Privacy Policy

Effective Date: October 26, 2023

Welcome to twirly.xyz. Your privacy is critically important to us. This Privacy Policy document outlines the types of information that is collected and recorded by twirly.xyz and how we use it. This policy applies to our website, twirly.xyz, and all related services (collectively, the "Service").

By using our Service, you consent to the data practices described in this policy. If you do not agree with the terms of this policy, please do not access or use the Service.

1. Information Collection

We collect several different types of information for various purposes to provide and improve our Service to you.

1.1 Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). This may include, but is not limited to:

• Email address
• First name and last name
• Usage Data: Information on how the Service is accessed and used (e.g., page views, session duration, features used).
• Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Service.

1.2 Automatically Collected Data

We automatically collect certain information when you visit, use, or navigate the Service. This information does not reveal your specific identity but may include device and usage information.

2. Use of Information

twirly.xyz uses the collected data for various purposes:

• To Provide and Maintain the Service: Including to monitor the usage of our Service.
• To Manage Your Account: To manage your registration as a user of the Service.
• For Contractual Performance: To develop, comply with, and undertake the purchase contract for the products, items, or services you have purchased.
• To Contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products, or contracted services.
• To Provide News and Offers: To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information.
• To Improve Our Service: We use data analytics to understand how our Services are used so we can improve functionality and user experience.
• For Security and Fraud Prevention: To protect you, our business, and others from fraud, security threats, and other malicious activity.
• To Comply with Legal Obligations: To comply with applicable laws, regulations, and legal processes.

3. Data Protection & Security

The security of your data is important to us. We strive to use commercially acceptable means to protect your Personal Data. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

We implement appropriate technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

• Encryption of data in transit using secure protocols (e.g., TLS).
• Regular security assessments of our systems and infrastructure.
• Access controls to personal information on a need-to-know basis.
• Regular review of our data collection, storage, and processing practices.

In the event of a data breach that affects your personal information, we will notify you and the relevant authorities as required by applicable law.

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Service and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. They are sent to your browser from a website and stored on your device.

We use both Session and Persistent Cookies for the following purposes:

• Essential / Necessary Cookies: Required for the operation of our Service.
• Preference Cookies: Allow us to remember your preferences and various settings.
• Analytics Cookies: Allow us to analyze how the Service is used so we can measure and improve performance.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

5. User Rights

Depending on your location, you may have certain rights regarding your personal information. These may include:

• The Right to Access: You have the right to request copies of your personal data.
• The Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The Right to Erasure: You have the right to request that we erase your personal data, under certain conditions.
• The Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
• The Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• The Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the information in the Contact section below. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

6. Third-Party Services

Our Service may contain links to other sites that are not operated by us. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

We may use third-party service providers to monitor and analyze the use of our Service, such as analytics providers.

7. Children's Privacy

Our Service does not address anyone under the age of 13 ("Children"). We do not knowingly collect