Twin Oak Systems
Limited
Privacy Policy For Remote Access Users
Effective Date 2 October
2014
OVERVIEW
This statement discloses the privacy practices for
the services provided by Twin Oak Systems Limited (“TOSL”)
The term "personal information" as used in
this Privacy Policy refers to information that specifically identifies an
individual (name, address, telephone number, e-mail address), and information
about that individual when such information is directly linked to personally
identifying information.
HOW WE COLLECT
AND USE INFORMATION
Via Websites & Mobile Device Apps: We only collect your email address and other
personal information when you subscribe to our services via our website and/or
mobile device App. Your contact
information is used to send you notifications of App updates and content that
you have subscribed for.
Email: We place email links on the Sites to allow
you to contact us directly. The information you provide, which may include
personal information, is used to respond directly to your questions or
comments.
Via Software: TOSL may obtain information as a result of
data being sent to our servers from our Apps ("agent"
information).
We store data, which tracks information such as
network signal quality, location, bearing, speed, time, service usage
statistics, and the end user's mobile device, in a database. Once the data is
in the database, we use it to build maps, aggregate relevant non-personal
and/or repackage the data to distribute it to improve our infrastructure so as
to improve quality of service. WE DO NOT
SHARE THIS DATA with clients and partners. Each data message received from the
handset or tablet includes a unique identifier to protect the quality of our
database. TOSL has elected not to use the phone’s number or IMEI so as not to
collect personal information; instead the identifier is created at install time
and is therefore unrelated to the mobile device itself.
OTHER USES OF
PERSONAL INFORMATION
TOSL may also use personal information collected
from you for the following general purposes:
a)
to fulfil your requests for Services;
b)
to improve our Services;
c)
to contact you to resolve problems;
d)
to conduct research; and
e)
to make the Sites
easier to use by reducing the need for you to enter information.
COOKIES
Cookies are alphanumeric identifiers that reside
within your browser to enable our computer systems to recognize your browser
and to tell our systems how and when pages within our Site are visited and by
how many people. The cookies from our Site do not collect personal information,
however, we may combine information collected through certain cookies we issue
on our Site with other personal information that you provide to us; again for
the sole purpose of improving the user experience.
LOG FILES AND
THIRD PARTY SERVICES
We automatically receive and store certain other
types of information whenever you interact with us. For example, our servers
track the type of Web browser you are using.
Our sites also use the Google Analytics service in
order to determine where you travel within the Site,
and the page to which you link from the Site. This type of collective data
enables us to figure out how often customers use parts of the Site, so we can
make the Site appealing to as many customers as possible. You can find the
Google Analytics Privacy Policy here: http://www.google.com/intl/en/privacy.html
HOW WE DISCLOSE
OR SHARE INFORMATION WITH OTHERS
Except as described in this policy, TOSL does not
rent, sell, or share personal information about you with other people or non-affiliated
companies unless we have your express permission, or under the following
circumstances:
•When necessary to comply with law or legal process;
•To establish or exercise our rights or property,
including defending against legal claims;
•When we believe it is necessary in order to protect
our customers or users, including from misuse or unauthorized use of the Sites
or our Services; or
•When we believe it is necessary to protect the
safety or property of our employees, customers and users.
Also, TOSL may disclose or transfer your personal
information (a) to its corporate affiliates (for example, a subsidiary or
parent corporation), (b) to its service providers (like fulfilment, hosting, or
payment service providers), but only for their use to provide the requested
service, or (c) to an acquirer in connection with the sale or other transfer of
the business or assets of TOSL. TOSL will require its corporate affiliates and
service providers that receive your personal information to limit their use and
disclosure of your information to the purposes for which you provided it.
HOW WE PROTECT
YOUR PERSONAL INFORMATION
TOSL uses reasonable efforts to protect your
personal information against unauthorized access and unauthorized alteration,
disclosure or destruction including industry standard encryption, firewalls and
policies and procedures that are designed to safeguard and control the flow of
information on a need to know basis.
However, we cannot guarantee that your personal
information will be absolutely protected. For example, your personal
information may be affected by actions outside of our control, such as computer
"hacking" and physical theft. You acknowledge that you provide your
personal information at your own risk.
TOSL takes privacy very seriously and has put the
following restrictions in place to guarantee your mobile device’s contributions
are anonymous:
•Data
collected by our applications is reported anonymously via a random identifier
•In
addition to being anonymous, TOSL does not share this identifier with anyone
•When
practical, precise timestamps of collected data is also not provided to anyone
but is instead rounded to the day
•Communication
with the server is encrypted
•Data
collection can be turned off
CHANGES TO THIS
PRIVACY POLICY
We may change this Privacy Policy at any time. We
will post all changes to this Privacy Policy on this page and will indicate at
the top of the page the modified policy's effective date. We therefore
encourage you to refer to this page on an on-going basis so that you are aware
of our current privacy policy. Your continued use of the Services or the Sites
constitutes your agreement to the Privacy Policy as modified.
CONTACT US
If you have any questions or suggestions regarding
this Privacy Policy, please contact us at support@TOSL.com.