Privacy Policy
This privacy policy (the "Privacy Policy") explains how Invision Publishing Ltd. (the "Company") collects, uses, shares, and protects information of the users of the Company's website and associated mobile applications or other software applications where this Privacy Policy is posted (collectively, the "Company Website"). This Privacy Policy is designed to fulfill the Company's legal obligations in the places where the Company operates-including, without limitation and where applicable, the California Consumer Privacy Act ("CCPA"), the EU General Data Protection Regulation ("GDPR"), and Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA").
Please note that this Privacy Policy only applies to the Company Website, and not to websites, applications, operating systems, or other platforms of third parties (collectively, "Third-Party Platforms"), even if such Third-Party Platforms are linked to or accessible from the Company Website. Each Third-Party Platform will have its own data collection and usage practices, and may use its own cookies, web beacons, and other technology to collect information from you and the Company you represent (collectively, "You"). The Company is not responsible for the content or practices of any Third-Party Platforms and, if You choose to visit or use them, You do so at Your own risk.
1. Who controls Your information?
Any information or other data provided to or gathered by the Company is controlled by:
Invision Publishing Ltd.
Nauschgasse 4/3/2 Unit #111
1220 Vienna
Austria
2. What types of information does the Company collect?
"Information," as used in this Privacy Policy, means personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household. Examples include a user's name, mailing address, email address, or IP address.
The Company collects and/or has collected over the past twelve (12) months the following categories of information about You and other users of the Company Website:
Information You Provide to the Company : The Company collects information from You when You voluntarily provide it to the Company through the Company Website. Such information may include Your name, email address, telephone number(s), street address, city, and state, province, and country.
Information from Third Parties : Company may acquire information about You from third parties, such as Your name, email address, telephone number(s), street address, city, and state, province, and country.
Device/Internet Connection Information : When You use the Company Website, the Company automatically gathers information made available by Your web browser, internet service provider, and device, depending on Your settings for each. For example, the Company may collect Your IP address, information about the operating system or type of device You use, the device ID associated with Your device, the date and time You access the Company Website, and Your log in attempts.
Geolocation Information : The Company may collect information about where You are located, both generally and at the time You access the Company Website. For example, the Company may collect Your mailing address or ascertain Your approximate location from Your IP address.
Other Information : From time to time, the Company may collect other information from You, such as when You request assistance through the Company's customer service department. You will always be asked for Your consent in advance of providing such other information, and the Company will not collect such information without Your permission.
Inference Information : The Company may also create new information about You by drawing inferences from the information identified in the categories listed above, such as to create a profile about You reflecting Your preferences and characteristics.
3. How and when does the Company collect information about You?
The Company gathers information about You through the following sources and means:
When You enter or upload information to the Company Website : The Company collects information You provide to the Company when You enter such information on a form on the Company Website.
When You communicate with the Company : The Company may also collect information You provide information to the Company outside of the Company Website, such as when You contact the Company's customer service department, or email the Company (including any response to an email communication from the Company). The information collected through the Company Website may be combined with information collected through other sources.
From Third Parties : The Company may also collect the following types of information from third parties: Your name, email address, telephone number(s), street address, city, and state, province, and country.
