At Twelo, we care deeply about privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by Twelo. This policy explains our privacy practices for Twelo.com (which we’ll refer to as the "Site"), Twelo’s mobile applications (the "Apps"), Twelo Payments, Twelo’s public Application Program Interface (the “API”), and our other services provided by Twelo, ("Twelo," together with "we," "us," and "our"). We'll refer to the Site, , the API, and our other services as the "Services." Twelo Ltd is the data controller and is responsible for your personal information for our UK operations. This policy does not apply to the practices of third parties (including other members who sell using the Services or API users) who may also collect or receive data in connection with your use of the Services.
- Information Collected or Received
- Choice & Control
- Messages from Twelo
- Information Uses, Sharing, & Disclosure
- Your Rights
- Your Responsibilities
- Withdrawing Consent
By using the Services, you acknowledge that Twelo will use your information in the United Kingdom and any other country where Twelo operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information continues to enjoy appropriate protections. Please read on to learn more about how we protect personal information that’s transferred outside of Europe. We abide by GDPR regulations.
2. Information Collected or Received
In the course of providing our Services, we collect or receive your personal information in a few different ways. Often, you choose what information to provide, but sometimes we require certain information for you to use and for us to provide you the Services.
Registration, Account Setup, Service Usage: In order to use the Services, you need to provide us with a valid email address, and for Services that require registration, an email associated with your account (Twelo Shop name for sellers). You may review or change your email address through your account settings. As a Twelo shop you can rename your shop if you so wish provided the new shop name is not in use however we advise against this and only permit one shop rename per seller.
You need to provide this information to enable us to provide you with the Services. Depending on which services you choose to use, additional information, such as a shop name, billing and payment information (including billing contact name, address, telephone number, credit card information), a telephone number, and/or a physical postal address, may be necessary in order for us to provide a particular service. You are not required to provide us with this information to sign up, but we will need it to provide certain services. For example, we need a physical postal address if you are buying something on the Site for delivery. As an Twelo seller, if you choose to use our BACS service ("Twelo BACS"), Twelo may require information such as your full name, , date of birth, driving license or passport and bank account information, photograph, credit card information, and/or other proof of identification in order to verify your identity, provide this service to you, and comply with applicable law. In addition, as a user of Twelo’s services Twelo may require this information from you in order to provide you with services (including, for example, to verify ownership of an account, to mitigate fraud and abuse on the Twelo platform, or to complete a transaction as a buyer or seller). We may need to store credit card information (or arrange for it to be stored by a third party secure provider) and use it for both billing and payment purposes. Twelo may contact individual shop owners confidentially to request more information about their shops or items listed through the Services, or to ensure compliance with our rules and applicable law. In order to use certain products or services on Twelo, you may be required to complete an application; information that you submit through the application process will not be displayed publicly and will only be used internally by Twelo, unless otherwise specified.
Profile: You may provide your name and other personal information (such as birthday, gender, location) in connection with your account and activity. You can edit or remove this information through your account settings.
Sellers - The shop name associated with your account, which you may review and change in your account settings, is publicly displayed and connected to your Twelo activity. Other people may see the date you joined; ratings, reviews, and related photos for items you sold; your profile information; items you listed for sale; your shop pages and policies; your Favorites, followers, and those you follow; sold item listings and the number of items sold; comments you post in our community spaces; and information you decide to share via social networks.
Automated Information: Twelo automatically receives and records information from your browser or your mobile device when you visit the Site or use the Apps or use certain other Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. Twelo may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a connected Internet of Things device such as a voice-activated assistant or Smart TV. We may combine this information from your browser or your mobile device with other information that we or our partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.
We may also automatically collect device-specific information when you install, access, or use our Services. This information may include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers.
Location Information: We may collect information about your use of the Services for advertising, for analytics, to serve content, and to protect the Services. This may include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). You may choose to publish your location when you sell on Twelo.
We may obtain location information you provide in your profile or your IP address. You may also choose to enable the Apps to access your mobile device’s camera to upload photographs to Twelo.
Analytics Information: We use data analytics to ensure site functionality and improve the Services. IInformation from Third Parties: Some members or visitors may choose to connect to Twelo or register an Twelo account using an external third-party application, such as Facebook, or an app developed using Twelo's API. Twelo may receive information from those connected third-party applications. Connecting your Twelo account to third-party applications or services is optional. If you choose to connect your account to a third-party application, Twelo may receive information from that application. We may also collect public information in order to connect with you. We may use that information as part of providing the Services to you. You can also choose to share some of your activity on Twelo on certain social media networks which are connected to your Twelo account, and you can revoke your permission anytime in your account settings.
