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.
We collect information through:
- Software applications made available by us for use on or through computers and mobile devices (the “Apps”);
- Our social media pages and apps (collectively, “Social Media Pages”);
- Offline business interactions you have with us.
TYPES OF INFORMATION WE COLLECT
PERSONAL INFORMATION: Twill may collect personal information in a variety of ways, including:
- Identifiers – Including real name, alias, date of birth, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name or other similar identifiers;
- Demographic information – Including age, gender and other personal information that may be considered a protected classification characteristic under California or federal laws.
- Internet or other electronic network activity information – Including how you interact with the Services and, if you link your information associated with your social media account such as your name, username, email address, gender, profile picture, etc.
- Geolocation data;
- Audio, electronic, visual or similar information; and
- Professional or employment-related information.
PERSONAL HEALTH INFORMATION: We may collect information regarding your physical and mental health, such as information on medications, medical history and other healthcare-related information (“PHI”). This includes PHI which you choose to share in the Services with all of our users or all other users belonging to your Twill Program Company, and PHI which you provide only to us, such as answers in connection with using self-assessment features offered in our Services.
SPONSOR ORGANIZATIONS: If an organization (“Sponsor Organization”), such as your or your partner’s, spouse’s or parent/guardian’s employer, university or health plan, is paying for access to our Services on your behalf, use of our Services may require you to provide additional registration information. This information is collected to confirm your eligibility with the Sponsor Organization. Information collected under these circumstances may include but is not limited to name, email address, date of birth and phone number. This information is required to confirm program or benefit eligibility and prevent insurance and benefit fraud.
HOW WE COLLECT INFORMATION
INFORMATION YOU SHARE WITH US: Directly from you (e.g. when you register for the Services or interact with certain Twill features such as assessments, the artificial intelligence-based (“Al-based”) chatbot named Taylor, the behavioral matrix and click-throughs to third parties within the Services);
INFORMATION WE COLLECT AUTOMATICALLY: From your devices (e.g., when you connect to the Services, your device shares information about you and your session);
INFORMATION YOU DIRECT US TO RECEIVE FROM THIRD PARTIES: For US users, From public databases, where permitted by law, or from third-party private sources, such as data brokers or our business partners.
HOW WE MAY USE PERSONAL INFORMATION
- PROVIDING THE SERVICES:
- To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with customer service;
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request other information about our Services;-To verify your information and provide related customer service;
- To send you administrative information, such as changes to our terms, conditions and policies; and
- To allow you to send messages to another person through the Services.
For processing your personal information for the above purposes we rely on the necessity to process your personal information for the establishment and performance of the Twill, Inc. Terms and Conditions; to the extent we process your PHI for the above purposes and where required applicable data protection laws, such as where you use our Services from the EEA/EU or UK, we rely on your consent which we ask for when you register for your account. You can withdraw your consent anytime with effect for the future by contacting email@example.com; however, please note that, since processing your PHI is necessary for the provision of the Services, if you do not provide or withdraw your consent you cannot use our Services.
- PROVIDING YOU WITH INFORMATION ABOUT OUR NEW SERVICES AND/OR MARKETING MATERIALS AND FACILITATE SOCIAL SHARING:
- To send you marketing related emails with information about our services, new products and other company news.
Where required applicable data protection laws, such as where you use our Services from the EEA/EU or UK, we rely on your consent for processing your data for sending email marketing which we ask for when you register for your account. You can withdraw your consent(s) anytime with effect for the future by contacting firstname.lastname@example.org, or by clicking on the 'unsubscribe' link at the end of the email marketing communication.
IMPROVING OUR SERVICES: We may use your personal information to the extent necessary for the purposes of our legitimates interests in improving our services.
PROVIDING PERSONALIZED SERVICES: We may use your personal information to the extent necessary for the purposes of our legitimate interests in better understanding your interests and preferences so we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
AGGREGATING AND/OR ANONYMIZING PERSONAL INFORMATION: We may aggregate and/or anonymize personal information that it will no longer be considered personal information. To the extent we aggregate and anonymize your PHI and where required by applicable data protection laws we rely on your consent which we ask for when you register for your account.
