Privacy Policy
The Twinphoton Privacy Policy was updated on September 2023
Your privacy is important to Twinphoton. So we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your information. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.
Collection and Use of Personal Information
Personal information is data that can be used to identify or contact a single person.
You may be asked to provide your personal information anytime you are in contact with Twinphoton or an Twinphoton affiliated company. Twinphoton and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.
GDPR
About the regulation and data protection
Background
As of May 2018, with the entry into application of the General Data Protection Regulation, there is one set of data protection rules for all companies operating in the EU, wherever they are based. Stronger rules on data protection mean
- people have more control over their personal data
- businesses benefit from a level playing field
Here are some examples of the types of personal information Twinphoton may collect and how we may use it:
What personal information we collect
When you create an Twinphoton Client ID, apply for commercial credit, purchase a product, download a software update, register for a class at an Twinphoton Retail Store, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, and credit card information. When you share your content with family and friends using Twinphoton products, send gift certificates and products, or invite others to participate in Twinphoton services or forums, Twinphoton may collect the information you provide about those people such as name, mailing address, email address, and phone number. Twinphoton will use such information to fulfill your requests, provide the relevant product or service, or for anti-fraud purposes. In certain jurisdictions, we may ask for a government issued ID in limited circumstances including when setting up a wireless account and activating your device, for the purpose of extending commercial credit, managing reservations, or as required by law.
How we use your personal information
The personal information we collect allows us to keep you posted on Twinphoton’s latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences. We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Twinphoton ID account holders. From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Twinphoton, you may not opt out of receiving these communications. We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Twinphoton’s products, services, and customer communications. If you enter into a sweepstakes, contest, or similar promotion we may use the information you provide to administer those programs.
Collection and Use of Non-Personal Information
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an Twinphoton product is used so that we can better understand customer behavior and improve our products, services, and advertising. We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address. With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.
If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
Cookies and Other Technologies
Twinphoton websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non?personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.
Twinphoton and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Twinphoton more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the Twinphoton Online Store. Knowing your country and language ? and if you are an educator, your school ? helps us provide a customized and more useful shopping experience. Knowing someone using your computer or device has shopped for a certain product or used a particular service helps us make our advertising and email communications more relevant to your interests.
If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. For browsers, check with your provider to find out how to disable cookies. Please note that certain features of the Twinphoton website will not be available once cookies are disabled.
As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and click stream data.
We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Twinphoton may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on the Twinphoton website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
Disclosure to Third Parties
At times Twinphoton may make certain personal information available to strategic partners that work with Twinphoton to provide products and services, or that help Twinphoton market to customers. For example, when you purchase and activate your iPhone, you authorize Twinphoton and your carrier to exchange the information you provide during the activation process to carry out service. If you are approved for service, your account will be governed by Twinphoton and your carrier’s respective privacy policies. Personal information will only be shared by Twinphoton to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes. Service Providers
Twinphoton shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Twinphoton operates. Others
It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence for Twinphoton to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Protection of Personal Information
Twinphoton takes the security of your personal information very seriously. Twinphoton online services such as the Twinphoton Online Store and iTunes Store protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by Twinphoton, we use computer systems with limited access housed in facilities using physical security measures.
When you use some Twinphoton products, services, or applications or post on an Twinphoton forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.
If you or anyone else using Family Sharing logs on to a device that is owned by a third party, any information shared within your Family—including calendar, location, photos, and iTunes purchases—may be downloaded on to that third-party device thereby disclosing any such shared information. [See About Family Sharing for more information.]
The security of your data is ensured through SSL certification available since November 2016 on this site. So any sensitive information sent to us, rest assured that there will be falsified or stolen by a third party. For more details, click on the green icon at the bottom of the screen where it says "SSL Certification"
Integrity and Retention of Personal Information
Twinphoton makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
Access to Personal Information
You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account at https://appleid.apple.com/. For other personal information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if Twinphoton is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made through the regional Privacy Contact Form.
Children & Education
We understand the importance of taking extra precautions to protect the privacy and safety of children using Twinphoton products and services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own Twinphoton Customer IDs, unless their parent provided verifiable consent or as part of the child account creation process in Family Sharing or they have obtained a Managed Twinphoton Customer ID account (where available) through their school.
If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible.
Location-Based Services
To provide location-based services on Twinphoton products, Twinphoton and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your Twinphoton computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Twinphoton and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.
Some location-based services offered by Twinphoton, such as the “Find My iPhone” feature, require your personal information for the feature to work. Third?Party Sites and Services
Twinphoton websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties for example, a third-party iPhone app.
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
If you purchase a subscription in a third party app or within News, we create a Subscriber ID that is unique to you and the developer or publisher which we use to provide reports to the developer or publisher that include information about the subscription you purchased, and your country of residence. If you cancel all of your subscriptions with a particular developer or publisher, the Subscriber ID will reset after 180 days if you do not resubscribe. This information is provided to developers so that they can understand the performance of their subscriptions. International Users
All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Twinphoton uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland. Twinphoton, as a European company, has a number of legal entities in different jurisdictions which are responsible for the personal information which they collect and which is processed on their behalf by Twinphoton. For example, point of sale information in our Retail entities outside the U.S. is controlled by our individual Retail entities in each country. Twinphoton, Online Store and iTunes related personal information may also be controlled by legal entities outside the U.S. as reflected in the terms of each service.
To make sure your personal information is secure, we communicate our privacy and security guidelines to Twinphoton employees and strictly enforce privacy safeguards within the company.
Privacy Questions
If you have any questions or concerns about Twinphoton’s Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us by phone at the relevant Twinphoton Support number for your country.
All such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
Twinphoton may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.
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