4. How does the Company use Your information?
The Company may use the information we've gathered from You or Your device, including from third parties, for the following purposes:
Business Purposes : When the Company uses Your information for a "Business Purpose," it means such use is reasonably necessary and proportionate to achieve an operational purpose of the Company. The following are the Business Purposes for which the Company may use Your information:
| Business Purpose | Types of Information |
|---|---|
For Security : The Company uses the information it collects from You and third parties to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and prosecute those responsible for that activity. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
To Provide the Services : The Company uses the information the Company collects from You and third parties to provide Company's services, including the communication of marketing materials and advertisements. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
To Improve our Products and Services : The Company uses the information the Company collects from You and third parties improve its services, including the communication of marketing materials and advertisements. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
To Improve the Company Website : The Company uses the information it collects from You and third parties to provide and improve the Company Website. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
To Communicate with You: The Company uses the information it collects from You and third parties to personalize communications with You and to respond to Your requests regarding Your use of the Company Website and the Company's services. The Company also use Your information to notify You of updates to the Terms of Service or this Privacy Policy. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
To Create Deidentified Aggregate Information: The Company may combine Your information with that of other users to create "Aggregate Information"-namely, statistical information about all users or a subset thereof. Aggregate Information is pseudonymized and deidentified. In other words, Aggregate Information cannot be used to identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer, including You.In turn, Aggregate Information may be used by the Company for the Business and Commercial Purposes listed herein. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
Commercial Purposes . When the Company uses Your information for a "Commercial Purpose," it means such use is intended to advance the Company's business interests, such as by inducing You to purchase a product or service. The following are the Commercial Purposes for which the Company may use Your information:
| Commercial Purpose | Types of Information |
|---|---|
To Advertise to You : The Company may use Your information to deliver ads to You via various media, including but not limited to emails. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
Scope and Legal Bases for Use
The Company only processes Your information to the extent that is necessary to accomplish the above-stated Business and Commercial Purposes, which serves as the Company's legitimate interest.If You reside in a location governed by the GDPR, then the following are the Company's legal bases for the processing of Your information: In so far as the Company has obtained consent for processing operations of information by the data subject, Art. 6(1) lit. a GDPR serves as the legal basis. For the processing of information necessary for the performance of a contract to which the data subject is a party, Art. 6(1) lit. b GDPR serves as the legal basis. The same applies to such processing operations which are necessary for carrying out pre-contractual measures. In so far as the processing of information is required to comply with a legal obligation to which the Company is subject, Art. 6(1) lit. c GDPR serves as the legal basis. In the event that processing of information may be necessary to protect the vital interests of the data subject or of another natural person, Art. 6(1) lit. d GDPR serves as the legal basis. If processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, processing operations are based on Art 6 (1) f DSGVO.
5. How does the Company share Your information?
Company may share Your information with Third Parties for the following purposes:
Business Purposes.When Company shares Your information for a Business Purpose, it means such use is reasonably necessary and proportionate to achieve an operational purpose of the Company. The following are the Business Purposes for which the Company may share Your information:
| Third Parties | Business Purpose | Types of Information |
|---|---|---|
Service Providers These third parties provide services to the Company that allow the Company to operate the Company Website, provide services to users of the Company Website, communicate with users of the Company Website, and so forth. | For security; to improve the Company's services; to improve the Company Website, to personalize your user experience; and to create Aggregate Information. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
Our Affiliated Entities: Affiliated entities are different than third parties in that they are businesses that are directly related to the Company and have common ownership with the Company. The Company may disclose, transfer, and sell Your information to its affiliated entities, if any, in which event, Your information shall be treated by the affiliated entity in accordance with this Privacy Policy. Should the Company be subject to an acquisition, merger, sale or other change of control or business entity status, the Company reserves the right to transfer or assign Your information as part of that acquisition, merger or sale. | For security; to improve the Company's services; to improve the Company Website, to personalize your user experience; and to create Aggregate Information. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
Government Officials and Private Parties Pursuant to Valid Legal Process : The Company may disclose Your information in response to subpoenas, court orders, and other legal processes. In very rare circumstances, the Company may disclose personal information when it believes such disclosure is necessary in order to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals. | To comply with the Company's legal obligations and to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals. | Information You provide to us; Information from Third Parties; Device/Internet Connection Information; Internet Activity Information; Geolocation Information |
6. How does the Company protect Your information?
The Company, and the third-party vendors the Company uses to store Your information, employ technical, administrative, and physical security measures (such as SSL encryption and HTTPS protocol) that are designed to protect against the loss, misuse, and alteration of the information under the Company's control. The Company regularly reviews its security procedures to consider appropriate new technology and methods.
However, no system can be completely secure. Therefore, although the Company takes steps to secure Your information, the Company cannot promise, and You should not expect, that Your personal and commercial information, or other communications, will always remain secure.
The safety and security of Your information also depends on You. Never share Your user account password with anyone else and notify the Company as soon as possible if You believe Your account security has been breached.
7. How long does the Company keep Your information?
The Company will retain Your information for the length of time necessary to fulfill the Business Purposes and Commercial Purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law or valid court order. If You request deletion of Your information pursuant to Section 9, Your request will be processed according to the timeframes indicated therein and/or pursuant to any applicable legislation.
