About Privacy

Twona is a SAAS solutions provider based in Amsterdam, The Netherlands. Our privacy policy provides you with information related to which personal data we collect from you or others and how it will be processed. We advise you to read and review the policy carefully.

Privacy Policy of www.twonas.com

This website (www.twonas.com), and all related web sites, as well as online accessible software applications either restricted by password or not (Twona AMS or other free access tools), and other services provided by us, and all other communications with individuals though from written or oral means, such as email or phone collect some Personal data from its users.

Definitions

  • Client means a customer of Twona.
  • Personal Data means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Twona sites/applications.
  • Twona AMS means any information relating to an identified or identifiable natural person.
  • User means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
  • Visitor means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or applications.

Owner and data Controller

  • For the purpose of the General data Protection Regulation (the GDPR) (the 'Law'): the data controller is PharmaceuticalDesign, B.V. (Twona).
    Keizersgracht 482 - 1017EG Amsterdam
  • Owner contact email: info@twonas.com

Types of data collected

Among the types of Personal data that this website and AMS system collects, by itself or through third parties, there are:

  • first name;
  • last name;
  • company name;
  • telephone number;
  • country;
  • industry;
  • email address;
  • Trackers;
  • Usage data;
  • data communicated while using the service;
  • number of users;
  • session statistics.

Complete details on each type of Personal data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the data collection.

These are the possible ways you provided us with your information:

  • Email, phone or any other way of correspondence with us
  • Any contact forms you fill in within our website
  • Applying to work with us
  • When you set up a user account for our software or request a trial of this.
  • When you use any of our online accessible tools and functionality
  • in case of Usage data, information is collected automatically when using this site or Twona’s Artwork Management System

Unless specified otherwise, all data requested by this site is mandatory and failure to provide this data may make it impossible to provide its services. In cases where this website and AMS specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the availability or the functioning of the service. Users who are uncertain about which personal data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools — by this website and AMS or by the owners of third-party services used by this website and AMS serves the purpose of providing the Service required by the data, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal data obtained, published or shared through this website and AMS.

Mode and place of processing the data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

In addition to the Owner, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of this website and AMS (administration, sales, marketing, legal, system administration)or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies,communications agencies) appointed, if necessary, as data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the user's location, data transfers may involve transferring the user's data to a country other than their own.

To find out more about the place of processing of such transferred data, users can check the section containing details about the processing of personal data.

Retention time

Unless specified otherwise in this document, personal data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the users’ consent.

The purposes of processing

The data concerning the data is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its users or third parties), detect any malicious or fraudulent activity, as well as the following:

  • Contacting the user
  • Displaying content from external platforms
  • Managing contacts
  • Sending messages
  • Managing contacts
  • Interaction with live chat platforms
  • Heat mapping and session recording
  • Traffic optimization and distribution
  • Tag Management
  • Analytics

For specific information about the Personal data used for each purpose, the data may refer to the section “Detailed information on the processing of personal data”.

Detailed information on the processing of personal data

Personal data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of data behavior.

Google Analytics 4
(Google Ireland Limited)

Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the data collected to track and examine the use of this website and AMS, to prepare reports on its activities and share them with other Google services.Google may use the data collected to contextualize and personalize the ads of its own advertising network.In Google Analytics 4, IP addresses are used at collection time and then discarded before data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

Personal data processed: number of users; session statistics; Trackers; Usage data.

Place of processing: Ireland –
Privacy Policy - Opt Out

Contacting the user
Contact form
(Twonas.com)

By filling in the contact form with their data, the user authorizes this website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal data processed: company name; country; email address; first name; last name; phone number; other data communicated while using the service.

Place of processing: Spain

Heat mapping, session recording and application rating

Heat mapping services are used to display the areas of this website that users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of data behavior. Some of these services may record sessions and make them available for later visual playback.

Rating services are used to process reviews from users about their experience with the websites and systems.

Hotjar Heat Maps & Recordings
(Hotjar Ltd.)

Hotjar is a session recording and heat mapping service provided by Hotjar Ltd. Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the user's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal data processed: Trackers; Usage data; various types of data as specified in the privacy policy of the service.

Place of processing: Malta –
Privacy Policy - Opt Out

Wootric
(InMoment)

Wootric is a modern customer experience management software and an AI-powered platform for measuring and boosting customer happiness.

Personal data processed: email, score data, any other data communicated while using the service.

Place of processing: United States –
Privacy information.

Interaction with live chat platforms

This type of service allows users to interact with third-party live chat platforms directly from the pages of this website, in order to contact and be contacted by this website‘s support service. If one of these services is installed, it may collect browsing and Usage data in the pages where it is installed, even if the users do not actively use the service. Moreover, live chat conversations may be logged.

Crisp Widget
(Crisp IM SARL)

The Crisp Widget is a service for interacting with the Crisp live chat platform provided by Crisp IM SARL.

Personal data processed: data communicated while using the service; Trackers; Usage data; various types of data as specified in the privacy policy of the service.

Place of processing: France –
Privacy Policy

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. They provide specific information or perform a particular function and often allow for user interaction. This type of service might still collect web traffic data for the pages where the service is installed, even when users do not use it.

Google Fonts
(Google Ireland Limited)

Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.

Personal data processed: Trackers; Usage data

Place of processing: Ireland –
Privacy Policy

Amazon Web Services

Amazon Web Services, Inc. is a subsidiary of Amazon that provides on-demand cloud computing platforms and APIs.

