Updated September 2022

Twill Inc. (“Twill,” the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information that we collect.

The purpose of this Twill Cookie Policy (“Cookie Policy”) is to explain our data collection and privacy practices with regard to the use of cookies and similar tracking technologies on our websites we operate from which you are accessing this Cookies Policy (“Websites”) and our Software applications made available by us for use on or through computers and mobile devices (“Apps”). This Cookie Policy applies when you are accessing our Websites and Apps from the European Economic Area (EEA), the European Union (EU) or the United Kingdom (UK).

WHAT ARE COOKIES?

Our Websites and Apps use so-called "cookies" and similar technologies (“Cookies”). Cookies are small text files that are stored in your end device via your browser. Cookies do not cause any damage to your end device, but store certain information (e.g. page settings) that is sent back to us by your browser when you visit the Websites or use the Apps again (depending on the life span of the Cookie).

The Cookies we use are stored on your end device either temporarily for the duration of a session (session Cookies) or beyond the duration of your session (persistent Cookies). Session Cookies are automatically deleted at the end of your visit (i.e. when you end your session and close your browser). Persistent Cookies remain stored on your end device until the storage time of the cookies expires or you delete them yourself.

Some of the cookies used are set by us (so-called "first-party cookies"). However, we also may work with third party providers (e.g. for analytics and marketing purposes – see below) who also set cookies on our Websites and Apps (so-called "third-party cookies").

ESSENTIAL COOKIES

Certain Cookies used on our Websites and Apps are technically necessary, as certain website functions would not work without them (so-called "Essential Cookies") (e.g. page navigation, saving page, displaying content). Essential Cookies we use, include, in particular, cookies that remember your cookie preferences over time. We base the lawfulness of the processing of personal data collected by means of Essential Cookies on the necessity of the processing to protect our legitimate interests (effective, secure, technically error-free and legally compliant functionalities and services on our Websites and Apps).

MARKETING, PERSONALIZATION AND ANALYTICS COOKIES

We also set further Cookies that

1. are used to deliver advertising that is more relevant to you and your interests, including to limit the number of times you see an advertisement and measures the effectiveness of advertising campaigns; these cookies are usually placed by third party advertising network (“Marketing Cookies”); Marketing Cookies we use include Google Analytics.

2. to remember choices you make (such as user name, language, or the region you are in) and provide enhanced, more personal features, e.g. a website may provide you with local whether reports or traffic news by storing data about your current location (“Personalization Cookies”); and

3. to understand how our Websites and Apps perform, how visitors interact with our Websites and Apps, and whether there may be technical issues; these Cookies usually do not collect information that identifies you (“Analytics Cookies”).

Marketing, Personalization and Analytics Cookies are not absolutely necessary for the provision of the services and functionalities offered on our Websites and Apps, but help us to offer you a more pleasant and attractive user experience. To the extent necessary under applicable data protection and privacy laws applicable in the EEA, EU and UK, we will ask for your consent prior to the use of Marketing, Personalization and Analytics Cookies and place such Cookies on your end device only if you have provided your consent. You can withdraw your consent and prevent the collection of data via all or specific Marketing, Personalization and/or Analytics Cookies via Cookie Preferences in the footer.

DETAILED INFORMATION ON THE COOKIES WE USE

Detailed information on the individual Essential Cookies and Marketing, Personalization and Analytics Cookies we are using on our Websites and Apps, including the functions of Cookies, the life span of the Cookies (Expiry) and the third party service providers we are using to deploy the Cookies, can be found in the Storage Preferences in our Cookie Preferences when you click on “View Cookies”. If we use third party service providers, the Cookies are usually placed on your end device by the respective service provider which may have access to the data collected from you by means of the Cookies.

PROCESSING OF PERSONAL DATA

To the extent that the data we collect by means of Cookies include information that qualify as personal data in the meaning of data protection and privacy laws applicable in the EEA, EU or UK, the following sections of the Twill Privacy Policy apply correspondingly to the processing of such data: DISCLOSURE OF PERSONAL INFORMATION, OTHER USES AND DISCLOSURES OF PERSONAL INFORMATION, RETENTION PERIOD, INFORMATION FOR USERS OUTSIDE THE USA, INFORMATION FOR USERS IN THE EEA/EU UK.

CONTACT US

If you have any questions or comments about this Cookie Policy, please email our Data Protection Officer at support@twill.health or send a letter to: Twill, Inc., 114 Fifth Ave, Floor 10, New York, NY 10011, USA. To reach a Twill representative in the European Union, contact Rickert Rechtsanwaltsgesellschaft mbH via email at datenschutz@rickert.net or send a letter to Kaiserplatz 7-9, 53113 Bonn, Germany.