Updated: 26 Oct 2020
When we say “Twiddle Steps”, “we”, “our”, or “us”, we mean Twiddle Steps Sdn Bhd (1480682-H) situated at #131 GF-16 The Waterfront at Parkcity, No.5 Persiaran Residen, Desa ParkCity, 52200 Kuala Lumpur, Malaysia which is the entity responsible for processing your personal data. When we say “website” or “platform”, we mean all of Twiddle Step’s websites and applications.
We are a public platform. When you write a review, the review and your profile will be visible to anyone who visits our platform. By clicking on your profile, such visitors can view certain details of yourself such as the reviews you’ve written. Similarly, if you’re a listing owner and reply to a review about your company, this will also be visible on our platform. So please remember that depending on the information you add to your Twiddle Steps profile and the username you choose, you may or may not be anonymous.
Personal data is any information that relates to an identifiable individual. When you create a Twiddle Steps user account, write a review, claim a business listing on behalf of your company, or otherwise use our platform, we may collect and process the following personal data about you:
- Contact information: Your name and email address or any other contact details you may provide to us from time to time.
- Device and location information: Your IP address, browser settings (the type of browser you use, browser language, time zone), and location.
- Member account information: Your username, password, photo, location & age of child (if provided).
- Business listing information: Your password, your company name and domain, and certain other information you choose to add to your business listing, such as details about the type of services your company offers.
- Usage and profiling information: Your Twiddle Steps search history, how you’ve interacted with our platform, including time you spend on our site, features or functions you’ve accessed, and links you’ve clicked.
- Information about reviews and ratings, including:
- Which business you reviewed.
- Whether you wrote a service review, a location review, or a product review.
- Your review content and star rating.
- The location of the business you reviewed.
- The dates you wrote your review, made any edits, or deleted the review.
- If we ask you to provide information or documentation to verify your experience, and you send us such documentation, we will collect and process the documentation for the purpose/s stated in the request.
- Information about views, likes and how useful your review is for others: How many people read your review and how many people find your review “useful”. We also collect information if you click “useful” on someone else’s review.
- Information about reports and replies to reviews from your business account: Your name, company details, the information you state in the reply to a review, which review you reported, the reason for the report, the date of the report.
- Preferences information: Selected preferences associated with your account, including specific consents you have given or declined, newsletters or similar email preferences and cookies containing your preferences.
- Communication information: Includes communications we receive from you such as review notifications, feedback, help requests and queries via email, and other electronic communication methods, as well as metadata associated with those communications, such as time and date.
- Call recordings: All inbound and outbound telephone calls made to or by Twiddle Steps may be recorded for training and quality control purposes. Personal data (for example, name and contact details) revealed during a telephone call will be digitally recorded to deliver appropriate services.
- Information from other services, including social networks: You may connect your Twiddle Steps profile with your social media profiles, for example, Facebook (“social network”) in the near future. When you do this, we automatically collect selected information about you from your social network, depending on what information you have made available on that social network and your privacy settings for sharing such information on that social network. We may collect the following information:
- Name and/or username
- Email address
- Profile photo
- Your social connections
- Before your request to connect your Twiddle Steps profile with a social network profile is carried out, you’ll be told which information we will collect from that social network. You can disconnect your social network profile from your Twiddle Steps profile via your Twiddle Steps account at any time. Twiddle Steps will then remove your social network unique ID, and disconnect/revoke Twiddle Steps from your social network.
We ask you not to share any sensitive personal documents or information with us, such as information revealing religious beliefs or health information.
In respect to all other personal data associated with our platform, such as information you provide when you create an account, leave a review, submit a reply, add a business listing, publish an announcement or create an event, Twiddle Steps is the data controller.
We’ll use your personal data to:
- Provide our services to you, including displaying your reviews and giving you access to your user account and our platform, or providing you with access to your business account and our website.
- Identify you as a registered user when you log into our platform and revisit our platform.
- Improve our platform and services.
- Respond to your questions and provide customer service.
- Send you our newsletters.
- Engage in various internal business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying our platform and our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- Train our staff and for quality control purposes, helping us improve the quality of our services.
- Exercise or comply with our own legal rights or obligations in connection with legal claims, or for compliance, regulatory and auditing purposes, where necessary. For example, we may retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body.
- Send you targeted advertising and/or marketing messages & offers from Twiddle Steps as well as partners.
If you have a Twiddle Steps user account, we’ll also use your personal data to:
- Verify the authenticity of your reviews.
- Invite you to leave more reviews.
- Pass on a message from the business you reviewed or the business that invited you to review a service experience or a product via our platform.
- Contact you if your review is flagged by businesses or other users and, if necessary, ask you to provide documentation to verify your review or experience.
- Inform you when other users find your review useful or otherwise provide feedback concerning your review.
- Facilitate the social sharing function, including giving you the option to connect with members of your network who are both users of Twiddle Steps and users of one or more social networks.
- Display which members of your social networks are also users of Twiddle Steps in order to increase confidence in reviews and to create a better user experience on our platform.
- Enforce our Terms & Conditions.
