ContactKeeper, Inc. (“Tweedo”, “we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, process, and disclose your information, including Personal Data (as defined below), in conjunction with your access to and use of our Services, and it applies to all of the Services offered by Tweedo and its affiliates including but not limited to all Tweedo Apps, Sites, APIs (including exports), and Tweedo Integrations. “Users” as defined in this Privacy Policy includes any user of our Services including individual End Users, organizational Clients, and Developers.
Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use located at Tweedo Terms, or your executed Master Services Agreement.
Specifically, we’ll cover:
1. Information We Collect
2. How We Use Information
3. How Information Is Shared
4. Data Retention
5. Third Party Websites
6. Minors
7. Data Protection
8. Your Rights
9. For EU citizens
10. Changes to This Privacy Policy
11. How to Contact Us
1. INFORMATION WE COLLECT
1.1 Types of Data We Collect
“Personal Data” means any information relating to an individual identified or identifiable (“data subject”); An identified individual is a person that can be identified, directly or indirectly, in particular by identifiers such as a name, identification number, location information, online identifier, or one or more factors.
1.2 Information You Provide Us
• Account Information. When you sign up for a Tweedo Account, we may require certain information such as your full name, organization, phone number, email address(s) and password. You may optionally choose to sign into Tweedo using a third party (e.g., your Google login). If you choose to do this, you will be asked whether you agree to the third party providing certain information to Tweedo, such as your name, email address, profile photo, and other information associated with your account.
• Profile Information. To help improve your experience or enable certain features of the Services, you may choose to create a profile including information such as your name, photo, email, phone, URLs, physical address, instant message handles, dates, job title, gender, bio, and interests.
• Referrals. When you use Tweedo to refer our Services to others we will collect and use any contact information you choose to provide and automatically generate an invitation to the contacts you select.
• Payment Information. Some of our Services require payment. We may use third party service providers such as Stripe or Authorize.net to collect all information necessary to complete the transaction. Such information may include name, credit card and billing information, as well as additional fields required for payment. We never share your billing and payment information.
• General Communication. If you contact us (for example via email or phone) we will collect information
such as your name, phone number, email address, as well as any other content that you provide. We also may create event logs to diagnose product or app related issues, and capture information relating to any support or service issues. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives and analyze any feedback provided through voluntary customer surveys.
• Additional Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, provide feedback, request support, post to forums, participate in promotions, or use other features of our Services. We may also collect information at other points in our Services when clearly stated that information is being collected.
1.3 Information We Receive From Your Use of Our Services
1.3.1 Your Contacts.
Tweedo provides a variety of Services that enable you to effectively manage contact information that you provide to us as part of those Services (your “Contacts” , also referred to as “End User Contact Data” in our Terms of Use). Contacts typically contain information on individuals (or organizations) including names, email addresses, phone numbers, URLs, social handles, online identifiers, and physical addresses. Your Contacts may also contain additional information on individuals such as organizational affiliations, job titles, birthdays, key dates, age, gender, general location, relationships, skills, interests, preferences, notes, photos, tags and other categorizations. Depending on which Services you elect to use, Contacts may be collected in one or more of the following ways:
• Connected Services. Many Tweedo Services allow you to connect with external systems or databases that contain your Contacts. Examples include but are not limited to: 1) third-party contact management applications and services, 2) communication applications such as email providers, video conferencing systems, calendar applications, and social networks, and 3) sales, marketing, customer service, and media applications and platforms. Connections to such services generally require you to sign into those services.
• User Interfaces. Many Tweedo Services allow you to directly enter, edit, or otherwise manage your Contacts by means such as typing into a user interface or speaking to a voice interface.
• APIs. Contacts may also be collected when you submit Contacts through Tweedo’s API. This includes both APIs for directly managing contacts as well as APIs for lookup or search.
• Uploaded Files. You may also elect to upload lists of Contacts to Tweedo for processing.
• Third-Party Applications. Tweedo may enable you to manually or automatically transfer, upload, or copy-and-paste contact information from certain third-party applications into Tweedo.
• Contact Extraction. You may elect certain Tweedo features that extract Contacts from email, text or photographs. Examples include our business card scanning feature and our email signature extraction feature. We will not process the content of the communication unless you have explicitly asked us to do so.
