This privacy notice tells you about the information we collect from you when you use our website and our services. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.
Who are we?
We are Twala, a company based in Manila, Philippines. You can contact us by email at info@twala.io.
How we use your information
Twala is committed to protecting and respecting your privacy.
This policy (Terms of Use) applies to your use of:
▲ Twala, which provides a Mobile Application for Digital Identity via Blockchain technology (App) which you may downloaded onto your mobile telephone or handheld device (Device). We also have an information website that you may visit (https://twala.io) (Site).
▲ This Privacy Policy applies to any of the services accessible through the App (Services) that are available on the Site or other sites of ours (Services Sites).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the Philippines Data Privacy Act, the data controller is Twala Inc, a company whose registration is pending with the Philippines Securities and Exchange Commission.
Information We Collect From You
1.1 We will collect and process the following data about you:
▲ Information you give us (Submitted information): This is information you give us about you by filling in forms on the Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use the Site, download or register the App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a competition, promotion or survey, or connect with your friends on our app and when you report a problem with an App, our Services, or any of our Sites. If you contact us, We will keep a record of that correspondence. The information you give us may include your name, address, e-mail address and phone number, the Device’s phone number, age, username, password and other registration information, financial and credit card information, personal description and photograph, the city you live in and your gender.
▲ Information we collect about you and your device. Each time you visit one of our Sites or use one our App we will automatically collect the following information:
• technical information, including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the IP address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting (Device Information), Device Token;
• details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to traffic data, weblogs and other communication data and the resources that you access (Log Information).
▲ When you login to our app or any third party apps that uses Twala Digital Identity, we will always ask for your consent to use your data (e.g. for billing purposes, to verify your identity as a signatory of a document, to verify you business, etc.)
• a cryptographic hash of identifying information, such as your name and date of birth;
• a cryptographic hash of contact information, such as your postal address, email address and mobile number;
• Know-Your-Customer (KYC) service data – Address – Proof of address, Utility bills, Self Addressed Mail
• Know-Your-Customer (KYC) service data – Identity Card Details such as Name, ID Number, ID Expiry, ID Image and Selfie
• Know-Your-Customer (KYC) service data – Business Information – Business Documents
• Know-Your-Customer (KYC) service data – Employment Data (Certificate of employment, Payslip, etc.)
• Know-Your-Customer (KYC) service data – Certificate of Authority for a Notarial Act
• blockchain identifiers, such as blockchain addresses and public keys.
▲ Location information. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by going to your Privacy Settings and turning off your location services on your device either for all our apps or for our app specifically.
▲ Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
▲ We keep you information safe. The signature and underlying data is published together on a decentralised public protocol along with a time-stamp. This Digital Identity is securely created and stored on the Users Mobile Device and can be accessed via the Users biometrics and Pin Codes. There is a double authentication process for you to get to your private key and this will unlock your data.
Cookies
We use cookies to distinguish you from other users of the App, Site, Appstore or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and Our sites. For detailed information on the cookies We use and the purposes for which We use them, see our App Cookie Policy.
Uses Made Of The Information
We use information held about you in the following ways:
▲ Submitted Information: to create an account with us and allow us to understand more about you so we can make better and more personalised recommendations to you.
▲ Device information: to understand more about the different bugs and fixes required on different devices, how the content can be presented better and for continuous improvement of our app.
▲ Log information: to understand how you interact with our app, which features you use most and understand more about what we can do to improve the app the experience we give to you.
▲ Third Party Information: to enable payments to be made seamlessly and get the support that we need to provide you with a better service from our trusted partners.
Disclosure Of Your Information
We will disclose the data we collect from you to the following third parties:
Category of DataRecipientPurposeSubmitted InformationMailchimpMarketing emails and notifications about our service
We will disclose your personal information to third parties:
▲ in the event that we sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets.
▲ If Twala or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
▲ If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
▲ In order to:
• enforce or apply Our Terms of Use and other agreements or to investigate potential breaches; or
• protect the rights, property or safety of Twala, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where We Store Your Personal Data
All information you provide to us is stored on our secure servers. Although we utilise blockchain technology, none of the personal data we collect about you is stored on a blockchain protocol. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where We have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
We will collect and store personal data on your Device using application data caches and browser web storage and other technology.
What We Would Also Like To Do With The Information
At Twala we take your privacy seriously and will only use your Information as mentioned above.
However from time to time we would like to inform you of our future offers and similar products. This Information is not shared with third parties and you can unsubscribe at any time via phone, email or our website.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting us at privacy@twala.io
Your Rights
If at any point you wish to know which Information we are processing about you, or if you do not wish for us to process your Information anymore or if you believe the Information we process on you is incorrect or obsolete you can request to see this Information and/or have it corrected or deleted by us by contacting us at privacy@twala.io
If you wish to raise a complaint on how we have handled your Information, please contact us at the email address above to have the matter investigated.
If you have a complaint about our use of your information, you can contact the National Privacy Commission via their website at https://privacy.gov.ph/ or write to them at:
National Privacy Commission
5th Floor Delegation Building, PICC Complex, Roxas Blvd. Pasay, Metro Manila
Our App and Sites may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Access To Information
The Data Privacy Act of 2012 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. We will provide you with such information free of charge.
Changes to Privacy Policy
Any changes We may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites or via email. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@twala.io