If you sign up as a listing owner on behalf of your company on Twiddle Steps, we’ll also use your personal data to:
- Notify you about a review on your business listing(s).
- Verify the legitimacy of your replies to reviews about your company.
- Inform you when users provide feedback concerning your reply to a review or your report of a review about your business.
- Enforce our Terms & Conditions.
We may also use the information in other ways for which we provide specific notice at the time of collection.
We need to process your personal data in order to:
- Perform our contract with you or your company.
- To exercise and comply with our own legal rights and obligations and operate an online review platform in compliance with applicable legal acts.
- Pursue legitimate business interests related to operating our website and providing our services to you. Where we process your personal data based on a legitimate interest we will only do so where the processing is relevant, adequate and limited to what is necessary for the purpose it was collected for. And of course, we’ll always ensure our legitimate interests don’t unfairly impact on your own rights and freedoms.
- For the establishment, exercise or defence of legal claims, where necessary.
In circumstances where you have expressly given your consent for us to process your personal data, for example, when subscribing to our newsletters or accepting certain cookies on your device, you are free to revoke your consent at any time, either by using the functionality provided within the appropriate product feature or by contacting us (refer to ‘Contact Information’). However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.
You have the right to object to how we process your personal data, or ask us to restrict the processing.
Your personal data on Twiddle Steps when you register as a member
We share your reviews on our platform so that others can read about your experience with a specific business. When you write a review, other users of our platform will be able to see your username and other information you have chosen to connect with your public profile. They can also see whether you’ve marked other reviews as “useful”.
If you connect to a social network, information such as your profile photo, your name, birth year and approximate location will be collected from your social network profile and used to identify you on our platform. Subject to your privacy settings and the level of information available from the social network, users of our platform can use this information to identify the reviews you have written.
If you’ve chosen to preserve anonymity by not using your name for your Twiddle Steps username, be aware that information from social networks can reveal your identity in part or in full and make it possible to identify which reviews you have written.
Your personal data on Twiddle Steps when you register as a listing owner
When you sign up as a listing owner on behalf of your company, we will disclose your company name and other information you have chosen to connect with your company’s public profile.
We recommend you exercise care in deciding which information to make available for disclosing on the website and be aware that depending on the level of information provided, you may or may not disclose personal data.
Other information provided by you on the website, including your replies to users’ reviews about your business, are also made available for other users of the website.
Your personal data shared with other services, websites and businesses
We permit other services to show reviews created on our platform, including but not limited to, companies’ replies to reviews created on the website.
The categories of third-party services and companies that can show your reviews together with your public user profile (or if you registered as a listing owner, your replies to reviews about your business) are:
- Search engines, including Google and Bing.
- Businesses you reviewed on Twiddle Steps.
- Businesses that invited you to review a product.
- Consumer portals and business portals, including price comparison websites, shopping guides, etc.
- Application partners and platforms, such as Magento, Shopify, WooCommerce.
- Other similar websites where, in Twiddle Step’s assessment, it will be relevant for users to search for reviews.
- Social networks.
Your personal data shared with data processors
We share your personal data with selected third parties that provide us with a variety of different services that support the technical operation of our platform and the delivery of our services (“data processors”). These third parties are data processors for the personal data for which we are the data controller. We have data processing agreements in place with the data processors, and it follows from these agreements that they must act solely in accordance with our instructions. By accepting this policy, you authorize us to instruct the data processors to process data in accordance with this policy and for the purposes of using the platform.
The data processors have taken reasonable technical and organizational measures to protect against the information being accidentally or illegally destroyed, becoming lost or deteriorating, and to protect against the information being disclosed to unauthorized persons, being misused, or in other ways being processed in violation of data protection laws.
In addition to the above, we share your personal data with the following parties and in the following circumstances:
- To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities.
- To cooperate with regulatory bodies and government authorities in connection with investigations or case referrals.
- To third parties in order for us to protect our operations or those of our affiliates.
- To third parties to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- To third parties in order for us to pursue available remedies, or limit damages that we may sustain.
- To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our platform.
- To third parties in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).
We only keep your data for as long as we need it, or are required to for legal reasons. We’ll then either delete it or anonymize it so that it doesn’t identify you. We treat data differently depending on what it’s used for, but you can delete your personal data or email us at email@example.com to have your data removed.
Personal data you provide, including your reviews, is kept for as long as you have a Twiddle Steps account, or as needed to provide you with our services. If you choose to delete your user account, we will only save a log with the following information: your name, email address and the date of the deletion of your account. We will keep the log for three years. All other information will be deleted, including your reviews.
In some cases, even if you delete your account, we retain certain information (for example, visits to our platform) in an anonymized or aggregated form.
Keeping your personal data secure is our highest priority. We use various organizational, technical and administrative measures to protect your personal data within our organization. However, since the internet is not a completely secure environment, we can’t ensure or warrant the security of the information you transmit to us. Emails sent via the platform may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.
Our platform contains links to other websites, but that doesn’t mean we endorse those websites. We encourage you to review the privacy policies for these third-party websites because their procedures for collecting, handling and processing personal data might be different to ours.