Background

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from www.TWIZ.com or from official links on social media provided by TWIZ. This Privacy Policy forms part of our terms and conditions of our various agreements with you (if any).

TWIZ is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

While your privacy is very important to us, nothing in this Privacy Policy constitutes a voluntary opt-in to any privacy laws, anywhere in the world, which we are not statutorily bound to comply with.

What Is Personal Information And Why Do We Collect It?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers, and bank account and/or credit card details for agreed billing purposes.

This Personal Information is obtained in many ways including correspondence, by telephone and facsimile, by email, when you use our website www.TWIZ.com, when you purchase a membership or other products or services from us, from your website, from media and publications, from other publicly available sources, from cookies and from third parties. This Privacy Policy applies to this website and our products and services only. We don’t guarantee website links or policy of authorized third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients, and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. These include administration needs, dealing with your feedback and requests, conducting research and development in respect of our services, and preventing and detecting any misuse of this website.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Marketing

From time to time, we may send you marketing or promotional material. Marketing and promotional material will only be sent to you if you have opted into receiving it. 

We (or an appointed third party) may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys will provide us with information that allows improvement in the type, quality, and the manner in which those products and services are offered to you.

You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing or selecting the “unsubscribe” link provided in the email.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

* for the primary purpose for which it was obtained;

* for a secondary purpose that is directly related to the primary purpose; or

* with your consent; or 

* where required or authorized by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances, we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure Of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

* to our employees, related companies, and professional advisers such as our lawyers;

* law enforcement agencies to assist in the investigation and prevention of criminal activities;

* credit-reporting and fraud-checking agencies;

* organizations who manage our business strategies;

* third parties where you consent to the use or disclosure; and

* where required or authorized by law.

We may also disclose anonymized information to third-party contractors or service providers with whom we have a business association, including integration providers, marketing service providers, accounting services providers, and information technology service providers including cloud application providers. 

Overseas Disclosure

While we do not otherwise actively disclose your personal information to overseas entities (unless provided for in a separate agreement with you), we may engage service providers (such as cloud data services or communications providers) who may have international data centers, hardware, and disaster recovery sites. Consequently, these providers may have access to your information. We rely solely on reputable organizations for such cloud services.

Security Of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access To Your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

TWIZ will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

We may decline to provide access to your Personal Information if:

* we believe giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;

* giving you access would be unlawful;

* granting that access would have an unreasonable impact on the privacy of other individuals;

* the request for access is frivolous or vexatious; or

* there are anticipated legal proceedings.

Maintaining The Quality Of Your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete, and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

IP addresses

We may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. We collect and manage IP addresses as part of our services, website and for security purposes. We may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, the website and any products/services.

Cookies

This website and our services may use “cookies” to help personalize your online experience. A Cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used by us: a persistent cookie and a session cookie.

A persistent cookie is entered by your web browser into the “Cookies” folder on your computer and remains in that folder after you close your browser and may be used by your browser on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. 

Cookies cannot be used to run programs. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. We extend the same privacy protection to your personal information, whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this site.

This site and our other services may use cookies in order to:

* remember your preferences;

* recognize you as logged in while you remain so (if applicable). This avoids your having to log in again every time you visit a new page;

* show relevant notifications to you (e.g., notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services); and

* remember details of data that you choose to submit to us (e.g., through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc).

Many of these cookies are removed or cleared when you log out, but some may remain so that your preferences are remembered for future sessions.

In some cases, third parties may place cookies through this site. For example:

* Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de-identified data about how long users spend on this site and the pages that they visit;

* Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and

* Third-party social media applications (e.g., Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in this site. Log files track actions occurring on the websites, and collect data including your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps.

In the case of Google Analytics information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. 

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. 

By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

GDPR

Although we do not operate an establishment within the European Union (EU) and do not target any offering of services towards clients in the EU specifically, we intend to comply with the data handling regime laid out in the General Data Protection Regulation (GDPR) in respect of any personal information of data subjects in the EU that we may obtain.

The requirements of the GDPR are broadly similar to those set out in the Privacy Act and include the following rights:

* you are entitled to request details of the information that we hold about you and how we process it.  For EU residents, we will provide this information for no fee;

* you may also have a right to:

* have that information rectified or deleted;

* restrict our processing of that information;

* stop unauthorized transfers of your personal information to a third party;

* in some circumstances, have that information transferred to another organization; and

* lodge a complaint in relation to our processing of your personal information with a local supervisory authority; and

* where we rely upon your consent as our legal basis for collecting and processing your data, you may withdraw that consent at any time.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.  However, please be aware that:

* such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other clients subject to appropriate confidentiality protections; and

* even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular:

* to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and

* in exercising and defending our legal rights and meeting our legal and regulatory obligations.

Policy Updates

We are obligated to regularly review and update this policy. We therefore reserve the right to amend this Privacy Policy at any time. Should any significant amendments occur, notification will be provided on the website after the changes have been made. Your continued use after you receive the notification indicates your consent to be bound by the amended Privacy Policy. 

Privacy Policy Complaints And Inquiries

Your privacy is important to us. If you have any queries or complaints about our information handling processes as they relate to your personal information or our Privacy Policy, please contact our privacy officer at:

TWIZ

support@TWIZ.com