Our personal data protection policy is designed to build a relationship of trust between you and our services, and to offer you a positive experience in a completely transparent way.
Thanks to this policy, we can take your requirements into account and meet your expectations.
To honor your trust, we, Hugo Pourrade (Twistrs), guarantee above all respect for your personal data and the confidentiality of our customers (hereinafter "Your data").
To be fully transparent with you and to guarantee secure use of our website twistrs.com in all its available versions and related applications (hereinafter the "Twistrs Website"), we explain how we process your data, so that our services always respect your rights. In this way, we ensure the security, confidentiality and integrity of your privacy and your data across all our platforms.
We guarantee that all necessary precautions are taken to protect all your data against disclosure, loss or alteration. That is why we provide you with all the information you need to easily understand how we process your data. This data is only kept for as long as necessary for the purposes for which it was collected. You may, of course, access and modify your data at any time, as it is available in your personal account on the Twistrs website.
To this end, we make every effort to take all necessary measures to comply with applicable data protection law.
Through this personal data protection policy, Twistrs undertakes to respect the essential principles of the European General Data Protection Regulation and French data protection law, by providing you with information on the existence and terms of the data processing applied (section 3), the rights you have regarding your data, and by applying these rights ourselves (sections 6 and 10). Information on any transfers to third countries or recipients is also provided, as well as the retention period of the data collected (section 5) and the security measures (section 9).
● WHO ARE YOU?
When we refer to "you" in this Personal Data Protection Policy, it is simply because it directly concerns you as a customer of Twistrs if you have placed an order on the Twistrs website, as a Twistrs customer if you have created a customer account without ordering any products or services, or as a visitor if you have browsed the Twistrs website without creating a customer account or placing an order.
● FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?
3.1. When do we collect your personal data?
Your personal data may be collected if you visit the Twistrs website using cookies, if you create a customer account on the Twistrs website, if you order one of our products or services, or if you agree to subscribe to our newsletters (SMS, emails).
We use your personal data to make your browsing on the Twistrs website smoother and to offer you a more personalized experience. This allows us to process your orders as well as possible, offer installment payments, prevent fraud, issue any necessary refunds and manage your customer reviews.
3.2. Your browsing on the Twistrs Website
To enable you to browse the Twistrs website, we process your data on the legal basis of your consent.
3.3. Processing your orders
We use your data to handle and process your orders.
We use it to manage mediation, customer relations (including through social networks), our after-sales and distance-selling services, our marketing and commercial prospecting activities for the Twistrs website, as well as the management, delivery and shipping of orders.
The performance of the contract between the two parties (you and us) is the legal basis for processing this data.
Twistrs' legal obligations are the legal basis for processing related to product recalls. Your consent or our legitimate interest, depending on the case, is the legal basis for marketing and commercial prospecting. Your consent is the legal basis for "express" payment.
3.4. Installment payments
For orders eligible for installment payment, and for certain customers, your data is processed so that we can offer you this type of payment. The performance of the contract between the two parties is the legal basis for this processing. However, your consent remains the basis for processing your banking data.
3.4.1 Klarna
In order to offer you Klarna's payment options, we may pass your personal data, including your contact details and order details, to Klarna so that Klarna can assess whether you qualify for its payment options and tailor them to your needs. Your personal data transferred will be processed in accordance with Klarna's privacy policy.
3.5. Customer reviews
In order to share your reviews with our customers and visitors, and to allow you to leave a review on the Twistrs website, we use your data on the legal basis of your consent or our legitimate interest.
3.6. Payment collection and fraud prevention
We use your data to collect payments and prevent fraud.
This also allows us to guarantee secure payments.
The performance of the contract between the two parties and the legitimate interest of Twistrs, as data controller, are the legal bases for this processing.
3.7. Advertising management operations of Twistrs
Twistrs' advertising operations are managed using your data.
This allows us to grow our customer and prospect data, manage maintenance and technical activities relating to prospects, produce sales statistics and advertising campaign studies, update prospecting files, handle solicitations, and run contests, sweepstakes and any other promotional operations, excluding online gambling.
The legal bases for the above are the user's consent or the legitimate interest of Twistrs.
● WHERE DOES YOUR DATA GO?
Your data is shared with several internal departments of Twistrs.
It is not sent to third parties, except in the situations described below:
In order to process your orders, your personal data may be transferred to several service providers specializing in banking transactions, customer relations, after-sales service, delivery, IT development, website management or the provision of warranties or insurance.