ACCOMPLISHING OUR BUSINESS PURPOSES: We may further use your personal information to the extent necessary for the purposes of our legitimate interests in achieving the following objectives:
- For data analysis to, for example, improve our efficiency;
- For audits to verify that our internal processes function as intended and to address legal, regulatory or contractual requirements;
- For fraud prevention and security monitoring to, for example, detect and prevent cyberattacks and identity theft;
- For developing new products and services;
- For enhancing, improving, repairing, maintaining or modifying our current products and services, as well as undertaking quality and safety assurance measures;
- For identifying usage trends; For determining the effectiveness of our promotional campaigns.
DISCLOSURE OF PERSONAL INFORMATION
PARTNERS: We may share your data (excluding your PHI in identifiable form) with other companies, such as companies with whom we jointly offer products and services.
THIRD PARTY SERVICE PROVIDERS: We may share personal information with certain service providers whose services and solutions complement, facilitate and enhance our own. These include hosting and server services, communications and content delivery networks (CDNs), data and cybersecurity services, performance measurement services, data optimization and marketing services, content providers and our legal and financial advisors. Such service providers may have access to personal information according to their particular roles and purposes.
INFORMATION YOU SHARE: Twill enables you to share your personal information with others, including healthcare providers, friends and contacts via social media, our app or other platforms. Please use caution when sharing your personal information with others. The information you share will be shared according to your instructions and actions, and we have no control over what happens with your information once you share it with others.
OTHER USES AND DISCLOSURES OF PERSONAL INFORMATION
APPLICABLE LAW: We may share personal information to comply with applicable law and regulations, which may include laws outside your country of residence.
TRANSACTION, LIQUIDATION: We may share personal information with third parties in connection with a transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, or in the event of a bankruptcy or related or similar proceedings.
PUBLIC AND GOVERNMENT AUTHORITIES, LAW ENFORCEMENT: Where permitted or required by applicable data protection laws, we may disclose your personal information pursuant to a legal request or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
PROTECTING RIGHTS AND SAFETY: Where permitted or required by law, we may share your personal information with others if we believe in good faith that it will help protect the rights, property or personal safety of Twill, any of our users or any member of the general public, with or without notice to you.
YOUR CHOICES REGARDING PERSONAL INFORMATION
EMAIL AND SMS MESSAGING: We may use your email address or phone number to send you messages, such as feature changes and special offers. Where necessary by applicable laws, such as if you are in the EEA/EU or UK, we send such messages only if you provided your prior consent. If you do not want to receive such notifications, you may opt-out or change your preferences by contacting our support team at email@example.com. Subject to regulatory requirements, opting out may prevent you from receiving notification including notices regarding updates, improvements or offers. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
MARKETING: We give you choices regarding our use and disclosure of your personal information for marketing purposes.
ACCESS, CHANGE, OR DELETE YOUR PERSONAL INFORMATION
If you would like to request to access, correct, update, suppress, restrict or delete personal information, object to or opt out of the processing of personal information, or if you would like to request a copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us per the “Contact Us” section below. We will respond to your request consistent with applicable law.
This Website may contain links to third-party owned and/or operated websites. Twill is not responsible for the privacy practices or the content of such websites. Third-party websites have separate privacy and data collection practices, and Twill has no responsibility or liability relating to them.
HOW WE ADVERTISE
We use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Services and other websites or online services. You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as mobile phone and laptop.
HOW NOT TO RECEIVE ONLINE ADVERTISING
For more information about this practice and how to opt out, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You also may download the AppChoices app at https://www.aboutads.info/appchoices specifically for mobile.
To support our Services, we may use one or more of the following cookie and tracking technologies for the purposes set forth below:
- TYPES OF TRACKING TECHNOLOGIES AND PURPOSES:
- Essential Cookies – To provide our Services to you. For example, essential cookies allow you to log into secure Services areas and help load content quickly. Without these cookies, Services you requested could not be provided.
- Functionality Cookies – To allow our Services to remember your user choices, such language preferences, login details, polls you voted in, poll results and any other customizable parts of our Services.
- Social Media Cookies – Used when you share information from our Services to your social media account(s). This may include selecting “share” or “like” from our Services platform or engaging with our content on our social media accounts. The social network will record that you have done this.
