Privacy Policy

Updated on February 4th, 2022

PT Twibbonize Teknologi Indonesia (“we”, “us”, or “our”) operates twibbonize.com . Our Privacy Policy governs your visit to twibbonize.com , and describes how we collect, maintain and disclose information that results from your use of our services.

Your privacy is important to us. It is Twibbonize’s policy to respect your privacy and comply with applicable laws and regulations regarding any personal information we collect about you, including across our website, https://www.twibbonize.com , and other sites we own and operate .

Personal information is any information about you that can be used to identify you. This includes information about you personally (such as your name, address, and date of birth), your device, and even information about how you use websites or online services.

If our site contains links to third party sites and services, please be aware that these sites and services have their own privacy policies. After following a link to any third party content, you should read the privacy policy information they post about how they collect and use personal information. This Privacy Policy does not apply to your activities after you leave our site. By using Twibbonize, you consent to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Information We Collect

The information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntaryly provided” information refers to any information that you knowingly and actively provide to us when using or participating in our services and promotions.

“Automatically collected” information refers to any information that is automatically sent by your device when accessing our products and services.

Log Data

When you visit our website, our servers may automatically log standard data provided by your web browser. This may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

In addition, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding the error. This data may include technical details about your device, what you were trying to do when the error occurred, and other technical information related to the problem. You may or may not receive notification of the error, even at the time it occurred, that the error has occurred, or what the nature of the error is.

Please note that while this information may not be personally identifiable by itself, it is possible to combine it with other data to personally identify individuals.

Device Data

When you visit our website or interact with our services, we may automatically collect data about your device, such as:

  • Device type
  • Operating system
  • Unique Device Identifier
  • Tool settings
  • Geographic location data

The data we collect may depend on your individual device and software settings. We recommend checking the policies of your device manufacturer or software provider to learn what information they provide us.

Personal information

We may ask for personal information — for example, when you submit content to us or when you contact us — which may include one or more of the following:

  • Name
  • Email
  • Social Media Profile

User Generated Content

We consider “user-generated content” as material (text, images and/or video content) that is voluntarily provided to us by our users for the purpose of publication on our website or republishing on our social media channels. All user-generated content is associated with the account or email address used to submit the material.

Please be aware that any content you submit for publication purposes will become public once posted (and the subsequent review or review process). Once published, it may be accessible to third parties not covered by this privacy policy.

Legitimate Reasons to Process Your Personal Information

We only collect and use your personal information when we have a valid reason to do so. In this case, we only collect personal information that is reasonably necessary to provide our services to you.

Information Collection and Use

We may collect personal information from you when you do any of the following on our website:

  • Register for an account
  • Take part in our competitions, contests, sweepstakes and surveys
  • Sign up to receive updates from us via email or social media channels
  • Use a mobile device or web browser to access our content
  • Creating content on the Twibbonize platform
  • Contact us via email, social media or other similar technologies
  • When you mention us on social media

We may collect, store, use and disclose information for the following purposes, and personal information will not be further processed in a manner that is inconsistent with these purposes:

  • To provide you with the core features and services of our platform
  • To enable you to customize or personalize your experience on our website
  • To contact and communicate with you
  • For analytics, market research and business development, including to operate and improve our website, related applications and related social media platforms
  • For advertising and marketing, including to send you promotional information about our products and services and information about third parties that we think may be of interest to you
  • To consider your job application
  • To enable you to access and use our website, related applications and related social media platforms
  • For internal record keeping and administrative purposes
  • To run competitions, sweepstakes and/or offer you additional benefits
  • To comply with our legal obligations and resolve any disputes we may have
  • To attribute any content (e.g. posts and comments) that you submit that we publish on our website
  • For security and fraud prevention, and to ensure that our sites and apps are safe, protected, and used according to our terms of use
  • To monitor the use of our Service
  • For technical assessments, including to operate and improve our applications, related applications and related social media platforms
  • For any other purpose with your consent

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may reveal data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it in a commercially acceptable manner to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.

While we will do our best to protect the personal information you provide to us, we recommend that no method of transmission or electronic storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for choosing any password and its overall security strength, ensuring the security of your own information within the limits of our service. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

How Long We Keep Your Personal Information

We retain your personal information only for as long as necessary. This time period may depend on what we use for your information, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for as long as your account is in our system. If your personal information is no longer needed for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for purposes of internal analysis, our compliance with legal, accounting or reporting obligations or for archiving purposes for the public interest, scientific research purposes, or historical or statistical purposes.

