Privacy Policy

A lot of companies say they care about your privacy — we say it and mean it. This document is our Privacy Policy, which describes what information we collect from you and how we use it. Our Privacy Policy applies to our website at www.twincel.com, our mobile website, our mobile application, and all other services Twincel provides. It covers personal information, which is information we can link to you personally. Personal Information (“PI”) includes data like your name, email address, phone number, or mobile device’s unique identifier.

This Privacy Policy is part of the Twincel Terms of Use. Twincel reserves the right to change this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology. Please check this page periodically for changes. By continuing to use our services, you accept those changes and agree to be bound by both policies, so please read them carefully. Please contact us at [email protected] if you have any questions about this Privacy Policy.

1. We Only Collect Your Personal Information When We Need It To Provide You a Service

2. Information Twincel Collects

3. What You Should Know About Specific Products

4. Cookie Policy

5. We Use Your PI to Provide, Improve, and Promote Our Services

6. We May Disclose Your Information in Accordance with the Law. We Will Notify You if We Are Required by Law to Disclose Your Personal Information.

7. We Share Your PI to Provide and Improve Our Services

8. We Share Your PI to Avoid Unnecessary Marketing

9. We Share Data That is Aggregated and Anonymized

10. You Can Access and Update Your Privacy Settings

11. Data Retention Policy

12. You Can Delete Location Data at Any Time

13. PI Posted to Our Blog and Community Forum Are Public

14. We Take Security Seriously

15. You Are Responsible for Maintaining the Accuracy and Confidentiality of Your Email Address and Password

16. International Visitors and Safe Harbor Compliance

17. You Need a Parent’s Permission to Use Twincel if You Are Under 13

18. We Are Not Responsible for Content on Third-Party Websites

19. This Privacy Policy Will Apply Upon Change in Control

20. We Post Updates on Our Website Whenever This Policy Changes

20. Contact Us if You Have Any Questions or Concerns


1. We Only Collect Your Personal Information When We Need It To Provide You A Service.

We are committed to only collecting the information necessary to provide and improve Twincel’s services. When we do collect your information, we store it and associate it with your account unless otherwise noted. We take your privacy very seriously and will only use and disclose this information under the terms statedin this Privacy Policy.

Note that some of our products, like Twincel Labs, which are standalone products, collect only limited information or no information at all. Not every section of this Privacy Policy will apply to these products.

2. Information Twincel Collects

a. Registration Information

To create an account, you must provide your email address and a password. You may also enter your mobile phone number on our website to initiate a text message with directions on how to download the app and register.

b. Credit Card Information

If you wish to upgrade to a Premium Account billed directly to us, we collect your credit card number, expiration date, and security code. We use this information to bill you for services. Twincel uses third-party payment processors and therefore has only limited information about your payment transactions.

c. Device Information

When you use Twincel services, our servers automatically record certain information about your mobile device. This information may include information such as an equipment identifier (e.g., IMEI, UDID), subscriber identifier (e.g., IMSI), device name, mobile phone number, device type and manufacturer, operating system type and version, wireless carrier / operator, network type, country of origin, Internet Protocol (“IP”) address, and the dates and times of your requests. We use this information to provide our services, and support if needed, and to calculate anonymous, aggregate statistics about the users of our products. For example, collecting your device’s phone number allows the service to contact your phone via SMS when you locate your phone from the Twincel web application.

d. Employment Application Information

If you wish to fill out our application form, we will ask for information, including your name, email address, phone number, and allow you to upload your resume and cover letter. We use this information to determine if you are an eligible candidate for an available position, to contact you to set up an interview if appropriate and to follow up with you about your application experience.

e. Social Media Features

Our website includes social media Features (“Features”), like the Facebook recommend button or interactive mini-programs that run on our site. If you use these Features, they will collect your IP address, which page you are visiting on our site, and set a cookie to enable the Feature to function properly. Features may be hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the privacy policy of the company providing the Feature, not by Twincel’s Privacy Policy.