• Shared Contacts. Other Tweedo users may elect to share their Contacts or their personal contact details with you.
1.3.2 Relationship Information
Tweedo provides a variety of Services that enable you to effectively manage your relationships. Depending on which Services you elect to use, relationship information may be collected in one or more of the following ways:
• Your Contacts. Your Contacts suggest a certain relationship between you and the people or organizations those Contacts represent. Your Contacts may explicitly indicate the nature of the relationship. We may also infer the strength or nature of a relationship based on the presence or absence of certain contact information such as mobile numbers or key dates, as well as shared elements such as physical addresses or organizational affiliations. Inferred relationship information may also be based on how you interact with individual Contacts such as how often you access or modify them.
• Connected Services. Many Tweedo Services allow you to connect with external systems or databases that may contain information on your relationships, such as “connections” on social networks or other platforms.
• Communication MetaData. Certain Tweedo Services may infer relationship information based on communication patterns. For example, any time communication is initiated within a Tweedo application, we may collect communication metadata including the individual contacted, the time, and the length or duration of the communication. We may similarly collect communication metadata from services you have elected to connect to Tweedo, such as email providers. In some cases, communication metadata may be collected directly from a device. We will not process the content of the communication unless you have explicitly asked us to do so (e.g., for purposes of contact extraction).
• Appointment Data. If you have connected a calendar or scheduling service to Tweedo, we may collect information such as the appointment time, location, duration, and participants.
1.4 Information We Receive from Third Parties.
We may receive information that others provide about you when they use the Services (through Contacts provided to us as described above), or obtain information from other sources, including but not limited to public or licensed APIs (“Public Data”), and combine that with information we collect through the Services. We do not control, supervise, or respond for how the third parties providing your information process your Personal Data.
• Analytics. We may collect and allow third parties to collect information about how you use and interact with our Site and Services. Examples of third-party providers of analytics and similar services we currently use include:
— Google Analytics and Facebook Analytics. Used to track site statistics and user demographics, interests and behavior on websites. Firebase, another Google service, is used on some of our mobile apps to track the effectiveness of our marketing campaigns and advertisements. We also use Google Search Console to help understand how our website visitors find our websites and to improve our search engine optimization.
— Rollbar; Crashlytics (Fabric). Used to help us better understand usage of Tweedo’s mobile apps to improve user experience and to identify and resolve the root causes of app crashes. We recommend you read Crashlytics’ privacy policy, and Rollbar’s privacy policy for more information about how these services use and process data, including Personal Data.
• Third Party Services. If you link, connect, or login to your Tweedo Account with a third party service (For Example: Google), the third party service may send us information such as your registration and profile information. This information varies and is controlled by that service or as authorized by you via your privacy settings in that service.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic or interests data, from third party service providers and/or partners, and combine that information with information we have about you. We may receive information about you and your activities whether as part of or outside our Services through partnerships, or about your experiences and interactions from our partner ad networks.
2. HOW WE USE INFORMATION
We use, store, and process information, including Personal Data, to provide, improve, and develop our Services, create and maintain a trusted and safer environment, and comply with our legal obligations.
2.1 Provide, Maintain, and Support the Services
Using the information we collect, we are able to deliver the Services to you and honor our Terms of Use. For example, we may process your Contacts to provide you with the contact management features you select, including but not limited to Contact storage, backup, editing, synchronization, deduplication, search, tagging, sharing, and segmentation.
Relationship information may be used for relationship management services including determining, classifying, and ranking relationships, as well as recommending communication actions, appointments, or new connections. Relationship information may also be used to improve certain contact management functions such as deduplication, tagging, and segmentation.
We also need to use the information you provide (including Personal Data) to facilitate the creation of and secure your Account on our network, identify you as a user in our system, provide improved administration and quality of experience of our Site and Services, send email, call, or send SMS text messages to you to verify ownership of the email address or phone number provided when your Account was created, send you service, support or maintenance messages, updates, security alerts, and Account notifications. Your information may also be used for the detection and prevention of fraud, spam, abuse, and other harmful activity, and for any purpose you authorize at the time of collection.
Additionally, to provide you technical support, we may need to review your Account and the contents of your Account to identify, research, troubleshoot, and resolve any issues that you report to us or that we otherwise become aware of.
2.2 Improve, Personalize, and Develop the Services
We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services.
