(Last Amended: May 24, 2022)
This Privacy Policy (“Privacy Policy”) is an integral part of our Terms of Use (“Terms”) and governs the processing and transfer of personal data collected or processed by Twigo.TV Ltd. (“Company“, “Twigo,” “we,” “us,” or “our”) in connection with its users' access and use of its website, Platform and Services. Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms
This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).
To provide the Facebook Products, we must process information about you. The types of information we collect depend on how you use our Products. You can learn how to access and delete information we collect by visiting the Facebook Settings and Instagram Settings.
1. ADDITIONAL POLICIES
In the event you are a resident of California please review our CCPA Privacy Notice.
2. CONTACT DETAILS OF THE CONTROLLER
Twigo is considered as the “Data Controller” of the Personal Data we collect from you directly, as further detailed below.
Twigo.TV Ltd., 114 Yigal Alon St., Tel Aviv-Yafo, 6744320, Israel.
Data Protection Officer “DPO”:
Twigo as the data controller appointed a data protection officer that can be contacted at: info@twigo.gg.
Other:
If you have any questions or comments about this Privacy Policy, or any concerns with respect to how your privacy any information are handled, please contact our privacy team at: info@twigo.gg.
3. WHICH DATA DO WE COLLECT AND FOR WHAT PURPOSE?
You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data and how it is technically processed.
We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from which we have collected the Non-Personal Data. Non-Personal Data usually includes technical information. The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”). For avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).
The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:
| DATA SET | PURPOSE AND OPERATIONS | LAWFUL BASIS |
|---|---|---|
| Online Identifiers Agent, unique ID, Cookie ID, IP and other online unique identifiers. | We process such data when a you browse our website through third party cookies for analytic and remarketing purposes. | Consent which we will obtain through our cookie notice and consent management platform we use (“CMP”). |
| Account Data When you register and create an account on the Platform, you will be required to provide us with information such as contact information (name, email address), user name, and assigned password. | We use this data to create an account and enable the Services. | Our lawful basis for the collection and processing of the Account Data is the performance of our contract with you – meaning, to create and administrate your Account in order to enable you to use our Services. |
| Premium Services Certain Services provided through the Platform, may be subject to payments or otherwise paid subscription. In such event, you will be requested to provide with the applicable details of your Personal Data and payment details. The payment is processed by our third-party partners; we do not store or process any of credit card information. If any of our plans will require any payment or subscription, we will also collect, retain and process your billing data, in a secure manner under common standards. | We will use and process purchase information in order to enable you to purchase the Premium Services | We process your member data for fulfilling our contract with you. After you will terminate the Services, we will keep record of your data as part of our legitimate interests. |
| Contact Information If you voluntarily contact us for support or other inquiries, you may be required to provide us with certain information such as your name and email address. | We will use this data to provide you with the support you requested or to respond to your inquiry. | We process such Contact Information subject to our legitimate interest in order to respond to your inquiry |
| User Generated Content If you voluntarily post a comment or make available any User Generated Content on the Platform, the content of your comments, might be stored. | To enable you leave a comment or any User Generated Content on one of our live streams. | Any information you provide is subject to YouTube, Twitch, Meta, and Trovo privacy policies which we recommend you review. |
Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of personal data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on out legitimate interests.
4. HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with the Platform and Services, we may collect information either automatically or voluntarily provided by you.
- Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies in connection with our website. The way in which we, and third parties placing cookies in connection with the Services, use cookies and collect data, is explained in our Cookie Policy. We further automatically process and collect the Recipient Behavior Data on behalf of the Customer.
- Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a physical agreement, contact us communications, etc. all as detailed in this Privacy Policy.
- Provided by Third Parties - as part of our digital marketing efforts as described hereunder.
5. DATA SHARING– CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
We share your data with third parties, including trusted partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.
| CATEGORY OF RECIPIENT | DATA THAT WILL BE SHARED | PURPOSE OF SHARING |
|---|---|---|
| Various Service Providers (payment processors, marketing, CRMs, etc.) | Contact and Payment Information. | Processing the payment, marketing, and support. |
| Cloud Service Provider | All data | AWS provide us with data storage and hosting services. Our servers are located in Ireland. |
| Analytics Service Provider | Online Identifiers | Please see our cookie policy. |
| Legal and law enforcement | Subject to law enforcement authority request. | We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose. |
Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).
6. AUTHORIZED THIRD-PARTY APPS INTEGRATION
To upgrade our Services and provide you with an all-in-one live streaming experience, our Platform enables you to connect accounts from other platforms to sync streaming data personalized to you. Twigo provides platform-compatible integration for the following platforms:
- YouTube API Integration - We use YouTube API Services to offer you to connect to your Google account to auto-capture YouTube live streams. By using YouTube's API integration, you agree with YouTube Terms of Service and Google Privacy Policy. Disclosure: Twigo's use of information received from YouTube APIs adheres with Google API Services User Data Policy.
- Twitch API Integration - Sync RTMP Ingests from a Twitch Channel. Twigo allows you to connect to Twitch channels to auto-capture live streams for the connected Twitch channel. By using Twitch's API integration, you agree with Twitch's Privacy Notice and Terms of Service.
- Trovo API Integration - Sync RTMP Ingests from a Trovo Channel. Twigo allows you to connect to Trovo channels to auto-capture live streams for the connected Trovo channel. By using Trovo's API integration, you agree with [Trovo's Privacy Policy](Privacy Policy) and Terms of Service.
- Meta API Integration - By using Facebook's API integration, you agree with Facebook's Privacy Policy and Terms of Use.
7. DATA TRANSFER
Our databases are currently located in Ireland and certain processing activities are conducted from the HQ offices in Israel.
Any information you provide us may be transferred to and processed in countries other than the country from which you accessed our Services. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.
8. DATA RETENTION
We only keep your data as long as required to fulfill the purpose for which the data was collected, or as we are required by law.
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
9. USER RIGHTS
You may have certain rights regarding the Personal Data that Twigo has collected about you. We provide all individuals, regardless of where you are based, the same opportunity to exercise your rights.
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Depending on your relationship with Twigo (e.g., if you are a visitor of our website or a user of our Platform), data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction):
- The right to access your Personal Data that we process;
- The right to ensure your Personal Data is accurate, complete and up to date;
- The right to have your Personal Data amended (by correcting, deleting or adding information);
- The right to object to the processing of your Personal Data, to the extent applicable;
- The right to send or “port” your Personal Data;
- The right to file a complaint with a supervisory authority in your jurisdiction;
- The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;
- Right to Non-Discrimination; and
- Rights to submit a “Do not sell” request, where applicable.
You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here, and send it to our DPO at: info@twigo.gg.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.
10. SECURITY
We take great care in implementing and maintaining the security of our website, Platform, our Services and your information. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such.
We have implemented technical, physical and administrative security measures to protect the Personal Data. In addition, we limit access to your information on our servers. The data collected by us is stored in the AWS Ireland data servers, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security/.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our website, Platform or Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
11. CHANGES AND UPDATES
The terms of this Privacy Policy will govern the use of the website, Platform, the Services and any information collected therein. Twigo reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. In the event of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the Website. Such substantial changes will take effect seven (7) days after such notice was provided on the Twigo Services or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Amended” date and your continued use of the Services after the Last Updated date will constitute acceptance of, and agreement to be bound by, those changes.