Privacy Policy

Revised November 15, 2018

Intwixt, Inc., a Delaware corporation (“Intwixt,” “our,” “us,” or “we”) respects privacy rights. In that regard, we have created this Privacy Policy to let you know what information we collect when you use our products and/or use our proprietary service (the “Service”), why we collect it, and how it is used.

YOUR CONSENT TO THIS PRIVACY POLICY

By using our products and the Service, you agree to this Privacy Policy and the collection and use of information contemplated hereby. This is our entire and exclusive Privacy Policy and it supersedes any earlier version.

We may change this Privacy Policy by posting a new version on our website or through the Service, and it is your responsibility to review this policy periodically. When we do change the policy, we will also update the “Revised” date and may notify you or post a message through the Service. Your continued use of the products and the Service constitute your agreement to this Privacy Policy and any updates.

PRIVACY SHIELD NOTICE

This Privacy Policy outlines our commitment to the Privacy Shield Principles (the “ Principles”) and our practices for implementing the Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, please visit the Department of Commerce’s dedicated Privacy Shield website, located at https://www.privacyshield.gov/.

 

WHAT INFORMATION DOES INTWIXT COLLECT?

Personal Information means any personally identifiable information that may be used to identify an individual or your account, including, but not limited to, first and last name, home or other physical address, email address and password, phone number, any applications you have created, your conversation history with the applications, list of Facebook pages you own, and credit card or other payment information. We may ask you to provide Personal Information that will enable us to enhance your use of the Service, for purposes such as facilitating correspondence with you, registering your entitlement to access certain special features, or to complete transactions. If you provide your Facebook or other third-party account credentials to, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy; for example, when you log in to our Services using your Facebook Messenger account, we may receive your Personal Information associated with that account, such as your Facebook pages. Certain information may be required to register with us or to take advantage of some of our features. It is always your choice whether or not to provide that Personal Information. If you choose not to provide requested Personal Information, you may not be able to use certain features of the Service.

We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Information, please contact us at privacy@intwixt.com.

Application Access Credentials

In order to enable you to integrate and use 3rd party services, including exchanging of information with these 3rd party services when you are not logged in the Service, we need to collect application credentials, such as application IDs and security tokens, used for accessing these services. Intwixt will not use these credentials in any way other than to enable your applications to connect to and exchange information with these 3rd party services on your behalf. These credentials could be collected during a login process, when you are logging in a 3rd party service through the Service. The personal identification information that you provide during the the login process with a 3rd party service, such as your username and your password is not visible to Intwixt. Therefore, Intwixt does not store this information.

Technical Information 

We may collect and use technical data and related information—including but not limited to technical information about your device(s), system and application software, and peripherals—that is gathered periodically to facilitate the provision of software updates, product support, and other services to you (if any) related to the Service. We may also automatically receive and record information on our server logs from your browser or device, which could include your IP address, cookie information, browser information, and the page you request. This information is not deemed by Intwixt to constitute Personal Information and while Intwixt will not use it in a way that associates such information with you, such information may be aggregated and used. Intwixt owns this information and may use it in any manner it deems appropriate.

 

HOW DOES INTWIXT USE PERSONAL INFORMATION?

The Personal Information that you provide will be kept confidential and used to support your relationship with Intwixt and our products and the Service. Among other things, we want to help you to build applications and communicate with applications others have built, leverage our tools in connection with your authorized use of our products and Service, process payment, analyze how you use our product and Service, facilitate interaction with third party services that you opt into via the Service, and alert you to product upgrades, special offers, updated information and other new products and services from Intwixt.

We may use Personal Information and Technical Information to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve our products or the Service. Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy.

ACCESS 

Individuals whose Personal Information is covered by this Privacy Policy have the right to access the Personal Information that Intwixt maintains about them as specified in the Principles. Individuals may contact us to correct, amend or delete such Personal Information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated).  Requests for access, correction, amendment or deletion should be sent to: privacy@intwixt.com.