2.3 Provide, Personalize, Measure, and Improve our Services
We use, store and process information about you, allowing us to provide a trusted, safe and quality-driven service. Additionally, it aids in further development of our Services.
– We enables you to access and use our Services.
– Make it possible for you to communicate with other members of the Service.
– By conducting research and analytics, it allows us to protect, operate, and improve the Services.
– Provide the best customer service.
– Through the our Services, at your request we may send you support messages, or updates, security alerts, and account notifications.
– In order to make referrals easier, or for fraud detection/prevention, you can share your contacts’ information with us.
2.4 Develop and Maintain a Safe Environment. – We will always try our best to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity
– We also conduct investigations and risk assessments.
– We make sure to verify and authenticate information or identification that is provided to us. This is very important for us.
– We conduct analysis against databases and other sources of information.
– We make sure to comply with our legal obligations.
– We try our best to resolve any issues revolving around our users and we enforce our agreements with third party entities.
– We enforce our Terms of Use and Tweedo Privacy Policy.
2.5. Combine Contacts Across Users
By selectively combining your Contacts and relationship information with information from other Tweedo users we can provide you and other users with enhanced features and Services. Your Contacts may be combined with other Users’ Contacts, as well as Public Data and other publicly available information and information we receive from third parties, to build more complete contact records of individuals (“Completed Contact Data”). Completed Contact Data reside in the Tweedo Database and may be processed for the purposes described in the remainder of this section.
Completed Contact Data may be used to provide you and other Users of our Services with enhanced deduplication. Deduplication is a service that cleans up Contacts by automatically merging duplicate Contact records. The deduplication service relies on making associations between different Contact elements. For example, you might have two Contacts for the same individual in your address book or in your Customer database or file: one Contact that contains just a first name and a phone number, and a second Contact that contains a full name and an email address only. In order to determine whether those two Contacts represent the same individual and should be merged, we look at the Completed Contact Data for that individual. If, in this example, both the phone number and the email address exist within Completed Contact Data for that individual, we may automatically merge (or suggest you to merge) your two Contacts.
In the above example, we may have learned of the linkage between the phone number and email address from publicly available sources. In other cases, we may have been able to infer the linkage or we may have learned the linkage from one or more other Users of our Services who have contributed a Contact that contains those two contact elements together. In this way you are benefiting from information that other Users of our Services have contributed to Completed Contact Data. Similarly, contributing your information to Completed Contact Data benefits other Users of our Services. Relationship information from you and other Users of our Services may also be used in providing enhanced deduplication. For example, the fact that two Contacts in your address book contain the same first name may increase the chances that those Contacts represent the same individual.
We also use Completed Contact Data to provide Contact Search, such as when an User of our Services wants to retrieve a set of Completed Contact Data based on a set of search criteria. With the exception of the shareable contact elements described above, all contact elements in a Completed Contact are considered private and are not shared with other Users of our Services. However, any contact element (including those private elements) may be used for lookup and matching purposes.
3. HOW INFORMATION IS SHARED
3.1 When You Consent, Agree or Direct Us to Share
You may authorize us to disclose your information to others, such as when you connect a third party application or website to access your Tweedo Account, when you participate in promotional activities conducted by Tweedo partners or third parties or when you exercise consent as requested in the use of our Services.
3.2 Sharing Between Users
To provide our Services, we may need to share certain information with other Users of our Services, as it is necessary for the adequate performance of the contract between you and us and for performance of certain features of our Services based on our legitimate interest. Examples include, but are not limited to, sharing information through our Tweedo for Teams products as well as information contributed to our Database for the purposes of improving the Services for both you and other End Users and Developers (as described in Section 2).
3.3 Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protection of Yours or Our Rights
Regardless of any choices you make regarding your Personal Data (as described below), Tweedo may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with applicable laws, including laws outside your country of residence; (c) to respond to requests from public and government authorities (including authorities outside your country of residence) or to respond to subpoenas or warrants served on Tweedo; (d) to protect or defend the rights or property of Tweedo and/or that of you or other End Users or Developers; and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use. In addition, under certain applicable laws, individuals may have the right to require that we disclose to them their information (including Personal Data) that we store in our Database. Tweedo will make such disclosures required by law, but we will not disclose you as the source of that information unless required by law.
