This Privacy & Security Policy describes how MLtwist, Inc., including its affiliates and subsidiaries (collectively, MLtwist and also referred to as our, us and we) collects, uses and discloses personal data, as well as any choices you have with respect to this personal data.
When we refer to “MLtwist”, we mean the MLtwist entity that acts as the controller or processor of your personal data, explained in more detail in the “Identifying the Data Controller and Processor” section below.
The organization (e.g., your employer or another entity or person) (“Customer”) that entered into our Terms of Service or Master Services Agreement (“Customer Agreement”) controls its instance of the Services (its “Organization”).
If you have any questions about specific Organization settings and privacy practices, please contact the Customer whose Organization you use.
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of personal data. In general, Customer is the controller and MLtwist is the processor of Customer Content.
As the controller for Customer Content, Customer may, for example, use the Services to grant and remove access to an Organization, assign roles and configure settings, access, modify, export, share and remove Customer Content and otherwise apply its policies to the Services.
As the processor for Customer Content, MLtwist processes Customer Content only on Customer’s request and in accordance with Customer’s written instructions, including the applicable terms in the Customer Agreement, Customer’s use of the Services, and as required by applicable law. For more information about how Customer Content is processed (such as how your personal data is processed, the purpose and legal basis for processing, and your data subject rights), we refer you to the relevant Customer’s privacy notice.
MLtwist is the controller for certain other categories of data (described in paragraph 3 below). If you have any questions or complaints, or would like to exercise your rights with regard to your personal data, please contact us at privacy@MLtwist.com.
Your personal data is provided by you, obtained from third parties, and/or created by us when you use the Services.
MLtwist may collect and receive Customer Content and other personal data (“Other Data”) in a variety of ways:
Customer Content. Customers or Authorized Users routinely submit Customer Content to MLtwist when using the Services.
Generally, no one is under a statutory or contractual obligation to provide any Customer Content or Other Data (collectively, “Personal Data”). However, certain Personal Data is collected automatically and, if some Personal Data, such as Organization setup details, is not provided, we may be unable to provide the Services.
MLtwist does not sell personal data and in general does not collect personal data. Customer Content will be used by MLtwist in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of the Services, and as required by applicable law.
MLtwist uses Other Data for the purposes of our legitimate interests in operating our Services, Websites and business. More specifically, MLtwist uses Other Data:
Further, note that we may keep certain types of Other Data after the deactivation of an account for the period needed for MLtwist to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.
This section describes how MLtwist may share and disclose personal data, as described in paragraph 3 above. Customers determine their own policies and practices for the sharing and disclosure of personal data. MLtwist does not control how they or any other third party chooses to share or disclose personal data.
MLtwist may share and disclose personal data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and the Customer’s use of the Services and in compliance with applicable law. Where necessary, may only share personal data with third parties where we have obtained consent to do so.
We may share personal data as follows:
MLtwist takes security of personal data very seriously. MLtwist strives to protect all Personal Data from loss, misuse, and unauthorized access or disclosure. If you have discovered a security or vulnerability in our application and would like to responsibly disclose it, please contact us at firstname.lastname@example.org.
Our Services may contain links to websites and services operated by third parties. If you follow a link to any of these websites, please note that these websites have their own privacy notices and terms and conditions. Further, we have no responsibility for, or control over, the information collected by any third-party website and we cannot be responsible for the protection and privacy of any information which you may provide to these websites. You should read the relevant privacy notices and terms and conditions before using their websites or services.
MLtwist does not allow use of our Services and Websites by anyone younger than 16 years old (“Minor”). If you learn that a Minor has unlawfully provided us with personal data, please contact us and we will take steps to delete this information.
By using our Services and Websites, you represent and warrant that you are not a Minor as of the date of first access to our Services and Websites.
If you are a Minor, you represent and warrant that you are accessing the Services and Websites with the consent of a competent guardian over the age of 16 years old who takes responsibility for your use of the Services and Websites. If you are a Minor accessing MLtwist via an education institution, that institution will have procured a license on your behalf and agreed to our terms and conditions. In particular, it will have agreed that it has obtained all necessary consents and will take responsibility for your use of the Services and Websites.
If you are based in the European Union, the following provisions also apply:
If you are based in California, the following provisions apply: