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Privacy Policy
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Privacy Policy


Last updated: 19 May 2021

This Privacy Policy explains in detail how we collect, use and disclose your personal data. Please read this document carefully before submitting any personal data to us.

General Information

1.1 About the Privacy Policy. This Triwey Privacy Policy (the “Privacy Policy”) governs the processing of personal data collected from natural persons (“you” and “your”) through the website https://triwey.com, the related software and services (collectively, “Triwey”). The Privacy Policy does not apply to any third-party websites, applications, software, products, or services that integrate with Triwey or are linked from Triwey. 
1.2 Owner of Triwey. Triwey is owned and operated by MCLEAF S.R.L. having a registered business address at Via Massena 12/7, 20145, Milano, Italy, and a registration number IT10432790961 (“we”, “us”, or “our”).
1.3 Our role as a data controller. We act in the capacity of a data controller with regard to the personal data processed through Triwey in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
1.4 Your consent. Before you submit any personal data through Triwey, you are encouraged to read this Privacy Policy that is always available on Triwey to understand on what legal bases (other than your consent) we rely on when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, your consent may be necessary if: (i) we intend to collect other types of personal data that are not mentioned in this Privacy Policy; (ii) we would like to use your personal data for other purposes that are not specified in this Privacy Policy; or (iii) we would like to transfer your personal data to third parties that are not listed in this Privacy Policy. 
1.5 Children. Triwey is not marketed and should not be used by children. We do not intentionally collect children’s personal data. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay.  
1.6 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.
1.7 Amendments. The Privacy Policy may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

What personal data do we collect and for what purposes do we use it?

2.1 Sources of personal data.
We obtain your personal data from the following categories of sources:
Directly from you. For example, if you submit certain personal data directly to us when contacting us;
Directly or indirectly through your activity on Triwey. When you use Triwey, we automatically collect technical information about your use of Triwey for analytics and security purposes; and
From third parties. We may receive information about you from third parties to whom you have previously provided your personal data if those third parties have a lawful basis for disclosing your personal data to us.
2.2 Types and purposes of personal data.
We respect data minimization principles. This means that we collect only a minimal amount of personal data through Triwey which is necessary to ensure the proper provision of Triwey as described below. We use your personal data for limited, specified, and legitimate purposes explicitly mentioned in this Privacy Policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying on one of the available legal bases. You can find more information about the legal bases below.
Your account.
When you register your user account, we collect your email address and password. When you decide to update your user account, you can add your phone number (optional). We use such data to register and maintain your user account and contact you, if necessary. The legal basis on which we rely is ‘performing a contract with you and ‘your consent (for your phone number). We keep such data until you delete your user account.
When you contact us by email or through the contact form available on Triwey, we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests (i.e., to grow and promote our business) and ‘your consent (for optional personal data). We keep your personal data until you stop communicating with us.
When you leave a comment under our blog post, we collect your name, email address, and any information that you decide to provide in your comment. We use such data to feature your comment and enforce our legal terms. The legal basis on which we rely is ‘pursuing our legitimate business interests. We keep such data as long as your comment is featured on Triwey.
Cookies and IP address.
When you use our website https://www.triwey.com, we collect your cookie-related data and IP address in an anonymized form for analytics purposes. For more information about the purposes for which we use cookies, please refer to our Cookie Policy. It also explains how long your cookies are valid. The legal bases on which we rely are ‘pursuing our legitimate business interests (i.e., to analyze and promote our business) and ‘your consent (for non-essential cookies).  
2.3 Sensitive data.
We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation.   
2.4 Refusal to provide personal data.
If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of Triwey, receive our services, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

What technical (non-personal) data do we collect?

3.1 Log files and analytics data. In order to analyze your use of Triwey and comply with the applicable laws, we collect non-personal technical data, such as:
Your device type;
Your operating system;
URL addresses clicked to and from Triwey; and
Information about your use of Triwey.
3.2 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records. 
3.3 Purposes of technical (non-personal) data. We use your technical (non-personal) data for the following purposes:
To examine the relevance, popularity, and engagement rate of Triwey; 
To investigate and help prevent bugs, security issues, and abuse; and
To develop and provide additional features to Triwey.
3.4 Aggregated and de-identified data. If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data and make sure that we have a legal basis for processing it. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.