Kids Privacy

We do not direct our products or services to children under the age of 13, and we do not knowingly collect personal information about children under the age of 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to delete that information from our servers.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

  • Parent, subsidiary or affiliate of our company
  • Third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, maintenance or troubleshooting providers, advertising providers, and professional advisors
  • Our employees, contractors and/or related entities
  • Our existing or potential agents or business partners
  • Sponsor or promoter of any competition, sweepstakes or promotion we run
  • Credit reporting agencies, courts, courts and regulatory authorities, if you fail to pay for goods or services we have provided you
  • Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with actual or prospective legal proceedings, or to establish, exercise or defend our legal rights
  • Third parties, including agents or subcontractors, who assist us in providing you with information, products, services or direct marketing
  • Third parties to collect and process data
  • Entities to which we purchase, or to which we transfer all or most of our assets and business

The third parties we currently use include:

  • Google Analytics
  • Google Adsense

International Transfer of Personal Information

The personal information we collect is stored and/or processed in Singapore, or where we or our partners, affiliates and third party providers maintain facilities.

The country in which we store, process or transfer your personal information may not have the same data protection laws as the country in which you originally provided the information. Your consent to this Privacy Policy followed by your submission of the information indicates your consent to the transfer.

If we transfer your personal information to a third party in another country: (i) we will make such transfers in accordance with applicable legal requirements; and (ii) we will protect the personal information transferred in accordance with this privacy policy.

Your Rights and Controlling Your Personal Information

Your choice: By providing us with personal information, you understand that we will collect, store, use and disclose your personal information in accordance with this privacy policy. You do not have to provide us with personal information, however, otherwise it may affect your use of our website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about another person, you represent and warrant that you have that person’s consent to provide personal information to us.

Marketing consent: If you have previously consented to us using your personal information for direct marketing purposes, you can change your mind at any time by contacting us using the details below.

~~Access: You can request details of the personal information we hold about you~~.

Correction: If you believe that any information we have about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Non-discrimination: We will not discriminate against you for exercising your rights to your personal information. Unless your personal information is necessary to provide you with a particular service or offer (e.g. providing user support), we will not refuse your goods or services and/or charge a different price or rate for the goods or services, including through the provision of discounts or other benefits, or impose penalties, or provide you with a different level or quality of goods or services.

Data breach notice: We will comply with the laws that apply to us with respect to any data breach.

Complaints: If you believe that we have violated the relevant data protection laws and wish to file a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the results of our investigation and the steps we will take to address your complaint. You also have the right to contact a regulatory body or data protection authority regarding your complaint.

Unsubscribe: To unsubscribe from our email database or opt out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt out using the opt-out facility provided in the communication. We may need to request specific information from you to help us confirm your identity.

Use of Cookies

We use “cookies” to collect information about you and your activity across our sites. A cookie is a small piece of data that our website stores on your computer, and is accessed each time you visit, so that we can understand how you use our site. This helps us serve content to you based on the preferences you have set.

Please refer to our Cookie Policy for more information.

Business Transfer

If we or our assets are acquired, or in the unlikely event that we go out of business or go bankrupt, we will include data, including your personal information, among the assets transferred to any party that acquires us. You acknowledge that such transfers may occur, and that any of our acquirers may, to the extent permitted by applicable law, continue to use your personal information in accordance with this policy, which they will assume as the basis for any ownership or use rights we have over that information.

Our Policy Limit

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of these sites, and cannot accept responsibility or liability for each other’s privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link you used to access this privacy policy.

If the changes are significant, or where required by applicable law, we will contact you (based on your chosen preferences for communications from us) and all of our registered users with new details and links to updated or changed policies.

Where required by law, we will obtain your consent or provide you with the opportunity to opt-in or opt-out, as applicable, any new use of your personal information.

Additional Disclosures for Australian Privacy Act (AU) Compliance

International Transfer of Personal Information

If the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be governed by the Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any third party engages in any act or practice that is contrary to the Australian Privacy Principles, it will not be liable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

Data Controller / Data Processor

The GDPR distinguishes between organizations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We, Twibbonize, located at the address provided in the Contact Us section, are the Data Controller and/or Processor with respect to the personal information you provide to us.

Legal Basis for Processing Your Personal Information

We will only collect and use your personal information when we have a legal right to do so. In this case, we will collect and use your personal information in a lawful, fair and transparent manner. If we ask for your consent to process your personal information, and you are under 16 years of age, we will seek the consent of your parent or legal guardian to process your personal information for that specific purpose.

Our legal basis depends on the services you use and how you use them. This means we only collect and use your information for the following reasons:

Your Consent

Where you give us your consent to collect and use your personal information for certain purposes. You can withdraw your consent at any time using the facilities we provide; however this will not affect the existing use of your information. You may agree to provide your name and contact details for the purpose of entering a giveaway or promotion. While you may withdraw your entry at any time, this will not affect any selection or assessment that has been made. If you have further questions about how to withdraw your consent, please feel free to ask them using the details provided in the Contact Us section of this privacy policy.

