Privacy Policy | Website & Cookies

LAST UPDATED: 29TH JULY 2020

1. About Twoosk – Inventory Management, S.A

Twoosk – Inventory Management, S.A. is the controller for the purposes of the General Data Protection Regulation (the “GDPR”) a company registered in Portugal at Lisbon Commercial Registry Office, with VAT number PT513846573. Our registered office is located at Aveiro Business Center, Rua da Igreja, nº79, Aveiro 3810-744, Portugal.

Twoosk – Inventory Management, S.A. operates twoosk.com and is the data controller of information provided to or collected by it.

The following Privacy Policy provides information on how we collect, use, share, and otherwise process personal data when you visit our Website. Personal data is any information that relates to an identified or identifiable living individual and is subject to the protection requirements set out in the GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).

If you have any questions or comments about this Privacy Policy or our privacy practices, including any requests to exercise your legal rights, you can contact the Twoosk Data Protection Officer at:

Twoosk (Administrative Office)
Rua Frei João Turiano, N13 Piso 1
2675-389 Odivelas
Portugal
Contact details
Phone: +351 21 19 19 472
Email: gdpr@twoosk.com
Customer Care Manager: Vanessa Paulo

2. Third Party Websites

Visitors to our Website may access links to and from other websites. You should be aware that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites and visitors are advised to review their policies before providing any personal data to those websites.

3. Collection of personal Data

Information provided by the user (the “Basic Data”)

Twoosk collects personally identifiable information specifically and voluntarily made available by users of the website. As a visitor to our Website, information about yourself are collected when you provide it to us, this will normally happen when you:

  • Register for an account on our Website,
  • Subscribe a service on our Website
  • Establish a contractual relationship with Twoosk
  • Place an order for products,
  • Fill any online forms (contact us form, registration form, shipping information form or surveys),
  • Sign up to receive our newsletters and special offers or enter a promotion,
  • Participate in social media functions with our Website, or
  • Contact us (by email, telephone, live chat, social media or otherwise) to request specific information.

Depending on what you give us, this information can include Basic Data such as your name, title, address, phone number and email address, purchase information, shopping preferences and other information related to the company you represent (professional information), such as company name, company address, company phone number and email address, company VAT ID and position in company. It also includes username/passwords for registration purposes and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).

Demographic information, including gender, date of birth or ethnicity is not usually required but may be submitted when a visitor responds to an online job application.

The collection of information should be limited to the needs and requests of the user. In cases where non-mandatory information is requested, the website visitor will be notified at the time of data collection.

As user of a business seller account, you can invite new users to the same company account. In this case we receive their details from you, so please make sure that you have their permission before sharing their contact details with us.

Excluding cases provided for by law, the processing of personal data relating to philosophical or political beliefs, party or trade union membership, religious belief, private life, racial or ethnic origin, as well as the processing of health and life data is expressly prohibited. including genetic data. At no time is the request or encouragement of the collection of sensitive data. If you voluntarily make them available, twoosk will not be liable for your treatment under this policy.

Information collected by our IT systems when you visit our Website (the “Usage Data”)

These data are primarily technical data such as the browser and operating system you are using or when you accessed the page. This information will be created and are automatically recorded by our IT systems as soon as you enter our website. That information includes:

  • Cookies: Further details of cookies are set out in section 6 below. We use Cookies to facilitate your interaction with us and enhance your experience with the Website by gathering information about your usage patterns while you navigate through it, such as storing your location or language preferences so you don’t have enter the same information multiple times when returning to, or ensuring that items you wish to order don’t disappear as you navigate between pages on our Website. We also allow certain trusted partners, such as Google Analytics, Hotjar, Albacross, Unbounce, among others, to place cookies on our site, this allow us to better serve you by providing you advertisement tailored to your interests.
  • Device data: depending on the type of device you are using (PC, Mac, iPhone, Android, or otherwise) this information will differ, but includes the type of device you have, the device’s IP address, the browser you are using or your mobile network provider, in case you are using a mobile device. Our systems will also recorded other data about usage of our Website and communications, like the pages you have visited, your time zone and country location, and crash or download error reports.

Information received from third parties (the “Marketing Data”)

We may also receive indirectly information about you from other accounts or sources (indirect collection). This data will be collected through partner entities or third parties that may include data brokers, social media providers (like Facebook and Instagram), advertising networks and analytics partners as well as payment and delivery service providers.

