Updated on April 05, 2024
This privacy policy is for cwistED LLC (also known as cwistED) (referred to as we, us, or our). It explains how and why we may gather, keep, use, and/or share (process) your data when you utilize our services (“Services”). This includes when you visit our website at cwisted.com, or any of our websites that link to this privacy policy.
This privacy policy states your privacy rights and options. If you disagree with our policies and practices, we kindly ask that you refrain from using our Services. If you have any questions or concerns, reach out to us at https://cwisted.com/contact-us/.
1. Collected Data
• Data you share with us: We gather personal data that you willingly give us. This happens when you sign up for our services, show interest in our products, participate in activities, or contact us. The data we collect depends on your interactions with us and our services, your choices, and the features you use. This may include names, phone numbers, email addresses, location, and school district. We don’t process sensitive information. All the data you provide should be accurate and up-to-date.
• Automatically collected data: We automatically collect some data, like your IP address and device details, when you use our services. This data helps us maintain our services and is used for analytics and reporting. It includes device and usage data, such as your IP address, device characteristics, operating system, language preferences, referring URLs, device name, country, location, and technical information about how and when you use our services.
• Cookies and similar technologies: Like many businesses, we also gather data through cookies and similar technologies. This includes log and usage data, device data, and location data. For example, we may use GPS and other technologies to collect geolocation data based on your IP address. You can opt out of this by refusing access to the information or by disabling your Location setting on your device. However, opting out may affect your use of certain aspects of the Services.
2. Handling of Personal Information
We handle your personal data for several purposes, which are determined by your interaction with our Services. These include:
• Assisting in the creation and verification of accounts and managing user accounts.
• Responding to user queries and providing support.
• Delivering administrative information to you.
• Facilitating communication between users.
• Seeking feedback.
• Sending marketing and promotional messages.
• Safeguarding our Services.
• Preserving or protecting a person’s essential interests.
3. Legal Basis
We process your personal data only when necessary and with a valid legal basis under applicable law. This may include obtaining your consent, fulfilling contractual obligations, complying with legal requirements, pursuing legitimate business interests, or protecting vital interests.
Under regulations such as the General Data Protection Regulation (GDPR), UK GDPR, and applicable Canadian laws, the legal grounds for processing your personal data may include:
• Consent
• Contractual obligations
• Legitimate interests
• Legal obligations
• Vital interests
If you are in Canada, this section applies to you. We may process your data if you have given us specific permission to use your personal data for a specific purpose, or in situations where your permission can be inferred. You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your data without your consent.
4. Sharing of Personal Information
Vendors, Consultants, and Other Third-Party Service Providers: We might share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and need access to such data to do that work. We have contracts with our third parties to help protect your personal data. This means they can’t use your personal data unless we instruct them to do so. They also won’t share your personal data with any organization apart from us. They commit to protect the data they hold on our behalf and to keep it for the period we instruct. The categories of third parties we might share personal data with include Ad Networks, Data Analytics Services, Data Storage Service Providers, Performance Monitoring Tools, Product Engineering & Design Tools, Sales & Marketing Tools, Social Networks, Website Hosting Service Providers.
We might share or transfer your data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We might share your data with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout.
5. Usage of Cookies and Other Tracking Technologies
We might use cookies and other tracking technologies to collect and store your data.
6. Retention of Your Information
We will only keep your personal data for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal data for longer than the period in which users have an account with us.
7. Personal Information Protection
We’ve put in place suitable and rational technical and organizational security procedures to safeguard any personal data we handle. However, no matter how robust our precautions are and how hard we work to protect your data, no online transmission or data storage technology can be assured to be completely secure. Therefore, we cannot make any promises or guarantees that hackers, cybercriminals, or other unauthorized entities will not be able to bypass our security and unlawfully gather, access, steal, or alter your data. While we will strive to protect your personal data, any transmission of personal data to and from our Services is at your own risk. We advise you to only access the Services within a secure environment.
8. Data from Minors
We do not knowingly collect data from individuals under the age of 18 without parental consent. If you believe we have inadvertently collected data from a minor, please contact us.
