Last updated on [DATE]

Please read this Privacy Policy (“Policy”) carefully. The users, subscribers, and viewers (“Users”) businesses, corporations, enterprises, educational institutes, non-governmental organizations, and governments (“Pages”) accept the terms of this Policy by accessing and/or utilizing the services of Together We Empower FZ-LLC (the “Company”). The Users and Pages acknowledge that they agree to this Policy and accept the rights and obligations created by it. This Policy is drafted to highlight the Company’s commitment to Data protection, privacy, and security. This Policy is designed to comply with applicable laws and standards.

1. INTRODUCTION

1. Purpose of the Privacy Policy: This Policy is instituted by the Company. The paramount objective of this Policy is to delineate and articulate the principles and practices adopted by the Company in relation to the collection, use, processing, storage, and protection of personal Data and information (collectively referred to as “Data”) furnished by or pertaining to Users and Pages of the +twe application (“App”) and website (“Website”) (collectively, the “Platform”). The Company acknowledges and upholds the significance of Data privacy and is committed to adhering to applicable Data protection legislation, including but not limited to, regulations governing privacy and Data protection in the jurisdictions in which the Platform operates. This Policy is crafted with the utmost diligence to ensure comprehensive compliance with such legal obligations and to foster a robust environment of trust and transparency with its Users and Pages. In establishing this Policy, the Company seeks to provide a clear, thorough, and unambiguous understanding of the nature of the Data collected, the rationale behind its collection, the modalities of its utilization, the circumstances under which it may be disclosed, the measures in place to safeguard it, and the rights afforded to the Users and Pages in respect of their Data. This Policy is an integral component of the Terms and Conditions and the Community Guidelines of the +twe Platform and is intended to be read in conjunction with the same. In the event of a conflict between the Terms and Conditions, Privacy Policy, and the Community Guidelines, the provisions of the Terms and Conditions shall prevail. The Company reserves the right to amend, modify, or update this Policy from time to time to reflect changes in legal requirements, operational needs, or the services provided. Users and Pages may be notified of such changes through appropriate channels, and continued use of the +twe Platform subsequent to any amendments will constitute acceptance of the revised Policy.

2. Scope and Applicability: This Policy extends to and governs all Data collected by the Company through the +twe Platform. It is applicable to all Users and Pages, encompassing individuals who engage with the +twe Platform in any capacity, including, but not limited to, learners, professionals, content creators, casual visitors, enterprises, and corporations. The Policy delineates the framework within which the Company operates in its handling of User and Page Data, ensuring that the practices are uniformly applied and adhered to across all facets of the Company’s operations. The applicability of this Policy is not confined to the Data actively provided by the Users and Pages, such as registration details and profile information, but also extends to Data acquired through the Users’ and Pages’ interaction with the +twe Platform, such as usage patterns, preferences, and other behavioral Data. Furthermore, the Policy encompasses Data that the Company may potentially collect in the future through new features, services, or partnerships. It is pertinent to note that this Policy does not extend to services, applications, or websites operated by third parties, even if they are accessible through links that may be provided on the +twe Platform. Users and Pages are advised to review the privacy policies of such third-party platforms to understand their Data handling practices. By accessing, registering, or using the +twe Platform, Users and Pages expressly consent to the collection, use, processing, and storage of their Data in accordance with the terms set out in this Policy. 

Should Users and Pages disagree with any aspect of this Policy, they are advised to refrain from using the +twe Platform. This Policy constitutes a binding legal agreement between the User, Page, and the Company.

2. INFORMATION COLLECTION

1. Types of Information Collected

1. Personal Identification Information: The Company is dedicated to safeguarding the privacy of its Users and Pages. In this regard, it collects Personal Identification Information, which encompasses Data that can be utilized to uniquely identify or contact a single person. This category of information includes, but is not limited to, the User’s or Page’s (as the case may be) name, email address, date of birth, and country of residence. The collection of such information is imperative for the provision of personalized services, maintenance of User and Page accounts, and ensuring a secure and optimal User and Page experience.