For installment payments, your data may be shared with service providers such as payment and transaction centers (banks, etc.), call centers for business process or customer experience management, or, for customer reviews, a provider that collects and processes customer reviews.
Twistrs' advertising operations are managed, using your data, with advertising clients and advertisers.
● DATA RETENTION
The data collected by Twistrs is kept only for the time necessary to carry out the operations listed in section 3 of our personal data policy.
We keep certain data collected by Twistrs for a certain period of time:
In active archives for prospects, for 3 years from the last contact with the customer (it can therefore be consulted by Twistrs). We do not keep this data in intermediate archives (for data of administrative interest for certain purposes, such as litigation, retention periods are set by the applicable statutes of limitation).
For orders, your data will be kept in active archives for 5 years after the end of the customer's use of the orders, and in intermediate archives for 5 years after the end of the active archiving period. The same applies to customers.
Banking data is kept in active archives for the entire validity period of the bank card (plus one day). No intermediate archiving is carried out for banking data.
Cookies, their use and retention periods are detailed in section 7 of our policy.
● EXERCISING YOUR RIGHTS
6.1. You have the right to request access to, modification and rectification of your Data.
6.2. You have the right to request restriction of the processing of your Data.
Important: to do so, you must contest the accuracy of your personal data for the period needed for us to verify it; or you consider that our use of your personal data is unlawful and you request restriction of its use rather than its deletion; or we no longer need your data for the purposes set out in section 3 but it is still needed for the establishment, exercise or defense of legal claims; or you exercise your right to object, for the time needed to determine whether our legitimate grounds override yours.
6.3. You have the right to request the deletion of your Data.
If you request the deletion of your personal data, Twistrs may nevertheless keep it in intermediate archives for the time necessary to meet its legal, accounting and tax obligations.
6.4. You have the right to object to processing for commercial prospecting purposes.
For email marketing, you can ask to change or unsubscribe from our newsletters by clicking the "unsubscribe" link in every newsletter, or by going directly to the contact page of the Twistrs website.
For SMS marketing, you can unsubscribe by replying "STOP" to any of our text messages, or by going to the contact page of the Twistrs website.
6.5. You have the right to give instructions regarding the retention, deletion and communication of your personal data after your death.
In the absence of such instructions, your heirs and successors may contact Twistrs to access the use of this data for the "organization and settlement of the deceased's estate" and/or to close the account on the website and/or to request that the processing of personal data be discontinued.
You may also request that your data not be communicated to a third party in the event of your death.
6.6. You have the right to data portability.
6.7. You have the right to withdraw your consent to processing based on that legal basis.
Important: withdrawing your consent does not affect the lawfulness of processing carried out before the withdrawal.
6.8. You have the right, at any time, to lodge a complaint with the competent supervisory authority (in France, the CNIL: www.cnil.fr).
To exercise your rights, please send your request (with your email address, last name, first name, a copy of your ID and your postal address) to Twistrs' data protection contact by email at contact@twistrs.com and/or by post to Twistrs – Hugo Pourrade, 9 Rue Wilson, 69150 Décines-Charpieu, France.
We will reply within a maximum of one (1) month from the date we receive your request.
● COOKIES
7.1. What is a cookie?
When you browse a website such as the Twistrs website, it may, depending on your choices, place a text file on your device (computer, phone or tablet) via your browser.
This text file is called a COOKIE. During its validity period, a cookie allows a website such as Twistrs to recognize your device when you visit again.
Only the issuer of a cookie can read or modify the information it contains.
7.2. What are cookies used for on Twistrs?
Cookies can be grouped into different categories. Some are issued directly by Twistrs and its service providers, while others come from third-party companies.
7.2.1. Cookies issued by Twistrs and its service providers
Several categories of cookies may be placed on your device when you browse our website:
7.2.1.1. "Essential" cookies
"Essential" cookies are necessary to access our website; for example, they allow you to place an order.
Without them, you might experience problems browsing the website and be unable to place an order.
"Essential" cookies also allow Twistrs to monitor its activity.
They may be placed on your device by Twistrs or by its service providers.
7.2.1.2. "Analytics and Personalization" cookies
"Analytics and personalization" cookies are not mandatory. They help make your searches easier, optimize your experience with us, better target your expectations, tailor our offers and improve the organization of our website.
7.2.1.3. "Advertising" cookies
Advertising cookies are displayed in the advertising spaces of our website. Their benefit to you is a better, more efficient browsing experience through the presentation of offers and advertisements that are relevant to you.
