Privacy Policy
Last Revised: (7/5/2024)
Introduction
TwistoPlast Ltd. (“TwistoPlast”, “we”, “our” or “us”) respect the privacy of our users (each, "you" or "User") and are committed to protect the privacy of Users who access, engage, use, download, install or register to our mobile application (the "Application"), or any other online services we provide (collectively: the "Services").
Our privacy policy ("Privacy Policy") will help you understand what types of information we collect through the Services, how the Company uses it, and what choices you have. We encourage you to read this Privacy Policy carefully and use it to make informed decisions. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy.
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services.
This Privacy Policy is integrated into and forms part of TwistoPlast's Terms of Use and is incorporated therewith by reference. Wise Breeze - User Agreement
We want to inform you that our Application operates on a third-party platform provided by Tuya Inc. As such, our App, Services and any Prenosal information provided by you is subject to Tuya’s privacy policy and ts guidelines, which can be found on their website Service Agreement&Privacy Policy (tuya.com).
Please note that the third-party provider's privacy policy may be updated from time to time, and it is your responsibility to stay informed by reviewing it periodically. While we, strive to ensure compliance with privacy laws and regulations in our use of their platform, we do not have direct control over changes made to their privacy policy.
When you register with your Personal Data or using the Services, and do not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. By using the App, you acknowledge that you fully understand and agree to the terms described herein. If you have any questions regarding this Policy, please contact us at:
support@wisebreeze.com
If you are in the European Union / United Kingdom, you may address privacy-related inquiries to our EU / UK representative pursuant to Article 27 GDPR:
EU: EU-REP.Global GmbH, Attn: Twitoplast, Hopfenstr. 1d, 24114 Kiel, Germany
UK: DP Data Protection Services UK Ltd., Attn: Twitoplast, 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom
twitoplast@eu-rep.global
www.eu-rep.global
We also have assigned a Data Protection Officer (DPO). Our DPO is Twitoplast LTD.
Wisebreeze CTO: David Twito.
If you have any questions or concerns regarding this Privacy Policy or our privacy practices, including the processing of your personal information, if you would like to exercise your data rights under applicable laws, or if you believe your privacy rights have been violated, you can also contact our DPO at dudi@twitoplast.co.il
In this Privacy Policy, you will read about, among other things:
What type of information we collect
How we use the information
With whom we share the information and for what purpose
International transfer
For how long we retain the information
Your privacy rights
How we protect your information
Minors
How to contact us
What information we collect:
We may collect un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services ("Non-personal Information"). We are not aware of the identity of the user from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time, the website's domain name from which you linked to the Services, etc.). We may use this information in order to administer the Services and analyze this information to improve and enhance the Services by expanding their features and functionality. Such information may also be used for troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, online browsing, etc.).
For the avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
Personal Information
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information may include:
1.Registration Information: When signing-up or registering to our Services, we may collect certain information that can be used to identify you. In this regard, we may collect the following information: full name, email address, address, phone number, age, videos, photos, as well as other relevant details that you agreed to share with us. During your interaction with our App, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account. If you choose to log in, access or otherwise connect to the Services through a social networking service or a single sign on service (such as Facebook, Twitter, Instagram, Google, Apple etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access.[Nir: the second paragraph is relevant YES FOR NOW ]
  1. Voluntary Information: We may collect information that you provide us voluntarily such as Information based on additional functions:
    • In order to offer you with more convenient and higher-quality services with optimized user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, if you do not provide such information, you may continue to use basic services of the App and connected smart devices, but certain features based on these additional functions may not be available. [Nir please confirm this is accurate: CONFIRMED] These additional functions may include: When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with other smart devices.
    • Personal Information that you provide to us while connecting our technical support team through email or any othermeans of communication.
3.Service Use Information: We may collect information that you provide usus during your use of the Services. This includes, inter alia, photos, videos, communications with us or other users, feedback, suggestions, complaints and reports that you send to us.
  1. Information we Collect Automatically
    • Usage Data:During your interaction with our App, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Appand Services.
    • Log Information:When you use the App, in order to improve your user experience, the system and exception log may be uploaded, including your IP address, language preference setting, operating system version, date or time of access, so that we can facilitate and accurately identify problems and help you solve them in timely manner.
  2. Information we collect via technologies
    • While using the Services we will access, collect process, monitor and remotely store “geolocation data” including through the collection of IP addressand other similar information to determine your location for analytics and security purposes.
