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TWICE COMMERCE PLATFORM PRIVACY POLICY

This Privacy Policy describes how we process the personal data of the users of Twice Commerce's service and website (“Services”) as well as the representatives of our customers and marketing contacts (all the aforementioned hereinafter “Customers”).

We may update this Privacy Policy from time to time. However, we will not make substantial changes to this Privacy Policy without providing prior notice.

Please note that this Privacy Policy only applies to the processing of personal data carried out by Twice Commerce as a data controller. Regarding the data of Twice Commerce’s customers' own end-users, Twice Commerce processes this personal data as a data processor, and the relevant customer acts as the data controller of this personal data.

Controller's contact details

• Twice Commerce Oy
• 2634632-5
• Kalevankatu 3B 8, 00100, Helsinki, Finland
• info@twicecommerce.com
• https://www.twicecommerce.com

Personal data processed and sources of the data

We collect two types of information concerning the Customers: (i) Customer Data; and (ii) Analytics Data. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with Customer Data. In such situations, Analytics Data shall also be considered to be personal data under applicable laws, and we will treat the combined data as personal data.

Twice Commerce may collect and process the following Customer Data: (i) name and contact details (including user names); (ii) organization and title (iii) phone number; (iv) e-mail address; (v) correspondence; (vi) invoicing and billing information; (vii) data concerning your orders and use of the Services or your interest in our Services; (iix) marketing opt-outs and opt-ins.

Most of the Customer Data is received directly from Customers. In addition, personal information may be collected and updated from service providers and public registers.

Analytics Data we gather in connection with the use of our Services includes, for example, the following data: (i) Customer’s IP address; (ii) device and device identification number; (iii) operating system; (iv) time of visit; (v) browser type and version; (vi) language setting.

Cookies, analytics, and third-party services

We use various technologies to collect and store Analytics Data and other information when Customers use our Services, including cookies.

Cookies are small text files sent and saved on your device that allow us to identify visitors of our websites, and facilitate the use of our Services, and create aggregate information of our visitors. This helps us to improve our Services and better serve our Customers. The cookies will not harm your device or files. We use cookies to tailor our Services and the information we provide in accordance with the individual interests of our Customers. Customers may choose to set their web browser to refuse cookies or to alert when cookies are being sent.

We also use services such as Google Analytics, Intercom, and Hubspot to compile Analytics Data and reports on visitor usage as well as for CRM and customer service purposes.

Please visit their privacy policies for more information.

Purposes and legitimate grounds for the processing

Twice Commerce processes personal data for the following purposes:

To provide our Services

We process the personal data of Customers in connection with providing our Services and to run, maintain and develop our business. We process and use personal data, for example, to provide essential functionalities of the Services and to provide access to the Services. If you contact our customer service, we will use the provided information for answering questions and solving possible issues.

For customer communication and marketing

We may process personal data for the purpose of contacting Customers regarding our Services and to inform Customers of changes in our Services as well as to market our Services.

For quality improvement and trend analysis

We may process information regarding the use of the Services to improve the quality of our Services e.g., by analyzing any trends in the use of our Services. When possible, we will do this using only aggregated data.

For legal reasons

We also process certain information to comply with our legal obligations, such as accounting legislation. We may also process data for responding to legal claims in similar situations.

Legitimate grounds for the processing

We process personal data based on our legitimate interests when providing the service to our Customers. We may also process personal data to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to run, maintain and develop our business, and to create and maintain Customer relationships.

When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy.

In some parts of the Services, Customers may be requested to grant their consent for the processing of personal data. In this event, Customers may withdraw their consent at any time.

International data transfers

Twice Commerce stores the Customers’ personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we or our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or the Customer’s domicile.

We will take steps to ensure that the Customers’ personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or other similar arrangements.