9. Your Privacy Rights
In specific regions (like the EEA, UK, Switzerland, and Canada), you possess certain rights under the relevant data protection laws. These rights may include the ability (i) to request access and obtain a copy of your personal information, (ii) to request rectification or deletion; (iii) to limit the processing of your personal information; (iv) if applicable, to data portability; and (v) to avoid being subject to automated decision-making. Under certain conditions, you may also have the right to object to the processing of your personal information. You can make such a request by reaching out to us using the contact form provided. We will consider and act upon any request in line with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to lodge a complaint with your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may reach out to the Federal Data Protection and Information Commissioner.
Revoking your consent: If we are processing your personal information based on your consent, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can revoke your consent at any time by reaching out to us using the contact details provided or updating your preferences. However, please be aware that this will not impact the legality of the processing before its withdrawal nor, when applicable law permits, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can opt out of our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by reaching out to us using the contact form. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
10. Do-Not-Track Features
At this point, no uniform technology standard for recognizing and implementing DNT signals has been finalized. Therefore, we currently do not respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is established that we must follow in the future, we will inform you about that practice in an updated version of this privacy notice.
11. Specific Privacy Rights for United States Residents
Residents of specific regions, such as California, Colorado, Connecticut, Utah, Virginia, and others, may have additional privacy rights as outlined in relevant state or provincial laws. These rights empower individuals to exercise greater control over their personal information and enhance transparency in data processing practices.
In the past twelve months, we have collected various categories of personal information, including identifiers such as contact details and online identifiers, personal information defined by the California Customer Records statute, internet activity data like browsing and search history, geolocation data, and professional or employment-related information. We will use and retain this information to provide our services as long as the user has an account with us. Additionally, we may collect other personal information through interactions such as customer support requests, participation in surveys or contests, and facilitating service delivery or responding to inquiries.
California Residents:
Under the California Consumer Privacy Act (CCPA), residents are entitled to certain rights regarding their personal information. These rights include the right to know what personal information is collected, used, shared, or sold, the right to opt-out of the sale of personal information, and the right to request deletion of personal information collected by businesses. Additionally, California residents have the right to non-discrimination for exercising their privacy rights.
Colorado Residents:
Colorado residents have specific rights under the Colorado Privacy Act (CPA), including the right to be informed about the processing of personal data, access personal data, correct inaccuracies, request deletion, obtain a copy of personal data, and opt out of certain processing activities. Businesses are obligated to respond to consumer requests and provide explanations for any decisions made regarding these requests.
Connecticut Residents:
Residents of Connecticut are afforded rights under the Connecticut Data Privacy Act (CTDPA). These rights include being informed about data processing activities, accessing personal data, correcting inaccuracies, requesting deletion, obtaining a copy of personal data, and opting out of certain processing activities. Businesses must respond to consumer requests within a specified timeframe and provide written explanations for any actions taken.
Utah Residents:
Under the Utah Consumer Privacy Act (UCPA), residents have rights concerning the processing of personal data. These rights include being informed about data processing activities, accessing personal data, requesting deletion, obtaining a copy of personal data, and opting out of certain processing activities, such as targeted advertising or the sale of personal data. Businesses are required to respond to consumer requests and provide written explanations for any decisions made.
Virginia Residents:
The Virginia Consumer Data Protection Act (VCDPA) grants specific rights to residents regarding their personal data. These rights include being informed about data processing activities, accessing personal data, correcting inaccuracies, requesting deletion, obtaining a copy of personal data, and opting out of certain processing activities, such as targeted advertising or the sale of personal data. Businesses must respond to consumer requests and provide written explanations for any decisions made.
In addition to the rights outlined above, residents of other jurisdictions may have similar rights under their respective laws. We are committed to upholding these rights and ensuring compliance with applicable privacy regulations. If you have questions or wish to exercise your privacy rights, please contact us using the provided contact information.
12. Updates to This Notice
This privacy notice may be updated periodically. We recommend that you review this privacy notice regularly to stay informed about how we are safeguarding your information.
13. Contact
If you have any queries or feedback about this notice, you can reach out to our Data Protection Officer (DPO), using the form available at https://cwisted.com/contact-us/, or you can write to us at: cwistED LLC Attn: DPO 11260 Overland Avenue Suite 9G Culver City, CA 90230 United States
14. Reviewing, Updating, or Deleting Your Data
Depending on the laws of your country, you may have the right to access the personal information we collect from you, modify that information, or delete it. To request a review, update, or deletion of your personal information, please visit: https://cwisted.com/contact-us/.
