TWCC Privacy Policy
This Privacy Policy describes how TWCC (“TWCC”) may collect information from or about you when you visit our website and use our service. TWCC values your privacy and is providing this Privacy Policy to explain what information we collect and how that information may be used by TWCC when you interact with TWCC online.
This Privacy Policy includes the following:
1. OUR COMMITMENT TO YOUR PRIVACY
2. THE INFORMATION AND DATA WE COLLECT
3. HOW WE USE YOUR DATA
4. WHAT DATA OR INFORMATION MAY BE SHARED WITH THIRD PARTIES
5. HOW LONG WE SAVE YOUR DATA
6. HOW TO EDIT OR MODIFY DATA
8. CHILDREN’S PRIVACY
9. INFORMATION SECURITY
11. WHEN THE TWCC PRIVACY POLICY APPLIES/LINKS
12. CHANGES TO PRIVACY POLICY
13. ACCEPTANCE
14. CONTACT
1. OUR COMMITMENT TO YOUR PRIVACY
Introduction - Our goal at TWCC is to help you achieve your goals of learning to communicate more effectively. As we continue to develop our service, we are committed to respecting your privacy and protecting your personal information. We have created our Privacy Policy to inform you about the types of personal information that we may collect from you and how it will be handled. Please take a few minutes to review our policy before using our service or submitting any personal information.
In addition to the aforementioned data, cookies are stored on your computer when you use our Website. Cookies are small text files that are stored on your hard disk by the browser you use and through which certain information flows to the user that places the cookie. Cookies cannot run programs or transmit viruses to your computer. They serve to make the Internet more user-friendly and effective overall.
Use of cookies and HTML 5 Local Storage:
a) This Website uses the following types of cookies, the scope and functionality of which are explained below:
• Transient cookies (see c),
• Persistent cookies (see d).
b) In addition to our use of cookies, this website also uses HTML 5 Local Storage to store website preferences and session information.
c) Transient cookies are deleted automatically when you close your browser. This includes session cookies, which store a so-called session ID that can assign different requests of your browser to the joint session. This will allow your computer to be recognized when you return to our Website. Session cookies are deleted when you log out or close your browser.
d) Persistent cookies and HTML 5 Local Storage are automatically deleted after a specified period, which may vary depending on the cookie or Local Storage setting. You can delete cookies and Local Storage at any time in the security settings of your browser.
e) You can configure your browser settings according to your wishes and refuse to accept HTML 5 Local Storage, third party cookies or any cookies, for example. Please note that, in this event, you may not be able to use all functions of our Website.
When You Create an Account - In order to access TWCC services, we require users to register with us. When you create an account with TWCC, we ask for some personal information, i.e., your name and phone number.
Use of Collected Information - We use the information we collect to operate, maintain, and improve our services.
Other Registration Information - No other registration information will be made public.
When You Add Information to Your Account - You can update your TWCC account or add information to your account at any time. Whenever you add this type of information, we collect it and store it in your TWCC account.
When You Use the Mobile App - You will be invited to download the TWCC App and enter your name and mobile number. This App enables you to record your speeches and upload them for analysis by the TWCC service.
When You Upload Audio in Your TWCC Account - When you upload your voice audio data, recorded through the mobile App, web browser, or by other means, the audio file will be not be stored to our servers. This data is only used for speech to text recognition and is associated with your account.
When You Contact Us for Help - Whenever you contact TWCC for assistance, we collect your name and mobile number along with additional information you provide in your request so that we can provide you with adequate assistance and improve the TWCC service. You can also contact TWCC through public forums such as WhatsApp or Instagram, but we cannot guarantee or maintain the privacy of your communications to us if you choose these public forums.
Information from Other Sources - We do not collect any information about you from other sources outside of your interactions with the TWCC mobile App and/or service unless you or your organization have provided permission to do so.
3. HOW WE USE YOUR DATA
General Administration - We use the information that you share with us to provide you with new and improved services and to better understand your needs.
