Tweak.com and all services operated from tweak.com are websites and services owned and operated by Tweak, a registered Irish company CRN 447835, and its affiliates (“Tweak,” “we” or “us”). Your privacy is very important to us and in order to best protect your information, we have adopted this privacy policy (“Privacy Policy”), which applies to any and all information you submit to us in connection with your access to and/or use of the Website. It is important to note that this Privacy Policy only applies to information that we collect through tweak.com and related websites and services that we own and control (the “Website”). Therefore, if you click any links on the Website that lead to websites owned or operated by third parties or if you access any other website, this Privacy Policy no longer applies.
You should review the privacy policies adopted by those third parties to ensure that you know what information is being collected and what it is being used. While registration is not required to access the Website, certain features and areas of the Website require you to register, create an account and become a member of the Website (each, a “Member” and collectively, “Members”).
Please read this Privacy Policy carefully before your registration for, access to, and/or use of the Website and/or the services provided through the Website (the “Service”). If you do not agree to abide by this Privacy Policy, please do not use the Website or Service. By submitting information to Tweak, you accept the practices described in this Privacy Policy and the Terms.
This Privacy Policy is governed by the Terms, including all disclaimers of warranties and limitation of liabilities. All capitalized terms not defined in this Privacy Policy will have the meanings outlined in the Tweak Brand End User License Agreement. A copy of the Terms can be found on the Website.
We may change the terms of this Privacy Policy at any time. Whenever we make a material change, we will post or otherwise make available the revised policy. The effective date of the most recent version of this policy will appear at the top of this page.
Your Rights
Under data protection law, you have the right to change or withdraw your consent and to request details of any personal data that we hold about you. Where we have no legitimate reason to continue to hold your information, you have the right to be forgotten.
We may use automated decision making in processing your personal information for some services and products. You can request a manual review of an automated decision's accuracy if you are unhappy with it.
If you wish to inform us of changes in consent for marketing, please email us at the following address finance@tweak.com.
Data Subject Rights
Each Data Subject has 8 rights: These are:The right to be informed; This means anyone processing your personal data must clarify what they are processing, why, and who else the data may be passed to.The right of access; this is the right to see what data is held about you by a Data controller.The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.The right to erasure: under certain circumstances, you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten.’ This would apply if the personal data has been withdrawn or the personal data has been unlawfully processed.The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing personal data, such as when a dispute or legal case has to be concluded, or the data is being corrected.The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data controller by him or her, to be provided in a structured, commonly used, and machine-readable format.The right to object; the Data Subject has the right to object to the further processing of their data, which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.Rights concerning automated design making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.
What Information We Collect and How We Collect It
Some of the information we collect is Personally Identifiable Information (“PII”). PII, collected only with your consent, may include your first and last name, email address, mailing address, phone number, and any other information that you provide to us that is linked to your identity. We will only collect PII that is relevant to the services that we provide and the maintenance of the Website and Service. This may occur, for example, in connection with registering to become a Member, subscribing to the Service, signing up to receive newsletters, responses you provide to survey questions or inquiries you may make through our Website, phone, mail, or email. Remember that you always have the option not to provide information by choosing not to use the Website or by not using the particular feature of the Website or Service for which the information is being collected.We may also collect information through the use of “cookies” or other similar technologies. “Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your web browser on your hard drive or via mobile IDs. Tweak (and, potentially, third-party advertisers or other partners) may set and access cookies on your computer or mobile device to track and store preferential information about you, for purposes such as (i) recognizing you when you return to the Website and use the Service, (ii) tailoring the Website and Service to your specific needs or preferences, and (iii) personalizing the content that you see to ensure you enjoy your visit, etc. We may also use cookies to control the display of ads, track your Website usage patterns, record registration and personalization information, and track the various Website items that you view and functions of the Service that you use. Tweak (and potentially third party advertisers) gathers anonymous information about users through cookie technology on an aggregate level only. Such aggregated information is used within Tweak’s internal organization and is only shared with third party advertisers on an aggregated and non-personally identifiable basis. You can always tell your Internet browser that you don’t want to have any cookies downloaded to your computer. Check with the provider of your particular browser to find out how. However, before