TWLP Privacy Policy

Data protection and security are important to TWLP AG ("TWLP", "we"). This Privacy Policy describes how we collect and process your personal data when you use our global community Platform twlp.org ("TWLP Platform").

  1. Collection and Processing of Personal Data

Personal data we collect and process in order to make the TWLP Platform available

You can visit the TWLP Platform and obtain general information about our community of animal rights activists without telling us who you are. As with any connection with a webserver, however, the server of our webhosting provider logs and temporarily stores certain technical data. Such data includes the IP address and operating system of your device, the date and time of access, the URL you visited, the type of browser you use and the geographic region from which you access the TWLP Platform.

In addition, the services we use in order to optimize, improve or (if required) restore the functioning of the TWLP Platform collect and temporarily store technical data such as your IP address and features of the TWLP Platform with which you have interacted. Our service providers and we require this data for technical reasons to make the TWLP Platform available to you and to provide you with the best possible user experience.

Data we collect and process in order to provide our services and to keep you informed

If you sign up for the TWLP Platform and join as a member, complete your profile or use the Events, Courses or Chat sections of the TWLP Platform, we collect and process the information you provide to us:

  1. Sign up

In the sign-up process, we ask you to provide your name and email address. This will allow us to notify you of relevant events and developments in your region, in the form of email newsletters.

Once you have submitted your details, we will also send a verification email with a link to confirm that your email account is valid and belongs to you. You will be required to click on the verification link to finish creating your user account.

If you sign up using the Facebook login option on the TWLP Platform, we will collect your Facebook account information. This includes name, email, gender, birthday, current city and profile picture URL.

  1. My Profile

In the My Profile section of the TWLP Platform, you may let other logged-in users of the TWLP Platform know about your background, experience and interests. This section also lists the teams or organisations you connect with on the TWLP Platform, the region or country in which you are typically active and events where you are or have been registered or checked in. The personal information you provide in this section is public to all logged-in users of the TWLP Platform.

  1. Events, Courses and Chat

We collect and store the content you upload or enter when using the tools that facilitate organisation and management of events or courses on the TWLP Platform. Team memberships, events, and chat messages sent to the public channel are public to all logged-in users of the TWLP Platform. Tasks allocated to team members and messages sent to group chat channels are accessible for members of the respective group.

We will use the personal data provided or generated on the TWLP Platform in order to perform our contractual obligations to you, provide our services or to notify you of activities and developments at TWLP. Furthermore, TWLP will generally analyze this personal data in order to send you personalized offers and information related to vegan living. However, you may notify TWLP at any time if you no longer wish to receive such information.

Data we collect and process in order to analyze and improve the use of the TWLP Platform

We use Google Analytics, a web analytics service provided by Google LLC. If you access the TWLP Platform in the European Economic Area (EEA) or Switzerland, Google Ireland Limited is the provider of Google Analytics and controller in relation to the processing of personal data in connection with Google Analytics. Google Analytics uses cookies to collect the information that is required to evaluate and create reports on the use of the TWLP Platform and to provide other services that support our analysis and improvement of the use of the TWLP Platform.

We use Google Analytics with IP anonymization. This means that your IP address will be shortened in Switzerland or the EEA. Only in exceptional cases, will the full IP address be transmitted to a Google server in the USA and shortened there. Accordingly, Google only stores the information collected via cookies in anonymous form and processes it in aggregated form. You can prevent Google Analytics from using your data by downloading and installing a browser add-on to disable Google Analytics.

Tools we use to integrate chat, maps, file storage, activity feed or other features

We use tools that allow us to integrate certain features on the TWLP Platform. We operate some of the tools on our own systems (e.g. the sign-up and chat features). In addition, we use services provided by third parties to implement certain map, search, activity feed and file storage features on the TWLP Platform.

For example, we use MapBox to display and support the navigation of maps on the TWLP Platform, the OpenCage geocoder to support search features, Amazon Web Services to allow you to upload files in the Events or Courses sections of the TWLP Platform, and Stream.io for activity and notification feeds on the TWLP Platform.

Tools we use to keep you informed and to optimize the communication with you

Further, the TWLP Platform uses Mautic and other marketing automation or targeting tools. We use these tools in order to automate promotional campaigns and other marketing processes, and to measure and customize our updates, promotions and other services or offerings.