  • The data we receive from you, such as name, email, address, physical address, or phone number can be complemented with information from data append services such as public or social graph data in order to improve the services we offer to our customers. This data will be associated with our existing customer account information, which means with your personal information, and will help us run our business and improve our Website and your experience by better understanding our customers’ interests and therefore providing more relevant product recommendations and advertising. It may also be used to increase our customer’s security when using our Website and to comply with our legal obligations, such as sanctions laws.

4. Use of personal data

Most personal data are collected to ensure the proper functioning of the Website and our services. Other data can be used to analyze how visitors use the site and to optimize their experience.

We also use information for marketing and advertising purposes, this happens either if you signed up to receive marketing communications, like our newsletters or if you placed an order through the Website. Twoosk will use personal information like your name, email address and phone number to occasionally send you promotion updates, news, and offers via email, message, or via social media.

There is also the possibility we may use information received from our partners, to send you communications like the ones described below.

If you no longer wish to receive any marketing communications or remain on a mailing list to which you previously subscribed, you can choose to stop receiving such communications by unsubscribing our email marketing communications. To do so please follow the opt out instructions in the promotional emails that are sent to you or contact us as detailed on section 1 above.

The personal information we received from users of the website is used for several different purposes and may take place in the following formats:

Purpose of Use and Data Collection

  • To register and administer your account in our Website. Basic Data Collection: name, email, password and other additional and optional details you may wish to add in your account, like phone number, addresses.
  • To order and receive products, services and training you requested through our Website. Basic Data collection: name, email, phone number, Billing and Shipping addresses, Order details (Products and prices), and optional company details like name and VAT ID.
  • To process payment for requested products or services. Credit/Debit Card Data Collection: We do not hold your payment information, which comprises the credit/debit card’s number, holder’s name and CVV, we only transfer them to our authorized payment processors.
  • To register for events, conferences, lectures, training actions or other online services. Basic Data Collection: name, email, password and other additional and optional details you may wish to add in the online form, like phone number, addresses.
  • To contact you and respond to your inquiries and requests for additional information or to know how was your experience with us and to help you to solve any issue you have with our services (Customer Services). Basic Data Collection: name, email, phone number when provided by the user, password and addresses and your contact history with us. We do this in the interest of retaining you as a customer.
  • To monitor the quality of our customer services. Basic Data Collection: name, email, password and addresses and your contact history with us. Based on our legitimate interests in running our business.
  • To administer and maintain our business operations and optimize our Website and our Services. Usage DataCollection: device IP address and type, Cookie identifiers and browsing information. We do this with the aim of running our business.
  • To provide you a more personalized experience on the Website and make it easier to use. Basic and Usage Data Collection: name, email, phone number, addresses, browsing and purchase history and behavior; shopping preferences, cookie identifiers, internal identifiers, country. We do this in the interest of running our business as well as improving our Website and your experience.
  • To send you relevant marketing communications about our partners’ products, personalized offers and opportunities that may be available to you. Basic, Usage and Marketing Data Collection: name, email, phone number, addresses, browsing and purchase history and behavior; shopping preferences, cookie identifiers, internal identifiers, country.
  • To advertise and remarketing our Partners’ products and services. Basic, Usage and Marketing Data Collection: email, cookie identifiers and device information. We do this in the interest of running our business.
  • To carry on research, analysis, enquiries and surveys on your use of our website and quick views (Customer Experience). Basic and Usage Data Collection: name, addresses, email and device information. We do this in the interest of running our business as well as improving our Website and your experience.
  • To produce aggregated statistical reports. We collect order history, provided that the result of such reports do not identify you. We do this in the interest in running and improving our business.
  • To protect the security and effective functioning of the Website from any fraudulent behavior and to perform credit checks to your and our financial security. Basic, Usage and Credit/Debit Card Data Collection: name, email, addresses, credit/debit card details (hold by our authorized payment processors), browsing and purchase history, IP address and device type and any publicly available information (like social media profiles or news). We do this with the aim of protect Twoosk and its customers from any fraudulent activities and to comply with a legal obligation.

If the visitor considers that excessive information has been collected or wishes to exercise the right to forget, we request that you contact us at gdpr@twoosk.com.