Non-Member Information: Twelo may receive or obtain information (for example, an email address or IP address) about a person who is not yet a registered Twelo member (a “non-member”) in connection with certain Twelo features, such as when a non-member chooses to subscribe to an Twelo newsletter, a member invites a non-member to visit the Site, a member uploads non-member information using the contact uploader feature, a non-member engages in a transaction, a member sends a gift card code to a non-member, or a non-member uses the Guest Checkout feature when making a purchase through one of the Services. Non-member information is used only for the purposes disclosed when it was submitted to Twelo, for purposes necessary to the functioning of Twelo's services or where Twelo has a legitimate interest, as disclosed in Section 7 below, or to facilitate action authorised by a member or the non-member.
Cookie tracking from Twelo: We also collect certain information from both members and non-members who visit websites hosted by us. This information may include your IP address or unique device identifier, and cookies and data from the pages you visit.
3. Choice & Control
We know that members of our community value having control over their own information, so Twelo gives you the choice of providing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Twelo account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request the deletion of the personal information in your account by submitting a GDPR data removal request.
Depending on your location, you may also have certain additional rights with respect to your information, such as: (i) data access and portability (including the right to obtain a copy of your personal data you provided to Twelo, via your settings); (ii) data correction (including the ability to update your personal data, in many cases via settings); (iii) data deletion (including the right to have Twelo delete your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Twelo, by contacting us); and/or, (iv) withdrawal of consent or objection to processing (including, in limited circumstances, the right to ask Twelo to stop processing your personal data, with some exceptions, by contacting us).
You may also control the receipt of certain types of communications from Twelo in your account settings. Twelo may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings, and you can learn more in the “Messages from Twelo” section of this policy.
If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account. Click here to learn how to close your account.
Many changes that you make to your account settings are updated immediately, but some may take a few days to take effect, particularly those that impact email or marketing preferences. Some major requests, such as changes to billing information or account data deletion, may require verification of identity before they can be processed.
You may choose to connect directly with your email service provider, your mobile device’s address book, or a social network account to import your contacts to Twelo. We do not retain the login information for your email service, mobile device, or social network site. You may be able to search for people you know by email address or phone number on the Site or by connecting to your mobile device’s contact list through the Apps. Finding your friends on Twelo helps you connect with them on our platform. For example, you can follow another member’s public activity, such as public Favorites. When you begin following another member’s activity, they will receive an email notification (if the member has consented to receiving this type of email).
If you do not want your contacts to be able to find you on Twelo through your email address, phone number, or social networking connections, then you may change your findability through your account settings. If you do not wish to be located on Twelo via your name, you can remove your name and instead may use a nickname or alias as your name in your public account information.
5. Messages from Twelo
On occasion, Twelo may need to contact you. Primarily, these messages are delivered by email, Twelo Conversations, or by push notifications for a variety of reasons, including marketing, transactions, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email or Conversations in your account settings or by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. Twelo may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent, Twelo may send you an SMS (or similar) message in order to provide you with customer support or to provide you with information about products and features that you may find of interest. You may update your contact preferences in your account settings.
Some messages from Twelo are service-related and necessary for members and Guest Checkout users. You agree that Twelo can send you non-marketing emails, Conversations, or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions, relaying Conversations with buyers, and correspondence with Twelo’s Support team.
When you register for an account, subscribe to a newsletter, or provide us with your email address or phone number such as for a Guest Checkout purchase, you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the opt-out link included in marketing emails or messages. Members may also control which marketing emails or messages they receive from Twelo through their account settings. Please note that some changes to your account settings may take a few days to take effect.
A contact-importer feature is available to help you locate and connect with your friends and contacts who may be members of Twelo (see the "Findability" section above for more information). If someone in your contact list is not already a member, you may invite them to join Twelo, and an email will be sent to them on your behalf. Recipients of email invitations may opt out of receiving future invitations by following instructions in the email invitation message. You may send an invitation only to someone who has given you consent to receive one.
Twelo is a marketplaces and a community. We offer several features that allow members to connect and communicate in public or semi-public spaces, such as Forums, which are a part of the Twelo Community. You don't have to use these features, but if you do, please use common sense and good judgment when posting in these community spaces or sharing your personal information with others through the Services. Be aware that any personal information that you choose to submit there can be read, collected, or used by others, or could be used to send unsolicited messages to you. We may engage certain third parties to assist in providing community services to you and, in the context of that relationship, we need to share some of your information with such third parties in order to provide that service. This may include, for example, information from your Twelo account that is publicly available, your account’s status, your forum posts and Team memberships, your Twelo username and/or shop name, the display name you’ve optionally chosen to share publicly in your Twelo account, avatar image, the date that you registered on Twelo, as well as your language and regional settings on the site. Twelo generally does not remove content from community spaces, and your posts may remain public after your account is closed, although your name will no longer be displayed alongside the post. You are responsible for the personal information that you choose to post in community spaces through the Services. You can set your privacy preferences and download your data in your Community Settings, and close or delete your Community account by submitting a request to Twelo.