Execution of Contract or Transaction

If you have entered into a contract or transaction with us, or to take preparatory steps before we enter into a contract or transaction with you. For example, if you contact us with a question, we may need personal information such as your name and contact details in order to respond.

Our Legitimate Interest

If we deem it necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, actions taken to operate our services efficiently, marketing analysis, and actions taken to protect our legal rights and interests.

Compliance with Law

In some cases, we may have a legal obligation to use or store your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have further questions about how we store personal information to comply with the law, please feel free to ask them using the details provided in the Contact Us section of this privacy policy.

International Transfers Outside the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of regulatory bindings. company or other legally acceptable means.

Your Rights and Controlling Your Personal Information

Restrict: You have the right to ask us to limit the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been processed unlawfully; (iii) you need us to keep personal information for legal purposes only; or (iv) we are in the process of considering your objection with respect to processing on a legitimate interest basis.

Object to processing: You have the right to object to the processing of your personal information based on our legitimate or public interests. If this is done, we must provide a valid and compelling reason for the processing that overrides your interests, rights and freedoms, to continue processing your personal information.

Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV or other machine-readable format. You also have the right to ask us to transfer this personal information to third parties.

Deletion: You may have the right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to remove your personal information from our current records. If you ask us to delete your personal information, we will tell you how the deletion affects your use of the website or our products and services. There may be exceptions to this right for certain legal reasons which, where applicable, we will establish for you in response to your request. If you terminate or delete your account, we will delete your personal information within 60 days of deleting your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been published at least once, such as certain profile information and public comments, even after you delete such information from our services or deactivate your account.

Additional Disclosures for California (US) Compliance

Under California Civil Code Section 1798.83, if you reside in California and your business relationship with us is primarily for personal, family, or domestic purposes, you can ask us about information we release to other organizations for their marketing purposes.

To make such a request, please contact us using the details provided in this privacy policy with “California privacy information requests” in the subject line. You can make this type of request once every calendar year. We will email you a list of the categories of personal information that we disclosed to other organizations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Don’t Track

Some browsers have a “Do Not Track” feature that lets you tell websites that you don’t want your online activity to be tracked. At this time, we do not respond to browser “Do Not Track” signals.

We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information in a lawful, fair, transparent manner and with legitimate legal reasons to do so.

Cookies and Pixels

At any time, you can refuse cookies from our site if your browser allows. Most browsers allow you to enable a setting on your browser to refuse setting all or some cookies. Therefore, your ability to limit cookies is based solely on the capabilities of your browser. Please refer to the Cookies section of this privacy policy for more information.

CCPA-allowed financial incentives

Subject to your right not to discriminate, we may offer you certain financial incentives permitted by the CCPA that may result in a different price, rate or level of quality for the goods or services we provide.

Any CCPA-permitted financial incentives we offer will reasonably relate to the value of your personal information, and we will provide written terms that clearly define the nature of the offer. Participation in financial incentive programs requires your prior participation approval, which you can withdraw at any time.

California Collection Notice

In the past 12 months, we have collected the following categories of personal information specified in the California Consumer Privacy Act:

  • Identifiers, such as name, email address, phone number, account name, IP address, and the ID or number assigned to your account.
  • Internet activity, such as your interactions with our services.
  • Audio or visual data, such as photos or videos that you share with us or posts on the service.
  • Geolocation data.
  • Inference, such as information about your interests, preferences and favourites.

For more information about the information we collect, including the sources from which we receive the information, please review the “Information We Collect” section. We collect and use this category of personal information for the business purposes described in the “Information Collection and Use” section, including to provide and administer our Services.

Right to Know and Erase

If you are a resident of California, you have the right to delete your personal information that we collect and find out certain information about our data practices in the previous 12 months. In particular, you have the right to request the following from us:

  • Categories of personal information we collect about you;
  • Categories of sources from which personal information is collected;
  • Categories of personal information about you that we disclose for business purposes or for sale;
  • Categories of third parties to whom personal information is disclosed for business purposes or sold;
  • Business or commercial purposes to collect or sell personal information; and
  • The specific piece of personal information we collect about you.

To exercise any of these rights, please contact us using the details provided in this privacy policy.

Shine the Light

If you are a resident of California, in addition to the rights discussed above, you have the right to request information from us about how we share certain personal information as defined by “Shine the Light” California with third parties and their affiliates. own direct marketing goals.

To receive this information, please submit a request to us using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and postal code.

Contact Us

For any questions or concerns regarding your privacy, you can contact us using the following details:

Sebastian Billy Anggara
Customer Excellence Officer, Twibbonize

hi@twibbonize.com