f. Information about Your Use of Twincel Services on Your Phone

We use analytics software so that we can improve the features and usability of our products. This software may analyze information such as how often you use the application, the events that occur within the application, and where the application was downloaded. We may also use such information to show you relevant content and suggest new features, products and services that can enhance your use of the Twincel Service. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile app.

g. Information About Your Use of Twincel’s Website and Mobile Website

We use analytics services to measure how people use our website so that we can improve our products and services and provide more relevant content to you. Analytics services may work by embedding invisible images that are associated with unique identifiers on our site.

h. Premium Content & Promotions

We may ask for your email address and other contact information in order to access various Twincel content, such as whitepapers, videos, or other research materials, to participate in surveys, contests, promotions, or sweepstakes, or to obtain additional information about Twincel services and products. This information will be used to provide you with additional information on products and services from Twincel or our business partners, which might be of interest to you. You can choose not to receive such marketing communications by clicking on the unsubscribe link in our emails.

3. What You Should Know About Specific Products

a. Backup

Twincel Backup securely stores copies of data that you choose to back up from your phone.

What types of information Backup collects:
• Backup Data.

• Backup transmits a copy of the data you choose to back up to on your device to a secure server using an encrypted protocol. The data may include your contacts, call history, pictures, and other data. Twincel Backup automatically backs up your data weekly or daily, based on your settings, can download your data to transfer to a new or existing phone, and allows you to retrieve your data any time from Twincel.com.

How the information that Backup collects is used:

If you choose to use the Twincel Backup feature, we will use the data you provide to deliver the Backup service. In order to notify you in the case of malicious behavior on your phone, Twincel may scan both the data that is stored on your phone and backed up to our servers. For example, some malware has been known to spread via malicious text messages or steal money by dialing expensive phone numbers. To detect this, our system would scan the SMS messages or call history stored on your phone or backed up on our servers.

4. Cookie Policy

Like many online services, we use cookies and other tools to collect and analyze information about you and your usage of our services. We also use these technologies to deliver content for relevant Twincel products and services. Cookies are small data files that we transfer to your computer. We use “session” cookies to keep you logged in while you use our services, to better understand how you interact with our services, and to monitor aggregate usage and web traffic information on our services. Session cookies disappear when you log out and close your browser. We also use “persistent” cookies to recognize you when you return to our services. Persistent cookies can stay on your computer for a longer period of time than session cookies do.

Most Internet browsers automatically accept cookies, but you can change your settings or use third-party tools to refuse cookies or prompt you before accepting cookies from the websites you visit. You can also use your browser settings or other tools to delete cookies you already have. Please be aware that some parts of our services may not work for you if you disable cookies.

Cookies from Third-Parties

We believe it is important for you to know exactly what cookies we use in our services. Here is a list of the third-party cookies that we use, which may collect personal information about your online activities over time and across third-party websites or online services. We have also included a link to the privacy policy governing the third-party cookie.

• Google Analytics and MixPanel — These cookies allow us to see how you use our website and mobile application so that we can improve your experience. We encourage you to read the Google Privacy Policy and MixPanel Privacy Policy. If you don’t want data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on.
• Optimizely — these cookies allow us to optimize the look, feel and messaging of our website based upon how you use it. You can read the Optimizely Privacy Policy here
• Greenhouse — these cookies are used to provide you with a personalized user experience when you apply for a job with us. You can read the Greenhouse Privacy Policy here.
• Marketo — these cookies help us track your visits to our website and enable us to create an engaging marketing experience for you. We also use Marketo cookies to understand your interaction with the emails we send you, and to ensure we’re sending you relevant information. For example, it lets us know whether our emails have been opened, and which links are clicked. You can read the Marketo Privacy Policy here.
• LinkedIn Insights — these cookies help us track your visits and your interactions on our website so that we can provide with you an engaging marketing experience. They also enable us to deliver more relevant services and content on twincel.com and on LinkedIn’s partner sites. You can read the LinkedIn Privacy Policy here.
If you prefer not to use any cookies, you can also opt out in some browsers by turning on “Do Not Track” or visit http://www.aboutads.info/choices to opt out directly. We currently do not support Do Not Track browser settings, but are committed to supporting it in the future once there is a consistent industry standard for compliance.