2. Professional and Educational Data: Given the nature of the services offered by the Company, Professional and Educational Data forms a significant component of the information collected. This includes Data relating to the User’s and Page’s educational background, work experience, skills, interests, and accolades. It may also include the Data gathered from the quizzes, surveys, challenges, streaks, enterprise and corporation services for the purpose of promotion, student and talent acquisitions, AI support, analytics insights, institutional ratings, Commission Program, and any other activity that happens on the App. Such information is vital for tailoring the learning and networking experience on the Platform, enabling Users and Pages to connect with peers and mentors, and facilitating a bespoke educational and professional development journey.

3. User-Generated Content: The Platform enables Users and Pages to create and share a variety of content, including posts, reels, messages, and comments. The Company collects this User-Generated Content to foster community engagement, enhance the User and Page experience, and maintain a safe and respectful environment on the Platform. This information is also instrumental in understanding User and Page preferences and enhancing the overall functionality of the Platform.

4. Technical and Usage Data: To optimize the functionality and security of the Platform, the Company collects Technical and Usage Data. This includes information about the User’s and Page’s device, operating system, browser type, IP address, and usage patterns. Such Data assists in diagnosing technical issues, improving system security, and tailoring the User and Page experience based on usage trends and preferences.

2. Methods of Data Collection

1. User and Page-Provided Information: A substantial portion of the Data collected by the Company is provided directly by the Users and Pages. This includes information entered during account creation, profile setup, and while using various features of the Platform. Users and Pages may also provide information when participating in surveys, quizzes, challenges, streaks, corporate and enterprise promotions services, student and talent acquisitions, AI support, analytics insights, institutional ratings, Commission Program, or contacting customer support.

2. Automatically Collected Information: The Company employs various technologies to collect information automatically as Users and Pages interact with the Platform. This includes the use of cookies, web beacons, and similar technologies that gather information about User and Page activity and preferences. Such automatic Data collection is integral for providing a seamless User and Page experience, analyzing the effectiveness of the services, and enhancing the overall functionality of the Platform.

3. Information from Third Parties: While currently, the Company does not collect information from third-party sources, it reserves the right to integrate such practices in the future to enrich the services offered on the Platform. This may include obtaining Data from partners, affiliates, or publicly available sources.

3. USE OF COLLECTED INFORMATION

1. Service Provision and Maintenance: The information collected by the Company is primarily utilized for the effective provision and ongoing maintenance of its services. This encompasses a broad spectrum of activities, including, but not limited to, the facilitation of User and Page registration, profile management, content personalization, and the delivery of educational, promotional, affiliate, and social networking features. The Company employs User and Page Data to ensure the efficient functioning of its Platform, facilitating seamless access to its varied features, such as learning modules, social networking tools, and goal-setting functionalities. This usage is integral to maintaining the operational integrity of the services, ensuring their availability and reliability for all Users and Pages.

2. Personalization of User and Page Experience: The Company is committed to providing a highly personalized User and Page experience. To this end, the information collected is analyzed and utilized to tailor the services to individual User and Page preferences, learning styles, and professional interests. This personalization extends to content recommendations, User and Page interface customization, and the provision of relevant learning opportunities, social networking suggestions, and any other relevant services such as enterprise and corporate promotions. The objective is to create an engaging and relevant Platform that resonates with the unique needs and aspirations of each User and Page, thereby enhancing their personal, professional, and educational development.

3. Communication with Users and Pages: User and Page information plays a crucial role in facilitating effective communication between the Company and its Users and Pages. This includes sending notifications, updates, alerts, and other relevant communications pertaining to the use of the Platform. The Company may also use this information to respond to User and Page inquiries, provide support, and offer assistance with respect to the various features and functionalities of the Platform. The aim is to ensure a responsive and supportive environment where Users and Pages can readily access assistance and information pertinent to their use of the Platform.