TWCC may use the following:-
Personal information - TWCC service may require your personal information, business details and your profile picture (The app may use your camera to capture your profile picture or can access the saved pictures from the gallery).
Third Party Channel-Partners – We may share information for research purposes. If you signed up through a link or site provided by a Channel Partner, such as Center for Creative Leadership (CCL), you may have executed terms that vary from this agreement. In some cases, the Channel Partner has been granted the right to own or use your data in different ways. To access your agreement, refer to your agreement with the third-party organization that provided your TWCC account invite link.
Third-Party Agents - We may employ individuals or other companies to perform business functions on our behalf. These trusted entities may have access to information that is required to perform their services but are prohibited by contract and commitments to your confidentiality from utilizing the information for any other purpose. These types of services may include data analysis, transcription of audio recording, payment processing, information technology and related infrastructure, and other similar services.
Disclosure to Government Authorities, Etc. - We may share personal information as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
Mergers and Acquisitions - Circumstances may arise where for business reasons, we decide to sell, expand, merge, or otherwise reorganize our business. A transaction like this may involve the disclosure of personally identifying information to prospective or actual purchasers and/or receiving such information from sellers. It is our practice to seek appropriate protection for your information in these types of transactions, including notifying you if a different company will receive this information. Any successor in a merger or acquisition shall be bound by this Privacy Policy.
Third-Party Links - We may provide links to external websites in order to make certain content and services available to you. These websites are beyond our control and are not governed by our Privacy Policy. Therefore, we are not responsible for the privacy practices or the content of third-party websites and cannot be responsible for the protection and privacy of any information you provide to these sites. When you leave the TWCC website, we encourage you to read the privacy policy of any other website you visit, particularly websites that ask for your personal information.
Cookies - A cookie is a small file containing a string of characters that is stored on a user’s hard drive. TWCC may send one or more cookies to your computer or smartphone in order to uniquely identify your browser. In general, cookies help us determine whether you have previously visited TWCC website and allow us to track the use of our website. Your TWCC cookies will not contain any personally identifiable information whether you have registered or not.
Purpose - We use cookies to store your account information and the preferences you have made while using TWCC. We may also use cookies to track the number of visitors to our website and to help us understand how visitors use the website.
Third-Party Cookies - Advertising partners may help TWCC deliver interactive advertising, such as banner ads, and may also use their own cookies to better understand the types of advertising and promotions that are most appealing to our customers.
Disabling Cookies - While most web browsers automatically accept cookies by default, you may choose to disable or decline cookies from a particular website. Please be aware that if you disable all cookies or even just the cookies delivered by TWCC, this may impact your ability to use our website as well as others.
Browser Controls for “Do Not Track” - Some newer browsers have “Do Not Track” (DNT) features. When engaged, most DNT features send a signal or preference to websites that you do not want to be tracked. Those websites or their third-party advertisers or content providers may continue to engage in activity you may view as tracking, even after you use the DNT, depending on the websites’ privacy practices. Because there is not yet a common understanding of how to interpret the DNT signal, TWCC does not currently respond to the browser DNT signals. We continue to work with the online industry to define a common understanding of DNT signals and to remain compliant with industry standards.
5. HOW LONG WE SAVE YOUR DATA
Personally Identifiable Information - Your personally identifiable information shall be retained by the Company unless you request that it be deleted by contacting info@twcc-tz.org. Your information will only be used for Company research purposes to develop new and improved services and to better understand customers’ needs.
Non-Personally Identifiable Information - We may retain and use non-personally identifiable information such as aggregate data, performance metrics, usage statistics and other data that has been anonymized.
6. HOW TO EDIT OR MODIFY DATA
Data that you provide to TWCC through the website can be deleted from your account from the Manage tab. If you remove data from your account, it will no longer appear to you or others who use the TWCC service. Backups of that data may remain associated with your TWCC account and in our archive servers.