TWLP also use marketing tools in order to target information about activities and updates as well as personalized offers to users of the TWLP Platform when they visit other websites or online platforms (re-targeting).

Data processing to facilitate social sharing

We use social media plug-ins in order to facilitate recommending and sharing content on social networks such as Facebook and Twitter. Those social media platforms use cookies in order to provide the sharing and recommendation features to you. They are the controllers of the data they thereby collect and process. Please consult the privacy notices of the respective social network providers for further information.

  1. Processing Principles and Legal Basis

We process your personal data responsibly, as necessary for the purposes set forth in this Privacy Policy or otherwise communicated to you, and in accordance with applicable laws.

We primarily use the collected personal data in order to make the TWLP Platform available, and provide our services in accordance with our contractual obligations to you, as well in order to comply with our legal obligations. In addition, we may process your personal data to pursue our or legitimate interests, in particular, to analyze and improve the use of the TWLP Platform, optimize, promote and personalize our services or to deliver targeted marketing and offers of TWLP.

However, we may also ask you for your consent to the processing of your personal data for certain purposes (e.g. for promotions). If you have consented to certain processing activities, we will process your personal data within the scope of and based on such consent, unless we have another legal basis for this processing, or no longer need one. You may withdraw your consent at any time with effect for the future.

  1. Data Security and Storage Limitation

We apply adequate technical and organisational security measures, commensurate with the level of known risk, in order to protect the confidentiality and integrity of your personal data.

We store your personal data only for as long as this is necessary to fulfill the purposes set forth in this Privacy Policy, to protect the integrity of the TWLP Platform and the interests of other members of the TWLP Platform, or to comply with our legal obligations. You may delete your personal data posted or shared on the TWLP Platform yourself in accordance and within the limits of the Terms of Use.

  1. Why we use Cookies

We use cookies, tags and similar technologies on the TWLP Platform to provide you with the best possible user experience and to help us improve our services. Cookies are text files that are downloaded to your computer or mobile device when you visit a website or online platform.

Some of the cookies we use are necessary in order to make available certain features of the TWLP Platform (e.g. social media sharing, chat, or maps features). We also use cookies to analyze the use of the TWLP Platform, optimize our services and to enable the use of marketing tools as set forth in this Privacy Policy.

  1. With whom we share your personal data

We share personal data with third-party providers in order to allow the use of maps, file storage, social sharing, activity or notification feeds and further features of the TWLP Platform. In addition, we share personal data with providers that allow us to communicate with you or to optimize the performance of the TWLP Platform. Examples of third party providers include but are not limited to: MailChimp, Rocketchat, Pubnub, Google Analytics, Firebase.

TWLP guarantees that no data will be forwarded to third parties for marketing purposes. A transmission occurs only on behalf of the data processors for example in case of data backup and data processing.

  1. Your rights regarding your personal data

You have the right to access or receive certain information regarding the personal data we process, and to receive a copy of this data. Further, you have a right to have your personal data rectified, object to the processing of your personal data, or to ask us to restrict processing or to delete your personal data.

Please note, however, that your rights are subject to exceptions or derogations. Where legally permitted to do so, we may refuse your request to exercise these rights. We may need to further process and retain your personal data to perform a contract with you or your company or organisation, to comply with legal obligations or to protect our own legitimate interests or the rights of others. However, you have a right to lodge a complaint with a competent supervisory authority.

  1. Controller / Contact

TWLP AG, Friesenbergstrasse 75, 8055 Zurich, Switzerland, is the controller in relation to the data processing described herein. General contact: info@twlp.org. If you have any queries about data protection at TWLP, please write to dataprivacy@twlp.org.

We have designated an EU representative, as the EU GDPR may govern some of our data processing activities on or in connection with the TWLP Platform: VGS Datenschutzpartner UG, Am Kaiserkai 69, 20457 Hamburg, Germany. You can contact our EU representative at info@datenschutzpartner.eu.

  1. Amendments of this Statement

We may amend this Statement at any time without prior notice. The current version published on the TWLP Platform shall apply.

Last updated: November 29, 2019