LAST UPDATED: 18TH January 2022
1. About Twoosk – Inventory Management, S.A
Twoosk – Inventory Management, S.A., a company registered in Portugal at Lisbon Commercial Registry Office, with VAT number PT513846573, is the controller for the purposes of the General Data Protection Regulation (the “GDPR”). Our registered office is located at Aveiro Business Center, Rua da Igreja, 79, 3810-744 Aveiro, Portugal.
Twoosk – Inventory Management, S.A. operates twoosk.com and is the data controller of information provided to or collected by it.
|Twoosk (Administrative Office)|
|Rua Frei João Turiano, N13 Piso 1|
|Phone: +351 21 19 19 472|
|Customer Care Manager: Vanessa Paulo|
2. Third Party Websites
3. Collection of Personal Data
Information provided by user (“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 is collected when you provide it to us. This will normally happen when you:
- Register an account on our Website
- Subscribe to a service on our Website
- Establish a contractual relationship with Twoosk
- Place an order for products
- Complete any online forms (contact form, registration form, shipping information form or surveys)
- Sign up to receive our newsletters and special offers or take advantage of a promotion
- Engage with social media functions via our Website, or
- Contact us (by email, telephone, live chat, social media or otherwise) to request specific information
Depending on what you provide, such information may 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, but our payment processors do).
Demographic information, including gender, date of birth or ethnicity, is usually not required but may be submitted when a visitor responds to an online job application.
The collection of information is 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 do we request or encourage the collection of sensitive data. If you make them available voluntarily, Twoosk will not be liable for their treatment under this policy.
Information collected by our IT systems when you visit our Website (“Usage Data”)
These data are primarily technical data such as the browser and operating system you are currently using or when you accessed the page. This information will be created and automatically recorded by our IT systems as soon as you access our website. That information includes:
- 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 your device, its IP address, the browser you are using or your mobile network provider, in case you are using a mobile device. Our systems will also record other data about usage of our Website and communications, such as the pages you have visited, your time zone and country location, and crash or download error reports.
Information received from third parties (“Marketing Data”)
We may also receive indirect 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, i.e. your personal information, and will help us run our business and improve our Website and your experience by better understanding our customers’ interests and thereby 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 is 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. For instances, if you signed up to receive marketing communications, such as our newsletters, or if you placed an order through the Website. Twoosk will use personal information such as your name, email address and phone number to occasionally send you promotion updates, news, and offers via email, messaging, or social media.
We may use information received from our partners to send you communications such as the ones described above.
If you no longer wish to receive any marketing communications or remain on a mailing list to which you previously subscribed, you may 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 in section 1 above.
The personal information received from users of the website is used for several different purposes and may use any of the following formats:
Purpose of Use and Data Collection
- To register and administer your account on our Website. Basic Data Collection: Name, email, password and other additional and optional details you may wish to add to your account, such as 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 such as name and VAT ID.
- To process payment for products ordered or services requested. Credit/Debit Card Data Collection: We do not hold your payment information, which comprises the credit/debit card 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 to the online form, such as phone number, addresses.
- To contact you and respond to your inquiries and requests for additional information or to learn about your experience with us and to help you solve any issue you may have with our services (Customer Services). Basic Data Collection: Name, email, phone number when provided by 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 with 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 and to enhance our Website and your experience.
- To advertise with registration for the newsletter. We send you relevant marketing communications about our partners’ products, personalized offers, and opportunities that may be available to you as well as news from the telecom & datacom industry. Basic, Usage and Marketing Data: Name, email, browsing and purchase history and behavior; shopping preferences, cookie identifiers, internal identifiers, country. We do this based on your consent. Unsubscribing from the newsletter is possible at any time and can be done either by sending a message to the contact option described below or via a link provided in the newsletter. After unsubscribing, we will delete your e-mail address, unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we will inform you in this declaration.
- To advertise without registration for the newsletter and your right to object. If we receive your e-mail address in connection with the sale of a product or service and you have not objected, we reserve the right to regularly send by email offers on products similar to those already purchased. Basic, Usage and Marketing Data: Name, email, cookie identifiers and device information. We do this in the legitimate interest of running our business. You can object to this use of your e-mail address at any time by sending a message to the contact option described below or via a link provided in the advertising e-mail.
- To carry out research, analysis, inquiries 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 and to enhance our Website and your experience.
- To produce aggregated statistical reports. We collect order history, as long as the results of such reports do not identify you. We do this in the interest in running and enhancing our business.
