We guarantee that:
We process your data exclusively for the delivery, improvement, and assurance of the services we offer;
Your data is securely stored in a safe environment;
Personal data is strictly confidential and will not be shared with third parties.
We use the data we collect for:
– Providing and managing services, including displaying personalized content and facilitating communication with other users;
– Facilitating the technical operation of services, including troubleshooting, service assurance, and preventing fraud and abuse;
– Sending administrative messages and information, notifications about changes to our services, and updates to our agreements;
– Sending information and messages regarding progress in benefits, new services, new features, promotions, informational messages (from which you can unsubscribe at any time);
– Requesting feedback and understanding your needs with the help of analytics service providers;
– Identifying unique users;
– Improving our services and developing new products, services, and features;
– Analyzing trends and website traffic or promoting our services on websites and applications.
The European Union's General Data Protection Regulation (referred to as "GDPR") entered into force on May 25, 2016, but became applicable starting May 25, 2018.
Protecting your personal data is important to us; therefore, we pay special attention to protecting the privacy of visitors who access the website www.itwistcorporation.com, in accordance with Regulation (EU) 2016/679 of the European Parliament and Council dated April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as "GDPR").
Please pay special attention to reading the following Personal Data Protection Policy.
The Personal Data Protection Policy explains the practices of ITwist Corporation regarding the application of GDPR provisions and your rights concerning how your information is used through the website www.itwistcorporation.com.
The processing of personal data by ITwist Corporation will always be conducted in accordance with the provisions of GDPR as well as with specific personal data protection regulations of each country where ITwist Corporation operates.
Through the Personal Data Protection Policy, ITwist Corporation aims to inform visitors about the nature of the personal data we collect and process, as well as the purposes of processing.
Additionally, website visitors are informed through the Personal Data Protection Policy about the rights they benefit from.
WHAT IS PERSONAL DATA?
"Personal data" means any information or set of information that can directly (for example, your name) or indirectly (for example, through pseudonymized data such as a unique identification number) identify you.
This means that personal data includes information such as address, full name, gender, date and place of birth, civil status records, phone/fax, address (home/residence), email, profession, workplace, professional training, family situation, financial situation, data regarding owned assets, habits/preferences/behavior, image, voice, personal preferences, shopping habits, user-generated content, financial information, and financial status information.
It may also include unique numeric identifiers such as the IP address of your computer or the MAC address of your mobile device, as well as cookies.
WHAT DOES THE PROCESSING OF PERSONAL DATA MEAN?
"Processing" means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
THE LEGAL BASIS AND PURPOSES FOR THE PROCESSING OF PERSONAL DATA
• For the purpose of concluding and executing contracts – According to Article 6(1)(b) of the GDPR, personal data can be processed for the purpose of concluding or executing a contract. In order to provide you with our services, we need to process your personal data.
• For the purpose of fulfilling legal obligations – According to Article 6(1)(c) of the GDPR, personal data can be processed to fulfill legal obligations. We request a series of personal data, including, in certain situations, your personal identification number, in order to fulfill obligations imposed by tax authorities related to invoicing and reporting.
• For marketing purposes – According to Article 6(1)(a) of the GDPR, personal data can be processed if the data subject has given their consent for processing for one or more specific purposes.
PRINCIPLES REGARDING DATA PROCESSING
ITwist Corporation undertakes to respect the principles of personal data protection (hereinafter referred to as "Principles") provided by the GDPR to ensure that all data are:
Processed lawfully, fairly, and transparently;
Collected for specified, explicit, and legitimate purposes;
Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
Accurate and kept up to date;
Stored in a form that permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
Processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
WHAT TYPE OF PERSONAL DATA DO WE COLLECT
Personal data means any information about you that allows us to identify you, such as your name, contact details, booking reference number, payment details, and information about your access to our websites.
We may collect personal data from you when you use the website www.itwistcorporation.com and other websites accessible through it, when you participate in a survey or contest, or when you contact us.
Specifically, we may collect the following categories of information:
Name, home address, email address, phone number, city;
Detailed information about participants, including name, date of birth, gender, ID card number;
Information about your purchases of services;
Information about your use of our website;
Communications you make with us or direct to us through letters, emails, chat services, calls, and social media;
Location, including the real-time geographic location of your computer or device via GPS and your IP address, along with Wi-Fi hotspot and GSM locations if you use location-based features and enable location services on your device and computer.
Personal details about physical or mental health are considered "sensitive" personal data under applicable data protection laws. We will only process such data if you have given explicit consent or if necessary (for example, if you request special assistance) or if you have deliberately made such data public.
WHAT DATA WE NEVER STORE
The Client's/User's/Buyer's payment card data will not be accessible to or stored by ITwist Corporation, but only by the entity authorizing the Transaction or another entity authorized to provide card data storage services, about which the Client/User/Buyer will be informed prior to entering the data.
3D Secure represents a new global approach to authenticating buyers and sellers in secure online transactions. This security measure involves redirecting the user at the time of payment to a secure page, where each cardholder's registration is completed by assigning an authorization code for each online transaction. Cards accepted for payment are those issued under the VISA (Classic and Electron) and MASTERCARD (including Maestro, if they have a CVV/CV2 code) logos.
