1. How this policy works
This Privacy Policy applies to the collection, use, disclosure and handling of Personal Information by Twine AI Pty. Ltd. and its related entities (“we”, “us”, or “Twine”), including information collected via twine.so (our “website”), product pages, mobile and/or web applications (collectively, the “Services”).
As Twine AI Pty. Ltd. is an Australian business, this Privacy Policy takes into account the requirements of the Australian Privacy Principles set out in the Australian Privacy Act, as well as other applicable privacy laws.
Any capitalized terms not defined in this Privacy Policy have the meanings given to those terms in our Master Subscription Agreement.
Your privacy is very important to us, and we encourage you to read this Privacy Policy carefully. By providing Personal Information to us, you consent to our collection, handling, use and disclosure of your information in accordance with this Privacy Policy. If we are not able to collect certain Personal Information about you, this may limit your ability to use or access the Services.
This Policy does not apply to websites, apps, products, or services that we do not own or control. Further, where our Services are made available to you via an organization (for example, where your employer is our Customer and has made you an Authorized User of the Services under our contract with them), that organization will control the information processed via the Services, including Customer Data. This means that this Privacy Policy will not apply to that information, and Twine will not be responsible for the privacy practices of that organization. Rather, your information will be subject to that organization’s practices, policies, and collection notices. We encourage you to review these materials as they relate to the handling of your information.
2. What information we collect
We collect Personal Information in several ways. We may collect information directly from you or during our dealings with you, for example where you use our Services, contact and correspond with us, attend our premises or events, or apply for a position of employment with us.
When you use our Services, you may provide information to us. This includes:
when you set up a profile, your name, email address, and profile photo (“Account Information”);
content you provide through the Services;
content, files, or other media that you import to the Services (including via our integrations such as Salesforce, Hubspot, Google, Slack, etc.), as well as certain account details associated with such integrations;
when you subscribe to our paid services, your billing details including your billing address;
details of services we have provided to you or that you have enquired about;
your responses to questionnaires, surveys, or requests for feedback; and
additional Personal Information that you provide to us directly or indirectly through your use of our Services, associated social media platforms or accounts from which you permit us to collect information.
We log certain information about your access to and use of our Services (“Technical Information”). This includes:
device data (including, but not limited to, the type of device you use, data on device advertising ID’s and similar hardware qualifiers, the browser you use, your operating system, and approximate geographic location data);
usage data (including, but not limited to, search terms entered, pages viewed, and other usage behavior identified by analytics events);
network and internet information (including, but not limited to, URLs, and Internet Protocol addresses); and
information we collect via cookies and other tracking technologies.
If you apply for a job with Twine, we may collect certain information in connection with your application such as your name, contact details, occupation, education and work history. We may also collect certain information necessary to verify your identification or working rights.
We may receive information about you from third party sources. This includes marketing or demographic information about you from third party providers, including data about your organization or industry or other public information available online, such as through professional profiles. We may combine this information with other data we have to improve your experience with the Services or inform you of Services we think may be of interest to you.
3. How we use information we collect
The way we use your information depends on our relationship with you and the purpose of collection. We collect and use your information:
to deliver our Services and enable you to access and use our Services;
to improve our Services and your overall user experience;
to process your payments where you have signed up to a paid service;
to contact and communicate with you;
to prevent and address technical problems, and maintain the security of the Services;
to provide you with support services, if requested;
to help us understand traffic patterns, and analyze how you use the Services;
for internal record keeping;
for advertising and marketing, including to send you information about our products and services;
in connection with a merger, acquisition, reorganization or similar transaction;
when required or permitted by law, or to respond to legal process;
for any other purpose with your consent.
4. How we share information we collect
We share information we collect in the ways set out below, including in connection with possible business transfers. We do not sell information about you to advertisers or other third parties.
Sharing with other users
Twine is collaborative cloud product built for teams. This means sharing information with others through the Services, and with certain third parties. For example, your profile information or content you upload to the Services may be shared with other members of your workspace or the Customer administering your workspace. These people are usually colleagues you work with day-to-day, or clients you have added to your workspace.
Sharing with third parties
In addition to the specific circumstances discussed elsewhere in this policy, we may share Personal Information:
with our corporate affiliates and subsidiaries;
with third parties performing services to support our core business functions and internal operations;
with third parties (including agents and sub-contractors) assisting us to provide information, products, services or direct marketing to you;
to support our audit, compliance, and corporate governance functions;
in connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
with credit reporting agencies and courts, tribunals and regulatory authorities where you fail to pay for goods or services provided to you;
if we have a good-faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to detect or protect against fraud or security issues;
if otherwise required or permitted by applicable law or regulation, including laws and regulations of Australia and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever we may do business; (b) protect and defend our rights or property; (c) act in urgent circumstances to protect the personal safety of our users, customers, and contractors/employees; or (d) enforce our legal terms or otherwise protect against any legal liability; and
with your consent or at your direction.
