Privacy Shield Notice


Effective: Dec 18, 2019

Twic, Inc. (“Twic”, “we”, “our” or “us”) complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (the “Frameworks”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information (as defined below) that is transferred from the European Economic Area (“EEA”), Switzerland or the United Kingdom to the United States in reliance on the Frameworks. Twic has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (the “Principles”) with respect to such information. If there is any conflict between this Privacy Shield Notice (the “Notice”) and the Principles, the Principles will govern. More information about the Privacy Shield can be found at www.privacyshield.gov. Our Privacy Shield certification can be found at www.privacyshield.gov/list.

This Notice supplements our Privacy Notice https://twic.ai/privacy-and-terms. Unless specifically defined in this Notice, capitalized terms in this Notice have the same meaning as in our Privacy Notice https://twic.ai/privacy-and-terms. In case of conflict between the Privacy Notice https://twic.ai/privacy-and-terms and this Notice, this Notice prevails.

As a data controller, we collect and process Personal Information from the EEA, Switzerland or the United Kingdom directly from individuals as set forth in our Privacy Policy https://twic.ai/privacy-and-terms.

As a data processor, we process Personal Information from the EEA, Switzerland or the United Kingdom, as provided to us by data controllers (i.e., our commercial customers) in order to provide them with our services. In that context, we only process Personal Information on behalf of and at the direction of our commercial customers.

For all types of processing, Twic commits to the Principles of the Privacy Shield with respect to all Personal Information received from the EEA, Switzerland or the United Kingdom.

1. Notice

Our Privacy Notice https://twic.ai/privacy-and-terms in combination with this Notice describe our privacy practices. Twic may receive from the EEA, Switzerland and the United Kingdom some or all of the information listed in our Privacy Notice https://twic.ai/privacy-and-terms. Some of that information may qualify as “personal information” or “personal data” (collectively, “Personal Information”) as defined in the Principles. To the extent that Twic receives Personal Information from the EEA, Switzerland or the United Kingdom in reliance on the Frameworks, Twic will handle such Personal Information in accordance with the Principles.

When we handle Personal Information as a data processor, our commercial customers determine the categories of Personal Information they upload in our systems and the purposes of the processing. Accordingly, our commercial customers are responsible for providing notice to individuals and you should review their privacy policies for more information regarding their data processing practices.

2. Choice

We will give you an opportunity to choose whether your Personal Information may be used for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by you, or if we intend to disclose it to a third party acting as a data controller that we have not previously disclosed to you. In such circumstances, we will notify you and offer you the opportunity to opt-out of such uses and/or disclosures where non-sensitive Personal Information is involved, and to opt-in where sensitive Personal Information is involved. To request to limit the use and disclosure of your Personal Information, please submit a written request as indicated in the section “Contact Us” below.

3. Onward Transfers

Twic may transfer Personal Information to third parties as described in the Privacy Notice https://twic.ai/privacy-and-terms, for the purposes described in the Privacy Notice https://twic.ai/privacy-and-terms. We remain responsible for the processing of Personal Information received under the Frameworks and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

4. Security

Twic takes reasonable and appropriate measures to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

5. Data Integrity and Purpose Limitation

Any Personal Information we receive may be processed by Twic for the purposes indicated in our Privacy Notice https://twic.ai/privacy-and-terms, or as otherwise notified to you. We will not process Personal Information in a way that is incompatible with these purposes unless subsequently authorized by you.

We take reasonable steps to limit the collection and usage of Personal Information to what is relevant for the purposes of processing, and to ensure that the Personal Information we process is reliable for its intended use, accurate, complete and current. We will adhere to the Principles for as long as we retain the Personal Information collected under the Frameworks. Individuals are encouraged to keep their Personal Information with Twic up to date and may contact Twic as indicated below or in the Privacy Notice https://twic.ai/privacy-and-terms to request that their Personal Information be updated or corrected.

6. Access

Where appropriate, we will provide you with access to the Personal Information we maintain about you, and correct, amend or delete that information when it is inaccurate or has been processed in violation of the Principles. Please send your written request as indicated in the section “Contact Us” below. We will review your request in accordance with the Principles, and may limit or deny access to Personal Information as permitted by the Principles.

When we process data as a data processor, our commercial customers control the type of information we obtain, how that information is used and disclosed, and how it can be modified. Accordingly, if you wish to request access, limit use or disclosure of your Personal Information, please contact the customer(s) that submitted your data to us. If you provide us with the name(s) of the customer(s), we will refer your request to those customer(s), and will support them as needed in responding to your request

7. Recourse, Enforcement and Liability

We conduct an annual self-assessment of our practices regarding Personal Information to verify that the attestations and assertions made in this Notice are true and have been implemented as represented

If you have any questions or concerns, we encourage you to first write to us as indicated below. We will investigate and attempt to resolve any complaints or disputes regarding our use and disclosure of Personal Information in accordance with the Principles

Twic has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Twic is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission

8. Changes to this Notice

This Notice may be amended consistent with the requirements of the Privacy Shield. When we update this Notice, we will also revise the “Last Updated” date at the top of this document. Any changes to this Notice will become effective when we post the revised version on our website.

9. Contact Us

If you have any questions, concerns or complaints regarding our privacy practices, or if you’d like to exercise your choices or rights, you can contact us via email at privacy@twic.ai or by mailing to

c/o Data Protection Officer

47000 Warm Springs Blvd., Suite 1-170

Fremont, CA 94539