Privacy Policy

1. Privacy Policy

We know that in this digital age, your privacy is important. This Privacy Policy reflects our commitment to protect personal data and the choices we offer you regarding how your data is used. We welcome you to read more about how we keep your information safe, as well as how you can exercise your rights. In addition, our Privacy policy covers our treatment of data that may be personal to you.

• We will review, update, and amend these policies from time to time consistent with our business needs and technology. We encourage you to check back periodically for new updates or changes. Your continued use of the service makes up your acceptance of any change to this Privacy Policy. We are the data controller of your information. We handle and process all data on behalf of our customers
• You may likewise decide not to give us "discretionary" Personal Data; however, please remember that without it, we will most likely be unable to provide you with the full scope of our administrations or with the best client experience when utilizing our Services.
• This Privacy Policy describes how Intelthink. Will gather, use, and maintain your Personal Information on the Twirex. It will also explain your legal rights with respect to that information.
• By using the website and mobile application or services, you confirm that you have read and understood this Privacy Policy and our Terms (together referred to herein as the "Agreement"). The Agreement governs the use of Twirex. We will collect, use, and maintain information consistent with the Agreement.

2. What private data do we collect from the people who visit our website and mobile application?

When enlisting on our site or buying subscriptions or services, as suitable, you could be approached to type in your name, email, postage information, payment information, or different subtleties to assist you with your experience.

When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:

• Account Data : To use certain features (like Paid or unpaid Services), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, name, and assign you a unique identifying number ("Account Data").
• Personal Data : Personal Data is information that can be used to identify you specifically, including your name, email address, telephone number, or demographic information like your hometown. You consent to give us this information by providing it to us voluntarily on our website and mobile application. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website and mobile application.
• Financial Data : Financial data is related to your payment methods, such as credit card or bank transfer details. We collect financial data to allow you to purchase or exchange services from our website and mobile application. We store limited financial data. Most financial data is transferred to our payment processor, PayPal, and Coinbase, and you should review these processors' Privacy Policy to determine how they use, disclose, and protect your financial data.
  • As a courtesy, PayPal Privacy Policy can be found here
  • Coinbase Privacy Policy can be found here.
• Contact information : An Authorized User is required to provide some contact information (e.g., an email address) when making an account on the Services.
• Minors' Data : We do not knowingly collect data from or market to children under 13 years of age. We do not knowingly solicit data from or market to children under 13 years of age. By using the Website and mobile application, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Website and mobile application. If we learn that personal information from users less than 13 years of age has been collected, We will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 13, please contact us.

3. Automatically collected information about your use of our Services or tools,

This information is registered automatically with the visit by own configuration or manual of each tool on the website and mobile application

• When you visit, connect with, or utilize our service, we may gather, record, or create specific specialized data about you. We do so either autonomously or with the assistance of third gathering Service Providers, including using "cookies" and other following innovations.
• We automatically collect certain information when you visit, use or navigate the Website and mobile application. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and mobile application and other technical information. This information is primarily needed to maintain the security and operation of our Website and mobile application and for our internal analytics and reporting purposes.

4. The information we collect includes:

Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website and mobile application, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings, and information about your activity on the Website and mobile application (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or another device you use to access the Website and mobile application. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data, such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website and mobile application. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note, however, if you choose to opt-out, you may not be able to use certain aspects of the Services.

5. How do we handle social signals?

If you choose to register or log in to our website and mobile application using a social media account, we may access certain information about you.

Our Sites offers you the ability to register and log in using your third-party social media account details (like your Facebook, Twitter, Google, or Apple logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture, as well as other information you choose to make public.

We will use the information we receive only for the purposes described in this privacy policy or that are otherwise made clear to you on the Sites. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their sites and apps.

The APIs that we use to store and access cookies and other information on your devices. If you are a user currently in the European Union, please look at our EU User Consent Policy.

6. How do we use your details?

We process personal data to operate, improve, understand, and personalize our services. We use personal data for the following purposes:

• To meet or fulfill the reason you provided the information to us.
• To help communication between The expert and the subscriber.
• Correspond with you and Prevent fraudulent activity on our website or mobile app and Analyze trends to improve our website or mobile application and offerings. To fulfill or meet the reason you provided the information (e.g., to help provide our Site services to you).
• To personalize and develop our site and the services we provide you and improve our offerings.
• To provide certain features or functionality of the services on the site.
• For marketing and promotions.
• To create, maintain, customize, and secure your account with us.
• To prevent illegal activity, fraud, and abuse.
• To help our site that will be ready to serve you better.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you've provided us with the means to do so. For example, if you've given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our services. If you do not want to receive communications from us, please indicate your preference by emailing us.