WHAT WE USE YOUR PERSONAL DATA FOR, WHY, AND FOR HOW LONG
Your data may be used for the following purposes:
To provide the services you request: we use the information you provide to perform the services you have requested regarding your participation, including requested changes related to courses;
To contact you in case of schedule changes or cancellations: we send you information regarding the services you have requested and any changes to these services. This information is not for marketing purposes and you cannot unsubscribe from it;
We use your payment information for accounting, billing, and audit purposes and to detect and/or prevent any fraudulent activity;
For administrative or legal purposes: we use your data for statistical and marketing analysis, system testing, customer satisfaction studies, maintenance and development, or to resolve a dispute or claim.
Please note that we may conduct data profiling based on the data we collect from you for statistical and marketing analysis purposes. Any profiling activity will only be carried out with your prior consent and by making every effort to ensure that all underlying data is accurate.
By providing any personal data, you explicitly agree that we may use it to conduct profiling activities in accordance with this Privacy Policy;
Security, health, administration, crime prevention/detection: it is possible that we may transmit your information to government authorities or law enforcement agencies to comply with legal requirements;
For customer service communications: we use your data to manage our relationship with you as a client and to improve our services and your experience with us;
To provide personalized services: we use your data to provide information that we believe you will find interesting before, during, and after your participation and to personalize the services we offer you.
We will only process your personal data if we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data.
We may also process your personal data in one or more of the following cases:
• To comply with a legal obligation (e.g., accounting requirements);
• You have given your consent for the use of your personal data (e.g., for marketing purposes);
• To protect your vital interests or those of another person (e.g., in the case of a medical emergency);
• As part of our legitimate interests in operating as a marketing agency (e.g., for administrative purposes).
Only children aged 16 or older can give their consent. For children under this age, parental or legal guardian consent is required.
We will not retain your data longer than necessary to fulfill the purpose for which it is processed. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process the data, and whether we can achieve those purposes by other means.
We must also consider the periods for which we might need to retain personal data to meet legal obligations or to deal with complaints, inquiries, and protect our legal rights in case of a claim.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider whether and how we can minimize the amount of personal data we use over time and whether we can anonymize your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
DATA RETENTION PERIOD
ITwist Corporation may retain processed data for different periods considered reasonable, in accordance with the purposes mentioned above. We retain your data only for as long as necessary to achieve the purpose for which we hold the data, to meet your needs, or to fulfill our legal obligations.
To determine how long your data may be kept, we use the following criteria:
When you purchase products and services, we retain your personal data for the duration of our contractual relationship;
When you participate in a promotional offer, we retain your personal data for the duration of the promotional offer;
When you contact us with a question, we retain your personal data for the time necessary to process your inquiries, but no longer than 5 years from the last correspondence sent;
When you have given consent for marketing, we retain your personal data until you unsubscribe or request its deletion or after a period of inactivity (without active interaction with our brands), defined in accordance with local regulations and guidelines. In this regard, we mention that data stored in our databases for direct marketing communication purposes is deleted from these records 5 years after the last interaction with you;
When cookies are stored on your computer, we keep them as long as necessary for their purposes and for a period defined in accordance with local regulations and guidelines.
In this regard, we mention that data processed via cookies used to deliver online behavioral advertising, to personalize our services for you, and to enable sharing our content on social media platforms (sharing buttons intended for displaying the site) will be retained for a maximum period of 5 years from the time of collection, based on your consent.
DATA PROCESSING SECURITY
ITwist Corporation has adopted technical data processing measures, updated in accordance with GDPR requirements, to protect your personal data against any unauthorized access, improper use or disclosure, unauthorized alteration, accidental destruction, or loss.
All ITwist Corporation members and collaborators, as well as any third parties acting on behalf of ITwist Corporation, are obligated to respect the confidentiality of your information and the requirements of GDPR, in accordance with the provisions of this Policy.
SECURITY OF YOUR PERSONAL DATA
We follow strict security procedures in storing and disclosing your personal data and protecting it against loss, accidental destruction, or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry-standard method for encrypting personal information and data so that they can be safely transferred over the internet.
All registration details are transmitted via an SSL connection and are stored in accordance with Data Security Standards.
We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures to protect your personal data, in accordance with Irish and EU data protection laws.
PROCESSING OF CONTACT OR REGISTRATION FORMS
ITwist Corporation will use the information you provide in the corresponding contact section on the website exclusively for the purpose of processing your request.
By providing any personal data via the website www.itwistcorporation.com, you understand and agree that your data will be processed in accordance with ITwist Corporation's Personal Data Protection Policy.
Please note that in order to process your requests submitted via the registration section, we may, in certain circumstances, be required to transmit your data to ITwist Corporation’s partners and/or other third-party service providers with whom ITwist Corporation collaborates.
However, ITwist Corporation has adopted appropriate technical measures to ensure the security of data transfer, as well as the processing of your data in accordance with GDPR requirements by the aforementioned entities.
ITwist Corporation undertakes not to process the personal data provided for any other purpose than that for which they were transmitted, except in cases where we have your explicit consent to use them for other purposes.