7. HOW TO CANCEL YOUR TWCC ACCOUNT
You can cancel your TWCC account by sending an email titled “Request to Terminate my TWCC Account” to info@twcc-tz.org. Upon any cancellation, your personally identifiable information shall be retained by the Company unless you request that it be deleted by contacting info@twcc-tz.org
8. CHILDREN’S PRIVACY
TWCC is not directed at persons under the age of 13. We do not knowingly collect any personally identifiable information from children under the age of 13. If a parent or guardian becomes aware that their child has provided us with information without their consent, they should contact the TWCC Privacy Officer at info@twcc-tz.org, and we will delete such information as soon as reasonably practicable.
9. INFORMATION SECURITY
Security Practices - We have incorporated security measures like password hashing and idle session logout to protect against the loss, misuse, and alteration of the information under our control. Further, only authorized affiliates, service providers, subsidiaries, and employees, who have agreed to keep the information on TWCC secure and confidential, will have access to our information. While we will make every effort to ensure that the information you provide us will be kept secure, there is no way for us to absolutely guarantee the security of your personal information.
No Liability for Acts of Third Parties - TWCC uses a combination of technical and administrative security controls to maintain the security of your data, exercising all reasonable efforts to safeguard the confidentiality of your personal information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made entirely secure. Consequently, TWCC shall not be liable for unauthorized disclosure of personal information due to no fault of its own, including—but not limited to—errors in transmission and unauthorized acts of TWCC staff and/or third parties.
10. ADDITIONAL INFORMATION FOR EU, UK AND SWITZERLAND BASED USERS
Data protection regulations in Europe require TWCC to disclose additional information regarding Personal Data collected from European users, and to limit TWCC use of such information in specific ways. This section provides additional information applicable to European Personal Data, which may not apply to users in other geographies.
If you are accessing TWCC from the United Kingdom, Switzerland or any country belonging to the European Union, please be advised that it is our policy and intent to adhere to the principles of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, as amended (commonly known as the General Data Protection Regulations, or “GDPR”) for your personal data that it receives from the United Kingdom, Switzerland or any country belonging to the European Union. Therefore, the following provisions shall apply to your personal information if you are accessing the TWCC services from the United Kingdom, Switzerland or any country belonging to the European Union and, although the Privacy Policy, in whole, applies to everyone using TWCC services, to the extent that the following provisions conflict with the provisions provided elsewhere in this Privacy Policy, the following provisions will apply to you.
TWCC is not directed at persons under the age of 16 in the United Kingdom, Switzerland or any country belonging to the European Union, and we do not knowingly collect any personally identifiable information from such children under the age of 16. If you are aware of a user under the age of 16 using any TWCC product or service, please contact us at info@twcc-tz.org. If a parent or guardian becomes aware that their child under the age of 16 has provided us with information without their consent, they should contact the TWCC Privacy Officer at privacyofficer@myTWCC.com, and we will delete such information as soon as reasonably practicable.
Information on the collection of personal data
(1) Personal data are all data that make you personally identifiable, e.g. name, address, email addresses, user behaviour.
(2) When you contact us by e-mail or via a contact form, the data you provide (your email address, if applicable, your name and your telephone number) will be saved by us in order to answer your questions. TWCC will delete the data collected in this context when its storage is no longer necessary or restrict the processing if statutory retention obligations exist.
(3) If TWCC makes use of contracted service providers for individual functions of our services or would like to use your data for advertising purposes, TWCC will inform you in detail about the respective processes below. TWCC does not directly collect sensitive personal information (e.g. information that reveals race, ethnic origin, political affiliations, etc.), but it is possible that you will provide such information in the content of your voice recordings.
(4) TWCC will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. TWCC will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Your rights
(1) You have the following rights regarding personal data concerning you:
(2) You also have the right to complain to a data protection supervisory authority about our processing of your personal data.
Data Portability
Upon request, TWCC shall provide individuals with their personal data that has been provided to TWCC in a structured, commonly used and machine-readable format.
