Privacy Policy
20 Trusted, 20Trusted, 20trusted.com, 20T and Twenty Trusted Contacts are a brand names of Twenty Trusted Networks Ltd (“20Trusted”). This Privacy Policy applies to and/or governs your use of the 20Trusted mobile app(s) and any websites owned or operated by 20Trusted including, without limitation, www.20trusted.com (the “System”) and relevant associated Services. In this Privacy Policy, Twenty Trusted Networks Ltd (“20Trusted”) may be referenced as “20Trusted”, “we,” “us,” or “our”.
Additional Information
Our Use of Your Information
Your Rights and Choices
Important Information
Contacting 20Trusted
20Trusted Privacy Policy
20Trusted is committed to protecting your privacy and developing technology that gives you a powerful and safe online experience. This Privacy Policy (the “Policy”) applies to the System and Services and governs online data collection and usage. By using the System or Services you consent to the data practices described in this Policy. All capitalized words not defined herein shall have the meanings ascribed to them in the Terms of Use (User Agreement).
Collection of your Personal Data
20Trusted collects personal data from you, including, but not limited to, your e-mail address, name, job title, company name or organization name, and telephone number. Additionally 20Trusted may collect location data received from a GPS-enabled mobile device or other mechanism that you have set up in order to show your location to other Users or provide information, including target advertising or promotions, to you specific to your geographic locality via the System. Many GPS-enabled mobile devices allow users to “turn off” location-enabling data being sent to 20Trusted or any other party. If you do not wish to provide us with your location, please disable the location-enabling functionality on your device when prompted by the System or simply update your preferences on the System to preclude collection of your location data.
20Trusted automatically collects certain information about your computer or mobile device hardware and software. This information can include: your IP address, mobile device type and model, browser type, device ID, domain names, access times and referring web site addresses. This information is used by 20Trusted for the operation of the System, to maintain quality of the System, and to provide general statistics regarding use of the System.
20Trusted may also collect information about you, such as name, email address, and use of social media websites, from publicly available sources. 20Trusted may collect this information by searching the Internet, including publicly available social media profiles, and may add the information collected to your user profile.
20Trusted may also collect demographic information, such as ZIP code, post code, age, gender, preferences, interests, and favourites.
Please keep in mind that if you directly disclose personal data or sensitive personal data through the System or Services (including, for clarity, the Communication Services), this information may be collected and used by others. (Note: 20Trusted does not read any of your private online communications with others Users of the System or Services.)
We will retain your personal data for the period necessary to fulfil the purposes outlined in this Policy and other legitimate business purposes unless we are otherwise required by law to dispose of your personal data. If you close your account, we will retain certain data for analytical purposes and recordkeeping purposes, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our System or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.
Collection of the Personal data of Others
In addition to your personal data, 20Trusted also may collect the personal data of others. If you so choose, the System may be used to upload and store your contacts (or individual entries) as part of the Services, for the purpose of enhancing your experience and growing your network by leveraging these contacts in various ways, including (i) suggesting potential contacts through the System with whom you have not yet connected, (ii) giving you the option to choose whether to invite contacts in your address book who are not yet users of the 20Trusted Systems or Services to use 20Trusted in order to grow your 20Trusted network, and (iii) any other services or tools which 20Trusted may acquire or develop in the future to enhance your experience using the System and the Services. Information of your contacts may include names, e-mail addresses, phone numbers, and other identifiers. Your contacts information may be uploaded to the system directly from the devices you use to access the System or by explicitly granting the System authorisation to access your contacts information stored on third party sites or services.
Third Party Web Sites
You may have the option to enter third party sites or pages through the System. 20Trusted cannot be assured that such third party sites or pages follow 20Trusted’s, or equivalent, privacy policies. As such, we have no responsibility or liability for the actions or policies of such third party sites or pages, nor do we endorse any product or service that may be mentioned or offered in such sites, and are not otherwise responsible for the content or privacy practices of such sites.