Personal data processed: files and related data communicated while using the service

Place of processing: Germany –
Privacy Policy

Digital Ocean

DigitalOcean Holdings, Inc. is an American multinational technology company and cloud service provider, offering developers, startups, and SMBs with cloud infrastructure-as-a-service platforms.

Personal data processed: email address; first name; last name; (encrypted) password; any other data communicated while using the service.

Place of processing: The Netherlands -
Privacy Policy

Dinahosting

Spanish company dedicated to domain register, hosting, VPS and dedicated server services.

Personal data processed: user first name, user last name, user email, any other data and files provided while using the service.

Place of processing: Spain -
Privacy Policy

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. This results in the users' data flowing through these services, potentially resulting in the retention of this data.

Google Tag Manager
(Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal data processed: Trackers.

Place of processing: Ireland –
Privacy Policy

Traffic optimization and distribution

This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance. Which Personal data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the user's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the data are transferred.

Cloudflare
(Cloudflare, Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the user's browser, while also allowing analytical data from this Application to be collected.

Personal data processed: various types of data as specified in the privacy policy of the service.

Place of processing: United States –
Privacy Policy

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Pipedrive

Pipedrive is a cloud-based software as a service company developing a sales customer relationship management (CRM) tool.

Personal data processed: company name; address details; country; email address; first name; last name; any file exchanges through e-mail communication; usage data.

Place of processing: Europe -
Privacy Policy

Mailgun

Mailgun Technologies Inc is an email delivery service for sending, receiving, and tracking emails.

Personal data processed: email address, first name, last name, subject; message body section; any other data communicated while using the service.

Place of processing: United States -
Privacy Policy

Mailchimp
(Intuit Inc.)

Mailchimp is an email address management and message sending service provided by Intuit Inc.

Personal Data processed: company name; country; email address; first name; last name; Usage Data.

Place of processing: United States -
Privacy Policy

Cookie Policy

This website uses Trackers. To learn more, users may consult our Cookie Policy

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Further Information for users

Legal basis of processing

The Owner may process personal data relating to users if one of the following applies:

  • users have given their consent for one or more specific purposes.
  • provision of data is necessary for the performance of an agreement with the data and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the users’ consent.

Therefore:

  • Personal data collected for purposes related to the performance of a contract between the Owner and the data shall be retained until such contract has been fully performed.
  • Personal data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
  • The Owner may be allowed to retain Personal data for a longer period whenever the data has given consent to such processing,as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.Once the retention period expires, Personal data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of users based on the General data Protection Regulation (GDPR)

users may exercise certain rights regarding their data processed by the Owner.

In particular, users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time . users have the right to withdraw consent where they have previously given their consent to the processing of their Personal data.
  • Object to processing of their data . users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent.
  • Access their data . users have the right to learn if data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
  • Verify and seek rectification . users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
  • Restrict the processing of their data . users have the right to restrict the processing of their data. In this case, the Ownerwill not process their data for any purpose other than storing it.
  • Have their Personal data deleted or otherwise removed . users have the right to obtain the erasure of their data fromthe Owner.
  • Receive their data and have it transferred to another controller . users have the right to receive their data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
  • Lodge a complaint . users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for data transfers abroad, including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their data.

Details about the right to object to processing

Where Personal data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the data objects to processing for direct marketing purposes, the Personal data will no longer be processed for such purposes. To learn whether theOwner is processing Personal data for direct marketing purposes, users may refer to the relevant sections of thisdocument.

How to exercise these rights

Any requests to exercise data rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing users with the information required by law. Any rectification or erasure of Personal data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal data has been disclosed unless this proves impossible or involves disproportionate effort. At the users’ request, the Owner will inform them about those recipients.

Additional information about data collection and processing
Legal action

The user's Personal data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this website or AMS or the related Services. The data declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about user's Personal data

In addition to the information contained in this privacy policy, this website and AMS may provide the data with additional and contextual information concerning particular Services or the collection and processing of Personal data upon request.

System logs and maintenance

For operation and maintenance purposes, this website and any third-party services may collect files that record interaction with this website (System logs) or use other Personal data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its users on this page and possibly within this website and AMS and/or - as far as technically and legally feasible - sending a notice to users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.Should the changes affect processing activities performed on the basis of the user's consent, the Owner shall collect new consent from the data, where required.

Definitions and legal references
Personal data (or data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number— allows for the identification or identifiability of a natural person.

Usage data

Information collected automatically through this website and AMS (or third-party services employed in this website), which can include: the IP addresses or domain names of the computers utilized by the users who use this website and AMS, the URI addresses(Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the data, the various time details per visit (e.g., the time spent on each page within the website) and the details about the path followed within the website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the user's ITenvironment.

Data

The individual using this website who, unless otherwise specified, coincides with the data Subject.

Data Subject

The natural person to whom the Personal data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal data, including the security measures concerning the operation and use of this website and AMS. The data Controller, unless otherwise specified, is the Owner of this website.

This website and AMS

The means by which the Personal data of the user is collected and processed.

Service

The service provided by this website and AMS as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states tothe European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the user’s browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -that enables the tracking of users, for example by accessing or storing information on the user's device.

Legal information

This privacy policy relates to this website, the artwork management system Twona with restricted user access, as well as any application accessible without login from our website.

Latest update: January 29, 2024