Effective as of 25th August, 2020
Welcome to Twelv App!
PERSONAL INFORMATION AND PRIVACY
• What personal information we collect and why we collect it;
• how we use Your personal information;
• who we share Your personal information with; and
• Your options to control access, update and remove your personal information from the App.
Overview of Our Privacy Practices
• Collect non-identifiable information regarding App users and activity within the App;
• Retain your personal information in compliance with our legal obligations and only as long as necessary for the purposes of which it was collected; and
• May share your personal information with our partners or service providers operating outside of Canada, including those in the United States.
WE DO NOT SELL, RENT, OR LEASE TO THIRD PARTIES ANY PERSONAL INFORMATION WE COLLECT ABOUT YOU.
We mitigate the risk and impact of potential harms involved in the disclosure of personal information through the adoption of reasonable physical, technical and organizational procedures appropriate to the sensitivity of the data in an effort to safeguard the personal information you provide to us.
Even with physical, technical and organizational measures adopted by us, there is a residual risk of the loss of, unauthorized access to or unauthorized disclosure of Your information which could result in financial or other harm to you. In addition, there is a risk that your personal information may be accessible to law enforcement and national security authorities in the jurisdictions in which our service providers are located.
You may withdraw your consent to the collection, storage, use, disclosure and retention of your personal information at any time.
Further information with respect to our privacy practices is set out below.
CONSENT FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
BY USING THE TWELV APP, YOU CONSENT TO THE COLLECTION, STORAGE,
USE, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION BY
WHAT KINDS OF INFORMATION DO WE COLLECT?
The information we collect from you depends on how you use the App. We will only personal information that is reasonably necessary to be collected for the purpose of providing our Services to you. You should exercise discretion when disclosing your personal information to us, and should not disclose sensitive or confidential information that you wish to remain private. The kinds of information we collect include:
• Personal information and content you provide to us directly.
When you subscribe to our services, we may collect certain basic information such as your name, address, email address, telephone number and Apple ID subscriber information. We use this information to register your account and set up your profile within the services. We also collect your login credentials for the purpose of administering the account. While using the services, you may create or share content, photos, communications and other information which contain personal information. This information may be used and stored by us for the purpose of providing the services. We may also collect personal information when you contact us directly or through the App. If you contact us, we may keep a record of the correspondence. We do not make any use of your email address or other contact information, other than to respond to the communication.
• Information others provide about you. We receive information from Apple Inc. when you subscribe to Twelv App. This information is used to register and maintain your Twelv App account. Additionally, we may receive content, communications and information that other users provide when they use the App. This can include information about you, such as when others share or comment on a photo of you or send a message to you on the App.
HOW DO WE USE THE INFORMATION WE COLLECT?
We use the personal information we collect for the following purposes:
• To register you to use the App and to authenticate users for security purposes;
• To cross reference with the personal information you previously provided to us
to ensure accuracy;
• To administer the App and your user account and to manage the emails that we send to you;
• To verify Your Apple subscription payments to use the App;
• To provide registered users with services on the App;
• To obtain feedback on your experience using the App;
• To contact you in connection with the App and to respond to Your inquiries;
• If you opted in to allow us to do so, to market and advertise our services to you;
• To communicate with you, provided you have opted to receive such communication;
• To improve the App’s performance and functionality;
• To conduct research and analysis, including to compile aggregated nonidentifiable information;
• To protect us and App users against fraud;
• To combat harmful content and maintain the integrity of our services;
• As permitted by, and to comply with, applicable laws and regulations.
USE AND DISCLOSURE OF PERSONAL INFORMATION
WE DO NOT SELL, RENT, OR LEASE TO THIRD PARTIES ANY PERSONAL
INFORMATION WE COLLECT ABOUT YOU. We may disclose or share personal
We may anonymize your information for internal use related to analysis and improvement of the App and its features.
Twelve App may use outside service providers with respect to some of its Services. We provide information and content to our service providers only as necessary to provide you with the App’s services. Information that is shared is strictly related to your use of the App and not for any third party use outside of the App.
Twelve App will disclose personal information only if consent is given by the relevant individual or:
• when permitted or required by law, such as in response to a subpoena or other legal process;
• to detect, prevent or mitigate fraud or security or technical issues;
• to protect against imminent harm to the rights, property or safety of our company, our customers or the public as required or permitted by law;
• to Twelve App’s service providers in accordance with this Policy; or
• to meet legal obligations, including but not limited to regulatory reporting obligations.
Twelve App uses the following third parties and service providers:
• we use Apple Inc. to subscribe and register you to our services and to maintain the subscription
• we use Amazon Web Services to host the App’s software infrastructure and monitor performance
• we use Twilio to send SMS texts for verifying your identity
HOW DO WE PROTECT YOUR PRIVACY?
We employ physical, technical and organizational safeguards appropriate to the sensitivity of the data to protect the personal information you provide to us from loss, theft, unauthorized disclosure, copying and unauthorized use or modification. Notwithstanding these measures, no collection, storage or transmission of information over the Internet on websites or otherwise can be guaranteed to be 100% secure, and therefore we cannot ensure, warrant or guarantee the security of any such personal information.
If you think the personal information you provided to us has been improperly accessed or used, or if you suspect that unauthorized use of your personal information, please contact us immediately at email@example.com.
Twelv App shall comply with, and provide users with reasonable assistance in complying with applicable laws with respect to any unauthorized use, access, or disclosure of personal information.
How long do we Retain your Personal Information?
We will keep and retain your personal information in compliance with our legal obligations, and only as long as necessary for the purposes for which it was collected. Personal information that is no longer required will be securely destroyed, erased or made anonymous according to our guidelines and procedures. For further details on our data retention periods, please contact us using the information provided in Section 14 below.
WHERE is YOUR PERSONAL INFORMATION stored?
YOUR RIGHTS AND ACCESS TO THE INFORMATION WE COLLECT
• You have the right to access personal information that Twelv App processes about you. You can request from us information about:
• the personal information we hold about you;
• the categories of personal information concerned;
• the purposes of the processing;
• details to whom your personal information has been/will be disclosed;
• how long we retain your personal information;
• if we did not collect the information directly from you, information about the source; and
• how to lodge a complaint with the correct supervisory authority.
You may also request from us the following:
• that we update any incomplete or inaccurate information about you; and
• that we delete your personal information in accordance with applicable laws.
You may request this information by contacting us as set out in Section 14 below.
WITHDRAWING CONSENT TO THE USE OF YOUR PERSONAL INFORMATION
You may withdraw your consent to the collection, storage, use, disclosure and retention of your personal information at any time, subject to legal and contractual restrictions and reasonable notice. To do this, please contact our Privacy Officer at firstname.lastname@example.org. Withdrawal of your consent to the collection, storage, use, disclosure and retention of personal information may result in you being unable to continue use of the App or our services.
Third Party Links
The App and the emails that we may send to you may contain hypertext links to the websites of third parties. We are not responsible for the privacy practices or the content of such other websites. Linked websites are maintained by third parties. Such links are provided for your convenience and reference only. We do not operate or control, in any respect, any information, software, products or services available on such third party websites. The inclusion of a link to a website does not imply any endorsement of the service or the site, its contents, or its sponsoring organization. We encourage our App users to be aware that when they leave our App, they should thoroughly read the privacy statements of each and every web site that collects personally identifiable information.
Mailing Address: 215 Carlingview Drive, Etobicoke, Ontario, Canada M9W 5X8 (Unit 308)
Email Address: email@example.com
Please note that when requesting access to personal information we may request confirmation of your identity to protect you.