PRIVACY POLICY
Table of contents
1. How do we use your personal data?
2. Who do we share your personal data with?
3. How long is your data kept for?
4. Profiling
5. Cookies and other tracking technologies
6. What are your rights?
7. Modification of this Policy
8. Contact
Twister, a simplified joint-stock company with capital of 1,176 euros, registered with the Trade and Companies Register of Nanterre under no. 829 745 512, having its registered office at 16 rue Chateaubriand, 92500 Rueil Malmaison (hereinafter "Twister", "We", “Us” or "Our") attaches great importance to the protection of Your personal data and closely monitors respect for protective provisions relating to privacy and the processing of personal data, in particular European Regulation no. 2016/679 of 26 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and the law of 6 January 1978 entitled "Data processing and freedoms" (“informatique et libertés”) as amended in 2018 (hereinafter the “Applicable Legislation").
For the purposes hereof, "You" or "Your" means the individual whose personal data is collected for the purposes set forth herein and who is considered to be a "data subject" within the meaning of the Applicable Legislation.
Twister undertakes to protect Your privacy. The aim of this privacy policy (hereinafter the "Policy") is to describe how and when Twister, as a "data controller" pursuant to Applicable Legislation, collects, uses and discloses certain personal data when You use Our Service through the Application or when You visit Our website www.twistr.com (the “Website”)..
This Policy and the General Terms and Conditions form an indivisible whole, and all terms defined in the General Terms and Conditions and used in the Policy have the same meaning.
1.How do we use your personal data?
When You visit Our Website, We may collect the email address You submitted. We also collect certain personal data through cookies, as described in section 5 of this Policy.
When You register with the Application in order to use the Service, Twister also collects some data such as Your name, Your gender, Your date of birth, Your email address, . Additionally, Twister may collect Your Application search history, Your location, the quality of Your Internet connection, the type of smartphone You use, or its operating system when You use the Application. Some of this data can be processed even when the app is not open on Your smartphone.
Twister uses Your data for the following purposes:
- Your use of the Application and the Service;
- managing requests for information;
- improving Our Application and Our Service;
- communication on user preferences;
- sending You marketing emails about Our Application.
Your data will only be used by Twister if an appropriate and relevant legal basis permits it.
Thus, Twister processes Your personal data when:
- this processing is necessary for the management and execution of the contract You have concluded with Twister, that is to say the General Terms and Conditions;
- You have consented to this processing, especially when You have agreed to receive marketing communication ;
- this is in our legitimate interest, for example to improve our Application or Our Website or to maintain them.
2.Who do we share your personal data with?
In the context of the purposes outlined above, We may transfer some of Your data to third parties such as:
- IT service providers, for the purposes of hosting Your data and maintaining Our systems;
- commercial partners, for the purpose of commercial prospection.
We also draw Your attention to the use of social network buttons such as "Connect via ...". The use of these buttons simplifies, in some cases, the entry of Your details in order to complete a form. The use of these buttons may lead to the collection of personal data by the social networks concerned.
We invite You to be vigilant and to consult the personal data protection policies of these social networks so that You are precisely aware of the information which is collected by these sites and applications as well as the purposes of use of Your data, in particular for advertising purposes.
Some of our providers may be located outside the European Union. Twister has ensured either (i) that it is contractually bound with these providers with a view to providing appropriate safeguards, in particular through the standard data protection clauses adopted by the European Commission, or (ii) its providers are Privacy Shield certified.
You can obtain a copy of these standard clauses or evidence of the Privacy Shield certification by sending an e-mail to Michel Grebenikof at the following address: michel@twistr.com.
If Our business is sold or merged with another company, Your data may be disclosed to our counsel, any potential purchasers and advisors, and transferred to new assignees or beneficiaries of the business.
We can also share information about You:
- in response to a request for information from a competent authority, if We believe that disclosure of such information is lawful or required by any applicable law or regulation, or in the course of legal proceedings;
- with representatives of law enforcement, judicial or administrative authorities or other authorised third parties.
3.How long is your data kept for?
Your data will be kept for a period not exceeding that necessary to fulfil the purposes set out in this Policy.
If Your data is no longer required for the purposes stated in this Policy, it will be duly deleted or anonymised unless it is necessary to keep it for longer:
(i) to ensure compliance with legal, accounting and tax retention requirements, i.e. 10 years;
(ii) for the retention of evidence during the applicable prescription periods, i.e. 5 years;
(iii) for commercial prospecting purposes, i.e. 3 years from the end of Our business relationship with You or from Our last contact with You.
In addition, if we believe Your account is inactive because You have not used it for more than 2 years, we may delete or anonymise Your personal data.
4.Profiling
Your personal data may be subject to profiling when You have the status of Peer. Indeed, personal data from Your smartphone (for example, your location, your browsing history, etc.) is used to create a user profile, so that other users around the world can benefit from Travel Products at attractive rates and at the same time You benefit from attractive rates thanks to other Peers having shared their personal data with Us.
5.Cookies and other tracking technologies
What is a cookie?
A cookie is a small text file that is downloaded onto Your device when you browse Our Website and allows it to recognise a user's device. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.
What cookies do We use?
Name
Google Analytics (_utmx)
Purpose
-We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of our website and compile reports for us on activity of our website.

-How to reject or delete this cookie - https://www.google.com/intl/en/privacypolicy.html
Maximum life duration
12 months
How can You restrict or delete cookies?
You may delete and block all cookies from this Website, but please be aware that restricting or deleting cookies may impact on the functionality of the Website.
Your web browser may allow You to restrict or delete cookies set by this Website. The Help function within Your browser should tell You how. Alternatively, You can visit www.allaboutcookies.org which provides general information about cookies and how You can manage cookies on Your device.
To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.
What are the other tracking technologies We use?
- Sentry: thanks to this fingerprinting technology, We can spot errors and bugs in the Application in order to repair them later;
- Google Analytics for Firebase: thanks to the technologies of Client ID, Device ID and Fingerprinting, We can collect data on the use of the Application in order to carry out statistics;
- Apple Analytics: thanks to the technologies of Client ID, Device ID and Fingerprinting, We can monitor performance and insights such as the number of installations of the Application, the number of removal and the build version distribution;
- Facebook and Google login: thanks to the technologies of Universal Login, We can, if you chose it, authenticate You when You connect to Our Application.
Personal data processed through these tracking technologies for which we are data controller are deleted or anonymised once You stop using the Application.
6.What are your rights?
You have a right of access, correction, deletion or limitation of the processing of Your personal data, a right of opposition and a right to the portability of Your data.
You also have the right to give instructions regarding the retention, deletion and communication of Your personal data after Your death.
When processing is based on Your consent, You have the right to withdraw it.
You can exercise these rights at any time by e-mailing Your request accompanied by proof of identity to michel@twistr.com or by writing to the following postal address: Twister, 16 rue Chateaubriand, 92500 Rueil Malmaison, France.
You can also file a claim with the French data protection authority (“Commission Nationale de l’Informatique et des Libertés”) if You consider that the processing of Your personal data infringes Your rights in terms of data protection.
You may opt out of receiving advertising messages from Us by following the instructions in the messages sent to You.
7.Modification of this Policy
We may update this Policy at any time. If We make significant changes to the way in which We process Your personal information or this Policy, We will notify You through Our Application, Website or other means, for example by email.
We invite You to periodically review this Policy to ensure You are up to date with Our privacy practices.
8.Contact
If You have any questions or requests regarding this Policy or in general about how We process Your data, You may contact Us at the following email address: michel@twistr.com.