- To protect the security and effective functioning of the Website against any fraudulent behavior and to perform credit checks for your and our financial protection. Basic, Usage and Credit/Debit Card Data Collection: Name, email, addresses, credit/debit card details (held by our authorized payment processors), browsing and purchase history, IP address and device type and any publicly available information (such as social media profiles or news). We do this to protect Twoosk and its customers against any fraudulent activities and to comply with legal obligations.
If a visitor considers that excessive information has been collected or wishes to exercise the right to forget, we request that you contact us at firstname.lastname@example.org.
5. Sharing of Personal Data
Twoosk reserves the right to disclose or share information to carefully selected third parties with whom we work. We do that under the following limited circumstances:
- Group companies for business purposes, Twoosk – Inventory Management, S.A. is part of a larger family of companies in the telecom industry (the “Yelco Group”). The Yelco Group comprises a diverse portfolio of businesses in telecommunications, including, but not limited to, Yelco Technologies, S.A., Yelco Consulting, S.A. and GW Fiber Optics. You can find information about the Yelco Group here . We may share your personal information in order to operate our business and provide the Website and services.
- Business Sellers (Seller Shop), from whom you purchase the products you see on our Website and for the purposes described above.
- Service providers, on whom we rely 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 to carry out the purposes identified above.
- Legal requirements we need to comply with, such as any judicial notification, court order, search warrant or any other admissible legal process or governmental request. Where we consider it appropriate and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of such legal demands.
- Aggregate information for usage analysis, where your information may be compiled with information from other users to create and organize a dataset about the usage of our services and users' interest in our products, with the purpose of running our business and enhance our Website and your experience. Such grouped information cannot be linked to you as an individual, wherefore it is not deemed to be personal data, but valuable insight in understanding the usage of our Website and identifying improvement potentials.
- Marketing advertising, where for the purpose of running marketing campaigns, your information may be shared with our advertising and social media partners, such as 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 available 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. Under any of such circumstances we may transfer your personal data to enable such 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.
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 in the list of cookie categories we use, please check Performance Cookies).
Visitors to our Website use different query programs and different devices. 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 domain name of the provider of your Internet service. This is done by Google Analytics (more details below in the list of cookie categories we use, please check Performance Cookies).
We use the following cookie categories 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 with services such as remembering your login details or shopping basket items.
- Functional Cookies These cookies remember choices you have made when you previously visited our Website, such as language preferences or requests to remain logged in. 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, record your visit to our Website or outside of it while browsing the Internet, the pages you viewed and links you 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 https://www.youronlinechoices.eu/ . 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 already stored on your computer, you can directly go to your internet browser settings. Under sections Help or “Support area" look for instructions on how to locate the file or directory that stores cookies. To learn more about deleting or controlling cookies go to 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 receive adverts tailored to your usage preferences, although you will 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.
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 by the user and until user requests the deletion of such information.
8. Data Subject Rights
As user you 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 as set in section 1 above
Please note that we need to verify your identity before responding to any requests to exercise your rights. If you appointed a third party to submit the request on your behalf, such person and/or organization needs to have a valid power of attorney issued by you. We are required to respond in writing (including by electronic means) to your request to exercise those rights, without undue delay and within a maximum period of one month from receipt of such 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 email@example.com or in writing to Data Protection Officer, at Rua Frei João Turiano, 13 Piso 1, 2675-389 Odivelas, Portugal. When so requested, Twoosk will remove any identifying information from the current systems.
If user´s request is 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, we will make the appropriate changes based on the information provided by the authenticated visitor.
Twoosk has implemented and maintains 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 therein. Furthermore, all Twoosk employees follow a network security policy and only authorized employees have access to personal data and are also bound by the duty of confidentiality.
Nevertheless, 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 using your passwords across more than one website. We require you to set a unique password to log 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 under section 1 above.
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 regularily monitors the actions carry out on its servers and IT systems to prevent and identify possible vulnerabilities and attacks. Unfortunately, the transmission of information via the Internet is still 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 Twoosk to proceed with the collection and intentional processing of personal data of children.
- By emailing us at firstname.lastname@example.org or
- by writing to the Data Protection Officer, at Rua Frei João Turiano, 13 Piso 1, 2675-389 Odivelas, Portugal
You also have the right to contact or lodge a complaint with the Portuguese Data Protection Authority, an independent body, with powers of authority throughout the Portuguese national territory (www.cnpd.pt) or with the data protection supervisory authority in the EU country, in which you live or work and where you think we may have infringed data protection laws.