TwistySystems - Privacy Policy

 

TwistySystems (“the Company”) and our contracted business partners CCPace Inc., Qburst Inc. and MapBox Inc. value and respect your privacy.  We offer mapping, route selection, GPS navigation, and community based services to users of www.TwistySystems.com (the “Website”) and/or users of TwistySystems’ mobile applications (the “Application”) (collectively referred to as the “Services”). 

We acknowledge that in using our services, you are trusting us with your personal information. We understand the seriousness of this responsibility and we make considerable efforts to protect your information and put you in control of it.

We are sharing our Privacy Policy with you so that you understand and control what information we collect, why we collect it, and how you can update, manage, and delete your information.

This is written in plain English to make it very clear to you what do and do not do with your information and so you can decide whether or not this is acceptable to you and so you are able to directly control what information we collect, and for how long we retain it.  

This Privacy Policy covers:

1. Why TwistySystems collects data

2. Information we collect from you and your device

3. User Accounts & Accessing our Services

4. Sharing your information

5. Visibility of your information

6. Integration with social networks other third party services

7. Advertising campaigns

8. How TwistySystems retains data we collect

9. How does TwistySystems use aggregated information?

10. Controlling your personal information

11. Information security

12. Compliance & cooperation with regulators

13. Changes to this Privacy Policy

This Privacy Policy is incorporated as part of the TwistySystems Terms of Use (the “Terms of Use” or the “Terms”). Your use of the Services is subject to the Terms of Use, Copyright Policy and this Privacy Policy and indicates your consent to them. We therefore counsel you to read this Privacy Policy in its entirety prior to using the Application.

 

To use our Services you must be 16 years of age or older. If you are under 16, you may not download or use the Services.

 

In this Privacy Policy, the term “personal information” means information which you provide to us which personally identifies you, such as your name, email address or billing information, and, in certain circumstances, your location and route information or other data which can be reasonably linked to such information by TwistySystems.

 

If you have any questions about this Privacy Policy, or if you believe that your privacy has been compromised in the course of using the Services, please contact Twisty Systems at: privacy@twistysystems.com

 

1. Why TwistySystems collects data

 

TwistySystems may use information collected from or provided by you for the following purposes:

Provide our services

 

We use your information to deliver our services. For example:

  • To use your location and route information and/or search query history to provide navigation services, best route choices, traffic alerts and to provide information about sites, shops and other places and attractions in your close vicinity; and

  • If you have opted in to the “find friends” feature, to use your phone number and the phone numbers which are stored in your device’s phone book to find and create a list of other TwistySystems users who you may know and with whom you may wish to connect.

  • To provide advertising services, including personalized ads, in accordance with the section titled ‘Advertising campaigns’ under this Privacy Policy.

  • To share your submissions with other users of the Services and to facilitate communication between you, TwistySystems and other users.

Maintain & improve our services

 

We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues you report to us, and we use your information to improve the service or to develop new features or services. For example, TwistySystems may use your route information to improve the accuracy of its mapping and navigation data.

Provide personalized services, including content and ads

We use the information we collect to operate the Services and to customize your experience with the Services. For example, TwistySystems may use your “home” and “work” and other “favorites” information (if you choose to provide such information) or route history to offer routes based on how you’ve chosen to travel between favorite destinations in the past. Based on your past activity on the Services we may also suggest to you common destinations where you use the app to navigate to. We may also use the information to provide you with support and handle requests and complaints. Depending on your settings, we may also show you personalized ads based on your interests and past activity. For more information see section titled ‘Advertising campaigns’ under this Privacy Policy.

Measure performance

 

We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your usage of the Services to do things like optimize product design. We also use the data we collected about the ads you view or interact with (e.g. click on) to help advertisers understand the performance of their ad campaigns and to provide them with aggregated reports. We may also use data to measure the usability and effectiveness of TwistySystems’s own marketing efforts on third party sites or platforms.

Communicate with you

 

We also use your information to send you updates, notices, announcements, and additional information related to the Services;

We may also use your information to conduct surveys and questionnaires; And if you contact TwistySystems we may keep a record of your request in order to help solve any issues you might be facing.

Subject to your prior indication of consent (to the extent required under applicable law), we may also use the email address that you provided to send you promotional and/or marketing materials. At any time you may choose not to receive such materials by clicking on the “Unsubscribe” link in the email messages that we may send to you. In any case, TwistySystems will not share your contact details with any advertiser, unless explicitly permitted or required by law.