RELATIONS WITH OTHER OPERATORS
Depending on the context, we may find ourselves in the absolute necessity to provide information at a higher level, both globally and internally or externally, to our partners and those to whom we transfer data, in compliance with the above-mentioned Regulation, in order to ensure the provision of the highest professional level of services. Information controlled by ITwist Corporation may be transferred, transmitted, or stored and processed within the EU or in countries other than the country where you reside, for the purposes described in this policy. These data transfers are necessary to provide high-level services and to continue to deliver our materials at the best professional level.
AUTOMATED DATA PROCESSING. COOKIE
The website www.itwistcorporation.com uses Cookie identifiers. In this regard, you can consult our Cookie Policy below and exercise your right to disable Cookies.
DATA SUBJECTS' RIGHTS
In accordance with the GDPR, you have several rights regarding the personal data processed by ITwist Corporation:
Right of access to the processed data – You have the right to access the personal data we hold about you.
Right to rectification – You have the right to request that your data be corrected if it is inaccurate or outdated and/or completed if it is incomplete.
Right to erasure ("right to be forgotten") – In some cases, you have the right to obtain the deletion or destruction of your data. This is not an absolute right as there may be situations where we are legally or contractually required to retain your data.
Right to restriction of processing – You have the right to request the restriction of your data processing. This means that the processing of your data is limited so that we can store it but not use or process it. This right applies in specific circumstances provided by the GDPR, namely:
– the accuracy of the data is contested by the data subject (i.e., you), for a period allowing the controller (i.e., ITwist Corporation) to verify the accuracy of the data;
– the processing is unlawful and the data subject (i.e., you) opposes the erasure of the data and requests the restriction of their use;
– the controller (e.g., ITwist Corporation) no longer needs the data for the purpose of the processing, but they are required by the data subject (i.e., you) for the establishment, exercise, or defense of legal claims;
– the data subject (i.e., you) has objected to processing based on the legitimate interests pursued by the controller (in this case, ITwist Corporation) pending the verification of whether the legitimate grounds of the controller (ITwist Corporation) override those of the data subject (i.e., you).
Right to data portability – You have the right to move, copy, or transfer the data you are interested in from our database to another. This applies only to data you have provided when the processing is based on your consent or a contract and is carried out by automated means.
Right to object – You can object at any time to the processing of your data where such processing is based on legitimate interest.
Right to withdraw consent at any time – You can withdraw your consent regarding the processing of your data whenever the processing is based on consent. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal.
Right to lodge a complaint with the competent supervisory authority – You have the right to lodge a complaint with the data protection authority in your country of residence or domicile to challenge ITwist Corporation’s data protection practices.
Right to object to the processing of your data for direct marketing purposes – You can unsubscribe or opt-out of our direct marketing communications at any time.
Right to object to the processing of your data by us when performing actions in the public interest or in the legitimate interests of ours or a third party – You can object at any time to the processing of your data when such processing is based on a legitimate interest.
Right to disable Cookies – You have the right to disable cookies. Internet browser settings are usually configured by default to accept cookies, but you can adjust them easily by modifying your browser settings.
You can exercise these rights, either individually or cumulatively, very easily by simply sending a request via email to: office@itwistcorporation.com.
LEGAL REQUESTS
We access, preserve, and share your information with regulatory authorities, law enforcement agencies, or other entities:
In response to a legal request when we, in good faith, believe the law requires us to do so. We may also respond to legal requests when we, in good faith, believe that the response required by the laws of the relevant jurisdiction affects users in that jurisdiction and is consistent with internationally recognized standards.
When we, in good faith, believe it is necessary to: detect, prevent, and address fraud, unauthorized use of any of our materials, breaches of our terms or policies, or other harmful or illegal activities, to protect ourselves (including our rights, property, or materials), you, and others, including during investigations or inquiries by regulatory authorities, or to prevent imminent death or personal injury. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse, and other harmful activities both on and off our materials.
Information we receive about you may be accessed and stored for a longer period when it is the subject of a legal request or legal obligation, a government investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
DISCLAIMER
The website www.itwistcorporation.com may contain links to other websites and/or web pages that are not owned by ITwist Corporation. Sapun De Constantanu assumes no responsibility for the content of these websites and therefore cannot be held responsible for the content, advertising, goods, services, software, information, or other materials available on or through these websites.
ITwist Corporation shall not be liable for the loss of personal data, any negative effects on the personal data of visitors, or any moral and/or patrimonial damages caused by access to those websites.
UPDATING THE PERSONAL DATA PROTECTION AND PROCESSING POLICY
Please note that this Policy may be subject to periodic content changes by updating the website www.itwistcorporation.com. We will send you a notification before making any changes to this Policy and give you the opportunity to review the revised content before choosing to continue using our materials.
Please do not continue to use ITwist Corporation websites if you do not agree with such changes. We also recommend that you check this page regularly for updates.
The terms of the Personal Data Processing Policy are interpreted in accordance with applicable law.
CONTACT
If you have any questions or concerns regarding how we handle and use your personal data, or if you wish to exercise any of your rights, please contact us at office@itwistcorporation.com.