5. Sharing of personal Data

Twoosk reserves the right to disclose or share information to carefully selected third parties with whom we work with. We do that in the following limited circumstances:

  • Our Seller Shop Partners, from whom you purchase the products you see in our Website and for the purposes we described above
  • Service providers, we rely on to assure the proper function of our Website and services. These third parties, such as Courier companies, Payment processors, Analytics and search engine providers, Marketing Tools providers, Performance Marketing providers and IT Technology providers, perform services on our behalf and under our instructions in order to carry out the purposes identified above.
  • Legal requirements, with which we need to comply on, such as any judicial notification, court order, search warrant or another admissible legal process or governmental request. Where we consider it appropriate and as long as we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands.
  • Aggregate information for usage analysis, your information may be compiled with other users information in order to create and organize a dataset about the usage of our service and interest for products, with the purpose of running our business and improve our Website and your experience. This grouped information cannot be linked to you as an individual, so it is not considered personal data, but it is a valuable insight in understanding the usage of our Website and in identifying improvements.
  • Marketing advertising, for the purpose of running marketing campaigns, your information may be shared with our advertising and social media partners, like Facebook, Instagram, or LinkedIn. Data will be shared to select and serve a specific audience with relevant adverts about our sellers’ products and our services to you and others.
  • Business Reorganization, as a result of a corporate transaction to the extent permitted by law, as part of a merger, acquisition, asset sale, transition of service to another provider or in the event of insolvency, bankruptcy, or receivership. In on one of these situations we may transfer your personal data to enable the concretization of that transaction, which means your personal information may be transferred as an asset of Twoosk.

Twoosk Website does not save or collect personally identifiable information for the purpose of sale to third parties or sending emails on behalf of third parties.

6. Cookies

We use cookies to collect and store information about your usage patterns and online preferences. By entering our Website, you agree to the use of cookies by twoosk.

Cookies are small text files sent by a website you visit and saved by your web browser; this information transfer allows the Website to uniquely identify your browser on each page.

We use the information to create reports and to help us improve the Website. Cookies collect information anonymously, including the number of visitors, the websites they come from, and the pages they visit. This is done by Google Analytics (more details below at the list of categories of cookies we use, please check Performance Cookies).

Visitors to our Website use different query programs and different devices. In order to make your queries as easy as possible, with the technology you are using, we automatically record the type of query program (such as Microsoft Edge) and operating system (Windows, iOS) used by a visitor, as well as the name domain of the provider of your Internet service. This is done by Google Analytics (more details below at the list of categories of cookies we use, please check Performance Cookies).

Cookie technology helps us deliver content tailored to the interests of visitors, right products to the right audience. Websites that offer online services use cookies to record and process the items on your purchase card. Whenever authorized, we may associate personal information with a cookie file in such circumstances.

We use the following categories of cookies on our Website:

  • Strictly Necessary Cookies These cookies are required for the proper operation of our Website and its features. They include cookies that enable us to provide you services such as remembering your login details or shopping basket items.
  • Performance Cookies These cookies allow us to know the use and performance of our Website by collecting information about the total number of visitors to our website, how visitors arrive to our site and how such visitors navigate through it. This data allows us to identify preference behaviors and areas where we can improve, helping us to keep our Website up to date and interesting for the visitors; in this process no identifiable personal information is extracted. We use Google Analytics cookies. You may exercise choice on the use of these cookies and withdraw your consent to these cookies at any time by reviewing your internet browser settings. To learn more about the use of Google Analytics cookies, please visit https://tools.google.com/dlpage/gaoptout.
  • Functional Cookies These cookies are responsible to remember choices you have taken when you previously visited our Website, like language preferences or that you have asked to remain logged into it. So, their function is to make the use of our site easier for you. You may exercise choice on the use of these cookies and withdraw your consent to these cookies at any time by reviewing your internet browser settings.
  • Targeting Cookies These cookies collect information about your browsing history, they record your visit to our Website or outside it while browsing the Internet, the pages you viewed and links you have followed, to help us offer you relevant advertisement according to your interests. They are also used to limit the number of times an advertisement is viewed and to help measure the effectiveness of an advertising campaign. These cookies are usually placed by third party advertising networks. You may exercise choice on the use of these cookies by reviewing your internet browser settings. To learn more about certain third-party targeting cookies, please visit the www.youronlinechoices.eu or for more information you can also go to https://digitaladvertisingalliance.org/ , https://www.networkadvertising.org/ , https://youradchoices.ca/ and https://www.edaa.eu/ .
  • Social Media Cookies These cookies allow you to share what you have been doing on the website on social media such as Facebook. Please review their respective privacy policies to be informed about how their cookies work.

Please remember that if you want to delete any cookies that are already stored on your computer, you can directly go to your internet browser settings, under the sections Help or “Support area" for instructions on how to locate the file or directory that stores cookies. Also, you can learn more about deleting or controlling cookies at www.AboutCookies.org .

Note however that by refusing and deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website and that you will no longer received adverts tailored to your usage preferences, you will although continue receiving online advertising.

