We, LLC-FZ Global TWR (from here on TWR Investments Group), located at UG02-D1, RAKEZ Amenity Center, Al Hamra Industrial Zone-FZ RAK, United Arab Emirates, A Dubai registered and licensed LLC-FZ with Registration No: 0000004028668 and License nu: 45000287, will be handling and processing your data.
Below we have summarized the most important rights regarding the use of your personal data in the form of Questions and Answers. Feel free to contact us if you have any questions.
Your right to data portability allows you to obtain and reuse your personal data upon request. We only ask for personal information when we truly need it to provide a service to you. We collect your data by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting data and how it will be used.
We understand and respect your right to be informed. We only retain collected information for as long as necessary to provide you with your requested service. What data we store, we protect within commercially acceptable means to comply. To prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.
Communication to our website, customer digital environment and payment platforms are encrypted with SSL/TLS Certificates approved by the ISRG Policy Management Authority. You have the right to erase: upon request we will erase your data, provided we do not have a compelling reason for keeping it.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective (or lack of) privacy policies and data security. Always check if the connection is secured (depicted by a lock next to the URL), if not please contact us directly and do not share personal data on a non-secured website.
You are free to refuse our request for your personal information, with the understanding that we may be unable to provide you with some of your desired services, it is your right to restrict processing of personal data.
Currently TWR Investments Group does not use technology for automated decision making and profiling, if for example for security reasons in the future this changes, our privacy policy will be updated and you will be informed. Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information.
If you have any questions about how we handle user data and personal information, or even improvements, feel free to contact us. We respect and understand your right to object to direct marketing from TWR Investments Group and will provide unsubscribe options in the content and in personal emails.
Kind Regards,
Ian Upton (Data Officer TWR Investments Group)
privacy@twrInvestmentsgroup.com
Q1: What information do you process?
Your first and last name; address details; telephone number; email address; IP address for geo-location; internet browser and device type for website optimisation; payment details (e.g. bank account number or credit card number, receipts of cash transactions), details about activities on the website and web applications; other personal data that you actively provide, for example by creating a profile on this website, in correspondence and by telephone & proof of acquisition.
Q2: How do you acquire the consent to use my data?
When you provide us with personal information to complete a transaction, verify your credit card, place an order or acquire our services, we imply that you consent to our collecting it and using it for that specific reason only. Important customer updates regarding TWR Investments Group or official notices are not classed as email marketing.
Q3: When do you ask for my consent specifically?
If we ask for your personal information for a secondary reason, such as marketing, we will ask you directly for your expressed consent, and provide you with an opportunity to opt out. Only with your permission, will we send you exclusive information and invitations to TWR Investments Group’s events, offers and other updates.
Q4: How do I withdraw my consent?
After you opt-in, if you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at data@twrnvestmentsgroup.com or posting a letter to:
Ian Upton, Privacy & Data Officer,
TWR Investments Group, UG02-D1, RAKEZ Amenity Center, Al Hamra Industrial Zone-FZ RAK, United Arab Emirates
Q5: What information do you disclose with third parties, why and when?
We don’t share any personally identifying information publicly or with third-parties, except when required to by law or if you are in violation of our Terms & Conditions. If you would like to object to any processing where our lawful basis is legitimate please write a formal notice to privacy@twrinvestmentsgroup.com.
In the case of contract breach, when all reasonable efforts fail and no dialogue or solution is possible, TWR Investments Group reserves the right to disclose necessary personal data with legal partners, collection agencies and public authorities.
Furthermore, TWR Investments Group has no intentions at all of unlawfully processed special or sensitive data, if you observe this it is unintentional and we request you kindly to contact us immediately privacy@twrinvestmentsgroup.com.
TWR Investments Group commits to solving the issue with the highest priority.
Q6: Where is my data?
Third-party providers we chose to use disclose your information to the extent necessary to allow them to perform the services they provide to us. We choose partners that are GDPR compliant, have a clear privacy policy and agree to our strict policies, terms and conditions regarding privacy. An overview of our key suppliers and privacy/security policies can be found below.
INFRASTRUCTURE - Google Domains, Google cloud Services, Google Workspace Business
SOFTWARE - Hubspot, Gmail, Google Workspace (gmail),
PARTNERS - PropChain, Cryptova Capital, Assistanc Blockchain Services, TWR Green Invest, FNDZ and Echo Trading Group.
Q7: Are there other third party service providers that use my personal data?
Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Q8: Can I prevent third party service providers from using my personal data?
Here are a few ways you can opt out of targeted advertising by:
Facebook - https://www.facebook.com/settings/?tab=ads
Google - https://www.google.com/settings/ads/anonymous
Bing - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Important: Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website's Terms of Service.
Q9: How do you keep my personal data secure?
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Our servers are secured in Google Cloud Platform. Gmail and G-Suite are used for communication, file transfer and storage, API's are used from trusted sources over encrypted connections and personal data is protected on robust servers with firewalls.
TWR Investments Group user management is regulated with Hubspot CRM, G-Suite Identity and Access Management.
Communication to our website, customer digital environment and payment platforms are encrypted with SSL/TLS Certificates approved by the ISRG Policy Management Authority.
Any CRM database access, change and deletion is logged for future auditing in Hubspot. TWR Investments Group users work in Hubspot and G-suite which are cloud-based, eliminating the need for local files or personal data on laptops or other devices.
Q10: Are online payments secure?
If you choose a direct payment gateway to complete your purchase, the online store transmits your credit card data. The store data is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.
After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
Q11: Do you use Cookies?
Some of our Site pages use “cookies” and other tracking technologies. A “cookie” is a small file that may be used, for example, to collect information about Site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a Site user. You may block cookies, or delete existing cookies, by adjusting the appropriate setting on your browser. Please consult the HELP menu of your browser to learn how to do this.
Q12: Will turning off cookies affect the functionality of the Site?
If you block or delete “cookies” you may find the usefulness of our Site to be impaired. Our website uses “Cookies” as data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
Please note that we do not alter our site’s data collection and use practices when we see a ‘Do Not Track’ signal from your browser.
Q13: Can I request my personal cookie information?
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us by mail at privacy@twrInvestmentsgroup.com.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.
Q14: How old do I have to be to provide consent?
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
The Site is not intended for or structured to attract children under the age of 18. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years of age.
Q15: Can this policy be changed and how do I stay informed?
We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
If our store is acquired or merged with another company, your information may be transferred to the new owners so that services will not be interrupted. In which case you will be notified in advance with the option to opt out.
The Privacy Policy is part of the Terms of Website Service.
Q16: What if I have more questions?
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or do you simply require more information?
Contact our Data & Privacy Officer at privacy@twrinvestments group.com.