8. Does the Company transfer Your information to a different country?
If You are visiting the Company Website from a location outside of the United States, Your connection will be through and to servers located in the United States, and all information You provide will be processed and securely maintained in our web servers and internal systems located within the United States. By using the Company Website, You authorize and specifically consent to the transfer of personal data to the United States and its storage and use as specified above when You provide such information to us.
9. What are Your rights when it comes to accessing, correcting, or deleting Your information, and how can You exercise them?
You may access all information the Company has collected and retained about You for purposes of correcting, amending, downloading, or deleting such information. Access can be obtained by filling out a Privacy Request at CCPA Request Form, or contacting the Company at contact@trendingtwist.com.
To protect Your privacy and security, the Company may take reasonable steps to help verify Your identity before granting access, making corrections, providing You with information, or deleting information.
Access and Correction
You may access and correct the personal information the Company has collected about You by filling out a Privacy Request at CCPA Request Form, or contacting the Company at contact@trendingtwist.com.
Right to Request Disclosure
You have the right to request that the Company disclose the following to You:
- o The categories of personal information the Company has collected about You;
- o The categories of sources from which the personal information is collected;
- o The business or commercial purpose for collecting or selling personal information;
- o The categories of third parties with whom the Company shares personal information; and
- o The specific pieces of personal information the Company has collected about You.
- o To request such a disclosure, please fill out a Privacy Request at CCPA Request Form, or contact the Company at contact@trendingtwist.com
Right to Request Deletion: You have the right to request that the Company delete any personal information about You which the Company has collected from You. To make such a request, please fill out a Privacy Request at CCPA Request Form, or contact the Company at contact@trendingtwist.com
California Shine the Light Disclosure: Under California's "Shine the Light" law, California residents who provide personal information to the Company Website may request certain information regarding the Company's disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please fill out a Privacy Request at CCPA Request Form, or contact the Company at contact@trendingtwist.com
10. How does the Company protect the privacy of children?
No Users Under 13
The Company will never knowingly collect any personal information about children under the age of 13. If the Company obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from the Company's database. Because the Company does not collect such information, it has no such information to use or to disclose to third parties. The Company has designed this policy in order to comply with the Children's Online Privacy Protection Act (COPPA).
11. How can You receive and opt-out from marketing communications?
By providing Your email address to the Company through the Company Website or an email initiated by You, other than to opt-out of receiving future marketing communications, You consent to receive emails from the Company. Depending upon Your location, the company may obtain additional consent from You via a checkbox disclosure or an email requesting confirmation before You can receive such information.
Providing consent to promotional emails is NOT a condition of purchasing any goods or services from the Company. You can unsubscribe to advertising emails at any time by clicking the unsubscribe link within the email, or by filling out a Privacy Request at CCPA Request Form, or contacting the Company at contact@trendingtwist.com. Please note that, even if You unsubscribe from advertising emails, the Company will still send You any necessary, non-promotional emails, such as about updates to our Privacy Policy and Terms of Service.
12. Does the Company respond to Do Not Track (DNT) Signals?
DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that Your browsing not be tracked. The Company does not currently respond to DNT requests.
13. How will You know when the Company changes the Privacy Policy?
Each time You use the Company Website, the then-current version of this Privacy Policy will apply. Although most changes are likely to be minor, the Company reserves the right to modify this Privacy Policy by posting such modification on this page; however, if changes are significant, the Company may provide a more prominent notice or email You. Depending upon Your location, the Company may obtain additional consent from You via a checkbox disclosure or an email requesting consent before You can continue to use the Company Website.
Unless the Company receives Your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy, and not to information collected under any earlier version.
14. How can You contact the Company regarding this Privacy Policy?
The Company Website contains a Contact Form at CCPA Request Form, which can be used for electronic contact with the Company. If You use this option to contact the Company, the data entered by You in the form will be transmitted to the Company and stored as part of Your information.
Alternatively, You can contact the Company via email at contact@trendingtwist.com. In this case, Your information transmitted by email will be stored. If needed, Your information will be relayed to the Company's third-party service providers to for the sole purpose of processing any request by You in the communication.