Personal data recipients

We do not share personal data with third parties outside of Twice Commerce’s organization unless one of the following circumstances applies:

It is necessary for the purposes set out in this Privacy Policy

To the extent that third parties need access to personal data to perform the Services, Twice Commerce has taken appropriate contractual and organizational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.

For legal reasons

We may share personal data with third parties outside Twice Commerce’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Twice Commerce, our Customers or the public in accordance with the law. When possible, we will inform Customers about such transfers and processing.

To authorized service providers

We may share personal data with authorized service providers who perform services for us (including data storage, sales, marketing, and customer support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy. Please bear in mind that if you provide personal data directly to a third party, such as through a link on our website, the processing is typically based on their policies and standards.

For other legitimate reasons

If Twice Commerce is involved in a merger, acquisition, or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Customers concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

With explicit consent

We may share personal data with third parties outside Twice Commerce’s organization for other reasons than the ones mentioned before when we have the explicit consent to do so. You have the right to withdraw this consent at all times.

Storage period

Twice Commerce does not store personal data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of the processing. The maximum period may therefore vary per use.

Customer Data relating to your use of the Services are typically deleted within a reasonable time after you no longer use the Services. We will store personal data for no longer than is required by law or reasonably necessary for our legitimate interests, such as claims handling, internal reporting, and reconciliation purposes.

We won't store Analytics Data relating to the Services longer than is reasonably needed.

Your rights

Right to access

You have the right to access your personal data processed by us. You may contact us, and we will inform you what personal data we have collected and processed regarding you.

Right to withdraw consent

If the processing is based on the consent you have granted, you may withdraw the consent at any time. Withdrawing consent may lead to fewer possibilities to use our Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed.

Right to erasure

You may also ask us to erase your personal data from our systems. We will comply with such a request unless we have a legitimate ground not to delete the data.

Right to object

You may object to the processing of personal data if such data are processed for other purposes than purposes necessary for the performance of our Services to the Customer or compliance with a legal obligation. If we do not have legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.

Right to restriction of processing

You may request us to restrict the processing of personal data, for example, when your data erasure, rectification, or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may, however, lead to fewer possibilities to use our Services.

Right to data portability

You have the right to receive the personal data you have provided us in a structured and commonly used format and to transmit those data to a third party independently.

How to use the rights

You may use the above-mentioned rights by sending a letter or an e-mail to us at the addresses set out above, including the following information: the full name, company name, address, e-mail address, and a phone number. We may request the provision of additional information necessary to confirm the identity of the Customer. We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.

Direct marketing

Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, including market research and profiling, by contacting us at the addresses indicated above or the unsubscribe possibility offered in connection with any direct marketing messages.

Information security

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include, for example, where appropriate, encryption, firewalls, and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience, and ability to restore the data. We regularly test our systems and other assets for security vulnerabilities.

Should, despite the security measures, a security breach occurs that is likely to have negative effects on the privacy of Customers, we will inform the relevant Customers and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

Lodging a complaint

If you consider our processing of personal data inconsistent with the applicable data protection laws, You may lodge a complaint with the local supervisory authority for data protection.

TWICE MARKET PRIVACY POLICY

Last updated on: February 29th, 2024

This privacy policy describes how Twice Commerce processes personal data in accordance with the EU   General Data Protection Regulation (“GDPR”) when providing the  Twice  Market service (including the Twice Market website and mobile applications, together referred to as the “Service”).

The controller for the processing described in this privacy policy is Rentle Oy, a Finnish company doing business as Twice Commerce.

We can be reached at support@twicecommerce.com. Please note that this privacy policy covers the processing that is related to providing the Service. Sellers using the Service may also process personal data for their own purposes when selling items through the Service. Such processing is not done by Twice Commerce and is not covered by the privacy policy.

1. PERSONAL DATA PROCESSED AND SOURCES OF DATA

The personal data processed when providing the Service can generally be divided into two categories:

(i) User Data and

(ii) Analytics Data.

These are described in more detail below. The specifics of what kind of data is processed depends on how you use the Service.