4. Development of New Features and Services: The Company may leverage collected Data to guide the development of new features and services. Insights derived from User and Page behavior, preferences, and feedback are integral to this process, enabling the Company to design and introduce enhancements that align with User and Page needs and market trends.

5. Legal and Regulatory Compliance: The Company recognizes its responsibility to comply with applicable legal and regulatory requirements. User and Page information is used for compliance purposes, including, but not limited to, adhering to Data protection laws, responding to lawful requests from competent authorities, and fulfilling regulatory obligations. This includes the management of User and Page Data in a manner that respects User and Page privacy rights and adheres to the highest standards of legal compliance. The Company’s use of User and Page information in this context is governed by a commitment to uphold the rule of law and cooperate with legal and regulatory bodies as required.

4. DATA SHARING AND DISCLOSURE

1. Sharing with Third Parties: The Company may share certain User and Page Data with third-party entities as part of its future expansion and enhancement of services. Any such sharing will be conducted with the utmost discretion and in full compliance with applicable Data protection laws. This may include, but is not limited to, sharing with partners for the development of new features, integration of additional services, or for analytics and research purposes. The Company will provide express notice to its Users and Pages regarding the nature of the Data being shared and the identity of the third-party recipients. Users and Pages may have the opportunity to opt out of such Data sharing arrangements as per the applicable law, ensuring their right to privacy and Data control is preserved.

2. Compliance with Legal Obligations: The Company is committed to upholding its legal and regulatory responsibilities in the jurisdictions where it operates. As such, the Company may be required to disclose User and Page Data in compliance with legal obligations, such as in response to valid requests from law enforcement agencies, court orders, or other legal processes. Such disclosures will be made only to the extent necessary to comply with the law and will be accompanied by efforts to ensure the continued confidentiality and protection of User and Page Data. The Company will make reasonable attempts to notify affected Users and Pages of such legal demands for their Data, unless prohibited by law or if doing so would compromise legal investigations or User and Page safety.

3. Business Transfers and Affiliates: In the event of a business transfer, such as a merger, acquisition, consolidation, or asset sale, User and Page Data may be among the assets transferred. The Company will ensure that the recipient of this Data adheres to commitments comparable to those made in this Privacy Policy. Users and Pages may be notified of any such transfer and will be provided with information about the new entity responsible for their Data. Similarly, as +twe grows and develops, User and Page Data may be shared with affiliates and subsidiaries for the purpose of providing seamless service delivery, operational efficiency, and consistent User and Page experience. All affiliates and subsidiaries will be bound by the terms of this Policy or will maintain similar Data protection policies.

5. DATA PROTECTION AND SECURITY

1. Security Measures: The Company is resolutely committed to safeguarding the security and integrity of User and Page Data. To this end, the Company has implemented comprehensive security measures designed to protect Data against unauthorized, illegal, or unlawful access, alteration, disclosure, or destruction. These measures may encompass both physical and electronic safeguards, including, but not limited to, advanced firewall and encryption technologies, secure server facilities, and rigorous physical access controls. The Company may also engage in regular security assessments and audits conducted by reputable external agencies to ensure the robustness of its security framework. Furthermore, internal protocols and employee training programs will be attempted to be rigorously maintained to ensure that all staff members are aware of and adhere to the Company’s high standards of Data security and confidentiality.

2. Data Encryption and Storage: All User and Page Data collected and processed by the Company is encrypted using state-of-the-art encryption technologies. This encryption applies to Data at rest within the Company’s Databases and Data in transit between the Company’s servers and User and Page devices. The Company’s servers are hosted on secure, cloud-based infrastructure, specifically Amazon Web Services (“AWS”), renowned for its high standards of security and Data protection. The Company reserves the right to change or modify the infrastructure for hosting without notifying the Users and Pages in prior. The Data centers employed are equipped with advanced security features, ensuring that User and Page Data are protected against a broad spectrum of threats. Moreover, the Company maintains strict Data retention policies to ensure that User and Page Data is not retained beyond the necessary period for which it is required as per the applicable laws, and is disposed of securely once its retention period expires as per the applicable laws. 