CHOICE

We collect and process Personal Information for the purposes described in this Privacy Policy.  Personal information covered by this Privacy Policy is collected and processed only as permitted by the Principles. Notice to individuals regarding the Personal Information collected from them and how that information is used may be provided through this Privacy Policy, other Intwixt notices, or other direct forms of communication with appropriate parties, such as contracts or agreements.  Where necessary and appropriate, consent for Personal Information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt-in consent for sensitive Personal Information). Unless Intwixt offers individuals an appropriate choice, Intwixt uses Personal Information only only as permitted by the Principles.

SHARING OF PERSONAL INFORMATION

Except as set forth herein or in any applicable Terms of Service or other customer agreement, Intwixt does not rent, sell or share Personal Information it collects about you to or with third parties, and Personal Information collected from you is only used to provide you with our products and the Service and to comply with any requirements of law.

Agents or contractors of Intwixt may have access to your Personal Information on a need to know basis for the purpose of performing services on behalf of Intwixt. All such agents or contractors who have access to such information are required to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for Intwixt or as otherwise required by law.

Intwixt or its agents or contractors may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with legal process; (2) protect and defend the rights or property of Intwixt or its agents or contractors; or (3) act in urgent circumstances to protect the personal safety of users of the Service or the public.

If Intwixt should ever merge with another organization, file for bankruptcy, or sell our assets, we may transfer the Personal Information you provide to us to a third party or share your Personal Information to the company with which we enter into such transaction as a part of such transaction.

We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Service. We never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

With applications you create using our products and the Service, you may have access to the Personal Information of your customers. If you use our Service to receive, process and store the data from their interaction with applications, we will treat any Personal Information of your customers as such. Any temporary information that contains Personal Information, which is generated by the Service during the execution of an application is collected for a limited time solely for the purposes of proper functioning of the Service. The Service will store this information for no more than 15 days.

 

SECURITY OF YOUR INFORMATION

We maintain physical, electronic, and procedural safeguards designed to protect Personal Information.

Your account is protected by a password for your privacy and security. If you access your account via Facebook or another third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

Despite the actions and precautions we take, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of your Personal Information and you transmit it to us at your own risk.

Please keep in mind that whenever you voluntarily disclose Personal Information through public facing aspects of the Service, through e-mail, or in chat areas, that information can be collected and used by others. In short, by posting Personal Information online that is publicly accessible, you may receive unsolicited messages from other parties in return. We are not responsible for the security or privacy of any Personal Information you choose to submit in connection with these public features.

We may send an email to you at the email address you have provided to us in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

 

THIRD-PARTY WEBSITES, SERVICES AND APPLICATIONS

Please be aware that other websites and services, including the websites of third parties that you connect with through our Service may collect personally identifiable information about you. This Privacy Policy does not cover the information practices of those third-party websites, services or applications.

 

INTERNATIONAL TRANSFERS

Personal Information collected through the Service may be stored and processed in the United States or any other country in which Intwixt or its affiliates, subsidiaries, agents or contractors maintain facilities, and by using the Service, you consent to any such transfer of information outside of your country.

LIABILITY FOR ONWARD TRANSFERS

Intwixt complies with the Privacy Shield’s Principle regarding accountability for onward transfers.  Intwixt remains liable under the Principles if its onward transfer recipients process Personal Information in a manner inconsistent with the Principles, unless Intwixt proves that it was not responsible for the event giving rise to the damage.

ENFORCEMENT 

In compliance with the Principles, Intwixt commits to resolve complaints about our collection or use of individual's Personal Information. Individuals with inquiries or complaints regarding our Privacy Policy should first contact Intwixt at: privacy@intwixt.com. Intwixt has a policy of responding to individuals within forty-five (45) days of an inquiry or complaint. Intwixt has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. The mediator may propose any appropriate remedy, such as deletion of the relevant Personal Information, publicity for findings of non compliance, payment of compensation for losses incurred as a result of non compliance, or cessation of processing of Personal Information of the individual who brought the complaint. The mediator, or the individual, also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Intwixt.

Individuals may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of their complaint under certain circumstances. For further information, please visit https://www.privacyshield.gov.

Intwixt complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union to the United States.

Intwixt has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

CONTACTING INTWIXT

For questions or comments regarding this Privacy Policy, please contact us at privacy@intwixt.com.