California Supplemental Privacy Notice
Last updated: January 1, 2023
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.
Please note that Do Not Track is a different privacy mechanism than the “Global Privacy Control” browser choice referenced below in the “Your Choices Regarding ‘Sales’ and ‘Sharing’” section, which is a browser-based control that indicates whether you would like to opt out of processing of your personal information for certain online behavioral advertising or analytics purposes.
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 disclose personal information to third parties for their own direct marketing purposes without your prior consent.
Under the CCPA, “selling” personal information has a specific definition that may cover our use of some advertising and analytics technologies (such as Google Analytics). We engage in these activities, for example, to understand the effectiveness of our marketing and advertising campaigns on digital ad networks.
Under the CCPA, ”sharing” includes the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites. We “share” information for these purposes to provide more relevant and tailored advertising to you regarding our services.
To opt out of our “sale” of your personal information or our “sharing” of your personal information for purposes of cross-context behavioral advertising, view this page.
Please note that we also respond to and abide by Global Privacy Control (GPC) signals on this domain as a form of opt-out preference signal. Any opt out preferences you have exercised through these methods will only apply to the specific device or browser on which you made them.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.
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 purposes for collecting, “selling” or “sharing” your personal information, and the categories of third parties to whom we “sold” or “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
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, public sources, other users or marketing partners who may refer you to our services, and your organization if they are a Twingate customer)
|Category of Personal Information||Purposes of Use||Categories of Third Parties to Whom Twingate Discloses this Personal Information||Categories of Third Parties to Whom Twingate “Sells” this Personal Information||Categories of Third Parties with Whom Twingate “Shares” this Personal Information|
|Contact and account information (including professional life data)||Provide the Services; Business Operations; Communicate with you; Marketing and advertising; Improve the Services; With your consent||Affiliated entities; Service providers; Online advertising partners; Connected third-party services; Entities for legal purposes; Entities for business transactions||Online advertising partners; Analytics service providers||Online advertising partners|
|Financial and transactional information||Provide the Services; Business Operations; Communicate with you; Marketing and advertising; Improve the Services; With your consent||Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions||We do not sell||We do not share|
|Customer service interaction information||Provide the Services; Business Operations; Communicate with you; Improve the Services; With your consent||Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions||We do not sell||We do not share|
|Surveys and sweepstakes information||Business Operations; Communicate with you; Marketing and advertising; Improve the Services; With your consent||Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions||We do not sell||We do not share|
|Employment application information||To process your employment application and for our legal purposes||We do not sell||We do not share|
|Information collected through automated technologies||Provide the Services; Business Operations; Marketing and advertising; Improve the Services; With your consent||Affiliated entities; Service providers; Online advertising partners; Connected third-party services; Entities for legal purposes; Entities for business transactions||Online advertising partners; Analytics service providers||Online advertising partners|