Privacy Policy

Latest Update: Twinkle's privacy policy was last updated on March 15th, 2021

Welcome to https://twinkle.io/, a website (the “Site”) operated by Vidello Ltd. (the “Company”).


WHO WE ARE AND HOW TO CONTACT US


https://twinkle.io/ is a site operated by Vidello Ltd. ("We"). We are registered in England and Wales under company number 10699864 and we have our Registered office address The Retreat, 406 Roding Lane South, Woodford Green, Essex, England, IG8 8EY


To contact us, please email: [email protected] 


Acceptance of Terms

This Privacy Statement describes how Twinkle.io (hereinafter “Twinkle”) manages personal information and respect your privacy. This policy may be amended from time to time. All “Personal Information” (which is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains) that we collect and maintain will be subject to this Privacy Policy, as amended from time to time. 

When we refer to “Twinkle”, we mean the Vidello Ltd. The Retreat, 406 Roding Lane South, Woodford Green, Essex, England, IG8 8EY, GB 268897425, entity that acts as the controller or processor of your information, as explained in more detail in the “Entities Collecting Personal Information” section below.


DPO Information:

We have appointed a data protection officer (DPO) for the TwinkleGroup who is responsible for overseeing questions in relation to this privacy notice. If you have any questions, concerns, or requests about this privacy notice, how we manage your Personal Information, or any other issue relating to your Personal Information, please contact our DPO:

Twinkle

Attn: Data Protection Officer
Mira Dobes

[email protected]


Collection Of Personal Information

When you register to use Twinkle, we may collect the following Personal Information from you:

- Contact information such as your name, phone and fax numbers, address and email address; and

- Billing information such as the number, expiration date, card type and billing address of your credit card;

- Profile data, including your username and password, details about your purchases and the Content that you license from us.


Updating Your Personal Information And Privacy Preferences

You have the right to access and correct, or delete your Personal Information and privacy preferences at any time by contacting our DPO. 


How Your Personal Information Is Used

Twinkle collects your information in order to provide services to you, comply with our legal obligations, and to improve our products and services. We do not sell, rent or share your personally identifiable information to or with third parties in any way other than as disclosed in this Privacy Policy. Twinkle may use this information to:

- Process your financial transactions.

- Send you order / renewal confirmations.

- Respond to customer service requests, questions and concerns.

- Administer your account.

- Keep you informed about special offers and services of Twinkle and selected third parties.

- Administer promotions and sweepstakes you enter and notify you of the results.

- nvestigate, prevent or take action regarding illegal activities and/or violations of our Terms of Service.

- Meet our research and product/service development needs and to improve our Site, services and offerings; and

- Customize your experience, including targeting our services and offerings to you.

We store information that we collect through cookies, log files, transparent images, and/or third party sources to create a summary of your preferences. We tie your personally identifiable information, and/or your membership usage history, to information in the summary, in order to provide tailored promotions and marketing offers, to improve the content of the site for you and/or to determine your preferences.

In certain situations, Twinkle may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Where required by law (e.g., to comply with a subpoena, warrant, court order, or legal process served on Twinkle), and when we believe that disclosure is necessary to protect our rights, avoid litigation, protect your safety or the safety of others, investigate fraud, and/or respond to a government request. We may also disclose information about you if we determine that such disclosure should be made for reasons of national security, law enforcement, or other issues of public importance.


Information Sharing With Service Providers / Agents

Twinkle uses one or more outside credit card processing companies to bill you for our goods and services. To the best of our knowledge, these companies do not retain, share, store or use personally identifiable information for any other purpose.

We also share Personal Information with certain companies that perform services on our behalf. We only share the Personal Information which is necessary for them to perform those services. We require any company with which we may share Personal Information to protect that data in a manner consistent with this policy and to limit the use of such Personal Information to the performance of services for Twinkle. We do not sell or otherwise provide Personal Information to other companies for the marketing of their own products or services.


Data Retention

We will retain your information for as long as your account is active, your information is needed to provide you services, or as required to fulfill our legal obligations. If you wish to delete your account or request that we no longer use your information to provide you services contact us at [email protected] We will respond to your request within 30 days. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Choice / Opt Out

You may “opt out” of receiving Twinkle’s email updates, newsletters and/or partner emails by emailing [email protected] The choice to opt out of such communications is also generally available during the sign-up process. Twinkle will still contact you when there are changes to the Terms of Service. Generally, you may not opt-out of these communications, which are not promotional in nature. If you wish not to receive them, you have the option of deactivating your account.


Protection Of Your Personal Information

The Personal Information that you provide in connection with the use of the Site is protected in several ways.

- Access by you to your account profile is available through a password and unique customer ID selected by you. This password is encrypted. You should strive to use a strong, alpha-numeric password which you should not divulge to anyone.
- Your Personal Information resides on secure servers that only selected Twinkle personnel and contractors have access to via password.

- Your Personal Information is encrypted whenever it is transmitted to Twinkle.

- When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using transport layer security technology.

We strive to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we take into account the sensitivity of the Personal Information we collect, process and store, and the current state of technology to use these measures to protect your Personal Information, we cannot guarantee its absolute security.


Cookie And Tracking Technologies

The Site may automatically collect information as you browse, such as Internet Service Provider, browser type and version, operating system and device type, average time spent on our site(s), pages viewed, information accessed, the Internet Protocol (IP) address used to connect your computer to the Internet and other relevant statistics. Such information is sometimes referred to as web analytics and/or clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, and provide site functionality. A cookie is a small, unique text file that a website can send to your computer when you visit a site. We may use session cookies, which terminate when a user closes his or her browser, and/or persistent cookies, which remain on the user’s computer until manually deleted. Most web browsers can either alert you to the use of cookies or refuse to accept cookies entirely. If you do not want us to deploy cookies to your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie on your computer. Rejecting cookies may affect your ability to use the Site.


Transfers Outside of UK

Where we use certain service providers or share information within the Twinkle Group, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.


Changes In Privacy Policy

Twinkle reserves the right to amend the Privacy Policy from time to time at its sole discretion and will provide notice by email or on the homepage of the Site when we make material changes to this Privacy Policy prior to the change becoming effective. 

Links To Third Party Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of Twinkle. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.



Referral Program Emails

If you choose to use our referral service to tell a friend about our Site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. Twinkle stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.


Children

We do not intend to solicit or collect Personal Information from anyone under the age of 18. If you are under 18, do not enter information on this site or engage our services. If you believe a child of yours under the age of 18 has entered Personal Information please contact [email protected] to have the data removed and terminate the child’s account.

Privacy Complaints

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information.


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We process your personal data as stated in our Privacy Policy. You may withdraw your consent at any time by clicking the unsubscribe link at the bottom of any of our emails.

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