Protect TwistySystems, our users, the public and for legal reasons

We may also use and process your information and content, using different technologies to the following purposes:

  • To enforce the Terms of Use or Privacy Policy;

  • To contact you when TwistySystems believes it to be necessary;

  • To comply with any applicable law and assist law enforcement agencies under any applicable law, when TwistySystems has a good faith belief that TwistySystems’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;

  • To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;

  • To handle breakdowns and malfunctions;

  • To take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other users or third parties with respect to, or in relation with the Services;

  • For purposes provided under this Privacy Policy and Terms of Use;

  • To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm TwistySystems, our users, or the public;

  • To create aggregated and/or anonymous data (where such data does not enable the identification of a specific user). See “How does TwistySystems use aggregated information”, below;

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

2. Information we collect from you and your device

We want you to understand the types of information we collect as you use our services.

 

TwistySystems collects information to provide better services to all its users - from computing the best route, to monitoring weather and traffic conditions, and in some cases for showing you relevant ads while using our services. The information TwistySystems collects, and how that information is used, depends on how you choose to use our services and how you manage your privacy controls.

Information you create or provide to us:

 

Account Information: information required when setting up a username you have chosen, such as your name and email address. Bear in mind that false, incorrect, or out-dated information may impair TwistySystems’s ability to provide you with the Services and to contact you when necessary. TwistySystems will explicitly indicate the fields for mandatory completion. If you do not enter the requisite data in these fields, you may not be able to set up a username (but you may still use our Services as explained in the above section “User Accounts & Accessing the Services”); and/or

 

Information that you choose to share with TwistySystems: information that you choose to share with TwistySystems, including a username you have chosen, phone number, “home” or “work”, other “favorites”, destinations you may travel to, search queries, and routes selected and/or navigated. 

 

Payment Information: You can also choose to add payment information to your account, if applicable, specifically for paid services (such as a TwistySystems Basic Subscription, and additional paid features such as Offline Routing and Social Networking, where and when available).

 

Communication which you choose to conduct through the TwistySystems Services: You may choose to use TwistySystems to communicate with other TwistySystems users or third parties through the TwistySystems Services, such as by sharing preferred routes on the TwistySystems platform. In other cases we may also collect information when you exchange communication with TwistySystems, for example, if you contact TwistySystems’s support team

 

We will not collect information from your social networks.  We do not request access to nor do we collect information from you existing social networking accounts such as Facebook, Instagram etc. 

 

Information we collect as you use our services

 

We collect information about your activity in the Services, which we use to provide you with the Services of TwistySystems, including features which are meant to personalize your experience. This includes your preferred destinations or routes as well as those commonly traveled by you so that we can better personalize your searches and routes traveled. The activity information we collect may include:

  • Detailed location, travel and route information. Location and route information is collected for example in the form of GPS signals (combined with a time-stamp) and other information sent by your mobile device on which the Application is installed and activated. This location and route information is saved to a route history of all of the journeys you have made while using the Application. The types of location data we collect depends in part on your device and account settings. For example, depending on your selected device settings and/or your account settings we may collect information about your location and travel in order to better understand your route and vehicle preferences, provide you with local weather and traffic updates, and where relevant analyze how effective our ads are and more;

Meta-data (information about your device, browser and app use):

 

Once you install the Application, TwistySystems collects information about the use of the Services and information from the device you have TwistySystems installed on. For example:

  • TwistySystems may collect and record how often you use the app and for how long, your device make, type and model, unique identifiers, operating system type & version, battery usage, information that you viewed on our Services, advertisements that are shown to you or that you view or click on, the Internet Protocol (IP) address and the name of the domain or cell service provider that serves you to access the Services, and the geographic location of the device that you are using to log in and use TwistySystems on.

  • TwistySystems does not collect information about apps installed on your device.

  • We also collect information about the interaction of your devices with our Services, including, crash reports, system activity, and the date, time, and referrer URL of your request.

3. User Accounts & Accessing our Services

 

Please note that when you install the Application on your mobile device, TwistySystems will set up an account associated with that mobile device (the “Account” or “TwistySystems Account”). After installation, TwistySystems will collect and use your information, including meta-data (as described below), in accordance with this Privacy Policy. This use may include linking your information with your Account. This is the case irrespective of whether or not you choose to create a TwistySystems username and password in the TwistySystems Application (as explained below).

TwistySystems may allow you to use the TwistySystems Application whether or not you choose to set up a username for yourself. If you choose to use the TwistySystems Services without setting up a username you may do so by skipping the username setup stage of the application installation process. If you do so:

  • TwistySystems will still link all of your information with your Account and a unique identifier generated automatically by TwistySystems in accordance with this Privacy Policy. This helps us do things like find you the best route.

  • Your Account and the information associated with your Account (including your unique identifier) will be visible only to TwistySystems.

  • When using the Application, your approximate location will be visible to TwistySystems and will be stored temporarily in our secure databases.