Right to Erasure
Upon request, TWCC shall delete an individual’s personal information without undue delay; provided, however, TWCC has the right to retain such personal information as may be necessary for (i) compliance with legal obligations or for a task carried out in the public interest; (ii) for reasons of public interest in the area of public health; (iii) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes if TWCC takes appropriate measures for data minimization that no longer permits the identification of the individual; and (iv) for the establishment, exercise or defense of legal claims.
Termination/Deactivation
When you terminate or deactivate your TWCC account, data that can identify you will be removed from the TWCC service, and if you consented during sign-up, we can retain your data after your account has been closed, but you are also able to revoke this consent at any time, either before, during or after account closure.
Access and Correction
Upon request, TWCC will grant individuals reasonable access to personal information that it holds about them. In addition, TWCC will permit individuals to correct, amend, supplement or delete information that is demonstrated to be inaccurate or incomplete. TWCC will notify any third party agent to whom the personal information has been disclosed that such personal information has been corrected, unless doing so proves to be impossible or involves disproportionate effort.
Use of social media plug-ins
(1) TWCC currently uses the following social media plug-ins: Facebook, LinkedIn, Twitter, YouTube. TWCC uses the so-called two-click solution. This means that when you visit our Website, no personal data is initially passed on to the providers of the plug-ins. You can recognise the provider of the plug-in by the marking on the box above its initial letter or the logo. TWCC offers you the possibility to communicate directly with the provider of the plug-in via the button. Only if you click on the marked field and thereby activate it, the plug-in provider receives the information that you have accessed the corresponding Website of our online offer. In addition, the data mentioned in the section "Collection of personal data when you visit our Website" of this Privacy Policy will be transmitted. In the case of Facebook, the IP address is anonymised immediately after collection, according to the respective provider. By activating the plug-in, personal data is transferred from you to the respective plug-in provider and stored there. Since the plug-in provider collects data mainly via cookies, TWCC recommends that you delete all cookies before clicking on the greyed-out box using your browser's security settings.
(2) TWCC has no influence on the data collected and data processing processes, nor is TWCC aware of the full extent of data collection, the purposes of processing, or the storage periods. TWCC does not have information on the deletion of the data collected by the plug-in provider.
(3) The plug-in provider stores the data collected about you as user profiles and uses these for the purposes of advertising, market research and/or demand-oriented design of its Website. Such an evaluation takes place in particular (also for non-logged-in users) for the representation of suitable advertisements and in order to inform other users of the social network about your activities on our Website. You have a right of objection to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. Through the plug-ins, TWCC offers you the ability to interact with social networks and other users, so that TWCC can improve our service and make it more interesting for you as a user. The legal basis for the use of the plug-ins is Art. 6 para. 1 sentence 1 lit. f GDPR.
(4) The data is passed on regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected with us will be directly assigned to your existing account with the plug-in provider. If you click the activated button and, for example, link the page, the plug-in provider also stores this information in your user account and shares it publicly with your contacts. TWCC recommends that you log out regularly after using a social network, especially before activating the button, as this way you can avoid being assigned to your profile with the plug-in provider.
(5) Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the privacy policy of these providers listed below. They will also provide you with further information about your rights in this regard and how to set options to protect your privacy.
(6) Addresses of the respective plug-in providers and URLs with their data protection information:
a) LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy. LinkedIn has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
b) Facebook Inc, 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; further information on data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications. Facebook has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework
c) Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. Twitter has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
d) YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA; https://policies.google.com/privacy?hl=en&gl=en.
Integration of YouTube videos
(1) TWCC have integrated YouTube videos into our online website, which are stored on http://www.YouTube.com and can be played directly from our website. These are all integrated in the "extended data protection mode", i.e. no data about you as a user will be transmitted to YouTube if you do not play the videos. Only when you play the videos will the data referred to in paragraph 2 be transmitted. TWCC has no influence on this data transmission.
