Twill Inc. (“Twill,” the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information that we collect.
The purpose of this Twill Privacy Policy (“Privacy Policy”) is to explain our data collection and privacy practices when you access Twill services. If you are a Twill client or customer (“Twill Program Client”) through your healthcare provider, health plan sponsor, insurer, pharmaceutical partner or related organization or company (each a “Twill Program Company”), this Privacy Policy is not intended to modify or supersede any privacy policy provided by your Twill Program Company. We handle all information in compliance with applicable laws and in a manner compliant with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), where applicable. Where we receive Protected Health Information in our role as a Business Associate of your healthcare provider, health plan sponsor, insurer or similar obligation, this Twill Privacy Policy does not apply; we will process your information consistent with the obligations in the Business Associate Agreement.
We collect information through:
Collectively, we refer to the Websites, Apps, Social Media Pages, emails as the “Services.” We encourage you to read this Privacy Policy closely as it describes in detail what types of information we collect about our users, how we collect it, how we use the information we collect, how long we keep the information and under what circumstances and with whom the information may be disclosed. This Privacy Policy also describes your rights concerning your personal information and security measures we take to protect your personal information. If you have any questions about this Privacy Policy, please email us at support@twill.health.
TYPES OF INFORMATION WE COLLECT
Remember, if you are a Twill Program Client, this Privacy Policy is not intended to modify or supersede any privacy policy provided by your Twill Program Company.
HOW WE COLLECT INFORMATION
HOW WE MAY USE PERSONAL INFORMATION
DISCLOSURE OF PERSONAL INFORMATION
OTHER USES AND DISCLOSURES OF PERSONAL INFORMATION
YOUR CHOICES REGARDING PERSONAL INFORMATION
ACCESS, CHANGE, OR DELETE YOUR PERSONAL INFORMATION
If you would like to request to access, correct, update, suppress, restrict or delete personal information, object to or opt out of the processing of personal information, or if you would like to request a copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us per the “Contact Us” section below. We will respond to your request consistent with applicable law. In your request, please clarify what personal information you would like to have changed or whether you would like to have your personal information suppressed from our database. We may need to verify your identity before implementing your request. We will comply with your request to the extent required by applicable law. If you are a California resident, please refer to the “Information for California Residents” section at the end of this Privacy Policy for more information about the requests you may make under California law.
THIRD-PARTY WEBSITES
This Website may contain links to third-party owned and/or operated websites. Twill is not responsible for the privacy practices or the content of such websites. Third-party websites have separate privacy and data collection practices, and Twill has no responsibility or liability relating to them.
ONLINE ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Services and other websites or online services. You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as mobile phone and laptop. For more information about this practice and how to opt out, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You also may download the AppChoices app at www.aboutads.info/appchoices specifically for mobile.
HOW WE MAY USE COOKIES AND OTHER TRACKING TECHNOLOGIES
When providing our Services, we may use cookies and similar tracking technologies for the purposes set out below. These technologies can track web activity over time and across third-party services. Cookies and local storage may be set and accessed on your computer. Upon your first visit to the Website and Services, a cookie or local storage may be sent to your device that uniquely identifies your browser. (Cookies and local storage are small files containing a string of characters sent to your computer's browser and stored on your device when you visit a website. Many web-based services use cookies to provide useful features for their users. Each website can send its own cookie to your browser. Most browsers are initially set up to accept cookies.) If you do not want cookies, you may set your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you reject cookies, you will not be able to sign into or take full advantage of our Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all cookies or indicate when a cookie is being sent, you will need to reset your browser to refuse all cookies or indicate when a cookie is being sent. Learn more about cookies at http://www.allaboutcookies.org/ and www.youronlinechoices.com/uk.
To support our Services, we may use one or more of the following cookie and tracking technologies for the purposes set forth below:
For more information, please visit www.allaboutdnt.com.
CHILDREN
Twill is committed to children's privacy. Twill does not knowingly permit any person under 16 years of age to register directly for our Services. If Twill learns that personal information of persons under 16 years of age has been collected on the Website or through the Services without parental consent, then we will take appropriate steps to remove the information or maintain and use such information (in accordance with the other provisions of this Privacy Policy) in order to notify and obtain consent from the parent/guardian and/or for other purposes permitted under applicable law. If you are a parent or guardian and discover that your child under the age of 16 has a registered account with the Services without your consent, please alert Twill at support@twill.health to either provide consent, request that we change your child’s account settings, or request that Twill remove the child’s personal information. Please provide the child’s name, address and email address.
RETENTION PERIOD
We will keep your personal information for as long as your user account is active so you can access your information and our Services. We may continue to retain your personal information after you deactivate your user account or stop using Twill, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our users, enforce our agreements or protect our legitimate interests, consistent with applicable law.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by emailing support@twill.health.
INFORMATION FROM USERS OUTSIDE THE USA.
The Services are operated in the United States of America. If you are located in another jurisdiction, please be aware that information you provide to us may be transferred to, stored and processed in the USA. Unless mandated by local laws, by using the Services or providing us with any information, you consent to this transfer, processing and storage of your information in the USA, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
To request to limit the use and disclosure of your personal information, please submit a written request to support@twill.health. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Twill is committed to resolving complaints about your privacy and our collection or use of your personal information transferred to the USA pursuant to applicable data protection law. Individuals in the EEA, Switzerland or UK with inquiries or complaints should first contact Twill by email at support@twill.health.
To review Twill’s General Data Protection Regulation (“GDPR”) Commitment, click here. You also have the right to object, the right to data portability and the right to withdraw consent at any time. An individual who seeks access or who seeks to correct, amend, object to or delete inaccurate data under the GDPR should direct their query to support@twill.health. We will respond to such requests within one month of receipt of the request.
Individuals have a right to lodge a complaint with the appropriate European Supervisory Authority, in particular in the EU Member State of his or her habitual residence, place of work or of an alleged infringement of the GDPR.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en
INFORMATION FOR CALIFORNIA RESIDENTS
California law provides specific privacy rights related to your personal information. These rights include the rights to know, delete, opt out of sale, and to not be discriminated against for exercising your rights. Please note that we do not sell personal information.
You or your authorized agent may submit a request by contacting us via email at support@twill.health Note that we require individuals to identify themselves and the information requested to be accessed or updated before we will process such requests.
We will comply with your request as soon as reasonably practicable, including by verifying your request by comparing the information you provide against the information we have on file. However, we may maintain personal information where exceptions to your rights apply.
We will not discriminate against you based on your exercise of the above-listed choices.
CHANGES TO THIS PRIVACY POLICY
Twill reserves the right to change or update this Privacy Policy at any time by posting a notice on the Website. We also will notify users via email and/or any other reasonable means acceptable under state and federal law.
CONTACT US
If you have any questions or comments about this Privacy Policy, please email our Data Protection Officer at support@twill.health or send a letter to: Twill, Inc., 114 Fifth Ave, Floor 10, New York, NY 10011, USA.
To reach a Twill representative in the European Union, contact Rickert Rechtsanwaltsgesellschaft mbH via email at datenschutz@rickert.net or send a letter to Kaiserplatz 7-9, 53113 Bonn, Germany.