibility for the content, safety, privacy or security of any third party application, service or website.

  • Application for employment

    If you wish to submit a resume, we may provide you the option to upload it to the Site and we collect your name, email address and mobile telephone number. We use this information to contact you regarding setting up an interview or to determine if you are qualified for the position in which you applied.

  • Applications

    When you use any of the TWDX Infrastructure applications on a mobile platform, we may record certain information and data, such as:

    •  your application usage, access, session times and in-app purchases and orders;
    •  your unique device ID (persistent / non-persistent);
    •  hardware type;
    •  media access control ("MAC") address;
    •  the version of your operating system ("OS");
    •  your email address;
    •  and your location.

    This information is useful to us for troubleshooting and helps us understand usage trends and improve and optimize the Services and your user experience, and may also be utilized for other purposes, such as interest based advertising as described elsewhere in this Policy.

    In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your profile information to track the TWDX Infrastructure applications you are using.

    We may occasionally send you push notifications through our mobile applications to send you updates or other service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

  • How we may disclose the data we collect to third parties

    TWDX Infrastructure does not share your personal information except as approved by you or as described below:

    •  TWDX Infrastructure may engage other companies and individuals to perform services on our behalf. Example of these services include analyzing data and providing customer support. These agents and service providers may have access to your personal information in connection with the performance of services for TWDX Infrastructure.
    •  We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection. In certain situations, TWDX Infrastructure may be required to disclose personal information in response to lawful requests by public authorities or for local law enforcement requirements.
    •  TWDX Infrastructure may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notice on our Site of any change in ownership or users of your personal information.
    •  We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.
  • Accessing, correcting and deleting data we collect from you


    Right of access

    You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information, and the law permits us to charge a fee for exercising this right of access. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why. We will try to respond to any request within a reasonable timeframe.

    Right to correct personal information

    We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us using the information below and we will correct it as soon as we can.

    Data deletion

    In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please contact us using the information below. Please note that to ensure that we do not collect any further information you should also delete our apps from your mobile devices and clear our cookies from any device where you have used our apps or web sites in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form.

  • Opting out of marketing

    You may opt-out of receiving promotional emails from us by following the instructions in those emails. If you opt-out, we may still send you non-promotional emails, such as emails about our ongoing business relations or emails for technical and operational communications.

  • Security standards

    TWDX Infrastructure takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties.

    Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems.

    Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

  • Data retention

    We retain your information for as long as needed to provide you the Service. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  • Our policy regarding minors

    We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the age of 16 or knowingly allow such persons to use our Service. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.

  • International transfer

    We may transfer information that we collect about you to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Policy.

  • Changes to this policy

    We may update this Policy to reflect changes to our data and information privacy practices. If we make any material changes we will notify you by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

  • Contact information of Data Controller

    • TWDX Infrastructure, LLC
    • One Marina Park Drive 14th Floor
    • Boston, MA 02210
    • U.S.A.

    If you have any questions or concerns about our data privacy practices, or if you have any requests for resolving issues with your personal information, please contact us at:   legal@towardex.com