This is an archived version of the California Supplemental Privacy Notice which is no longer in effect. View the current version of the California Supplemental Privacy Notice.

Last updated: May 26, 2020

This California Supplemental Privacy Notice (“Notice”) supplements the information in and forms part of the Twingate Privacy Policy (“Privacy Policy”). This Notice applies solely to California residents. This Notice applies to all products, services, apps, and websites that link to our Privacy Policy, except where otherwise noted.

1. Your California Privacy Rights

1.1. Do Not Track Signals

Twingate currently does not respond to “Do Not Track” signals sent by browsers or mobile apps due to a lack of standardization regarding how that signal should be interpreted. Learn more about Do Not Track.

1.2. Third Party Disclosure Requests

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their “personal information” (if any) as defined under California Civil Code 1798.83 for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. See the “Contact Us” section below for where to send such requests. Note that Twingate does not share personal information with third parties for their own direct marketing purposes without your prior consent.

1.3 Opt-Out From Sale

You may have the right to opt out of the “sale” of your personal information as defined by the California Consumer Privacy Act (CCPA). Twingate does not “sell” (as defined by the CCPA) your personal information.

1.4 Additional Rights

California law may permit you to request that we:

• provide you the categories of personal information we have collected or disclosed about you in the last twelve months, the categories of sources of such information, the business or commercial purpose for collecting or selling your personal information, and the categories of third parties with whom we shared personal information. This information is provided in this Notice;

• provide access to, or a copy, of certain information we hold about you;

• delete certain information we have about you.

You may also have the right to receive information about the financial incentives that we offer to you (if any), and the right to not be discriminated against (as provided for in the CCPA) for exercising certain of your rights.

Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the services to you and for compliance with applicable law.

When you exercise certain rights, we may take reasonable steps to authenticate your identity before fulfilling your request (such as verifying your email address or payment instrument). If you ask us to delete certain information, you may no longer be able to access or use our services.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with a signed, written permission to make such requests, or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at:

Twingate Inc., 541 Jefferson Ave, Suite 100, Redwood City, CA 94063, United States

Email: privacy@twingate.com

2. Summary of How we Handle your Personal Information

The California Consumer Privacy Act (CCPA) requires that we make certain disclosures to California residents, including the categories of personal information we collect, the purposes for which we use that information, the categories of sources of personal information, and the categories of third parties with whom we share personal information. This section lays out this information in the manner specified by the CCPA, but it does not differ in substance from the information we provide in our Privacy Policy.

Sources of Personal Information

All the categories of personal information we collect come from the following categories of sources:

• You (either via voluntary submission or automatic collection, such as when you use our services)

• Our affiliates within the Twingate family of companies

• Third parties (such as service providers, other users or marketing partners who may refer you to our services, and your organization if they are a Twingate customer)

Categories of Personal Information Collected and with Whom we Share It

• Identifiers (such as name account username, email address)

• Commercial information (such as transaction data)

• Financial and transactional data (such as payment instrument details)

• Internet or other network or device activity (such as app usage and interactions with our services)

• Geolocation information (e.g., your city and state based on IP address)

• Professional or employment-related information

• Demographics and statistical information (such as age and gender)

• Customer service information (e.g. support requests)

• Survey responses and other research information

• Other information that identifies or can be reasonably associated with you

Categories of Third Parties with Whom we Share Your Personal Information

The categories of personal information collected, as described above, may be shared with the following categories of third parties:

• Your organization (if they are a Twingate customer)

• Our affiliates within the Twingate group of companies

• Third party service providers that perform services on our behalf (e.g. payment processors, analytics providers)

• Third parties for legal purposes (e.g. in response to legal process)

• Others with your consent or at your direction

More detail about these categories is available in Section 3 of our Privacy Policy.

Categories of Business & Commercial Purposes for Which We Use Your Personal Information

The categories of personal information collected, as described above, are used for the following categories of purposes:

• To provide, maintain, troubleshoot, and support our services.

• For billing and payment purposes.

• To communicate with users and prospective users.

• To improve our services.

• To develop new services.

• To market and advertise our services.

• To prevent harm or liability.

• For legal compliance.

More information about these categories, including examples of use cases, is available in Section 2 of our Privacy Policy.