7. When we share personal information

Once your personal information is collected, as detailed above, we may share it with third parties for various reasons, among them email delivery, data hosting, analytics, payment processing, and content streaming. These services may collect browsing data that includes IP addresses, referring pages, and users' movements as they navigate the Website or mobile application. Other third parties help us with our marketing efforts, including sending and analyzing our marketing efforts by measuring whether recipients have opened an email and clicked on any content within it.

When we share your personal information with a third party, we require that the third party protect the information consistent with this Statement and limit its use of the information to perform the services they provide to us. For example, when we share personal information with payment processors or presenters of web seminars, its use is limited to providing that service.

7. Do Not Track

Currently, various browsers — such as Internet Explorer, Firefox, and Safari — offer a " do not track" or "DNT" option that relies on a technology known as a DNT header, which sends a signal to Web sites visited by the user about the user's browser DNT preference setting. Company_name does not currently commit to responding to browsers' DNT signals with respect to the Company's Web sites, in part because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators, including no consistent standard of interpreting user intent. Company_name takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

8. How we use cookies

We use cookies and similar technologies for several purposes, depending on the context or service, including:

• Recognize you if you sign in to use our offerings. This allows us to provide you with recommendations, display personalized content, and provide other customized features and services.
• We are keeping track of your specified preferences. This allows us to honor your likes and dislikes, such as your language and configuration preferences.
• Detecting and preventing fraudulent activity and improving security.
• We are conducting research and diagnostics to improve our offerings.
• Reporting, which allows us to measure and analyze the performance of our offerings.

9. First-party cookies

• a ). Strictly Necessary Cookies : These cookies are necessary for the website to function and cannot be switched off in our systems. They are often set in response to actions made by you, which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.
• b ). Functional cookies : These cookies enable the website to provide enhanced functionality and personalization. They may be set by third-party providers whose services we have added to our pages or by us.
• c ). Performance cookies : These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.
• d ). Targeting cookies : These cookies may be set through our site and may be used to build a profile of your interests and show you relevant adverts on other sites.

10. Third-party cookies

In addition to our own cookies, we may also use various third-party cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

11. What are your choices regarding cookies?

Cookie Preferences : on the website: Our cookies allow you to take advantage of some essential and useful features. Blocking some types of cookies may impact your experience of our sites. You can change your cookie preferences at any time by clicking 'Cookie Preferences in the footer of the website.

Browser settings : You can also manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to remove cookies from your device, prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. Check the support site for your browser to understand the privacy settings available to you. If you block or reject some of our cookies through your browser's settings, you might not be able to use certain offerings that require you to sign in to an account, and some features and services may not work. You might also have to manually adjust your preferences or settings every time you visit our website or mobile application.

Google Analytics Cookies : We use Google Analytics to investigate the utilization of our site of users and visitors. Google Analytics assembles data about site use through cookies. The data assembled identifying with our site is utilized to make reports about the utilization of our site.

12. California Consumer Rights

The California Consumer Privacy Act provides specific rights to those who live in California. If you are a California-based consumer, as that term is defined under California law, this section shall apply in addition to all other applicable rights and information contained in this Statement.

• You have the right to request that we provide you with information about what personal information we collect, use, and disclose.
• You have the right to request that we delete the personal information we, or our service providers, store about you
• We will not discriminate or retaliate against you if you elect to exercise any rights under this section of our Privacy Statement.
• You may request that we not sell your personal information. As noted above, we do not sell your personal information, and we only share your personal information with third parties, as described in this Statement.
• You have the right to designate an authorized agent to make a request on your behalf. Please see the Identity Verification Requirement below for information on our process for verifying that we have received a legally valid request.
• If you are a California consumer and have additional questions based on this section of our Privacy Statement or wish to submit a request to request that we not share your information with third parties, please contact us by email or through the contact us page.
• See more at https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/

According to caloppa, we agree to the following:

• Users can visit our site anonymously.
• You'll be notified of any ONLINE PRIVACY POLICY changes Via Email

13. Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at info@Twirex with the subject line " Nevada Do Not Sell Request " and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Customer Data" means any personal data that Intelthink processes on behalf of Customer via the Services, as more particularly described in this DPA.

