This website and/or its mobile sites and applications (“Platform”) is owned and operated by MAS Innovation (Private) Limited (“TWINERY”). This TWINERY Digital Privacy Policy (“Privacy Policy”) describes how we collect and use your information through a variety of digital means. By accessing or using this Platform on any computer, mobile phone, tablet, console or other device (collectively, “Device”), you consent to our Privacy Policy. TWINERY may modify this Privacy Policy at any time effective upon its posting. Your continued use of the Platform constitutes your acceptance to this Privacy Policy and any updates. By using our Services and submitting personal information to this site, you are accepting and consenting to the practices and uses described in this Privacy Policy. This Privacy Policy is not a contract. TWINERY will seek to obtain your additional consent where required by applicable law. This Privacy Policy is incorporated into, and is subject to, the Terms of Use.
WHAT INFORMATION TWINERY COLLECTS.
TWINERY collects information in the following ways:
Active collection:
The information you voluntarily provide to us upon our request. We may ask you to provide us with your name, your surname, your email address, phone number, geographic location and other limited amounts of personal information. We will only use this information to optimize our products and services, learn more about our customers, and serve them better, personalizing their correspondence with us. This includes building a database of interested consumers who can help TWINERY finalize and customize its products, and identify potential early adopters to whom we will send an email and other marketing messages about our products and services. We also collect certain information such as contact age, gender, occupation, and educational details from you when you join us to work together as start-ups, experts and co-creators. The personal information TWINERY collects also allows us to keep you posted on our latest news, careers, investments and product announcements. You are also free to provide comments and feedback on our blog page.
Passive collection:
Information which is automatically collected, without your knowledge, as you navigate through and interact with the content on the Platform, as well as install information on your Device (such as cookies). The sole purpose of passively collecting your information is to understand the visitors’ behaviour and engagement to different areas of the website, along with to improve the overall customer experience. Through the tracking code embedded in our website, the information collected includes:
Device-specific data
The following information may be collected through your Device and browser:
- your Device’s IP address (collected and stored in an anonymized format);
- device screen size;
- device type (unique device identifiers) and browser information;
- geographic location (country only);
- the preferred language used to display the webpage.
- Log data
Our servers automatically record information that includes:
- referring domain;
- pages visited;
- geographic location;
- The preferred language used to display the webpage;
- date and time when website pages were accessed;
Cookies
The Platform uses cookies to collect non-personal information including standard internet log information and details of your behavioural patterns upon visiting our Platform. TWINERY does this to provide you with a better experience, identify preferences, diagnose technical problems, analyse trends and to improve the Platform.
Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the website.
Most browsers allow you to choose whether to accept cookies or not. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies, before accessing the Platform. Please note that by doing so some features of the Platform may not be available to you.
Find out more about our cookie policy
What we collect from other TWINERY interactions and third parties
We may combine information you give us with other information from TWINERY sources, transactions and communications. This may include, but is not limited to, information from TWINERY stores, direct mail, catalogues, events, products and applications, or other TWINERY interactions. We may also combine that information with data that is publicly available and data from third parties. We also collect information about gift recipients provided by the giver. For purpose of vendor and customer registration we may collect information such as name, addresses and telephone numbers, email address, bank account number and associated billing address, corporate-contract, employer and/or other corporate affiliation (e.g., employer name, title, work address and contact information).
USING INFORMATION
In addition to the discussion above, we may use your information to do the following:
OPERATE, IMPROVE AND ANALYZE
Operate, provide, improve and maintain TWINERY’s Products, use collected information for research purposes, including analysing user behaviour and trends. Send you administrative messages and other information about TWINERY. Communicate with you about TWINERY news, products and services, your account information or customer service.
OPEN CHALLENGE
To receive information when you respond to the Open Challenge, the terms and conditions relating to the Open Challenge is set out herein.
PROVIDE AND CONDUCT MARKETING AND PROMOTIONS
With your consent:
Communicate with you about our products, services and events, and for other promotional purposes.
Administer contests, promotions, events, surveys or other features
Display relevant marketing to you
SHARING INFORMATION
We may provide your information to TWINERY, its holding company and Affiliates. (“TWINERY Family”).
Affiliates shall mean any one or more business entities which, directly or indirectly, are controlling, controlled by, or under common control of TWINERY. Control shall mean the ownership of 33% or more of the share capital of a company or having management control of a company.
SERVICE PROVIDERS
We may transfer your information to TWINERY Family service providers to conduct our business. For example, they may handle data management, email distribution, market research, information analysis, and promotions management, vendor and customer registrations. We may also share your information to administer features (e.g. music download, race registration, or workout routine). We also share information with certain third party companies with which we have a business relationship such as logistic partners, system developers, auditors, legal and regulatory institutes.
BY LAW OR TO PROTECT RIGHTS
We may disclose information upon governmental request, in response to a court order, when required by law, to enforce our policies, or to protect our or others’ rights, property or safety. We may share information to prevent illegal uses of TWINERY’s products and services or violations of the Terms of Use or to defend ourselves against third-party claims. We may also share information with companies assisting in fraud protection or investigation.