3.4 Service Providers
Tweedo uses a variety of third party service providers to help us provide our Services. These Service providers may be located anywhere worldwide in countries outside your country of residence. In particular, currently use service providers based in Europe, India, Asia Pacific and North and South America.
In order to facilitate payments for Services we provide, certain information as described above may be shared with the relevant payments service providers. This data sharing is necessary for the performance of the contract between you and us.
These service providers may have limited access to your information as necessary to perform these services on our behalf, and are contractually bound to protect and to use your information only for the purposes for which it was disclosed and consistent with this Privacy Policy.
Tweedo may need to share your information in order to deliver the Services to you and honor our Terms of Use. 3.5 Corporate Affiliates
In order to provide our Services, your information may be shared within our corporate family of companies (including financial and non-financial entities) that are related by common ownership or control. This entities are covered by this Privacy Policy and if/when these services have any additional claus specific to them, we will make you aware of them via our Services.
All information shared is saved at the Tweedo inc. headquarters located in Lewes, Delaware, USA. The types of information that will be saved includes when you create an Experience, book a Local’s Experience, or find a travel buddy. The information shared in these circumstances includes:
(i) your full name, email address and phone number,
(ii) information relating to the Experience,
(iii) information contacts that you have added.
We will notify you in advance in the above situations if anything were to change via our Services.
3.6 Social Media Platforms
In addition to the information you choose to provide us with, we also collect information from other third party sources and/or services. We are not responsible for the way in which these third parties may disclose your information and we do not comply to any of their terms.
When linking/connecting or logging into your Tweedo account via a third party service (i.e. Facebook, Google), these third party services will share your registration and profile information from that service with us. The type and amount of information provided to us varies and is completely controlled by those parties and as authorised by you, in your privacy settings in that service.
Please note that you may, at any time ask Tweedo to cease processing your Personal Data by sending an email to: info@tweedo.io
3.7 Business Transfers
If at any point in time, Tweedo inc. is involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy event, We may be forced to sell, share or transfer some, if not all, of our assets. Within these assets, your information is included. In the case that this happens, we will bring this up to your attention, before your personal information is transferred and has to adhere to a different Privacy Policy.
3.8 Aggregated Data
For business purposes such as demographic profiling, industry analysis, marketing and advertising, We may combine information about our users, so that they are no longer identifiable individual users, but instead a group of users that share similar characteristics.
4. DATA RETENTION
We generally retain your information for as long as is necessary for the performance of the Services to you and our other Users and to comply with our legal obligations. This includes information that you have made available to the Tweedo Database for the purposes of improving the Services for both you and other Users of our Services (as described in Section 2).
You may request that we delete your information and close your Tweedo Account or you can delete your End User Contact Data and close your Account on your own. Please note that if you request the deletion of your information or if you delete your information:
• We may retain some of your information as necessary for fraud detection and prevention and enhancing safety. For example, if we suspend a Tweedo Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user from opening a new Tweedo Account in the future.
• We may retain and use your information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, and auditing obligations.
• Information you have shared with other systems (e.g., Google) may continue to exist in those systems, and in some cases be publicly visible.
• Some copies of your information (e.g., log records) may remain in our Database but are disassociated from personal identifiers.
• Because we maintain backup to protect our Services from accidental or malicious loss and destruction, residual copies of your information will be included in backups and may not be removed from our backup systems.
5. THIRD PARTY WEBSITES
When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites, or the manner in which they collect, use and handle information or content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.
6. MINORS
Our Services are not intended for or designed to attract anyone under the age of 18 (“Minors”). We don’t intentionally or knowingly collect personal information regarding Minors and our Terms of Use explicitly prohibit the use of our Services by Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without such parent or guardian’s consent, he or she should contact us. We will then delete such information from our Database.
7. DATA PROTECTION
7.1 Security
We are continuously implementing and updating appropriate technical and organizational measures to help protect your Personal Data against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your Personal Data are firewalls and data encryption, and information access controls. If you know or have reason to believe that your account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the “Contact Us” section below.
7.2. Our International Operations and Data Transfers
To bring you our Services, we operate globally. We may transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia and North America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the European Economic Area (the “EEA”) may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy.
