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Privacy Policy

Last updated on January 15th, 2020 (“Effective Date”).

By downloading and using the Twism mobile application or visiting or using the website and domain name, any other linked pages, features, content, and any other services we offer from time to time in connection with any of the foregoing (collectively, the "Website"), you agree to the practices and policies set forth in this Privacy Policy, and you hereby acknowledge and consent to our collection, use, sharing, and protection of your information as described in this Privacy Policy.

This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Website. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage, even if you have accessed the websites or services of those companies through our Website.

Whenever you interact with our Website, we automatically receive and record information on our server logs from your mobile device and/or browser including your mobile device universal ID#, IP address, "cookie" information, and the page(s) you requested. "Cookies" are identifiers we transfer to your computer or device that allow us to recognize your browser or device and tell us how and when pages in our Website are visited and by how many people. We do not respond to ˜Do Not Track” signals.

When we collect usage information (such as the numbers and frequency of visitors to the Website and to which pages within the Website, as well as the actions performed on the Website), we only use such data in aggregate form, in a manner that assures your anonymity. We may provide this aggregate usage information to our partners; our partners may use such information to understand how often and in what ways people use our Website, so that our partners, too, can endeavor to provide you with an optimal online experience.

You may optionally add your personal information via the Website. This information may include personal data such as your name, birthday and email address, transaction history, mobile phone number, social media account information and could include payment card and related payment information if you so choose. You may review, update and/or remove your personal information via the Website at any time.

We use the information we collect to operate, improve and personalize the online experience we offer. We also may use the information to communicate with you, for example, informing you about new products and services that might be of interest to you.

We may contact you by push notification, SMS, email, or other means. If you do not want to receive email or other communication from us, please indicate your preference by changing your account settings accordingly.

We neither rent nor sell your Personal Information in personally identifiable form to anyone. We share your Personal Information in personally identifiable form with third parties only as described below:

We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Our agents do not have any right to use the Personal Information we share with them beyond what we deem necessary to assist us in performing such tasks.

We may release Personal Information when we believe in good faith that release is necessary to comply with laws; enforce or apply our conditions of use and/or other agreements; or protect the rights, property, or safety of Twism, our employees, our users, or others. We may exchange information with other companies and organizations (including governmental authorities) for fraud protection reduction.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites or services. We strongly advise you to review the Privacy Policy of every site you visit. Except as set forth in this Privacy Policy, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information. You may also opt-out at any time of having your Personal Information used for third party services.

We take the security of your data seriously. We use technical and administrative security measures such as, but not limited to, firewalls, encryption techniques, and authentication procedures, among others, to work to maintain the security of your online session and personal information.

The Website may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site, you should read that site's privacy policy.

Twism offers Facebook users the opportunity to interact with friends and to share on Facebook using Facebook Connect. If you are not currently registered as a Twism user and you use the Website's Facebook connection functions, you will first be asked to enter your Facebook credentials and then join Twism. If you are already logged into Twism but not logged into Facebook, when you use the Website's Facebook connection functions, you will be prompted to enter your Facebook credentials or to sign up for Facebook. By proceeding through any of these scenarios, you grant Twism permission to access your Facebook profile information and to use it in accordance with the Facebook terms of use and this Privacy Statement. Please refer to the privacy settings in your Facebook account to manage the performance of your Facebook account.

Twism uses Spreedly, Inc. & Fidel, Inc. (“Spreedly & Fidel”) to gather End User’s data from financial institutions. By using this service, you grant Twism, Spreedly & Fidel) the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by (Spreedly & Fidel) in accordance with the (Spreedly & Fidel) Privacy Policy.

Periodically, we may make updates to this Privacy Policy and make the updates available on the Website. You are bound by changes to the Privacy Policy when you use the Website after those changes have been posted. In the event of a material change, we shall notify you via email or via the Website.

What Information Does Twism Collect, and why?

Notwithstanding anything to the contrary in the Terms or Privacy Policy, Company and its Third Party Service Providers (including Fidel & Spreedly) will use transaction information solely as follows:

Use transaction data to confirm a Qualifying Purchase or return to match transactions to confirm whether you qualify for a statement credit or an Offer;

Processing payments made on the Twism platform using card details securely stored by Spreedly

Share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points should be awarded; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;

Provide participating merchants or Third Party Service Providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and Third Party Service Providers to assess the results of their campaign;

Create a record of the transaction data and thereafter maintain and use data in connection with

Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.

You authorize the sharing, exchange and use of transaction data described above and herein by and among Company and Company’s Third Party Service Providers, applicable Payment Card Networks and applicable Merchants.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data includes first name, last name or similar identifier, date of birth and gender.

Contact Data includes email address and telephone numbers.

Financial Data includes payment card details stored by service provider Spreedly details and we therefore cannot process card payments on your behalf.

Transaction Data includes details about payments made to and from our partners using the Twism app.

Transaction Data includes details about payments made on the Twism App.

Technical Data includes Internet protocol (IP) address, your login data, browser type and version, operating platform, timezone setting and geolocation. Each time you use our app, we may automatically collect information, including the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface and the mobile phone number used on the device), your mobile operating system and the type of mobile browser you use.

Profile Data includes your name and password, feedback and survey responses.

Usage Data includes information about how you use our website, app and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and our communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your physical data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Twism services through our app). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

If you have any questions or concerns regarding privacy, please contact us at Your privacy is important to us and we will make every effort to resolve your concerns.

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