Privacy Policy for RetailTwin.com

Effective Date: 1 January, 2024

Privacy Policy

Owner And Data Controller

Retail Twin Labs B.V., Wouwermanstraat 38-2, 1071MA Amsterdam, The Netherlands.

Owner contact email: hello@retailtwin.com

Introduction

At RetailTwin.com, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines how we collect, use, and safeguard your data when you interact with our website and services. By subscribing to our services, you agree to the terms outlined in this policy.

Types Of Data Collected

Among the types of Personal Data that www.retailtwin.com may collect, by itself or through third parties, are: Tracker; Usage Data; email address; phone number; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using www.retailtwin.com.

Unless specified otherwise, all Data requested by www.retailtwin.com is mandatory and failure to provide this Data may make it impossible for www.retailtwin.com to provide its services. In cases where www.retailtwin.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by www.retailtwin.com or by the owners of third-party services used by www.retailtwin.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through www.retailtwin.com and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode And Place Of Processing The Data

Methods Of Processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of www.retailtwin.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal Basis Of Processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The Purposes Of Processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Displaying content from external platforms, User database management, Managing support and contact requests, Managing contacts and sending messages, Platform services and hosting, Advertising, Remarketing and behavioral targeting, Interaction with external social networks and platforms, Heat mapping and session recording and Tag Management. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed Information On The Processing Of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on www.retailtwin.com, possibly based on User interests.

‍This does not mean that all Personal Data is used for this purpose. Information and conditions of use are shown below.

‍Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside www.retailtwin.com. For more information, please check the privacy policies of the relevant services.

‍In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

LinkedIn Ads (LinkedIn Corporation)

‍LinkedIn Ads is an advertising service provided by LinkedIn Corporation.

Personal Data processed: Tracker; Usage Data.

‍Place of processing: United States – Privacy Policy – Opt out

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of www.retailtwin.com and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

‍‍Google Fonts (Google LLC)

Google Fonts is a typeface visualization service provided by Google LLC that allows www.retailtwin.com to incorporate content of this kind on its pages.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of www.retailtwin.com.

‍The interaction and information obtained through www.retailtwin.com are always subject to the User’s privacy settings for each social network.

‍This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

‍It is recommended to log out from the respective services in order to make sure that the processed data on www.retailtwin.com isn’t being connected back to the User’s profile.

‍LinkedIn Button And Social Widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.Personal Data processed: Tracker; Usage Data.Place of processing: United States – Privacy Policy.

‍‍X Posts (formerly Twitter Tweet) Button And Social Widgets (X.com, formerly Twitter, Inc.)

The X post button and social widgets are services allowing interaction with the X.com social network provided by X.com, Inc.Personal Data processed: Tracker; Usage Data.Place of processing: United States – Privacy Policy.

Managing support and contact requests

This type of service allows www.retailtwin.com to manage support and contact requests received via email or by other means, such as the contact form. The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Remarketing and behavioral targeting

This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.‍

Some services offer a remarketing option based on email address lists.

In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

LinkedIn Website Retargeting (LinkedIn Corporation)

LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of www.retailtwin.com with the LinkedIn advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Meta Pixel Remarketing (Meta Platforms, Inc.)

Meta Pixel Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of www.retailtwin.com with the Meta advertising network.

‍Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

This type of service allows www.retailtwin.com and its partners to inform, optimize and serve advertising based on past use of www.retailtwin.com by the User.

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to www.retailtwin.com, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving www.retailtwin.com.

‍Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on www.retailtwin.com.

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilises the Data collected to track and examine the use of www.retailtwin.com, to prepare reports on its activities and share them with other Google services.

‍Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Google Analytics Advertising Reporting Features (Google LLC)

Google Analytics on www.retailtwin.com has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users’ ads interaction Data) and, if enabled, demographic Data (information about the age and gender).Users can opt out of Google’s use of cookies by visiting Google’s Ads Settings.

Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt Out.

LinkedIn Conversion Tracking (LinkedIn Insight Tag) (LinkedIn Corporation)

LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on www.retailtwin.com.

The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of www.retailtwin.com.

Users may opt out of behavioral targeting features through their device settings, their LinkedIn account settings.

Personal Data processed: device information; Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Meta Ads Conversion Tracking (Meta Platforms, Inc.)

Meta Ads conversion tracking is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta advertising network with actions performed on www.retailtwin.com.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Session recording

Session recording services are used to display the areas of www.retailtwin.com that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.

Some of these services may record sessions and make them available for later visual playback.Leadfeeder

‍We use heat mapping tools to track user behaviour and improve website conversions.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Services and hosting

These services have the purpose of hosting and running key components of www.retailtwin.com, therefore allowing the provision of www.retailtwin.com from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.

‍Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Ghost (the retailtwinlab.com website platform): 

Ghost websites collect, use, and process personal data. Their policy includes details on the types of data collected, such as contact information, technical information, and data shared when using their services, as well as how this data is used, such as for account registration, identity verification, payment processing, and providing support. Additionally, it covers the sharing of data with third-party vendors and hosting partners, primarily for operational purposes, and the measures taken to protect personal data.

Ghost Foundation emphasizes that they do not sell personal data and detail the circumstances under which they might share data, such as legal requirements or user-initiated integrations with third-party platforms.

For more detailed information, you can review Ghost's privacy policy here. Ghost runs and hosts www.retailtwin.com.

Personal Data processed: Usage Data.

Place of processing: United States.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on www.retailtwin.com in a centralized fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

‍Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

‍Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy

The Rights Of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details About The Right To Object To Processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How To Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

www.retailtwin.com uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional Information About Data Collection And Processing

Legal Action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of www.retailtwin.com or the related Services.The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional Information About User’s Personal Data

In addition to the information contained in this privacy policy, www.retailtwin.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System Logs And Maintenance

For operation and maintenance purposes, www.retailtwin.com and any third-party services may collect files that record interaction with www.retailtwin.com (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information Not Contained In This Policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” Requests Are Handled

www.retailtwin.com does not support “Do Not Track” requests.To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes To This Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within www.retailtwin.com and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

‍Definitions and legal references:

Personal Data (Or Data): Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.‍‍

Usage Data: Information collected automatically through www.retailtwin.com (or third-party services employed in www.retailtwin.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use www.retailtwin.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.‍

User: The individual using www.retailtwin.com who, unless otherwise specified, coincides with the Data Subject.‍

Data Subject: The natural person to whom the Personal Data refers.‍

Data Processor (Or Data Supervisor): The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.‍

Data Controller (Or Owner): The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of www.retailtwin.com. The Data Controller, unless otherwise specified, is the Owner of www.retailtwin.com.‍

www.retailtwin.com (Or Its Applications): The means by which the Personal Data of the User is collected and processed.‍

Service: The service provided by www.retailtwin.com as described in the relative terms (if available) and on this site/application.‍

European Union (Or EU): Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.‍

Cookie: Cookies are Trackers consisting of small sets of data stored in the User’s browser.‍

Tracker: Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal Information: This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).This privacy policy relates solely to www.retailtwin.com, if not stated otherwise within this document.