Privacy policy

Twinbees (“Twinbees,” “us,” “we,” or “our”) is committed to protecting and respecting your privacy in connection with your use of our website, www.twinbees.com (the “Website”), and application (“App”).

This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you or that you provide to us, in connection with our Website and App, will be processed by us.

Please read the following carefully to understand our practices regarding your personal data and how we will collect, use, and disclose your personal data.

1 – The data we may collect

We may collect and process the following data about you:

• Personal data including, for example, your first name, last name, email address, and in certain instances, the first names of your children if provided by you.
• Device information such as operating system version, device type, and system performance data.
• Data collected via tracking technologies, as fully described in section 5.

Twinbees does not collect or process credit or debit card data. Apple collects payment card data with respect to in-app purchases made through the App.

Twinbees does not provide you with a password. Any authentication to the app is made through Apple ID, which allows the use of an anonymous email. We recommend keeping your Apple ID and associated email confidential and not sharing them with anyone.

2 – Uses made of the data

We use information held about you in the following ways:

• To provide you with access to the App.
• To respond to your inquiries, providing information, and addressing any complaints you may have.
• To ensure that the App’s content is presented in the most suitable manner for you and your device.
• To send you promotional communications, such as emails, in accordance with your consent and in compliance with applicable laws regarding notice and opt-out rights
• Fulfilling our obligations under any agreements between you and us.
• Enabling your participation in interactive features as per your choice.
• Notifying you about updates or changes to features and content.
• Gaining a general understanding of your approximate geographic location (e.g., zip code, state, or country) to help identify user groups by geographic market.
• Delivering advertisements to you through third-party platforms, other websites and apps, or across your devices, in accordance with your consent and in compliance with applicable laws regarding notice and opt-out rights

3 – Confidentiality and security

We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. Your data are encrypted at rest. We do not provide your personal data to any third party without your consent. We maintain technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, misuse or disclosure. Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.

4 – Newsletters or other electronic communications

If you choose to subscribe to our email and/or push notification promotional materials, we will utilize the data you provide to deliver the requested communications.

In the event that you decide to discontinue receiving email promotional materials, you can unsubscribe by selecting the “unsubscribe” option at the bottom of the communication or by contacting us at [email protected]. We will then remove you from our mailing list.

If you no longer wish to receive push notifications, you have the option to disable them in the App.

Please note that certain service or transactional email messages that are necessary for the functioning of our App may not be eligible for opt-out.

5 – Mobile analytics

 We use mobile analytics software to allow us to better understand the functionality of our App on your devices. This software may record data such as how often you engage with the App, the events that occur within the App, aggregated usage and performance data, and where the App was downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.

6 – Where we store your personal data

All data you provide to us through the Website and App is stored by Amazon Web Services in Europe.

Your data rights

As you may know, the European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are:

• A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof.

• A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

• A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Twinbees will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Twinbees may have legal or legitimate grounds for keeping such data.

• A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.

• A right to data portability: you have the right to receive the personal data concerning you which you have provided to twinbees, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from twinbees. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.

• A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Twinbees. Twinbees may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences in the app.

• A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Twinbees’s personal data protection practices.

• A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Twinbees instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email [email protected]

Legal bases of personal data processing

In accordance with GDPR, Twinbees provides the following information regarding its legal bases for personal data processing: The performance of the contract (the Terms & Conditions) between you and Twinbees for the data processing relating to your use of the App.

Twinbees’s legitimate interest, more specifically:

• Our business interest in providing you with emails and push notifications for timely introductory materials and information about your account, and our features and updates.

• Our financial interest in providing you with promotional offers and/or discounts with respect to paid subscriptions and special offerings.

• Our business interest in offering you particularized or adapted content based on your usage of the Products.

• Our business interest in collecting data regarding your general usage activities for the purpose of improving our Twinbees user experience.

• Our business interest in requesting that you partake in surveys in order to better understand your needs and expectations.

• Our business interest in collecting data related to unplanned downtime or errors in the Products.

• Our business interest in complying with our legal obligations, such as maintaining accurate financial records.

7 – Disclosure of your data

In some limited circumstances, our email service provider may receive certain information you share in-app to provide you with personalized email communications.

If Twinbees is under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of Twinbees, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.

8 – Data retention

The retention periods applied by Twinbees comply with applicable legislation in effect on the date hereof, namely:

For data relating to your account: such data will be permanently and irrevocably anonymized in the event that your account is inactive for a period of two (2) years.

Moreover, we will permanently and irrevocably anonymize your account data within thirty (30) days of your written request to do so via email to [email protected].

For data collected based on your consent to receive our marketing communications: we will use such data until you opt out, withdraw consent or applicable law requires that such data is no longer used.

When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.

When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.

• Withdrawal of consent for processing activities

To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing [email protected].

• Links to third party site

The Website and App may, from time to time, contain links to our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.

• Changes to our privacy policy

We may update this Privacy Policy to reflect changes to our data practices. We encourage you to periodically review this page for the latest data on our privacy practices.

• Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].

• Transmission to other countries

The third parties to whom Twinbees may disclose your personal data may be domiciled abroad, and in particular outside the European Union, Switzerland, and the United Kingdom.

In such a case, Twinbees will require them to take, in accordance with applicable legislation, contractual, organizational and technical measures designed to ensure an adequate level of protection of your personal data, such as the use of Standard Contractual Clauses approved by the European Commission.