5. We Use Your Personal Information to Provide, Improve, and Promote our Services.

We use your personal information to provide you with a better service, improve the quality of our products and services, and promote our services. For example:

• If you fill out a survey or email Twincel for support, we may retain the information you give us in order to provide you with support and to improve our services.

• Where available, Twincel may use client device information to let you know you need to update your operating system.

• We may send text messages to your phone to communicate with your device.

• We may use your email address or mobile number to send privacy or security related notices and notify you of major Twincel services changes.

• We may use your email address or mobile phone number to communicate about product announcements and special promotions from Twincel or our business partners, or to administer participation in special events, surveys, contests and sweepstakes.

• We may use your information to conduct market research and engage in joint promotional activities with companies that have products that can add value to Twincel products or services (for example, with mobile operators).

You can choose to opt out of receiving emails or notices from us at any time by logging into your web account and changing your account preferences or by clicking the unsubscribe button/link at the bottom of our emails.

6. We May Disclose Your Information in Accordance with the Law.

Like other companies, we may disclose your information in accordance with law, for example, to (i) comply with a law, regulation, or legal request; (ii) protect the safety of any person; (iii) address potential violations of our Privacy Policy or Terms of Service; (iv) investigate fraud, security, or technical issues; or (v) protect Twincel’s rights or property, our employees, users and the public.

However, we strongly believe that you have a right to know if we are required by law to disclose your information. As such, before we disclose your Information in response to a law enforcement request (for example, a subpoena or court order), we will notify you at the email listed in your account, unless (a) we are prohibited from doing so or (b) in emergency cases where notice could create a risk of injury or death to an identifiable individual or group of individuals, or the case involves potential harm to minors. In such cases, we might delay notice to you. Furthermore, nothing in this Privacy Policy is meant to limit any legal defenses or objections that you may have to a third party including any government’s request to disclose your information.

7. We Share Your Personal Information to Provide or Improve Our Services

We share your personal information to provide or improve our services. For example:

• We may share your information with third party providers of products and services integrated with our software that need to know your information to fulfill your product or service requests (for example, to map your location or send you an SMS), support our products and services, or analyze data for product performance and product improvement purposes.

• We may share your information with mobile operators who participate in our Customer Care Web Application program to enable them to assist you directly with Twincel Missing Device features, such as remote locate, lock, wipe, or Scream through our Customer Care Web Application, at your request.

• We may share your information to perform accounting, auditing, billing reconciliation, and collection activities.

• We may share your information with our affiliates, resellers or other third party service providers that are working with Twincel (for example, mobile operators and MDM providers) to ensure proper delivery of your purchase and related support services, perform business-related functions, and provide you with information about products and services.

8. We Share Your Personal Information to Avoid Unnecessary Marketing

In order to prevent you from receiving duplicate or unnecessary marketing about Twincel products or service, we may share your personal information or your status as a current Twincel customer with our partners or service providers.

9. We Share Data That is Aggregated and Anonymized

We share anonymized, aggregated data with partners and third-parties and in security reports. Such data are never associated with personal information and cannot be identified with you. For example, we may share the number of devices that have ever encountered a particular piece of malware in our security reports.

10. You Can Access and Update Your Privacy Settings

Both the Twincel website and the Twincel ‘Settings’ on your device have options that allow you to update or modify your privacy settings at any time. To protect your privacy and security, we require your username and password in order to verify your identity before granting you profile access or making changes. If your email-address changes, you may update your information within the Twincel website. Simply go to the “Account” page and select the information you wish to update. If you wish to correct or delete inaccuracies within your personal information, or to request access to any personal information we obtain about you, please contact us at [email protected]. We will respond to your request to access within 30 days. In certain situations, however, Twincel may not be able to provide access to all of the personal information that it holds about you.

11. Data Retention Policy

Our policy is to retain data only as long as reasonably necessary to provide our products and services to you and others.