"Data Protection Laws" means all data protection laws and regulations applicable to a party's processing of Customer Data under the Agreement, including, where applicable, EU Data Protection Law and Non-EU Data Protection Laws.

"EU Data Protection Law" means all data protection laws and regulations applicable to Europe, including (i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ( General Data Protection Regulation ) ("GDPR "); (ii) Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector; (iii) applicable national implementations of (i) and (ii); and (iv) in respect of the United Kingdom ("UK ") any applicable national legislation that replaces or converts in domestic law the GDPR or any other law relating to data and privacy as a consequence of the UK leaving the European Union.

"Europe" means, for this DPA, the European Union, the European Economic Area and/or their member states, Switzerland, and the United Kingdom.

" Non-EU Data Protection Laws " means the California Consumer Privacy Act ("CCPA"); the Canadian Personal Information Protection and Electronic Documents Act ("PIPEDA"); and the Brazilian General Data Protection Law ("LGPD "), Federal Law no. 13,709/2018.

" SCCs " means the standard contractual clauses for processors as approved by the European Commission or Swiss Federal Data Protection Authority (as applicable), which shall be applied only to transfers of Customer Data from the European Union.

" Sensitive Data " means (a) social security number, passport number, driver's license number, or similar identifier (or any portion thereof); (b) credit or debit card number (other than the truncated (last four digits) of a credit or debit card); (c) employment, financial, genetic, biometric or health information; (d) racial, ethnic, political or religious affiliation, trade union membership, or information about sexual life or sexual orientation; (e) account passwords; or (f) other information that falls within the definition of "special categories of data" under applicable Data Protection Laws.

" Services Data " means any data relating to the Customer's use, support, and/or operation of the Services, including information relating to volumes, activity logs, frequencies, bounce rates, or other information regarding emails and other communications Customer generates and sends using the Services.

• Parties' roles: If EU Data Protection Law or the LGPD applies to either party's processing of Customer Data, the parties acknowledge and agree that concerning the processing of Customer Data, Customer is the controller and is a processor acting on behalf of Customer, as further described in Annex A (Details of Data Processing) of this DPA.
• Purpose limitation : Intelthink shall process Customer Data only following Customer's documented lawful instructions as outlined in this DPA, as necessary to comply with applicable law, or as otherwise agreed in writing ("Permitted Purposes"). The parties agree that the Agreement sets out the Customer's complete and final instructions to Intelthink concerning the processing of Customer Data. Processing outside the scope of these instructions (if any) shall require a prior written agreement between the parties.
• Prohibited data : Customer will not provide (or cause to be provided) any Sensitive Data to Intelthink for processing under the Agreement, and Intelthink will have no liability whatsoever for Sensitive Data, whether in connection with a Security Incident or otherwise. To avoid doubt, this DPA will not apply to Sensitive Data.
• Customer compliance : Customer represents and warrants that (i) it has complied, and will continue to comply, with all applicable laws, including Data Protection Laws, in respect of its processing of Customer Data and any processing instructions it issues to Intelthink; and (ii) it has provided, and will continue to provide, all notice and has obtained, and will continue to obtain, all consents and rights necessary under Data Protection Laws for Intelthink to process Customer Data for the purposes described in the Agreement. Customer shall have sole responsibility for the accuracy, quality, and legality of Customer Data and how Customer acquired Customer data. Without prejudice to the generality of the preceding, Customer agrees that it shall be responsible for complying with all laws (including Data Protection Laws) applicable to any emails or other content created, sent, or managed through the service, including those relating to obtaining consents (where required) to send emails, the content of the emails and its email deployment practices.
• The lawfulness of Customer's instructions : Customer will ensure that United Kingdom processing of the Customer Data by Customer's instructions will not cause Intelthink to violate any applicable law, regulation, or rule, including, without limitation, Data Protection Laws. Intelthink shall promptly notify Customer in writing unless prohibited from doing so under EU Data Protection Laws if it becomes aware or believes that any data processing instruction from Customer violates the GDPR or any UK implementation of the GDPR.

14. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request deletion of your data. This enables you to ask us to delete or remove personal data where there is no good reason to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
4. Object to processing your data where we are relying on a legitimate interest (or those of a third party), and there is something about your situation that makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object to processing your data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, overriding your rights and freedoms.
5. Request restriction of processing of your data. This enables you to ask us to suspend the processing of your data in the following scenarios:
   1. If you want us to establish the data's accuracy.
   2. Where our use of the data is unlawful, but you do not want us to erase it.
   3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
   4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you.