  • Note that in order to access certain features of the Services unique to you (for example offline routing, route ranking or route sharing) you will need to set up a unique username to identify yourself.

If you do set up a TwistySystems username and password in the Application:

  • TwistySystems will link all of your information with your Account and that username. This includes information received from all mobile devices running the Application on which you have chosen to sign in using your username and password;

  • When using the Application, your approximate location and other information you may choose to contribute will be visible only to TwistySystems and those users you have associated with that username.

  • Your login details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of providing your login details to someone else. We urge you to maintain your login details in complete confidentiality and that you do not disclose them to others. We also urge you to change your password frequently and at least once every six months.

4. Sharing your information

 

TwistySystems does not sell, rent or lease your personal information to third parties.

TwistySystems will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in TwistySystems’s good-faith discretion:

  • As necessary for the facilitation and operation of the Services. For example, making public road conditions you report and which are associated with your username and your location;

  • If TwistySystems reasonably believes that you have breached the Terms of Use or is investigating potential breach of the Terms of Use, or believes that you abused your rights to use the Services, or performed any act or omission that TwistySystems reasonably believes to be violating any applicable law, rules, or regulations. TwistySystems may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be required to handle any result of your wrongdoing;

  • If TwistySystems is required, or reasonably believes that it is required by law to share or disclose your information;

  • In any case of dispute, or legal proceeding of any kind between you and TwistySystems, or between you and other users with respect to, or in relation with the Services;

  • In any case where TwistySystems reasonably believes that sharing information is necessary to protect against harm to the rights, property or safety of TwistySystems, our users, or the public as required or permitted by law, including to prevent imminent physical damage or damage to property;

  • To detect, prevent, or otherwise address fraud, security, or technical issues;

  • If TwistySystems organizes the operation of the Services within a different framework, or through another legal structure or entity, or if TwistySystems is acquired by, or merged into or with another entity, or if TwistySystems enters bankruptcy, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;

  • To collect, store, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to TwistySystems, as reasonable for business purposes, which may be located in the European Union and the U.S.A., potentially countries outside of your jurisdiction;

  • TwistySystems may also share personal information with companies or organizations connected or affiliated with TwistySystems, such as software partners CCPace Inc., Qburst Inc., and MapBox Inc. 

  • Personal information may also be shared with TwistySystems’s trusted partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer services.

5. Visibility of your information

 

Please note that your username and all other collected information will be visible to a restricted number of approved senior staff of TwistySystems and CCPace responsible for application development and testing. They are all bound by a strict confidentiality agreement and are required not to divulge information to third parties under penalty of legal action. 

In addition, your friends on TwistySystems will see your name & profile photo (if supplied) and any other information you chose to share with them.

6. Integration with social networks other third party services

 

TwistySystems does not link your TwistySystems account and your social network accounts (such as Facebook or Instagram), nor does TwistySystems offer you the option to link TwistySystems to third party services that may be useful to you. 

7. Advertising campaigns

 

TwistySystems allows advertisers to run ad campaigns on the Services.

The information and advertisements that you may see when accessing the Services may be targeted on the basis of your current TwistySystems activity, such as your current location, your destination or contextual information based on your current drive session. 

 

Depending on your settings, you may also see ads personalized to you based on:

  • Information we received from you (for example, your type of vehicle)

  • Past activity and search query history (for example, preferred routes that appear in your saved route list)

  • Information from our ad partners, including entities that belong to the Google group of companies and other trusted ad partners.

Please note:

  • We don’t knowingly collect nor do we show you personalized ads based on sensitive categories, such as race, religion, sexual orientation, or health.

  • We don’t share information that personally identifies you with advertisers, such as your name or email, unless you ask us to. 

  • When you visit a third party website from the Application, such third party may use cookies on your computer. The third party’s use of cookies is subject to their own privacy policies and not to this Privacy Policy. If you wish to study the privacy policies of those third parties you should visit their services, or contact them directly.

It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable for any loss, damage, cost or expense that you may suffer or incur as a result or in connection thereof.

8. How TwistySystems retains data we collect

 

Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.

  • Information retained until you remove it - Account related information such as your name , email address, geographic locations, dates, routes searched, and routes selected and navigated will be retained in your TwistySystems Account until you choose to remove it and/or update it.

  • Data that expires after a specific period of time - in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. For example, data concerning your geographic locations, dates, routes searched and routes selected and navigated will be anonymized at pre-determined time periods.

  • Information retained until your TwistySystems Account is deleted - we may keep some data for the life of your TwistySystems Account if it’s useful for helping us understand how users interact with our features and how we can improve our services. For example, if you made an incident report, we will keep information about how many reports you have submitted, even after the event is removed. When you delete your TwistySystems Account, the information about how many reports you have submitted is also removed.

