Last Modified: August 17th, 2023
Aylo Premium Ltd (hereinafter “we”, “us” or “our”) operates the Website www.twinkpop.com (hereinafter the “Website”) and is the controller of the information collected or provided via the Website and its affiliates.
For greater certainty, the term “Personal Information” or “Personal Data” means any information or data regarding a person or a user which can lead to identify such person or user, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person or user.
If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.
The Data We Collect About You
We may collect different kinds of Personal Data about you, depending on whether you chose to create and register an account with us.
This Website is only accessible to registered users. That is, persons who visit this Website and choose to create and subscribe to an account on the Website, including persons who sign up in the Content Partner Program (collectively, the “Registered Users”)
We may use your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.
Our Website are not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Website are accessed (“minors”), and we prohibit minors from using the Website. We do not knowingly collect personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us at email@example.com to have that minor’s personal information deleted.
The Sources from Which We Collect Personal Information
We collect Personal Information in the following ways:
Purposes for Which We Use Your Personal Information
To our Registered Users, we use your personal information for the purposes described below.
For our Registered Users and other visitors visiting our Website, we use information collected for the following purposes below.
Our Legal Bases Under Canadian and European Union (EU) Privacy Law
We have the following legal bases under Canadian and EU Privacy law for processing your personal data for the purposes described under Purposes for Which We Use Your Personal Information section:
Disclosure of Your Personal Information
We disclose personal information:
Cookies and Automatic Data Collection Technologies
As you navigate through and interact with our Website, we use automatic data collection technologies to collect website activity data.
We currently use the following types of cookies, which are set by the Website’ domains, or by other domains we own or control:
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use the Website, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only for the purpose of providing Google Analytics services to us and will not use this information for other purposes. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU. You can learn more on how Google uses data here - https://policies.google.com/technologies/partner-sites - , and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page: https://tools.google.com/dlpage/gaoptout.
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
Your Choices About How We Collect, Use and Disclose Your Personal Information
We strive to provide you with choices regarding the Personal Information you provide to us.
Your Rights Related to Your Personal Information
Generally, in some regions like Canada, European Economic Area (“EEA”), and the United Kingdom, you have certain rights regarding the Personal Information we collect, use, or disclose and that is related to you, including the right:
You may exercise your right to access and deletion using the buttons at the bottom of this page. Additionally, you may, at any time, send us an e-mail at firstname.lastname@example.org to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area or the UK, you have a right to lodge a complaint with your local data protection authority.
Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be in a position to respond to your request. Additionally, in some cases in order to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricably linked to the use of certain Personal Information (e.g., your e-mail address).
California Rights and Choices
The California Consumer Privacy Act (“CCPA”) provides you certain rights in relation to your Personal Information:
To exercise the rights described above, please use the buttons at the bottom of this page or email us at email@example.com with the email subject line “CCPA Request.” In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request in order for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
We disclose certain categories of California residents’ personal information for our business purposes, as described in the section above titled Disclosure of Your Personal Information.
Resident’s Rights – Jurisdictions in the United States, Where Applicable
In some states in the United States, we do not sell, trade, or exchange the Registered Users’ personal information with anyone for money.
We employ third-party service providers to help verify your identity and age and to check background records and the authenticity of identification documents you provide using facial recognition technology. The facial recognition technology creates a mathematical representation of your face and detects facial features from the live scan of your face, your selfie, and the government-issued ID you submit or previously submitted to us. This mathematical representation, which is considered biometric information/identifier/data under the laws of certain states and countries, is not shared by our service providers with us, and is deleted by our service providers 7 days after its creation. Information derived from this mathematical representation, which may be considered biometric information/identifier/data under the laws of certain states and countries, is shared by our service providers with us as further described below.
Your biometric information will be used to:
We may disclose your biometric information, face scan, selfie, and government-issued ID (including any government-issued ID or selfie you previously submitted to us) with members of our corporate group, and with third-party service providers. These entities may be located in jurisdictions that do not offer the same level of data protection as your jurisdiction. We (and/or any of these entities) may perform facial recognition and collect your biometric information from your face scan, selfie and any government-issued ID, and use your biometric information for the above purposes.
You will be asked to provide your consent to biometric processing. You may withdraw your consent to this processing at any time by using the links below. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.
Notice to Law Enforcement
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:
We reserve the right to refuse online service through our platform for Legal Service Process, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
Transfers of Your Personal Information to Other Countries
Where the laws of your country allow you to do so, by using the Website you consent to the transfer of information that we collect about you, including Personal Information, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer Personal Information to countries outside of the EEA or other regions with comprehensive data protection laws, we will ensure that such information is transferred in accordance with the applicable laws. Where relevant, our transfers outside the EEA are made pursuant to standard contractual clauses approved for use by the European Union.
Retention of Personal Information
We will only retain your Personal Information for as long as your account is active, or for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider a number of factors, including which Personal Data we are processing, the risk of harm from any unauthorised disclosure, why we are processing your Personal Data and whether we can achieve this outcome by another means without having to process it.
Where permissible, we will also delete your Personal Information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.
Third-Party Links and Sites
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
Our Data Protection Officer can be contacted at the following email address: firstname.lastname@example.org.
Manage Your Private Data
With respect to Data Protection Laws in users' jurisdictions, Registered Users may request for a copy of their personal data as well as request us to delete their personal data.
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