Privacy policy
Last updated: 2023-01-18
Privacy policy
Your personal integrity is of high importance for us.
- Who we are
Twiceme Technology AB (“Twiceme Technology”, “we”, “our” or “us”), reg. no. 559120-3905, is a company founded in Sweden. Twiceme Technology is the data controller and can be contacted at the following address: Kronobergsgatan 21, 112 33, Stockholm, Sweden, e-mail: info@Twiceme.com. Twiceme Technology respects your privacy and is committed to responsibly collecting, maintaining, and using personal information about you. Our aim is to ensure that all personal data processed by us should be kept safe and secured at all times and that personal integrity is respected.
- What we do
Twiceme Technology has developed a concept in which personal vital data is uploaded from a near field communication (“NFC”) enabled smartphone, with a Twiceme mobile application (“Twiceme software”) to an integrated device (“Twiceme hardware”) which is denoted by the Twiceme trademark (“Twiceme brand”). In case of an emergency situation, an NFC enabled smartphone is placed over the Twiceme Brand, that signifies the integrated Twiceme Hardware, which enables the uploaded vital information to be read by the Twiceme Software (“the Twiceme Concept”).
All data provided to the Twiceme Software is locally stored and all data uploaded to the Twiceme Hardware is locally stored, hence Twiceme Technology does not process any personal data within the Twiceme Concept, whether or not by automated means, such as collection, recording, organisation, structuring, storage, use and disclosure by transmission other than in your smartphone, which only the user has access to. As part of the functionality of the Twiceme Concept, the user is aware that the information uploaded to the Twiceme Hardware can only be scanned at close range with any smartphone by anyone at any time. To confirm the user’s awareness of the Twiceme Concept, the person needs to accept the Terms and Conditions(“Terms and Conditions”) in the Twiceme Software when installing it.
- Introduction to Privacy Policy
To pursue the legitimate interest of Twiceme Technology, we process personal data in our daily operations following the general data protection regulation (“GDPR“) or, for our companies outside of the EU/EEA, other applicable personal data protection legislation.
This Privacy Policy (“Privacy Policy”) applies to anyone visiting Twiceme.com, referred to as “Twiceme Technology Site”, as well as to anyone using our services, products or that we interact with such as customer representatives, representatives of potential customers, representatives of rescue organizations, supplier, and distributor representatives or salespersons. However, this Privacy Policy does not apply to Twiceme Technology employees, interns or employee or intern candidates.
Twiceme Technology is the data controller with respect to the processing of your personal data and may change this Privacy Policy by updating this page. Please review this Privacy Policy from time to time to stay updated on any changes. However, if we would make any changes to this Privacy Policy that could have an impact on your fundamental rights as a data subject, will we inform you directly. If you have any questions regarding this Privacy Policy or our handling of your personal information, please contact us by sending an email to info@Twiceme.com.
- Information we collect
Twiceme Technology is the data controller for personal data processed when someone uses the Twiceme Technology Site, contacts us or we in any other way interact with.
This means that Twiceme Technology is the data controller also for personal data processed about website visitors. Twiceme Technology is further the data controller of personal data relating to customer and supplier representatives and people who use our products and services or otherwise interact with us.
This also means that Twiceme Technology is the data controller for representatives of potential customers or suppliers who are either website visitors who submit personal data through any of the forms on the Twiceme Technology Site or otherwise contact us or people who might be interested in our products and services whose information we got from other sources.
Twiceme Technology will also be the data controller for the data that we collect on how customers or potential customers interact with our communication.
| Type of data | When is it collected? | Why is it collected? |
|---|---|---|
| Email Address | When creating an account | To establish an account identified through an email |
| User’s Name | When an account is created | To display the user’s name for other users and for the user themselves |
| Profile Picture | When an account is created | (optional) To display the user’s profile picture for other users and for the user themselves |
| Last Known Location and Timestamp | When location is shared with selected friends | To provide location sharing functionality with selected friends |
| Authentication Provider (Google or Apple) | When creating an account | To authenticate and link the account using Google or Apple credentials |
| Twiceme Hardware UID | When connecting Twiceme equipment | To associate the Twiceme hardware with the user’s account and enable adding friends through tapping the hardware |
- Lawful ground for processing your data
| Purpose and type of data | Lawful ground for processing |
|---|---|
| To handle and inform representatives of customers, rescue organizations, suppliers, distributors, and other business partners who we interact with.Type of data: Contact information: e.g. name, address, phone number, email or equivalent | The processing is necessary in order for us to meet our legitimate interest of sending information about our business and communicating with our customers and business partners. |
| To understand how representatives of customers, rescue organizations, suppliers, distributors, and other business partners interact with our communications.Type of data. Contact information: e.g. name, email and actions made within the email. | The processing is necessary in order for us to meet our legitimate interest of tailoring the information sent about our business and communicating to our customers and business partners and to inform them in a more efficient way. |
| Our duty to fulfill legal obligations according to legal requirements, judgment by court or decision by authority, e.g. the Accounting ActType of data. Name, personal identification number, e-mail address, phone number, user name, billing address, information about payment | Fulfillment of legal obligation. This collection of your personal data is required by law. |
| Website visitors and individuals using our support or contact us functionType of data. Contact information: e.g. name, address, phone number, email or equivalent. Behavioral and tracking details: e.g. IP-number, cookie identifiers, unique identifier of devices you use to access the Twiceme Technology Site. | The processing is necessary in order for us to meet our legitimate interest of sending information about our business and communicating with our customers. |
| To handle employment and assignments.Type of data. Name, e-mail address, phone number, age and personal identification number, information in resume. | The processing is based on you giving your consent to us communicating with you regarding the current hiring process. The processing of any references and previous colleagues is based on a balancing of the interests of the data subject and the controller. |
| Information about our suppliers, customers and business partners.Type of data. Name, personal identification number, address, e-mail, telephone number and bank account number. | The processing is necessary to fulfill our contract with our suppliers, customers and business partners. |
| Information that is collected as you add additional functionalities to your use of our Twiceme products. Type of data. Username, e-mail address, profile picture, last known location, authentication provider, Twiceme Hardware UID. | The processing is based on you giving your consent to us in order for you to get access to additional services. |
- Sharing personal information to third parties
We may share personal information with members of Twiceme Technology for the purposes set out in this Privacy Policy. Your information may also in certain cases be accessed by third-party service providers who we cooperate with and who will process that information solely for our benefit and in accordance with our instructions and this Privacy Policy.
We may also disclose personal data to authorities to the extent we are under a statutory obligation to do so. Such authorities include tax authorities, police authorities, enforcement authorities, and other authorities in relevant countries.
High levels of security and confidentiality is always considered when transferring your personal data.
- Links to third party sites
Our websites may include links to other websites (“Third Party Sites”) which are outside of our control and not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their Privacy Policy, which may differ from our Privacy Policy. If you decide to access any of the Third Party Sites linked to from Twiceme Technology Sites, you should understand that you do so at your own risk.
- Retention of personal data
We will not process personal data for a longer period than is necessary for fulfilling the purpose of such processing as set out in this Privacy Policy. We will store your personal data in order to communicate with you as long as you are a client, a representative of an entity that is either a client or, when it comes to a potential client of ours, for as long as it is necessary in order to determine whether a business relationship is established or not. We will keep your personal data for as long as it is necessary for us to fulfil our contractual obligations with you, and the entities you represent or until you withdraw your consent. We will also retain your personal data to ensure compliance with our legal requirements.
Your personal data will be anonymized or deleted once it is no longer relevant for the purposes for which it was collected.
- Transfers to third countries
We aim to retain all of your personal data within the European Economic Area (EEA) although, given the global nature of some of our service providers, there may be occasions where it is necessary to transfer your personal data outside the EEA. Should we use a service provider who transfers your personal data to countries outside of the EEA, China for example, we will take measures to protect your personal data in accordance with applicable legal requirements for the purposes set out in this Privacy Policy and we base such transfers and processing on the EU Standard Contractual Clauses.
- How we protect information
We process personal data in accordance with applicable laws and regulations and have implemented appropriate technical and organizational security measures to prevent that your personal information is used for non-legitimate purposes or disclosed to unauthorized third parties and otherwise protected from misuse, loss, alteration, or destruction. Such technical and organizational measures are designed to ensure a level of security appropriate to the risks that are associated with our data processing activities.
- Data subject rights
At any time, you can recall any consent you have given us involving personal data. You have the right to access your personal data or the information we have obtained. You have the option to mitigate your personal data if it is incorrect and have the option to ask us to limit the process of personal data or delete you as an object of personal data. You also have the right to disclose the personal data in a readable format. In order to exercise any of these rights, please feel free to contact us by sending an email to info@twiceme.com.
You have the right (once a year at no cost) to be provided with information regarding what of your personal data we are processing and how we are processing it. You also have the right to obtain rectification in regards to personal data we are processing about you. You also have the right to obtain the erasure of personal data (“the right to be forgotten”). This means that you may demand the erasure of your personal data if it is no longer necessary in relation to the purpose for which it was collected. Bear in mind that there may be legal obligations which prevent an erasure, e.g. legal requirements in tax- or accounting legislation. In order to exercise any of these right, please contact us by sending an email to info@twiceme.com. We may, however, require that you provide an appropriate proof of your identity, e.g. a copy of your ID card, or passport, or any other valid identifying document or service.
You also have the right to lodge a complaint to a Data Protection Authority if you believe that your personal information has been collected or used in breach of relevant privacy regulation. If you are located in Sweden, you should contact the National Data Protection Authority (in Sweden ” Integritetsskyddsmyndigheten”). You may find their contact details at: www.imy.se.
If you are located in the EEA, this will be the Data Protection Authority in the country in which you are located. You may also seek a remedy through local courts if you believe your rights have been breached.
- Use of cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor use of the website and to compile statistical reports on website activities. You may set your browser not to accept cookies. However, in a few cases, some of the Twiceme Technology Site features may not function as a result.
For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.
- Any questions?
Please contact us if you have any further questions regarding this Privacy Policy or our handling of your personal information by sending an email to info@twiceme.com.