Except for current Premium Accounts, we reserve the right to delete (i) all Backup Data if you have not accessed our services for 90 consecutive days, or (ii) pictures and call history from your Backup Data if you have not upgraded to a Premium Account within 90-days after your Premium trial or if you have discontinued your Premium Account for 90 consecutive days. We will notify you via the email address associated with your account before deleting your Backup Data.

12. You Can Delete Location Data at Any Time

When you delete location data through your account dashboard on Twincel.com, it is no longer linked to your account and is anonymized on our application production systems.

13. Personal Information Posted to Our Blog and Community Forum Are Public

If you comment on our blog or other public forums, you should be aware that any personal information you submit there can be read, collected, or used by other users of those blogs, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these blogs or for any content you receive as a result of sharing such information.

To request removal of your personal information from our blog or community forum, contact us at [email protected]. If we are not able to remove your personal information, we will let you know why.

14. We Take Security Seriously

Twincel is a security company, and securing your data is one of our top priorities. Twincel uses commercially reasonable physical, managerial, and technical safeguards. For example, we use a combination of firewalls, encryption, authentication, physical security, and other safeguards to protect your account and your data.

We perform third-party penetration tests to harden our systems from attack. Because no method of transmission over the Internet or method of electronic storage is 100% secure, we cannot ensure or warrant the security of any information that Twincel receives on your behalf to operate the Twincel services, or information that you transmit to Twincel. All such receipt or transmission of your information is at your own risk.

We cannot guarantee that such information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

The security of your personal information is important to us. When you enter sensitive information (such as credit card number or location based information) on our website, within the Twincel app, or in our order forms, we encrypt that information using secure socket layer technology (SSL).

If Twincel learns of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. Twincel may also post a notice on the Twincel services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

15. You Are Responsible for Maintaining the Accuracy and Confidentiality of Your Email Address and Password

You are responsible for maintaining the secrecy of your password at all times. We recommend a strong password that you do not use with other services. If you believe your password has been compromised, please change your password immediately via the Twincel website, or contact us at [email protected] for assistance. You are responsible for ensuring that the email address associated with your account is accurate. We use that email to contact you about service updates, changes to our policies, and account activities such as requests for your information or locate attempts on your device. Twincel is not responsible for personal data transmitted to a third party as a result of a user’s providing an incorrect email address.

16. International Visitors and Safe Harbor Compliance

Twincel is a London, United Kingdom-based Company with servers housed in the India. Personal information collected from users outside the Kenya & India United is transferred to the India and processed according to Indian law. Twincel complies with the U.S. – E.U. Safe Harbor Framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Twincel has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Twincel's certification, please visit http://export.gov/safeharbor.

17. You Need a Parent’s Permission to Use Twincel if You Are Under 13

Twincel does not knowingly collect or store any personal information about children under the age of 13-16. If you believe a child is using this service without parental consent, please contact us at [email protected].

18. We Are Not Responsible for Content on Third-Party Websites

Our site contains links to other websites. When you click on one of these links, you leave Twincel’s website and go elsewhere. Twincel does not accept liability for misuse of any information by any website controller to which we may link. We encourage you to read the privacy statements of these linked sites, which may differ from ours. In addition, if you take advantage of an offer from one of our partners, you may be providing information directly to that partner. We encourage you to review the privacy statements of these partners, as we are not responsible for the privacy practices of any partners or linked sites.

19. This Privacy Policy Will Apply Upon Change in Control

In the event that Twincel is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your information may be sold or transferred as part of that transaction.

20. We Post Updates on Our Website Whenever This Policy Changes

This Privacy Policy may be revised to keep pace with changes in our products and services and laws applicable to Twincel and you. If we make material changes to this policy, then we will notify you in our application, here on this website, by email, or by means of a notice on the Twincel home page. Please note that your continued use of our services means that you agree with, and consent to be bound by, the new Privacy Policy. If you do not wish your information to be subject to the revised Privacy Policy, you will need to close your account.

21. Contact Us if You Have Any Questions or Concerns

Please contact our privacy manager at [email protected], or by postal mail at Twincel Limited, Attn: Privacy Officer, Twincel Limited, Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX,with any questions or comments about this privacy policy.

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