15. International Data Transfer

The personal information we process may be transmitted or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country.

The servers for our platform are in Tunisia, and third-party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of those countries.

We have taken appropriate steps and put safeguards in place to help ensure that your personal information remains protected in accordance with this Privacy Statement. For example, any data transfers between our group companies are governed by our intragroup agreements, which incorporate strict data transfer terms (including the European Commission's Standard Contractual Clauses, for transfers from the EEA) and require all group companies to protect the personal information they process in accordance with applicable data protection law.

We also require that third-party service providers to whom a data transfer is made have appropriate safeguards in place to protect your personal information in compliance with applicable data protection law. The measures used will depend on the service provider, and our agreements with them may include European Commission-approved Standard Contractual Clauses, the service provider's certification under the EU-U.S. and/or Swiss-U.S. Privacy Shield certification, or reliance on the service provider's Binding Corporate Rules, as defined by the European Commission.

16. How do we protect your details?

• We have implemented industry-accepted administrative, physical, and technology-based security measures to protect against the loss, misuse, unauthorized access, and alteration of personal information in our systems. We ensure that any employee, contractor, corporation, organization, or vendor who has access to personal information in our systems are subject to legal and professional obligations to safeguard that personal information.
• We do not use vulnerability scanning and/or scanning to PCI specifications.
• We use regular Malware Scanning.
• Your individual information is comprised behind secured systems and is merely accessible by a restricted number of folks who've special access privileges to such systems and must keep the information confidential carefully. Furthermore, all very sensitive/credit information you resource is encrypted via Secure Socket Layer (SSL) technology.
• We implement several security measures whenever a user gets into, submits, or accesses their information to keep up the protection of your individual information.
• While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or form of electronic storage is 100 percent secure. Therefore, we cannot guarantee its absolute security.
• Intelthink prohibits unauthorized access or use of personal information stored on our servers. Such access is a violation of law, and we will fully investigate and press charges against any party that has illegally accessed the information within our systems.

17. Can-spam act

The CAN-SPAM Act is a regulation that sets the guidelines for commercial email, establishes requirements for commercial announcements, offers recipients to have emails ceased from being delivered to them, and spells out hard fines for violations.

We accumulate your email to be able to:

• Send information, react to questions, and/or other demands or questions
• To maintain compliance with CANSPAM, we consent to the next:
• Not use untrue or misleading subject matter or email addresses.
• Identify the concept as an advertisement in some realistic way.
• Include the physical address of our site headquarters or business
• Screen third-party email marketing services for conformity, if one can be used.
• Honor opt-out/unsubscribe demands quickly.
• Allow users to unsubscribe utilizing the link at the bottom of every email.
• If anytime you want to unsubscribe from receiving future emails, you can email us by using the contact form at our website or mobile application, and we'll immediately remove you from ALL communication.

18. Limitation of liability

• Some jurisdictions do not allow the limitation or exclusion of liability for incidental or consequential damages, so some of the above limitations may not apply to you.
• We make no legal representation that the website mobile application or services are appropriate or available for use in locations outside Tunisia. You may access the website or mobile application from outside Tunisia. At your own risk and initiative and must bear all responsibility for compliance with any applicable foreign laws.

19. Indemnification

Upon visiting this website or mobile application, you agree to release, indemnify, defend and hold harmless Intelthink and any of its contractors, agents, employees, officers, directors, shareholders, affiliates, and assigns from all liabilities, claims, damages, costs, and expenses, including reasonable attorneys' fees and expenses, of third parties relating to or arising out of your use of the website or mobile application content; your use of the services; your violation of any provision of these terms; any unauthorized information or data you supplied to us. You will have sole responsibility to defend us against any claim, but you must receive our prior written consent regarding any related settlement.

20. Governing Law and Jurisdiction

This website or mobile application originates from Tunisia. The laws of Tunisia. Without regard to its conflict of law, principles will govern these terms to the contrary. You hereby agree that all disputes arising out of or in connection with these terms shall be submitted to the exclusive jurisdiction of Tunisia. By using this website or mobile application, you consent to the jurisdiction and venue of such courts in connection with any action, suit, proceeding, or claim arising under or by reason of these terms. You hereby waive any right to trial by jury arising out of these terms.

21. Changes to this privacy notice

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the Intelthink website or mobile application by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all the changes. The use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contacting us

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact us or email us at admin@twirex.com.