Use of your Personal Data and the Personal Data of Others
20Trusted collects and uses your personal data and such other personal data of others you may provide us, to operate the System and deliver the services you have requested. 20Trusted also uses your personal data to inform you of other products or services available from 20Trusted and its affiliates. 20Trusted may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered by 20Trusted.
20Trusted may monitor the websites and pages our customers visit within the System, in order to determine what 20Trusted services are the most popular among 20Trusted’s customers or users. This data is used to deliver customized content and advertising within the System to customers whose behaviour indicates that they are interested in a particular subject area.
Except as set forth in this Policy, we will not use, disclose, or transfer your personal data or the personal data of others you have provided us unless (1) you expressly authorise us to do so; (2) it is necessary to allow our service providers or agents to provide services for us, (3) it is necessary in order to provide our products or services to you (and contacting you when necessary), (4) we are sending you other information that may be useful to you, (5) subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, (6) it is necessary to protect the confidentiality or security of your records, (7) subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of 20Trusted or the merger of 20Trusted into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which 20Trusted is not the survivor, (8) it is necessary in connection with other business purposes including, without limitation, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution, (9) it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity; (10) it is necessary for us to provide it to our attorneys, accountants, regulators, auditors or other advisors; or (11) it is otherwise necessary for us to disclose it as required or permitted by law.
We use various web site analytics tools and technologies regarding activities on our web sites that require storage of web session data. The overall aim of these tools is to aid in making our web sites easy to use, to proactively identify and correct error conditions and to provide more relevant advertising and content to you. These tools and technologies are also used to assist web site visitors who report problems in the use of our web sites. Stored web session data is used in accordance with this privacy policy.
Disclosure of Personal data to Third Parties
20Trusted does not sell, rent, or lease its customer lists or the identity of individual customers to third parties. 20Trusted may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personal data is not transferred to the third party.
20Trusted may share personal data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are contractually prohibited from using personal data provided by 20Trusted except to provide these services to 20Trusted, and they are required to maintain the confidentiality of your information with equal or greater protections than those provided by 20Trusted.
20Trusted shall not use or disclose sensitive personal data, such as race, religion, or political affiliations to any entity, except as required by statute, regulation, or order of a government tribunal, without your express consent.
20Trusted will disclose your personal data, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on 20Trusted or the System; (b) protect and defend the rights or property of 20Trusted; and, (c) act under exigent circumstances to protect the personal safety of users of 20Trusted or the public.
Additionally, with respect to personal data of third parties provided to us by you via the System, we do not share such information with any other users of the System or third parties, unless (i) you expressly authorise us to do so, or (ii) we are required to do so by operation of law or regulatory requirement.
Use of Cookies
The System use cookie technology to help you personalize your online experience. A “cookie” is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to alert a web server that you have returned to a specific page. For example, if you personalize 20Trusted pages, or register with 20Trusted sites or services, a cookie helps 20Trusted to recall your specific information on subsequent visits. This simplifies the process of recording your personal data, such as billing addresses, shipping addresses, and so on. When you return to the same System, the information you previously provided can be retrieved, so you can easily use the 20Trusted features that you customized.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the 20Trusted services or web sites you visit.
Security of your Personal data
20Trusted secures your personal data, and the personal data of others, from unauthorized access, use or disclosure. 20Trusted secures such personal data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal data is transmitted to other web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System may happen to transmit or otherwise supply will be totally secure.
Communications with 20Trusted
We appreciate your questions and comments about the System and Services and welcome your messages to recipients listed on the System including messages or emails provided to our customer support (which may be from time to time subcontracted to carefully chosen third parties). We will share your communications with those within our organization or subcontracted third parties who are most capable of addressing the issues contained in your message. We may archive your message for a certain period of time or discard it, but your e-mail address and e-mail will only be used in accordance with this Policy.