you note that deleting cookies or directing your browser to refuse them may limit your ability to use certain portions of our Website that require cookies to function. Lastly, third parties who partner with us to display advertising may also use cookies to collect or store data. Please note that your internet browser may enable you to send a message requesting that the Website not track your usage. As described, we use this information to determine which pages of the Website you view and which links you click to tailor our content and advertising for you. Therefore, the Website currently does not follow these messages from your browser (but again, you may disable cookies if you so wish).The last form of information we may collect is non-personally-identifying information but relates to your Website or Service usage or is necessary for the proper functioning of the Website or Service, such as the time and date and the extent of your usage of the Website and Service, the location of where you use the Website and Service, your usage preferences, how you interact with other users, which pages of the Website you visit and for how long, the mobile platform or service provider you use, your browser, your operating system, your IP address, and other unique device identifiers (“Other Information”). We may also compile this data to enable the statistical analysis of our services used internally or with external assistance to make improvements to our Website. We may also provide this information to third parties, including advertisers. Remember, though, that this information is not personally identifiable. If we ever associate Other Information with you as a specific and identifiable person, we treat it as PII.Information collected by us may be stored and processed in the Republic of Ireland or any other country where our agents or we maintain facilities. By using the Website and Service, you consent to any such transfer of information outside of your country, where data protection laws may be different. Tweak makes no representation or warranty concerning any duty to store any information you may provide permanently. By using the Website or Service and providing us with information, you waive any claims that may arise under your own or any other local or national laws, rules or regulations, or international treaties. From time to time, we may transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format. We may also combine information we collect online with information from other sources, including information received from our advertisers and promotional partners. This Privacy Policy applies to your information for as long as your information is in our possession, even if you terminate or discontinue your use of the Website and Service.Please note that all payment processing connected with the Website and Service is done through our payment processing partner, Stripe. Therefore, Stripe will collect and store your payment information, and you expressly agree that Stripe may do so and may charge you the amount you agree to pay to Tweak. Please review Stripe’s privacy policy to find out how they treat your information.
TWEAK IS NOT LIABLE FOR THE ACTS OR OMISSIONS OF STRIPE.
Our Use of Information
We may use the information we collect for several purposes. For instance, we may use it to enforce the Tweak Brand End User License Agreement, respond to your inquiries and otherwise correspond with you, to process transactions that you request, to maintain your Member account (if you have one), to customize the content you see on the Website or Service, to maintain the security and integrity of our Website and the Service, to conduct market research or surveys, and for the administration, review and/or the improvement of the content of our Website and Service. We may also use your information to communicate with you about services that we think may interest you or may aggregate your information for market research, project planning, troubleshooting problems, and detecting and protecting against error or fraud, or as otherwise described to you at the time of collection. You agree that Tweak may use information collected about you to analyze Website and Service usage, improve or customize the Service, customize the content, respond to your requests, questions, and comments, managing your Member account, facilitate communications between users, and as otherwise outlined in this Privacy Policy, or as Tweak believes necessary to protect its rights and the rights of others, including by enforcing the Terms for the Service. You also agree that Tweak may use your information to contact you. Unless you specifically opt-out, you agree that Tweak may use your information to deliver information to you that is relevant to your use of the Website or Service such as administrative notices, product enhancements, or Service “newsletters,” or that, in some cases, is targeted to your interests, such as targeted advertisements that Tweak believes you may be interested in learning more about. By accepting the Terms of Use and this Privacy Policy, you expressly agree to receive this information unless you specifically opt-out in applicable circumstances. Tweak maintains a strict “no-spam” policy. If you register for the Website and Service, you may receive newsletters, notices, and/or special offers via email or text message, unless you have requested otherwise at the time of registration or as set forth below. You may unsubscribe from these electronic newsletters, notices, and/or special offers at any time by following the instructions contained at the very end of every such email or text message or elsewhere as directed by Tweak. If a third party vendor provides such newsletters, you may unsubscribe following the instructions provided by such third party. If you are having problems unsubscribing, please contact us at finance@tweak.com (forwarding the newsletter, if applicable, and including in the Subject line the words “Unsubscribe”), and we will use reasonable efforts to remove you within seven (7) business days. Please note that Tweak will not process any unsubscribe requests submitted as direct replies to any newsletter.