7. Data storage

Personal Data provided by you is stored for as long as you have your account with us or, if related to marketing activities, for as long as you accept marketing communications from us. In any case, upon request we will securely delete information that identifies you as an individual in accordance with applicable law.

We retain your information only for the period necessary to comply with the purposes for which the data are processed, which are outlined in this Privacy Policy. This means the period of time during which data is stored and preserved varies according to the purpose for which the information is processed. Although, in some justifiable cases, we may be obligated to extend the retention period due to legal requirements applicable to us.

Visitors' contacts, such as email addresses, obtained through access to certain areas of the website, will be stored for the purposes of running marketing campaigns after confirmation of the user and until the user requests the deletion of such information.

8. Data Subject Rights

All users have certain rights related to the information we retain about you. Where legally required you have the right to:

  • Confirm that we retain your Personal Data
  • Verify its content and accuracy
  • Access, change, port, delete your Personal Data
  • Block or Withdraw consent to the processing of certain Personal Data
  • Refuse the use of your Personal Data for direct marketing communications
  • Contact us through our Data Protection Officer set on section 1 above

Please note that we will require you to verify your identity before responding to any requests to exercise your rights. If appointed a third party to do the request on your behalf, that person and/or organization needs to bear a valid power of attorney issued by you. We must respond in writing (includes electronic means) to a request by you to exercise those rights without undue delay and within a maximum period of one month from the receipt of the request, except in certain complex situations and particular circumstances, in which this may be extended by a further two months. All questions regarding the exercise of your rights should be directed to gdpr@twoosk.com. or by writing to Data Protection Officer, at Rua Frei João Turiano, nº13 Piso 1, 2675-389 Odivelas, Portugal. When so requested, twoosk will remove identifying information from current systems.

If the request submitted by the user are manifestly unfounded or excessive, in particular due to its repetitive nature, Twoosk reserves the right to charge administrative costs or refuse to procced with the request.

Twoosk assumes the responsibility of keeping a strict record of the information provided by the users of the website. However, it is not responsible for checking the accuracy of this information. Whenever possible, and should you become aware that certain information collected through the website is not correct, you will make the appropriate changes based on the information provided by the authenticated visitor.

9. Security

Twoosk has implemented and maintain an appropriate technical and organizational measures to protect you and your personal data against loss, misuse, alteration or destruction, this is done by twoosk in our servers. However, Twoosk uses internationally recognized web platforms, such as Hotjar and Google Analytics, and therefore, when used, transfers to them the responsibility to protect the information stored there. Furthermore, all twoosk employees follow a network security policy and only authorized employees have access to personal data, which are also linked to the duty of confidentiality.

However, please keep in mind that you also have an important role in protecting your Personal Data, by not sharing your username and password with anyone, and not re-use your passwords across more than one website. We require you to establish a unique password to log in into your account on our Website. If you have any reason to believe that your username or password has been compromised, please contact us as detailed on section 1 above.

Some other measures include:

  • Both Twoosk and our authorized payment processors use a Transport Layer Secure (TLS) to encrypt the personal data that you send us during the process of checkout and submit an order, this includes any financial information such as credit or debit card details that are transferred to our payment providers;
  • Twoosk does not keep details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number); and
  • Twoosk performs regularity monitoring actions on its servers and IT systems in order to avoid and identify possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not entirely secure. For any other ways of communication outside our system, security is handled by other systems. We cannot guarantee the security of your personal data transmitted to or through our Website, and any such transmission is at your own risk. In particular, please be aware that if you voluntarily disclose personal information in a non-protected environment, that information can be collected and used by others outside of our or your control.

10. Use by children

The Website and the services provided by Twoosk are not intended to be used by children. It is neither the policy nor the intention of the twoosk to proceed with the collection and intentional processing of personal data of children.

11. Complaints

If you have any questions or concerns about this Privacy Policy, please contact us:

  • by emailing us at gdpr@twoosk.com; or
  • by writing to the Data Protection Officer, at Rua Frei João Turiano, nº13 Piso 1, 2675-389 Odivelas, Portugal

You also have the right to contact or launch a claim with the Portuguese Data Protection Authority, an independent body, with powers of authority throughout Portuguese national territory (www.cnpd.pt/) or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

12. Updates to this Privacy Policy

Twoosk reserves the right to modify or amend this statement at any time, either due to changes in our privacy practices or due to a legal requirement. If any changes are made, they will be posted on this page and the date of the last change, available at the top of this, is also updated. It is highly advisable to regularly consult our Privacy Policy to keep informed of any update. When legally required we will be notifying you by email and ask your consent to the changes.