Promotions and Advertisements
We may send you e-mails or other communications and third party advertisements with promotional offers if you opt-in to receiving such communications or advertisements. If you would no longer like to receive special promotion information, advertisements, or other messages from us or third party advertisers, please email us at hello@20trusted.com or follow the “Unsubscribe” instructions on such messages, or update your setting and preferences on the System. Please allow us a reasonable period of time in order to satisfy your request, as some advertising campaigns or promotions may already be in process at the time you request to no longer be sent such advertisements or promotions.
Contests, Sweepstakes and Other Promotions
On the System, you may wish to participate in contests, sweepstakes and other promotions that we may offer from time to time. Through these promotions, you may choose to participate in activities such as sharing information found on the System or such social media platforms with others and sending e-mail invitations. In connection with any contests, sweepstakes and other promotions that we may offer from time to time via the System or such platforms, we use the information you provide to administer the contests, sweepstakes and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our products and services or our partners may use such information to communicate with you about the contests, sweepstakes or other promotions or their products and services. If you choose to participate in these promotions, and are eligible to do so, we may ask you for information such as your name, e-mail address, date of birth and telephone number.
Social Media Platforms and Web sites
By visiting any of our pages that are contained on a social media platform or web site, you are representing and warranting to us that you have reviewed the applicable privacy policy and terms of use of such platform or web site and that you will abide by all such provisions contained therein.
20Trusted offers social-type features on the System , please be aware that these areas may allow you to publicly post, and share with other users, certain messages, content, or other information (e.g., profile updates and information, job postings, pictures, requests for information from other users, recommendations, etc.). Although we may take certain precautions to protect those who use these areas of the System, we encourage you to be wary of giving out any personal data, or any personal data of others to which you may have access, in such forums. The information you post can be collected and used by people you don’t know. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.
Using the System or Services From Outside the United States
If you are using the System or Services from outside of the United States, please be aware that your information, including any personal data to which we may be given access, may be transferred to, stored, or processed in the United States. Alternatively, if you are using the System or Services from within the United States, such information may be transferred to, stored, or processed in a jurisdiction outside the United States, including, for clarity, at facilities and on servers located in the United Kingdom and/or the European Union. The data protection and other laws of the United States and other countries may not be as comprehensive as those in your country, but we will take strong measures to protect your personal data. By using the System, you understand that your personal data may be transferred to our facilities and to those third parties with whom we share such information as specified in this Policy.
No Information Collected from Children
20Trusted will never ask for or knowingly collect information from children. We are strongly committed to preserving online privacy for all of our web site visitors, including children. We do not knowingly collect information about children or sell products to children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13. Furthermore, we may restrict entries to any contests, sweepstakes or promotions to entrants who are at least 18 years of age.
Changes to this Policy
We may change this Policy at any time and from time to time. The most recent version of the Policy is reflected by the version date located at the bottom of this Policy. If we make any material changes to our Policy, those changes will apply to the personal data collected after the effective date listed on the Policy, and we will notify you by placing a notice on the System prior to the change becoming effective. We encourage all users to periodically review this Policy for the latest information on our privacy practices.
California Privacy Rights and Do Not Track Disclosures
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personal data, such as name, e-mail, and mailing address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the name and address of all such third parties. To request the above information, please email us at hello@20trusted.com with a reference to California Disclosure Information.
We will respond to such requests to information access within 30 days following receipt at the e-mail stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.
We treat the data of everyone who uses the System in accordance with this Policy, whatever their Do-Not-Track setting or use of any other mechanism that provides them with the ability to exercise choice about the collection of their personal data.
We give you choices about turning off tailored advertising, sharing your information with third parties, and receiving promotional offers. You can exercise your choices by emailing us at hello@20trusted.com , following the “Unsubscribe” instructions on promotional messages, or updating your setting and preferences on the System.
Contact Information
20Trusted welcomes your comments regarding this Policy. If you believe that 20Trusted has not adhered to this Policy, please contact 20Trusted at hello@20trusted.com . We will use commercially reasonable efforts to promptly determine and remedy the problem.
This Policy was last updated on 13th Feb 2022.