3. User and Page Responsibility in Data Protection: Users and Pages are advised to choose strong, unique passwords for their accounts and to keep these passwords confidential. Additionally, Users and Pages should be cautious about sharing sensitive information through the Platform and should use the privacy settings provided to control the visibility of their personal information. Users and Pages are also encouraged to be vigilant against phishing and other forms of online fraud. In the event a User or a Page suspect that their account security has been compromised, they are urged to contact the Company’s customer support team immediately for assistance.

6. USER AND PAGE RIGHTS AND CHOICES

1. Accessing and Updating Personal Information: The Company recognizes and upholds the fundamental right of Users and Pages to access and update their personal information. Users and Pages have the right to review, amend, or update their personal information at any time through their account settings on the +twe App. The Company is committed to providing mechanisms that are straightforward and User/Page-friendly, enabling Users and Pages to maintain accuracy and currency in their personal Data. This includes the ability to update profile information, educational qualifications, professional experience, and contact details. The Company encourages Users and Pages to periodically review their information to ensure it reflects their current situation and preferences. In cases where Users and Pages are unable to make certain changes directly through the App, the Company’s customer support team will be available to provide assistance.

2. Deletion of User and Page Accounts and Data: Users and Pages retain the right to request the deletion of their account and associated Data from the +twe Platform. Upon such a request, the Company will take appropriate steps to remove the User’s and Page’s personal information from its active Databases in a timely manner, in accordance with applicable legal requirements and Data retention policies. This deletion will result in the removal of the User’s and Page’s profile, posts, and all other Data linked to the account. However, Users and Pages should be aware that some information may remain in the Company’s records for a period as required by law, for record-keeping purposes, or as necessary to comply with legal obligations, resolve disputes, and enforce agreements. The process for account deletion and Data removal will be clearly outlined in the User and Page settings, and assistance will be available through customer support for those requiring additional guidance.

3. Opt-Out Options: The Company provides Users and Pages with various options to opt-out of certain aspects of Data collection and processing. This includes the ability to opt-out of marketing communications, targeted advertising, and certain Data analytics processes. Users and Pages can exercise these opt-out rights through their account settings, where they can manage their preferences for how their information is used by the Company. For instance, Users and Pages can choose not to receive promotional emails or notifications from +twe by adjusting their notification settings in the App. Similarly, for any future third-party Data sharing arrangements, the Company may provide clear options for Users and Pages to opt out of such sharing. It is the Company’s practice to respect the choices of its Users and Pages and to provide them with control over their personal information, consistent with legal and operational obligations.

7. CHILDREN’S PRIVACY

1. Age Restrictions: In compliance with global Data protection laws and the inherent nature of its services, +twe enforces strict age restrictions for its User and Page base. The Platform is not intended for individuals under the age of majority as per the jurisdiction and applicable law in which they reside. The Company takes proactive measures to prevent the collection and use of personal information from Users and Pages under the age of majority as per the jurisdiction and applicable law in which they reside. During the registration process, age verification procedures are implemented to ensure compliance with this restriction. In instances where the Company becomes aware that Data has been collected from a person under the age of majority (as per the jurisdiction and applicable law in which they reside) without verifiable parental or legal guardian’s consent, immediate steps will be taken to remove such Data from the Company’s servers. The Company advises parents and legal guardians to monitor their children’s internet usage and to instruct their children never to provide personal information on +twe or any other online Platform without their permission.

2. Protection of Children’s Data: Recognizing the vulnerability of children’s Data, the Company is committed to ensuring the utmost level of protection and security for any such Data that may inadvertently be collected. In the rare case where the Company collects personal information from children — either due to falsified information or other circumstances — the Company will adhere to stringent Data protection protocols. This includes the implementation of enhanced security measures, limited processing of children’s Data, and ensuring that such Data is not used for any marketing or promotional purposes. Additionally, the Company will provide parents and guardians with the means to review any personal information collected from their children and to request the deletion of such information. The Company will also ensure that its communication channels are clear and accessible, providing parents and guardians with straightforward mechanisms to raise concerns and queries related to children’s privacy.

