Instant-System has developed a mobile application (TWISTO, “App”) that collects data from your device in order to provide you with pertinent transport information for nearby services.
1. Objective
By using TWISTO, you accept the terms and conditions described in this Privacy Policy.
2. Purpose
This Privacy Policy describes how we collect, use and disclose your information and how this information can be accessed and deleted when necessary.
3. Scope
TWISTO may contain links to websites, apps, products or services that are operated by third parties. This Privacy Policy does not extend to these third parties on which we have no control and for which we cannot be held liable. We encourage you to read about the privacy policies, procedures and practices of those third parties.
4. What information we collect from you
We collect and process information from your device in several ways, including:
- Once you have given us your consent to track your location, we keep track of your location and movement, including your latitude, longitude, time and speed of travel.
- The collection of location data only happens while TWISTO is in the foreground (unless explicitly stated otherwise by TWISTO) and if you’ve granted TWISTO access to your device’s location services.
- We collect your preferences, including favorite routes, saved locations.
- We also automatically collect usage details each time you use TWISTO, including the country of origin, the searches you make, the routes you interact with, the type of phone or OS you are using, etc.
- We collect contact information (push notification token) when you explicitly request to be notified when TWISTO supports a new market.
5. How we use your information
We may use information collected from or provided by you for the following purposes:
- Provide you with pertinent transport information for nearby services;
- Understand your preferences so that we can customize TWISTO for you, such as recommending personalized transport options;
- Restore your preferences if you log into your TWISTO account on a different device;
- Measure usage of TWISTO, including usage of specific features and views;
- Generate real-time location data of TWISTO vehicles and broadcast the vehicle location and predicted arrival times to other users;
- Develop and improve TWISTO based on your feedback and interactions;
- Guide product development and build new features;
- Conduct research on users habits and how they use public transportation;
- Identify and correct bugs and other problems with TWISTO;
- Respond to your emails and help with support queries;
- Comply with law and regulations and lawful requests or orders.
6. Users’ options
The following are some examples of your options with regard to collection, use and disclosure of your information:
- You can stop all collection of location data easily and at any time by disabling location services in your device’s settings or by uninstalling TWISTO.
- You are not required to indicate any preferences (including setting your home and work address) in order to use TWISTO, nor are you required to create a TWISTO account that records your email, since these are optional.
- You can provide anonymous feedback by using an email account that does not reveal your identity, and does not include your name.
7. Disclosure to Third Parties
We do not disclose your information to third parties without your explicit consent except for the following purposes:
7.1 Third Party Software/Service
While using TWISTO, we may be using third party software and/or service for various needs, inter alia, in order to collect and/or process the information detailed herein (the "Third Party Service Provider"). These third party services include the usage of Software Development Kits (“SDKs”) from the following companies and for the following purposes:
- Mixpanel SDK, which is used for product analysis.
- Google Analytics SDK, which is used for product analysis.
- Fabric SDK, which is used for crashes and issues analysis
- Firebase SDK, which is used for user’s preferences, favorite location storage and sending push notifications.
Note that these are independent software and/or service providers and we do not take any liability about the information collection policies of these providers, or about any kind of issue, legal or otherwise, relating thereto.
8. Security Safeguards
We are committed to securing your information and we take reasonable physical, organizational and technical measures to protect your information against unauthorized access, use, disclosure, modification or destruction.
These safeguards include, but are not limited to:
- Storage on secure servers;
- Encryption of the communication channels;
- Limited access to employees and contractors on a “need-to-know” basis.
Although we take great efforts to protect your information, no security system can prevent all potential security breaches nor be immune from any wrongdoings or malfunctions.
9. Retention Period
We will retain your information as long as you use TWISTO and for a reasonable time thereafter.
10. Right to Access and Removal
We store your information on servers located in Europe.
If you would like to remove or access any information that we have collected through TWISTO that is stored on our servers, please contact us at contact[@]instant-system.com. On receiving such a request, we will use reasonable efforts to provide you or delete such information.
11. Children
We do not knowingly collect, use or disclose information from children under the age of 13. If we learn that we have collected information of a child under 13 without first receiving parental consent, we will take steps to delete such information within a reasonable time. If you have reason to believe that a child under the age of 13 has provided information to us, please contact us and we will take steps to delete such information within a reasonable time.
12. Rights of European Data Subjects
If you are in one of the EU/EEA countries, you are be entitled to certain rights under the General Data Protection Regulation (GDPR).
By using TWISTO or communicating with us, you consent to the purposes for which we process your personal data. We may process your personal data if we have other lawful grounds to do so.
You have a right to:
- Withdraw consent to processing, where consent is the basis of processing.
- Access your personal data that we hold and how to process it, under certain conditions.
- Demand rectification of inaccurate personal data about you.
- Object to unlawful data processing under certain conditions.
- Require erasure of past data about you (your "right to be forgotten") under certain conditions.
- Demand that we restrict processing of your personal data, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal data is inaccurate.
- Port personal data concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
- Complain to a data protection supervisory authority in your country.
The personal data we collect is not used for automated decision making and profiling, except for automated processes in the context of marketing. As stated above, you can opt-out of our direct marketing under certain conditions.
To learn more about your rights under the GDPR you can visit the European Commission’s page on Protection of Personal Data.
13. Update
We reserve the right to amend or change this Privacy Policy at any time without notice. In case of substantial changes to this Privacy Policy, we will alert you through our social media accounts within 30 days before such changes enter into effect. We will also update the privacy policy within the app on the date that such changes become effective. By using TWISTO, you agree to be bound by the version of the privacy policy displayed on the date upon which you use the app. If you do not accept the amended or changed Privacy Policy, you may not access, use or continue to use TWISTO. By continuing to access and use TWISTO, you are acknowledging your acceptance of the amendments and changes. In any case, we recommend that you consult this page regularly in order to be informed of any changes in this Privacy Policy.
14. Contact information
If you have any questions or concerns about this Privacy Policy, please contact us by email at contact[@]instant-system.com and we will examine and reply to all communications within reasonable delays.