<p>
<em>Last Updated:</em> January 26, 2021</p>
<p>Twitter, Inc.
and Twitter International Company ("we" or “our”) provide the Revue services to our website visitors ("you").
Our online services include providing a tool that allows writers and publishers (“Publishers”) to create and send out newsletters and for users (“Readers”) to engage with a Publisher’s newsletters through our website, including by signing up to and receive such newsletters, as well as other services through our website(s) and application programming interfaces (APIs) (“Websites”) (“Service").</p>
<p>In this Privacy Policy, we disclose what personal data we collect and use and for what purpose and applies to personal data collected by or under our control.
We advise you to read our Privacy Policy carefully.</p>
<p>You can find the Privacy Policy relating to the Revue platform here.</p>
Types of Data Collected
<p>When using our Websites, we may collect the following Information about you:</p>
<ul>
<li>Personal identification data: name, surname;</li>
<li>Contact information data: email, employer.
and</li>
<li>Other data: IP address, social media accounts, feedback and other communication</li>
</ul>
Purposes of Processing
<p>Personal data is processed by us for the following purposes:</p>
<ul>
<li>Logging in and verifying/authenticating users of the Websites;</li>
<li>Communication between us and Website visitors;</li>
<li>Providing you ways to interact across our other services, such as Twitter;</li>
<li>Monitoring, securing, and auditing the Websites, including using data from our other services, such as Twitter.
and</li>
<li>Analysing statistics and optimising the Websites, and our other services.</li>
</ul>
<p>We process your personal data under one of the following legal bases: legitimate business interests, performance of a contract between you and Revue, legal obligation, or consent.
If the processing is based on consent, it can be withdrawn at any time.</p>
Data Storage
<p>We only keep your data for as long as necessary to fulfil the purposes described in this Privacy Policy, for which your data have been collected.</p>
Your Rights and Contacting Us
<p>You have the right to request access to the information we have about you.
You can do this by contacting us directly at RevuePrivacy@twitter.com or at the appropriate address below.
We will make sure to provide you with a copy of the data we process about you in a machine-readable format.
We may need to verify your identity to comply with your request.</p>
<p>If you believe that the information we have about you is incorrect, you can contact us, so we can update the information to ensure it is accurate.
You also have the right to object to certain data processing operations, such as direct marketing.
If at any point you wish for us to delete information about you, you can communicate it to us.</p>
<p>If you live in the United States or any other country outside of the European Union, EFTA States, or the United Kingdom, the data controller responsible for your personal data is Twitter, Inc.
with an address of:</p>
<ul>
<li>Twitter, Inc.</li>
<li>Attn: Privacy Policy Inquiry</li>
<li>1355 Market Street, Suite 900</li>
<li>San Francisco, CA 94103</li>
</ul>
<p>If you live in the European Union, EFTA States, or the United Kingdom, the data controller responsible for your personal data is Twitter International Company, with an address of:</p>
<ul>
<li>Twitter International Company</li>
<li>Attn: Data Protection Officer</li>
<li>One Cumberland Place</li>
<li>Fenian Street Dublin 2</li>
<li>D02 AX07 IRELAND</li>
</ul>
<p>You can confidentially contact Twitter’s Data Protection Officer here.
If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or Twitter International Company’s lead supervisory authority, the Irish Data Protection Commission.
You can find their contact details here.</p>
Provision to Third Parties
<p>We engage service providers to perform functions and provide services for us in the United States, Ireland, and other countries.
For example, we use a variety of third-party services to help operate our Service, such as hosting our various blogs and wikis and to help us understand the use of our Service, such as Google Analytics.
We may share your private personal data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.
We share your payment information with payment services providers to process payments.
prevent, detect, and investigate fraud or other prohibited activities.
facilitate dispute resolution such as chargebacks or refunds.
and for other purposes associated with the acceptance of credit and debit cards.</p>
<p>Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer to you, we may preserve, use, share, or disclose your personal data or other safety data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request.
to protect the safety of any person.
to protect the safety or integrity of our platform, including to help prevent spam, abuse, or malicious actors on our Service.
to address fraud, security, or technical issues.
or to protect our rights or property or the rights or property of those who use our Service.
However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your personal information data.</p>
<p>In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction.
This Privacy Policy will apply to your personal data as transferred to the new entity.
We may also disclose personal data about you to our corporate affiliates in order to help operate our Service and our affiliates’ services, including the delivery of ads.</p>
International Data Transfers
<p>To bring you our Websites, we operate globally, and we may have to transfer your data to other countries.
Where the laws of your country allow you to do so, you authorize us to transfer, store, and use your personal data in the United States, Ireland, and any other country where we operate.
In some of the countries to which we transfer personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country.
Learn more about our global operations and data transfer here.</p>
<p>When we transfer personal data outside of the European Union, EFTA States, Brazil, or the United Kingdom we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws and/or, contractual obligations placed on the recipient of the data (where we rely on the EU standard contractual clauses, these may be requested by inquiry as described below).</p>
<p>Twitter, Inc.
complies with the EU-US and Swiss-US Privacy Shield principles (the “Principles”) regarding the collection, use, sharing, and retention of personal data from the European Union, EFTA States, and the United Kingdom as described in our EU-US Privacy Shield certification and Swiss-US Privacy Shield certification.
We do not rely on our EU-US and Swiss-US Privacy Shield as our lawful basis to transfer personal data from the European Union, EFTA States and the United Kingdom, however.</p>
<p>If you have a Privacy Shield-related complaint, please contact us here.
As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, we will seek to resolve it through our internal complaint resolution process, alternatively through the independent dispute resolution body JAMS, and under certain conditions, through the Privacy Shield arbitration process.</p>
<p>Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies.
Under certain circumstances, participants may be liable for the transfer of personal data from the EU, EFTA States, or the United Kingdom to third parties outside the EU, EFTA States, and the United Kingdom.
Learn more about the EU-US Privacy Shield and Swiss-US Privacy Shield here.</p>
Cookies and Analytics
<p>💡 No tracking will be performed on profile page activities if the account opted for our ‘privacy option’.</p>
<p>On our Websites, we make use of functional cookies.
These cookies are saved for the duration of the (browser) session.
Additionally, when you use our Service, your IP address is automatically saved in the log files of our web server.
This is necessary to allow us to properly manage and secure the Service.
You can always refuse the cookies.</p>
<p>User data that you provide may be kept for making statistical analyses, including via Google Analytics.
These statistics are used to optimise our Websites.
Wherever possible, we make this data pseudonymized.</p>
Third Party Websites
<p>This Privacy Policy does not apply to third party websites that are visited from our Websites through links.
We cannot guarantee that these third parties will handle your personal data safely and reliably.
We advise you to read the Privacy Policies of these websites before making use of them.</p>
Changes to This Privacy Policy
<p>We may revise this Privacy Policy from time to time, for example, in the event of changes to our Websites or applicable laws and will provide prior notice of such changes as required by law.
The most current version of the policy will govern our processing of your personal data and will be available on our Websites.
If we make a change to this policy that, in our sole discretion, is material, we will notify you on this website or by sending an email to the email address associated with your account.
By continuing to access or use our Websites after those changes become effective, you agree to be bound by the revised Privacy Policy.</p>