- Pixel Tags – These small graphic files allow us and third parties to monitor and collect data about your visit, such as the IP address of the computer that downloaded the page where the tag appears, how long you remained on the page, which browser you used to get there, and the identification number of any cookie previously placed by that server on your computer. We may use pixel tags provided by us or by third party advertisers, service providers and ad networks in combination with our cookies to provide offers and information of interest to you. Pixel tags also may enable ad networks to serve you targeted advertisements.
For more information, please visit https://allaboutdnt.com/.
We will keep your personal information for as long as your user account is active so you can access your information and our Services.
We may continue to retain your personal information after you deactivate your user account or stop using Twill, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our users, enforce our agreements or protect our legitimate interests, consistent with applicable law.
We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by emailing firstname.lastname@example.org.
ADDITIONAL INFORMATION FOR USERS OUTSIDE THE USA
To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Twill is committed to resolving complaints about your privacy and our collection or use of your personal information transferred to the USA pursuant to applicable data protection law.
ADDITIONAL INFORMATION FOR USERS IN THE EEA, EU and UK
If you are in the European Economic Area (EEA), European Union (EU) or United Kingdom (UK), your personal information may be protected by the European Union General Data Protection Regulation or the United Kingdom Data Protection Act (collectively, “European Privacy Laws”). For individuals whose Personal Information is protected by the European Privacy Laws, please know that Twill, Inc. is the data controller responsible for the collection, use, and disclosure of your Personal Information under this Privacy Statement.
If your Personal Information is protected by the European Privacy Laws, you may have the following rights in relation to your Personal Information:
- The right to access: You have the right to request from us a copy of the Personal Information we hold about you.
- The right to rectification: You have the right to request that we correct any Personal Information about you that is inaccurate, and to request that we complete the Personal Information we hold about you where you believe it is incomplete.
- The right to erasure: You have the right to request that we erase your Personal Information, under certain conditions. In the event of an erasure request, we may retain a copy of your Personal Information for our record keeping purposes and to avoid entering your Personal Information in our systems after your request.
- The right to restrict processing: You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
- The right to object to processing: You have the right to object to our processing of your Personal Information, under certain conditions, and you have an unconditional right to object to the processing of your Personal Information for direct marketing purposes.
- The right to data portability: You have the right to request that we transfer the Personal Information we have collected about you to another organization, or directly to you, under certain conditions. You can also request a copy of your Personal Information in a structured, common, and machine-readable format.
- The right to withdraw consent: Where we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. Your withdrawal of consent does not impact the lawfulness of our processing up to the point of consent withdrawal.
- The right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you in a similar way, if the legal requirements are not met. An automated decision making process is not carried out by Twill.
- The right to make a complaint to your data protection regulator. Here is a list of the data protection regulatory authorities in the EU: https://edpb.europa.eu/about-edpb/board/members_en.
Please note that there are exceptions to the various rights listed above. As an example, in certain circumstances we may have a legal obligation to retain some of your Personal Information.
You can submit requests to exercise these rights by emailing firstname.lastname@example.org. We try to respond to all legitimate requests within one month or quicker if legally required to do so. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information or to exercise any of your other rights. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you would like to submit a complaint regarding our practices in relation to your Personal Information, please email our Data Protection Officer at email@example.com. We will reply to your complaint as soon as we can. Our EU representative for data protection purposes is Rickert Rechtsanwaltsgesellschaft mbH. If you would like to contact our representative, please e-mail firstname.lastname@example.org, or send a letter to: Kaiserplatz 7-9, 53113 Bonn, Germany.
INFORMATION FOR CALIFORNIA RESIDENTS
California law provides specific privacy rights related to your personal information. These rights include the rights to know, delete, opt out of sale, and to not be discriminated against for exercising your rights. Please note that we do not sell personal information. You or your authorized agent may submit a request by contacting us via email at email@example.com Note that we require individuals to identify themselves and the information requested to be accessed or updated before we will process such requests. We will comply with your request as soon as reasonably practicable, including by verifying your request by comparing the information you provide against the information we have on file. However, we may maintain personal information where exceptions to your rights apply. We will not discriminate against you based on your exercise of the above-listed choices.