BUSINESS TRANSFERS
Your information may be transferred to a third party as a part of our business assets in a sale of a part or all of TWINERY. If this should happen, notice will be provided by posting to the website or other forms of communication.
PUBLIC SHARING
DEFAULT SHARING
When you join or use certain services, you agree to publicly share a basic amount of information, which may include your username and city location.
SHARING YOU CHOOSE
You may choose to share certain information. In order to participate in certain features, you may have to adjust your privacy settings and share more information. You may also choose to share your activity on other platforms, such as Facebook and Twitter. Please read the privacy policies of those platforms, because your TWINERY activity published on those platforms will no longer be governed by TWINERY’s Privacy Policy.
TWINERY SHARING
Information that is publicly shared may be used by TWINERY for promotional purposes.
PROTECTING INFORMATION
Security Measures: We use a variety of security measures, including encryption and authentication tools, to help protect your information.
NO GUARANTEE
However, like other companies, TWINERY cannot guarantee 100% the security or confidentiality of the information you provide to us.
CHOICES
MODIFYING OR DELETING YOUR INFORMATION
Your information previously posted may still be publicly viewable. TWINERY may keep information and content in our backup files and archives.
COMMUNICATION/UNSUBSCRIBE/OPT-OUT
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case, your personal data will no longer be processed for such purposes by us.
To unsubscribe and stop receiving messages, please send an email to [unsubscribe@twinery.co] with the word “unsubscribe” in the subject line. If you have unsubscribed from any TWINERY communications, due to production schedules, you may receive communications already in production.
APPLICATION OF LOCAL LAWS
Where required by local law, you may have the right to access, update or request that we delete your personal information. To inform us of inaccuracies or changes to your personal information, please use the below contact information to reach out to TWINERY. We will, in accordance with applicable law, update, grant access to, or delete such information. Please note, requests to correct, transfer or delete personal information are subject to applicable legal, ethical reporting, or document retention obligations imposed on us.
When you provide us with your information, you acknowledge that this information may be stored, transferred, and processed on servers located anywhere in the World, including either inside or outside of the USA, Singapore or the European Economic Area.
Your rights
If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Pursuant to applicable data protection law you may have the right to: request access to your personal data, request rectification of your personal data; request erasure of your personal data, request restriction of processing of your personal data; request data portability, and object to the processing of your personal data. Please note that these aforementioned rights might be limited under the applicable national data protection law. For further information on these rights, please refer to Section “Your rights in detail”.
You also have the right to lodge a complaint with a data protection supervisory authority. To exercise your rights please contact us as stated in Section “Contact us”.
Your rights in detail
Right of access
You may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.
You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to be informed
You may have the right to know the purposes for processing your personal data, our retention periods for that personal data, and with whom it will be shared. This privacy policy provides you with this information. You may reach out to us to obtain any further information needed to enable to exercise your rights.
Right to rectification
You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (“right to be forgotten”)
Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
Right to restriction of processing
Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
Right to data portability
Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
Right to object
If the processing of your personal data is based on legitimate interests, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.
NOTICE FOR MINORS
Our website is not designed or directed at children. We will not intentionally collect, maintain, or distribute information about anyone under the age of 16.
If you are a parent or guardian of a child who has provided personal information without your knowledge and consent, you may request us to remove this children’s information by emailing us at PrivacyOffice@masholdings.com
The TWINERY Platform contains a feature that permits you to upload questions or comments to the Platform. If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion you can contact our Support team directly here PrivacyOffice@masholdings.com. Although we offer this deletion capability, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the services.
INTERNATIONAL USERS
Our digital operations are conducted, in whole or in part, in the United States. Regardless of where you live, you consent to have your personal data transferred, processed and stored in the United States, and allow TWINERY to use and collect your personal information in accordance with this Privacy Policy.
STORAGE AND RETENTION
We may keep information and content in our systems, backup files and archives. Your personal data will be retained as long as necessary to provide you with the services requested. When we no longer needs to use your personal data to comply with contractual or statutory obligations, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your personal data, including if we need to keep your personal data to comply with legal or regulatory obligations to which we are subject, e.g. statutory retention periods and usually contain retention periods, or if we need it to preserve evidence within the statutes of limitation.
LINKS TO OTHER SITES
We’d also like to remind visitors that we provide additional links to resources we think you’ll find useful. These links will lead you to sites that are not affiliated with TWINERY and may operate under different privacy practices. Our visitors are responsible for reviewing the privacy policies for such other websites, as we have no control over information that is submitted to these companies.
TERMS OF USE
Your use of our products and services, and any disputes arising from them is subject to this Privacy Policy as well as our Terms of Use, which explains other terms governing the use of our products and services.
CONTACT US
If you have other questions, comments or concerns about our privacy practices, or if you wish to issue a request to exercise your rights where applicable by law, please contact our Privacy Office at PrivacyOffice@masholdings.com. Please provide your name and contact information along with the request. Alternatively, inquiries may be mailed to the following address:
Mailing address:
PrivacyOffice@masholdings.com
MAS Holdings (Private) Limited
-c/o – Data Protection Officer
Privacy Office
No.199, Kaduwela Road,
Battaramulla
Sri Lanka
Effective date – Policy was last updated and effective on MARCH 15, 2021.