  • Information retained for extended time periods for limited purposes - sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when TwistySystems processes a payment for you, we’ll retain this data for longer periods of time as required for tax or accounting purposes.

  • Reasons we might retain some data for extended periods of time include

    • Security, fraud & abuse prevention

    • Financial record-keeping

    • Complying with legal or regulatory requirements

    • Ensuring the continuity of our services

    • Direct communications with TwistySystems​

9. How does TwistySystems use aggregated information?

 

TwistySystems may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).

 

TwistySystems may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/or anonymous form to help improve the map and solve map problems, traffic data may be provided to cities, and aggregated ads analysis may be provided to advertisers.

10. Controlling your personal information

 

You can always review and update certain information by visiting your Account & Login settings (such as your phone, email and more).

If you find that the information associated with your Account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up a username and impair the ability to provide you with Services.

Deleting your information 

 

If you would like us to delete your Account, please send an email to DeleteData@twistysystems.com.

 

On receiving such a request, TwistySystems will use reasonable efforts to delete such information, however please note that information may not be deleted immediately from our back-up systems. We aim to initiate the deletion process immediately after your request. Once we receive your request, your data will no longer be used to personalize your TwistySystems experience. We then begin a process designed to safely and completely delete the data from our storage systems. As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and time frames defined in this policy.

 

When your data has been deleted, you will receive an email informing you.

Cookies

TwistySystems does not use cookies and similar technologies on the Services. Cookies are packets of information sent by the Website’s servers to your web browser and then sent back by the browser each time it accesses the Website’s servers.

11. Information security

TwistySystems considers information security to be a top priority. TwistySystems services are built with strong security features that continuously protect your information. TwistySystems implements systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to TwistySystems employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you.

However, these measures are unable to provide absolute assurance. Therefore, although TwistySystems takes great efforts to protect your personal information, TwistySystems cannot guarantee and you cannot reasonably expect that TwistySystems’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

12. Compliance & cooperation with regulators

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data transfers

We store data on servers located around the world and your information may be processed on servers located outside of the country where you live.

Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

European requirements

If the European Union (EU) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, delete, and restrict the processing of your information.

 

You can also export a copy of data in your TwistySystems account if you want to back it up or export your information to another service. 

Downloading Personal Data

If you wish to download your personal data that is stored on Twisty Systems’s secure server, please send an email to DownloadData@TwistySystems.com

We will then send you a copy of all your personal data stored on the Twisty Systems secure server. 

Deleting Personal Data

If you wish to delete your personal data that is stored on Twisty Systems’s secure server, please send an email to DeleteData@twistysystems.com.

 

We will then fully anonymize your data and place it in a pool of aggregate statistical data with no means of linking it to you personally, and subsequently we will  delete all your personal history of geographic locations, dates, routes searched, routes selected and navigated. This is irreversible, and once effected, it will be impossible to recover your information and associate it with your account.You also have the right to object to the processing of your information.

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage your settings at any time, including your in-app Privacy Settings.

When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics) while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

  • Providing, maintaining, and improving our services to meet the needs of our users

  • Developing new services and features that are useful for our users

  • Understanding how people use our services (including how they interact with our ads) to ensure and improve the performance of our services

  • Customizing our services to provide you with a better user experience

  • Marketing to inform users about our services

  • Providing advertising to make our services freely available for users

  • Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services

  • Protecting against harm to the rights, property or safety of TwistySystems, our users, or the public as required or permitted by law

  • Performing research that improves our services for our users and benefits the public

  • Fulfilling obligations to our partners like developers and rights holders

  • Enforcing legal claims, including investigation of potential violations of applicable Terms of Service

 

When we’re providing a service

 

We process your data to provide a service you’ve asked for under a contract (including our terms of use).

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process.

 

If you have questions, you can contact TwistySystems and our data protection office, led by our Data Protection Officer, at: admin@twistysystems.com.

 

And you can contact your local data protection authority if you have concerns regarding your rights under local law.

13. Changes to this Privacy Policy

 

TwistySystems may from time to time change the terms of this Privacy Policy. Substantial changes will take effect 30 days after TwistySystems has posted a:

  • System message to users notifying them of changes to the Privacy Policy; and

  • Notification on the Website’s homepage or any other relevant web pages, explaining the changes to the Privacy Policy alongside a comparison of the “old” and “new” versions of the Privacy Policy.

Other changes will take effect 7 days after their initial posting on the Website. However, if TwistySystems amends this Privacy Policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.

 

You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must avoid any further use of the Services.

Last modified: 25 March, 2021