Some of the third parties noted above may be located or store data outside of Australia, including the United States. For example, we use certain third parties located overseas to process Customer Data on our behalf.
5. How we use Google API Services
Our use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
User Consent for AI apps
In order to work with integrations such as Google Calendar, we need to access your data.
We will only access the data that is necessary for the integration to work. In the case of Google Calendar, we ask for the following permissions:
calendar.readonly: to read your calendars events and schedule bots to join your Zoom meetings.
While some data will be sent to third party AI models hosted in our AWS infrastructure (your and participant names, calendar event title, meeting transcripts) to extract intel, it is never shared or disclosed publicly as per our Privacy Policy.
6. How we use tracking technologies
Some features in the Services may require the use of “cookies” (i.e. small text files that are stored on your device). You may delete and block all cookies from our Services, but parts of the Services may not work. We use different categories of cookies for different reasons. These categories, and your options for managing your preferences, are set out below.
Required cookies
Required cookies enable you to navigate the Services and use its features, such as accessing secure areas of the Services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you when you are logged into the Services and to process your online transactions and requests.
Performance cookies
These cookies collect information about how you use our Services, including which pages you go to most often and whether you receive error messages from certain pages. These cookies do not collect information that individually identify you, and the information is only used to improve how the Services function and perform.
Functionality cookies
Functionality cookies allow our Services to remember information you have entered or choices you have made (for example, changes you have made to text size, font and other customizations) to provide enhanced, personalized features and optimize your use of the Services after logging in. For example, we may use local shared objects to store your preferences or display content based on what you view.
Analytics cookies
When you visit our website, our third party analytics services providers (such as Google Analytics and Twilio Segment) may use cookies and other tracking technologies to collect and store certain Technical Information.
7. How we respond to Do Not Track signals
Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. Please note, we do not alter our practices when we receive a Do Not Track signal from a visitor’s browser. To find out more about Do Not Track, please visit https://www.allaboutdnt.com.
8. Managing your information
You can review, update, correct or delete the Personal Information held by Twine by contacting legal@twine.so. If you are a Twine user, you may also manage certain information directly via your user account. If you wish to remove your user account, you may do so through your account settings. However, this will not necessarily remove all Personal Information held about you by Twine.
For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner.
Please note that we may retain certain information in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required or permitted by law.
We may use some of the information we collect for marketing purposes, including to send you promotional communications about new features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions such as clicking "Unsubscribe" (or similar opt-out language) in those communications. You can also contact us at legal@twine.so to opt out. Please note that we may continue to send you service-related communications, including notices of any updates to our terms of service or privacy policy, via email.
9. Data storage, transfer, and security
Twine hosts data with hosting service providers in countries outside of Australia, including the United States. Your Personal Information may also be stored and processed in other countries where we have facilities or in which we engage service providers.
We aim to ensure that your information is secure at all times. We have in place a number of physical, technical and organizational measures to safeguard and secure your information and protect it from misuse, interference, loss and unauthorized access, modification and disclosure.
Although we take measures to safeguard your information, due to the inherent nature of the Internet, we cannot guarantee the security of any information that you transmit to us or receive from us.
10. Children under 16
The Services are not directed to individuals who are under the age of 16 and we do not solicit nor knowingly collect Personal Information from children under the age of 16. If you believe that we have unknowingly collected any Personal Information from someone under the age of 16, please contact us immediately at legal@twine.so and we will take steps to ensure that the information is deleted.
11. Links to other websites
Our Services may contain links to other websites of interest. We do not have any control over those websites. We are not responsible or liable for the protection and privacy of any information which you provide while visiting such websites, and such websites are not governed by this Privacy Policy.
12. Changes
We reserve the right to change this Privacy Policy at any time, and such changes will be effective when they are posted to this page. We will notify you of any changes by posting the updated policy to this page, and/or by sending notice to the contact email address associated with your Twine account, if you have one. By continuing to use our Services or otherwise continuing to interact with us, you acknowledge that the collection, use and sharing of your Personal Information is subject to the updated Privacy Policy. We recommend that you review this page periodically for any changes.
13. Contact us
Please contact legal@twine.so if you have any questions or concerns about this Policy or our information handling practices, or if you believe that we have not complied with this Policy or applicable privacy laws, including the Australian Privacy Act.
We will take any privacy complaint seriously and will investigate and aim to resolve any such complaint in a timely and efficient manner. Our target response time is 30 days, and we request that you cooperate with us during this time, including providing us with any relevant information we may require.
We expect to be able to deal with your complaint fairly and promptly. However, if you are not satisfied, and the Australian Privacy Act applies, you can contact the Office of the Australian Information Commissioner (the “OAIC”). The OAIC’s contact details are made available on their website.
14. Data retention
We will retain your Personal Information for as long as your account is in existence or otherwise as necessary to provide you the Services, or as otherwise required or permitted by applicable law.