User Data includes data you provide when using the Service, such as:

• Name and contact information
• User account data, such as creation date, usage data (views, follows, likes, etc.)
• Subscription and payments data
• Account settings, such as notification & communication preferences
• Bio, listing, and search data, including photos of items
• Virtual items
• All forms (e.g. text, voice, video, images) of communication in the Service
• Other data provided by you through the Service

User Data is primarily received from you during the registration process, through your use of the Service, or through your interactions with us. We also receive personal data from our partners who offer their services through the platform.

Analytics Data includes data such as:

• IP address
• Device and browser type, version, and operating system
• Traffic source data
• Language and accessibility settings
• Data on the use of and interactions with the Service

Analytics Data is collected automatically when you use the Service. Analytics data does not usually include any direct identifiers (such as a name), but sometimes individuals can be identified from it, either alone or when combined or linked with other data. This is why we handle it as personal data.

2. PURPOSES AND LEGAL BASIS OF PROCESSING

Purpose of the Processing

To provide the Service (legal basis: performance of a contract and legitimate interest)

We process personal data in order to provide the Service in accordance with the Twice  Market Terms of Service and to run and maintain our business. Personal data is processed to carry out our contractual obligations towards the users and based on our legitimate interests to ensure the
functionality, security, and reliability of the Service. This includes using the data for creating listings as requested by our users and providing AI-enabled suggestions and other features.

For customer relationship management, marketing, and communication (legal basis: legitimate interest, consent)

We process personal data to manage relationships with our users and to communicate about the Service.

For service development and analytics (legal basis: legitimate interest, consent)

We process Analytics Data regarding the Service to improve the quality of our Service and to develop new features and functionalities, for example, by analyzing trends in how the Service is used. Where
possible, we will do this using only aggregate data from groups of users. In some instances, individual users may be identifiable, which is why we handle any such data as personal data.

For our legal obligations (legal basis: compliance with a legal obligation)

We process personal data to enable us to fulfill our legal obligations. This includes data processed, for example, for complying with our bookkeeping obligations.

3. INTERNATIONAL TRANSFERS

We process personal data primarily within the European Economic Area (the “EEA”). However, some of our service providers, including OpenAI and Stripe, also process personal data outside the EEA. Transfers to countries outside the EEA, including the United States, are based on decisions by the
European Commission regarding the adequate level of data protection in such countries, or on the use of Standard Contractual Clauses approved by the European Commission and additional safeguards implemented by our service providers.

4 RECIPIENTS OF PERSONAL DATA

Your personal data is shared within the Service through listings based on your own choices and your use of the Service, including without limitation your use of the chat function in the Service. We use third-party service providers to run the Service, and these companies also process personal data. Such providers include, for example, our payment processor Stripe, Inc., and our artificial intelligence technology provider OpenAI, L.L.C.

In addition, your personal data may also be shared with relevant authorities in case we have a legal obligation to do so.

5. STORAGE PERIOD

We process your personal data generally for as long as you have an account for the Service. Some data may also be stored after you no longer have an account (such as data required to fulfill our legal obligations and messages you have sent to other users).

6. YOUR RIGHTS

You have the right to access your data and the right to have any inaccurate or false data corrected. You also have the right to ask that your data is deleted, that the processing of your data is restricted, and to object to the processing. For any processing that is based on your consent (such as marketing
communications), you have the option to withdraw your consent at any time.

You can manage your own data and exercise your rights primarily through the Service. You can also contact us at support@twicecommerce.com. Please note that some of the rights are subject to
additional requirements and may not be applicable in each case.

In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. Twice  Market is supervised by the Finnish Data Protection Ombudsman (https://www.tietosuoja.fi).

Providing personal data is required in order to use the Service. Your personal data is not used for making automated decisions with significant effects, as referred to in Article 22 of the GDPR. As regards profiling, the data is used for segmenting users into categories based on their use of the Service.