8. INTERNATIONAL DATA TRANSFERS

1. Cross-Border Data Transfer Processes: In recognition of its global User and Page base, the Company acknowledges that it operates in a multi-jurisdictional environment. This may necessitate the transfer of Data across international borders. The Company is committed to managing such cross-border Data transfers with the highest level of care and in accordance with applicable international Data protection laws. This includes ensuring that Data transfers are conducted securely, using encrypted channels, and in compliance with the legal frameworks of the countries involved. Prior to any Data transfer, the Company will conduct thorough assessments to ensure that the recipient country or entity provides an adequate level of Data protection, as required by the originating jurisdiction. In cases where Data is transferred to countries without adequate Data protection laws, the Company will implement appropriate safeguards, such as standard contractual clauses or reliance on binding corporate rules, to ensure the continued protection of User and Page Data.

2. Compliance with International Privacy Laws: The Company rigorously adheres to international privacy laws, including, but not limited to, the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and other applicable regional Data protection laws. This commitment is reflected in the Company’s practices of obtaining explicit consent for Data collection and processing, offering Users and Pages the right to access, rectify, or erase their Data, and providing transparency about Data use. The Company continually monitors changes in international privacy laws to ensure ongoing compliance and adjusts its Data transfer practices as necessary. Furthermore, in the event of any conflict between international laws, the Company undertakes a careful analysis to reconcile these differences in a manner that maximizes Data protection for its Users and Pages.

9. CHANGES TO THE PRIVACY POLICY

1. Notification of Changes: The Company reserves the right to amend, revise, or update this Policy at any time to reflect changes in legal requirements, operational demands, or the services we provide. The Company is committed to maintaining transparency and ensuring that Users and Pages may be fully informed of any significant changes to this Policy. Notifications regarding amendments to the Privacy Policy may be conveyed to Users and Pages through various channels, which may include email notifications, in-app notifications, or announcements on the +twe Website. The notification will detail the nature of the changes, the reasons behind the changes, and the effective date of the new Policy. In cases where changes to this Policy substantially or materially alter Users’ and Pages’ rights, the Company may provide a more prominent notice, which may include, but is not limited to, direct communication with Users and Pages or highlighting the changes on the Platform. Users and Pages are encouraged to review the Privacy Policy periodically to stay informed about how their personal information is protected and used.

2. User and Page Acceptance of Changes: The continued use of the +twe Platform following the notification of changes to this Policy will be regarded as acceptance of the revised terms by the Users and Pages. If a User or a Page does not agree to the changes, they are free to discontinue the use of +twe’s services. It is important to note that the refusal to accept changes to the Privacy Policy may limit or restrict Users’ and Pages’ ability to access certain features or functionalities of the Platform. In instances where changes to this Policy require express consent from the Users and Pages, the Company will seek such consent through legally recognized methods before the changes take effect. The Company is committed to ensuring that Users and Pages are provided with clear and unambiguous choices in relation to the processing of their personal information.

10. CONTACT INFORMATION

Users and Pages with questions or concerns related to privacy and Data protection are encouraged to contact the Company through the following methods:

Email: info@twe.co

Address: in5 tech, DIC, Dubai

Additionally, for general questions about privacy features and settings within the Platform, Users and Pages can reach out to the Company customer support team. 

The Company also values User and Page feedback on its privacy practices and encourages Users and Pages to provide suggestions or feedback for improvement. This feedback can be submitted through the Platform’s feedback feature or directly to the designated privacy email address. 

In cases of a Data breach or urgent privacy matters, Users and Pages have access to a dedicated emergency contact mechanism, the details of which may be provided on the Platform. This ensures a prompt response from the Company when dealing with urgent privacy concerns, especially those related to the security of User and Page Data.