    • As part of your use of the Services you may choose which home application, air condition systems and other “smart devices” you wish to pair with the App . We will maintain a registry of all devices paired with the App and may store certain technical information derived from such use of the App in connection with such paired devices.
**With respect to Personal Information, the Company will act as a "data controller" and will handle such information in accordance with the provisions of this Privacy Policy and applicable law.
YOU ARE UNDER NO LEGAL OBLIGATION TO AGREE TO THE COLLECTION OF SUCH PERSONAL INFORMATION OR TO DELIVER THE PERSONAL INFORMATION TO US AND THE DELIVERY OF THE PERSONAL INFORMATION IS DONE WITH YOUR OWN FREE WILL AND CONSENT. HOWEVER, YOU AGREE THAT WITHOUT THE COLLECTION OR DELIVERY OF THE PERSONAL INFORMATION WE MAY NOT BE ABLE TO OFFER YOU OUR SERVICES NOR THAT YOU WILL BE ABLE TO USE ALL OF THE FUNCUNALITIES, SERVICES OR CONTENT OFFERED BY THE APPLICATION.
How we use the information
We use the information in the manners described in this Privacy Policy. In addition to the purposes listed herein, the information we collect, which may include your Personal Information, is used for the following purposes:
·To investigate and resolve disputes in connection with your use of the Services;
·To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority,or to comply with a subpoena or similar legal process or respond to a government request.
[Nir please review the list above and confirm /amend /delete CONFIRMED]
With whom we share the information and for what purpose
We do not rent or sell any Personal Information. We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) trusted subcontractors and third-party service providers; and (v) any potential purchasers or investors in the Company.
We may also share Personal information with vendors, commercial software providers, consultants and data processers who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the App. Please note that we collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction.
We may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations; and (iii) performing research, technical diagnostics, personalization and analytics that will enable us to improve the Services.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.
Third-party collection of information
Our Privacy Policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.
You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.
Cookies and other tracking technologies
When you access or use the App, we or our third-party service providers may useindustry-wide technologies such as “cookies", Ad-id, or other similartechnologies which store certaininformation on your computer or device("Cookies"), which will allow us to, gatherinformation and enable automaticactivation of certainfeatures thus makingyour experience much more convenientand effortless. We or our authorized third-party service providers may use bothsession cookies (which expire once youclose the App) and persistent cookies (which stay on your system until youdelete them). It is easy to disable or deleteCookies. Most browsers will allow you toerase cookies from your computer's harddrive, block acceptance of cookies, orreceive a warning before a cookie is stored.Note that Cookies usually store only a NonpersonalInformation, such as the webpages you have visited, the duration ofyour browsing, etc. We do notcontrol such third-party service providers.
International transfer
Please note that our operations, partners, and service providers are global. The information we collect, including Personal Information, may be stored and processed in various jurisdictions worldwide. These locations may not offer the same level of data protection as your home country. In such instances, we ensure the use of applicable safeguards and legal mechanisms to align with data protection law.
For how long we retain the information
We retain the information that we collect from our users for as long as it is relevant based on the purpose it was collected for. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we may keep records containing Users' Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish, or remove incomplete or inaccurate information, at any time and at our own discretion.
Your privacy rights
Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:
●Right to verify your Personal Information (to access, delete, change, or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
●Right to see what Personal Information about you we have;
●Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
●Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
●Right to export Personal Information in a portable format.
If you wish to exercise any of these rights, contact us at DPO's email above. When handling your request, we may ask for additional information to confirm your identity (which may include Personal Information).
How we protect your information
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the confidentiality, integrity, and availability of your information, the safety of your Personal Information and prevent unauthorized use of any such information.
However, we cannot guarantee that hackers or unauthorized personnel will not gain access to information despite our efforts. You should note that by using our Services, your information would be transferred through third-party infrastructures that are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security, and we make no warranty, express, implied or otherwise, that we will prevent unauthorized access to our Services.
Updates or amendments to the Privacy Policy
We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our Application (as reflected in the "Last Revised" heading). In the event of a material change to the Privacy Policy, we will notify you through the Services or via email, or you may be notified within the Application. We encourage you to review this Privacy Policy regularly for any changes.
Your continued use of the Services, following the notification of such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
Other
Minors. The App is not designed for or directed at children under the age of 16 years old (“Minors”). If you are a Minor, you should not register or provide Personal Information through the App. We do not knowingly collect Personal Information from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, they should contact us using the details provided above. If we later obtain actual knowledge that a user is under 16 years of age, we will take steps to remove that user’s Personal Information from our systems
Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: support@wisebreeze.com
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.