To do this, "advertising" cookies target your expectations in real time and offer you advertising content tailored to your current interests, based on your recent browsing history on other websites.
This avoids showing you advertising that is of no interest to you. Likewise, Twistrs prefers its offers and advertisements to be shown to users who are interested in them.
The advertising content offered may contain cookies issued by Twistrs, by its service providers, or by third parties through a cookie associated with an advertiser's content.
7.2.2. Cookies issued by third-party companies
Third parties using cookies on our website apply their own privacy policies. These cookies are not necessary to use our website.
7.2.3. Cookies issued by third-party applications embedded in our website
When you browse our website, we may include third-party applications that allow you to share content and/or your opinion from our website with others, for example when you click the "share" or "like" buttons from social networks.
These social networks may identify you through these buttons even if you did not use them while browsing the website, if during your last visit you were also logged in to or active on your social network on your device. We have no control over how they use this, nor over the data they hold.
To find out more about how your data and advertising content are used, you can visit your social networks and read their personal data protection policies. These policies should allow you to manage your settings according to your preferences on each social network account you have.
Privacy policies of the social networks mentioned above:
Facebook: https://www.facebook.com/privacy/policy
X (Twitter): https://x.com/en/privacy
Google: https://policies.google.com/privacy
Regarding our advertising operations, as mentioned above, all our advertising spaces may contain third-party cookies (the advertiser behind the advertisement shown, the advertiser's third-party providers, etc.).
During their validity period, these cookies allow them to display advertisements in the spaces reserved for third-party advertising, count the number of ads they display in our spaces, measure the audience of these ads and the number of clicks, so that they can claim the amounts owed to them and compile their statistics. They can also tell that your device previously visited another website containing one of their advertisements, and therefore target you and personalize their content accordingly.
7.3. Options offered by your browser (Firefox, Google Chrome, Safari, Edge, etc.)
Your browser contains many options that you can set according to your preferences. This allows you to accept or refuse cookies on your device.
However, if you choose to accept cookies on your device, they will be automatically stored when you visit websites or content that use them.
Depending on your preferences, you can choose to be asked whether you accept or refuse cookies before they are stored, or to refuse them systematically.
However, the choices you make in these settings may alter your browsing on the Internet or on certain websites or services that require these cookies (such as placing an order on our website).
If you choose to refuse these cookies or delete those already stored, we decline all responsibility for the consequences of any impaired functioning of our services resulting from our inability to store or access the cookies they need to function.
7.3.1. How to set your options in your browser
Different options are available depending on your browser. To find out more, see your browser's help menu.
Microsoft Edge™: https://support.microsoft.com/en-us/microsoft-edge
Safari™: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
Chrome™: https://support.google.com/chrome/answer/95647
Firefox™: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
Opera™: https://help.opera.com/en/latest/web-preferences/
● TRANSFERS OUTSIDE THE EUROPEAN UNION
As Twistrs is based in France, your data is mostly stored within the European Union.
However, when our service providers are located outside the European Union (including in the United States), we share some of your data with these countries, including countries for which the European Commission has not issued an adequacy decision.
In such cases, we ensure that this sharing complies with the applicable regulations and that your privacy and fundamental rights are protected (for example, through the European Commission's standard contractual clauses).
Our data protection contact can provide you with more information on data transfers upon request.
● SECURITY MEASURES
Through the technical and organizational measures we take, we can guarantee a level of security appropriate to the risks to the rights and freedoms of individuals with regard to the processing described in section 3. To do so, we take into account the nature, scope, context, costs and state of the art, the purposes of the processing, and the risks identified.
In addition, we comply with the Payment Card Industry Data Security Standard (PCI DSS), which reflects our commitment to security.
● PROFILING AND AUTOMATED DECISION-MAKING
Some of the automated processing we use (profiling, for example) may produce legal effects that concern you.
This is necessary for entering into or performing the contract between you and us.
This is how we can offer and carry out automated customer identification and "pay in 4 installments". This is based on the analysis of various factors relating to the type of products, the services ordered or the customer profile.
If the risk assessed using these statistics is too high (fraud/non-payment), this payment option will not be offered.
However, if you wish, you can obtain human intervention even though the decisions are automated, and you can express your point of view and/or contest the automated decision.
● POLICY UPDATES AND REVIEW
Our personal data policy will be updated whenever necessary to remain in line with the regulations applicable to the protection of your data (at least every three (3) years).