7.3 EU-US and Swiss-US Privacy Shield
Tweedo Inc. complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States, respectively. Tweedo 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.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, Tweedo is subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at: Tweedo, Inc., Legal Department, 1200 17th St., Denver, CO 80202 or via email info@tweedo.io. If we are not able to resolve your concern, you may also contact our designated Privacy Shield independent dispute resolution provider, BBB EU Privacy Shield. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.
8. YOUR RIGHTS
8.1 Email Choices
We offer you choices regarding the collection, use, and sharing of your Personal Data. If you are a User of our Services , we may periodically send you free newsletters and emails that promote our Site or Services as well as products or services we think you may be interested in. When you receive such promotional newsletters or communications from us, you may indicate a preference to stop receiving them from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.
8.2 Access, Correction, and Deletion
Tweedo allows any data subject, including the End Users of our Services, to access, modify, and set permissions with respect to Personal Data that it holds about them. You and any data subject may access and make corrections and choices about their Personal Data by sending an email to info@tweedo.io.
Please note however that, if you request that we delete your Personal Data, we will not do so to protect your rights and freedoms because, if we do, another user may later upload your contact information and we will not have a record that you requested that your contact information be deleted. Instead of deleting your End User Contact Data from the Tweedo Database, we will retain it but flag it, restrict any further processing and not use or share it with any third parties. Finally, Tweedo provides you with the ability to export your Personal Data, End User Contact Data or Completed Contact Data from some of our Services at any time using industry standard formats.
Further information for data subjects can be found at Privacy Policy.
8.3 California Privacy Rights
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses that share customer personal information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. Alternately, such businesses may have in place a policy not to disclose a customer’s personal information to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As described in Section 8.2 of the Privacy Policy, you can opt-out of our sharing of your personal information with anyone (including with third parties for the third parties’ direct marketing purposes) by sending an email to info@tweedo.io. To find out more about your opt-out rights, please contact us at the address listed in Section 11 of the Privacy Policy. Please note that under California law businesses are only required to respond to a customer making such a request once during any calendar year.
9. For EU citizens.
In the Use of our Services we mainly act as data processor and, in some cases, we may act as data controller when we determine the purposes and means of the processing of Personal Data.
EEA residents may exercise any of the rights described in this section by using the applicable functionality in our Services or by contacting us directly. If you reside outside of the European Union, you may have similar rights under your local laws. Please note that we may ask you to verify your identity before taking action on your request.
9.1 Purposes and Legal Basis for Processing.
The purposes for processing are described in detail in Section 2 (“HOW WE USE INFORMATION”). In the Use of our Services when we act as data controller the legal basis for processing is as follows:
• Provide and Maintain the Services (Section 2.1): This enables us to deliver the Services to you and honor our Terms of Use in the performance of a contract.
• Improve, Personalize, and Develop the Services (Section 2.2): This use is based on our Legitimate Interest in improving our services for you and other users.
• Provide, Personalize, Measure, and Improve our Services(Section 2.3): This use is based on our Legitimate Interest in our Services.
• Combine Contacts and Relationship Information Across Users (Section 2.6): This use is necessary to deliver certain Services to you and is based on your explicit Consent.
9.2 Categories of Recipients of Data.
Recipients of data are detailed in Section 3 (“HOW INFORMATION IS SHARED”).
9.3 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete Personal Data concerning you (and which you cannot update yourself within your Tweedo Account).
9.4 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your Personal Data held by us. You may also be entitled to request copies of Personal Data that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
9.5 Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your Personal Data by Tweedo you may easily withdraw your consent at any time specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Data, in particular where (i) you contest the accuracy of your Personal Data; (ii) the processing is unlawful and you oppose the erasure of your Personal Data; (iii) we no longer need your Personal Data for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 9.2.6 below (“Objection to Processing”) and pending the verification whether the legitimate grounds of Tweedo override your own.
9.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require Tweedo not to process your Personal Data for certain specific purposes, where such processing is based on legitimate interest. If you object to such processing we will no longer process your Personal Data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defence of legal claims.
Where your Personal Data is processed for direct marketing purposes, you may, at any time, ask us to cease processing your Personal Data for these direct marketing purposes by sending an email to: info@tweedo.io.
9.7 Lodging Complaints.
You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities. If you are a EEA resident, you have the right to file a complaint with your applicable data protection authority.
10. CHANGES TO THIS PRIVACY POLICY