How do we communicate with you?

4.1 Newsletters. We may, from time to time, send you a newsletter informing you about the latest developments related to Triwey and our special offers. You will receive our newsletters by email in the following instances.
If we receive your express (“opt-in”) consent to receive marketing messages; or
If you voluntarily subscribe to our newsletter; or
If we decide to send you information closely related to services already used by you.
4.2 Opting-out. You can opt-out from receiving our commercial communication at any time free of charge by clicking on the ‘unsubscribe link that you can find in each newsletter or by contacting us directly.
4.3 Tracking pixels. The newsletters sent by us may contain tracking pixels that allow us to conduct an analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We use such information to conduct analytics and pursue our legitimate business interests.
4.4 Service-related notices. If necessary, we will send you important informational messages, such as updates, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out of service-related notices. 

How long do we keep your personal data?

5.1 Retention of personal data. We store your personal data in our systems only for as long as such personal data is required for the purposes described in section 2 of this Privacy Policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.
5.2 Retention of technical (non-personal) data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. For example, we can store it for the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
5.3 Retention as required by law. In certain cases, we are required by law to store your personal data for a certain period of time (e.g., for business records). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires

How do we share and disclose your data?

6.1 Disclosure to data processors. From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:
Ensuring the proper operation of Triwey;
Ensuring the delivery of the services ordered by you;
Providing you with the requested information;
Pursuing our legitimate business interests;
Enforcing our rights, preventing fraud, and security purposes;
Carrying out our contractual obligations; or 
If you provide your prior consent to such disclosure. 
6.2 List of our data processors. We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that have access to your personal data are: 
Our hosting and database service provider SiteGround located in Bulgaria;
Our mailing service providers Mailchimp and Activecampaign located in the United States;
Our marketing service providers Hotjar located in Malta, Facebook, and Google located in the United States; 
Our chat service providers Tidio and ManyChat located in the United States; 
Our review service provider Trustpilot located in Denmark;
Our analytics service providers Hotjar located in Malta, Google Analytics located in the United States, and Getsitecontrol located in Cyprus;  and
Our independent contractors and consultants.
6.3 Disclosure of technical (non-personal) data. Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving Triwey, responding to lawful requests from public authorities, or developing new products and services. 
6.4 Legal requests. If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
6.5 Successors. In case Triwey is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy. We will notify you of any changes to the data controller. 
6.6 Selling personal data. We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetization purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross-device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your personal data used for such purposes as described in our Cookie Policy.
6.7 International transfers. Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.

How do we protect your personal data?

7.1 Our security measures We implement organizational and technical information security measures to protect your personal data from loss, misuse, unauthorized access, and disclosure. The security measures are taken by us include:
Access control;
Secured networks;
Strong passwords;
Security certifications;
Anonymisation of personal data (when possible); and
Carefully selected data processors.
7.2 Security breaches.
Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law. 

What rights do you have with regard to your personal data?

8.1 The list of your rights. You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):
Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
Right to rectification: you can rectify inaccurate personal data that we hold about you;
Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
Right to restriction: you can ask us to restrict the processing of your personal data;
Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
Right to object: you can ask us to stop processing your personal data;
Right to withdraw consent: you have the right to withdraw your consent if you have provided one; or
Right to complaint: you can submit your complaint regarding our processing of your personal data.
8.2 How to exercise your rights? If you would like to exercise any of your rights, please contact us by email or by post (you can find our contact details at the end of this Privacy Policy) and explain your request in detail. In order to verify your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.
8.3 Complaints. If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
8.4 Non-discrimination. We do not discriminate against you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with lower quality services.

Our contact details

If you have any questions about this Privacy Policy or our data protection practices, please contact us by using the following contact details:
Email: privacy@triwey.com 
Postal address: MCLEAF S.R.L., Via Massena 12/7, 20145, Milano, Italy