Another member may follow your public activity on the Site to receive updates, such as when you add an item to your public Favorites. You may choose to make certain activities private through your account settings. You have the option to block any member with whom you do not wish to share your updates.
7. Information Uses, Sharing, & Disclosure
We respect your privacy. Twelo will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy.
You may control your privacy settings through the opt-out buttons in your account settings privacy tab. Please note that some changes to your privacy settings may take a few days to take effect. We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site.
When you access or use the Services, we collect, use, share, and otherwise process your personal information as described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:
- You have consented to the processing, which you can revoke at any time;
- Necessary to comply with a legal obligation, a court order, or to exercise or defend any impending or asserted legal claims;
- Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners;
- You have expressly made the information public;
- Necessary in the public interest; and
- Occasionally necessary to protect your vital interests or those of others.
Note that we principally rely on consent (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.
We rely on consent for targeted online and offline marketing including through tools like Facebook Custom Audience and Google Customer Match. We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site. As part of this, we may work with advertising partners such as Facebook, Google, and other partners disclosed in our Cookies and Similar Technology Policy, and you may see the privacy policies and privacy choices for these partners in our Cookies and Similar Technology Disclosures.
Where we process your information on the basis of legitimate interests, we do so as follows:
Providing and Improving our Services: We may use your information to improve and customize our Services, including sharing of your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help sellers find the best ways to market and sell their products on Twelo
Keeping our Services Safe and Secure: We may also use your information for safety and security purposes, including sharing of your information for such purposes, and we do so because it is necessary to pursue our legitimate interests in ensuring the security of our Services. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kind.
We use your information to provide and improve the Services and our products, for billing and payments, for identification and authentication, and for general research and aggregate reporting. For example, in accordance with our existing case resolution process, we may use information you provide to resolve disputes with Twelo or other members.
If Twelo receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, Twelo may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, and company name. Find out more about how Twelo responds to requests for records or information about members of Twelo’s community in our Requests for Information Policy.
Aggregated Information: Twelo may share demographic information with business partners, but it will be aggregated and de-personalized so that personal information is not revealed.
Service Providers: Twelo also needs to engage third-party companies and individuals (such as payment processors, research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Twelo not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like processing payments and shipments and helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.
This policy does not apply to the practices of third parties (such as other members who sell using the Services, certain third-party providers on whom we rely to provide certain services, or API users) that Twelo does not own or control or individuals that Twelo does not employ or manage, except as otherwise provided for in the Terms or as required by law. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While Twelo requires these third parties to follow Twelo’s privacy and security requirements, Twelo does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, Twelo is not responsible for the privacy or security practices of these sellers, API users, or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these sellers, third party providers, and API users are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.
Twelo operates a global service by primarily focuses on the UK and Europe. By using our Services, you understand that Twelo.com may share some of the information it gathers with our operations in other countries, on occasion
The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law. Likewise if your information is held in the UK, it could be made accessible to UK authorities in accordance with UK law if we are so instructed.
To the extent that Twelo is deemed to transfer personal information outside of the EEA, we rely separately, alternatively, and independently on the following legal bases to transfer your information:
Necessary for the Performance of the Contract between Twelo and its Members
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. If you have any questions about the security of your personal information, you can contact us at legal at Twelo.com.
Twelo encrypts certain information (such as credit card numbers) using TLS (transport layer security). Twelo follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
Twelo will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Twelo member account), as described in this policy, or as needed to provide the Services to you. If you no longer want Twelo to use your information to provide the Services to you, you may close your account. Twelo will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, Twelo sellers may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address, username, or shop name (if any) for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.
11. Your Rights
You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so via your Twelo account settings or by contacting us. Upon request, Twelo will provide you with information about whether we hold any of your personal information. By visiting your account settings, you can access, correct, change, and delete certain personal information associated with your account. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format. Please ensure you've read the options you have under the "Choice & Control" section above. If you need further assistance, you can contact Twelo through one of the channels listed below under “Contact.” We will respond to your request within a reasonable timeframe.
If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings. Please note that some changes to your account settings may take a few days to take effect.
12. Your Responsibilities
13. Withdrawing Consent
You can choose to withdraw your consent to our processing of your information and your use of the Services at any time by permanently closing and deleting your account through the Privacy tab of your account settings, or by using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If your account does not have any open issues such as unpaid bills, unfulfilled orders, unresolved cases, or policy violations, you will receive an email with instructions to confirm your deletion request. This process may take up to approximately two weeks after which your account will be deleted to the extent permitted. Depending on which of our Services you've used (such as whether you've made purchases or sales on Twelo), we may be required to retain certain information for legal, regulatory, tax, security, or compliance reasons for a limited period of time, after which it will be deleted. This deletion is permanent, and your account cannot be reinstated.
We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the Apps’ platform. We encourage you to check back regularly and review any updates.
If you have any questions:
Contact Twelo’s Support team via our Help Center
Send an email to Twelo's Data Protection Officer at dpo at Twelo.com