(2) By visiting the Website, YouTube receives the information that you have accessed the corresponding subpage of our Website. In addition, the data mentioned in the section "Collection of personal data when you visit our Website" of this Privacy Policy will be transmitted. This does not depend on whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged into Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. YouTube stores your data as user profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation takes place in particular (even for non-logged-in users) to provide demand-oriented advertising and to inform other users of the social network about your activities on our Website. You have the right to object to the creation of these user profiles, but you must contact YouTube to exercise this right.
(3) Further information on the purpose and scope of data collection and processing by YouTube can be found in YouTube's privacy policy. There you will also find further information about your rights and how to set options to protect your privacy. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
Choice.
You can contact us any time to opt-out of (a) promotional communications, or (b) any new processing of your personal information that we may carry out beyond the original purpose, or (c) the transfer of your personal information outside the United Kingdom, Switzerland or any country of the European Union (opting out of this subsection (c) will cause TWCC services to be ineffective upon opt-out).
Transfers to Agents.
TWCC will obtain assurances from its agents that they will safeguard personal information consistently with GDPR, including providing the same level of protection as is required under GDPR. Where TWCC has knowledge that an agent is using or disclosing personal information in a manner contrary to GDPR, TWCC will take reasonable steps to prevent or stop the use or disclosure.
Security.
TWCC will take reasonable precautions to protect personal information in its possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Enforcement.
TWCC will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. Any employee that TWCC determines is in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment.
Retention of Personal Information.
If your TWCC account becomes inactive because it was not timely renewed, and you have not opted in to permit us to retain your personal information, we will keep your personal information for a period of three months prior to beginning the process of deleting it. This will enable us to promptly reactivate your account in the event you renew during the initial three month period. Once the process of deleting your personal information has begun, it is possible that it may take up to an additional three months for all copies of your personal information to be removed from all of TWCC systems, backups, log files, and archives.
Objection or revocation of the processing of your data
(1) If you have given your consent to the processing of your data, you can revoke it at any time. Such revocation affects the lawfulness of processing your personal data after you have made it known to us.
(2) If we base the processing of your personal data on the weighing of interests, you may object to the processing. This is the case in particular if processing is not necessary to fulfil a contract with you, which we explain in the following description of the functions. When you do object, we would ask you to explain the reasons why we should not process your personal data. In the event of a justified objection, we will examine the situation and either stop or adjust data processing, or point out to you our compelling reasons worthy of protection, on the basis of which we will continue processing.
(3) Of course, you can object to the processing of your personal data for the purposes of advertising and data analysis at any time. You can inform us about your contradiction using the following contact data:
TWCC,
Dar-Es-Salaam, Tanzania
email: info@twcc-tz.org
Contact/Dispute Resolution
Any questions or concerns regarding the use or disclosure of, or any of your rights regarding, your personal information should be directed to the TWCC Privacy Officer at info@twcc-tz.org. TWCC will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Privacy Policy.
11. WHEN THE TWCC PRIVACY POLICY APPLIES/LINKS
The TWCC Privacy Policy applies to all of our services, products, mobile applications, and our website.
If you use external links that are offered on our website, this Privacy Policy does not extend to those links. When TWCC provide links, we endeavour to ensure that they also comply with our Privacy Policy and security standards. However, we have no influence on compliance with privacy policy and security regulations by other providers and websites. Therefore, please also inform yourself about the privacy policies provided on the websites of other providers.
12. CHANGES TO PRIVACY POLICY
The use of the information that we gather is subject to the Privacy Policy in effect at the time the information is submitted. We reserve the right, however, to update this Privacy Policy at any time. We will post any Privacy Policy changes on this page, and if the changes are more significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes to registered users and/or display notifications on the TWCC website). We will not reduce your rights under this Privacy Policy without your explicit consent. We will also keep prior versions of the Privacy Policy in an archive for your review.
13. ACCEPTANCE
When a significant change to this Privacy Policy goes into effect, registered users will be prompted to review the changes and to select whether they accept or do not accept TWCC planned updates.
14. CONTACT US
You can contact us with any questions or comments at: info@twcc-tz.org