Legal bases for processing (For EEA Users)
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect your information only where: We need it to provide you with the Services, including to operate the Services, provide customer support and personalized features, and to protect safety and security of the Services; It satisfies a legitimate interest(which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; You give us consent to do so for a specific purpose, or we need to process your data to comply with a legal obligation.
Disclosure of Information
Except as expressly provided herein, absent your prior consent, we do not share your PII with any unrelated third parties. We may use third parties to outsource one or more aspects of our business (such as email or customer service providers, data processing, and security execution and clearing services), in which case, we would have to disclose to such third parties (who would be required by us to comply with this Privacy Policy and any other obligation of we have concerning any information provided by you in connection with the Website and/or Service, to the same extent as our obligations) the PII necessary for such third parties to provide such services. We also reserve the right, and you hereby authorize us, to share or disclose your PII, including, without limitation, any content, records, or electronic communications of any kind, when we determine, in our sole discretion, that the disclosure of such information is necessary to identify, contact, or bring legal action against you if:You are or may be violating the Tweak Brand End User License Agreement or this Privacy Policy;You are interfering with Tweak’s or a third party’s rights or property;You are violating any applicable law, rule, or regulation;Necessary or required by any applicable law, rule, or regulation; and/orRequested by governmental authorities in the event of any investigation, an act of terrorism, or instance of local, regional or national emergency.If Tweak is acquired by or merged with a third party entity or sells all or substantially all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the information and content we have received and collected from our users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your PII is treated, transferred, or used.
How We Protect Your Information
Tweak takes a range of security measures designed to protect your information and keep it confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorized alteration. However, by its nature, the internet is not a secure environment. The nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to managing those risks. While we strive to keep current our security technology and will review, refine and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete security of any information collected, stored, or used by us cannot, therefore, be guaranteed. We have security standards and procedures in place designed to prevent unauthorized access to your Member account and information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. In the unlikely event that an unauthorized third party compromises Tweak’s security measures, Tweak will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information. If you ever discover inaccuracies in our data or your PII, we urge you to notify us immediately.
You hereby acknowledge that Tweak shall not be responsible or liable for disseminating your information that results from your disclosure of such information to any third party.
Links to Third Parties
The Website may include links to third-party websites, apps, or services, including payment providers. Such links are not an endorsement by Tweak of those websites, apps, and/or the products or services they offer. Third parties have different privacy policies, and Tweak is not responsible for such third parties' privacy practices. If you click on a link to a third-party website, app, or service, Tweak encourages you to check the applicable privacy policy, as it may differ substantially from that of this Privacy Policy. Tweak makes no representations or warranties, nor is Tweak responsible for any third party's privacy policies. If you decide to access any third-party links appearing on the Website or Service, you do so at your own risk.Links to Third PartiesThe Website may include links to third-party websites, apps, or services, including payment providers. Such links are not an endorsement by Tweak of those websites, apps, and/or the products or services they offer. Third parties have different privacy policies, and Tweak is not responsible for such third parties' privacy practices. If you click on a link to a third-party website, app, or service, Tweak encourages you to check the applicable privacy policy, as it may differ substantially from that of this Privacy Policy. Tweak makes no representations or warranties, nor is Tweak responsible for any third party's privacy policies. If you decide to access any third-party links appearing on the Website or Service, you do so at your
own risk.
Children’s Privacy
Children's privacy is of the utmost importance, and we are committed to complying with the Children’s Online Privacy Protection Act (COPPA). This Website does not knowingly collect, use, or disclose PII from children under the age of 13. If we ever discover that we have inadvertently collected PII from children under the age of 13, we will delete it as soon as possible. If you are a parent or legal guardian and believe that we have collected PII from your child under the age of 13, please email us at finance@tweak.com, and we will take steps to delete this PII as soon as possible.
Access to Your Information
We will provide you with access to PII you provide us for as long as we maintain that information in a readily accessible format. We will also work with you to correct any errors in your PII. If you wish to access or correct any PII that you have submitted through our Website or to have us completely remove your PII from our systems, please send an e-mail with your specific request to finance@tweak.com.
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:“Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: https://sopro.io/. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”
We kindly request you to update your privacy policy in accordance with the above, so the prospecting activity is compliant with the GDPR. Please don’t hesitate to get in touch if you would like to discuss this in further detail.
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