Privacy Policy


1. Introduction:

Please read the following to learn more about Tweli, Inc.’s (“Tweli”) Privacy Policy. Tweli respects the privacy of its online visitors and users (collectively referred to as a “User” or “Users”) of its products and services, and intends to give Users certain control over their personally identifiable information. Tweli recognizes the importance of protecting any information collected from Users and has adopted this Privacy Policy to inform its Users about the types of information Tweli gathers about a User online while using Tweli’s Service, how Tweli may use that information, whether Tweli discloses it to anyone, and the choices a User has regarding use of and correction of the information. This policy does not apply to the practices of third parties that Tweli does not own or control, or to individuals that Tweli does not employ or manage. In addition, the Service may contain links to third-party websites, applications or other outside sources that Tweli has an interest in, connection to, association with or otherwise has entered into a contractual relationship with (“Affiliate”). While Tweli attempts to provide links only to those sites that share its particular respect for privacy, it cannot take responsibility for the content or privacy policies of third-party sites. Therefore, Tweli encourages its Users to carefully review the privacy policies of any third-party sites visited and the third party applications used.

By visiting or using www.tweli.com, Tweli’s services, applications, and any other linked pages, features, or content on Tweli in connection therewith (collectively, the "Service"), Users acknowledge that they are an adult and accept the practices and policies outlined in this Privacy Policy. Tweli does not allow registration and does not knowingly collect personally identifiable information from anyone under eighteen (18) years of age. By registering for the Service Users represent and acknowledge that they are over the age of eighteen years and agree to be bound by the terms of this Privacy Policy. Users may email Tweli with any privacy-related questions at hello@tweli.com.

Effective Date: The Privacy Policy detailed herein applies to any and all information that a User may have obtained from or provided to Tweli. Tweli reserves the right, at its full and complete discretion and without prior notice, to change, modify, amend, add, subtract, or otherwise remove portions of its Privacy Policy at any time and for any or no reason. Although we may attempt to email Users a copy of the revised Privacy Policy at the email address on file, if any, please periodically continue to check the Privacy Policy at www.tweli.com for any changes. Such modifications will be effective immediately, and will apply to disputes arising under the Privacy Policy from the date of posting forward. A User’s continued access to and use of the Service after the posting of any amendments, deletions or other changes to the Privacy Policy will constitute acceptance, acknowledgment and agreement to the respective changes.

2. Privacy Policy Coverage:

This Privacy Policy covers Tweli’s treatment of personally identifiable information (“Personal Information”) and other data that Tweli gathers when you are accessing the Service. Tweli collects User information in a variety of ways. By using Tweli’s Service Users agree that Tweli may collect aggregate information, individual information, and personally identifiable information, as defined below. Tweli receives and stores information entered by Users when using the Service or otherwise provided to Tweli. The information provided is used to ensure that Users can interact with the Service, Affiliate sites or other third-party applications and/or services as authorized and identified by the User; to ensure that Users can use the features of the Services; to ensure that Users can interact with other Users; to improve the content of the Service; to customize the content presented to User; and to communicate about specials and new features. Additionally, to use certain aspects of the Service you may need to grant Tweli permission to access your account information for other social networking sites (including, but not limited to, Facebook, Twitter, and Pinterest). Moreover, as the Service will allow you to register or interact with Affiliates you grant Tweli and the Service permission to access such Affiliate account information or deliver to or register your Tweli account information with the Affiliate, as may be necessary. Tweli may also utilize information in order to adapt the Service for a specific User’s needs and for research purposes. Tweli may share aggregate information and individual information with other parties. Tweli shall not share Personally Information with other parties, except as described in the policy below.

3. Collection and Use of Information:

Registration: At the time a User registers for an account, Tweli requires that the User provide certain information, including a user name, email address and password. Users may optionally choose to provide their full name and other personal information (such as location, interests or “about” information) to be publicly displayed in connection with their account. However, Tweli strongly advises its Users to seriously consider the implications of displaying any Personal Information as part of their account.

Registration for Affiliates Sites: As part of the Service Tweli may collect and retain registration information, payment information or other data submitted by a User, and may deliver said information to the Affiliates designated by a User for such purpose. This type of data delivery enables Tweli’s Service to automatically connect and interact with such identified Affiliate or to support the processing of any purchase or sale transactions made through the Service. To the extent that Tweli intends to share such information with Affiliates for any other purpose, in any way different that described herein, such information and shared use will be specifically described at such time.

Information Collected Automatically: As part of the Service Tweli may continually and automatically collect usage data for statistical measuring and other purposes. This type of data enables Tweli to determine, among other things, how often Users access specific parts of the Service in order to allow Tweli to revise, improve and develop said services. As part of this improvement function, Tweli may provide aggregate information to its Affiliates. However, unless as otherwise specified herein, Tweli will not disclose aggregate information to an Affiliate in a manner that would allow for a User to be personally identified.

Promotions: From time to time Tweli may present special offers, contests, sweepstakes or other promotions. In order to enter into said promotions, a User may need to provide additional personal information such as a physical mailing address that will be used to deliver prizes. To the extent that Tweli intends to share such information with any third party involved in the promotion, such information and shared use will be specifically described as part of the terms of any offer, contest, sweepstakes or promotion. This third party will be prohibited from using the personal information for any other purpose. Surveys and Feedback: Tweli is committed to providing the best experience for its Users. Therefore, Tweli may request information or feedback from Users as part of surveys or other feedback requests as part of its continuing work to make the Service the best it can be. Tweli may employ Users’ non-personally identifiable information to improve the look, functionality and content of the Service or to personalize User experience, products, programs and service offers.

User Generated Content: Tweli encourages Users to submit their video, audio, content, ideas or other materials, in compliance with the Terms of Service and Copyright Policy for the Service. That being said, Tweli retains full control and determination of whether and how such submissions are used. To the extent that a User submits any content, ideas or other materials as part of the Service, the User acknowledges and agrees that Tweli may share such submission with other Users.

Emails or Contacts from You: If a User contacts Tweli by email, Tweli will use the personally identifiable email address information only to respond to the specific inquiry. Additionally, as part of the Service, Users may receive emails and other communications relating to their submissions to Tweli. All Users acknowledge and agree that by posting any User submissions, Tweli may send a response email and other communication that it determines in its sole discretion relates to said User.

Communications from Us: Tweli may send its Users, or deliver to its Users on behalf of its Affiliates or other Users, special announcements and correspondence, including newsletters, news and events, virtual greetings, promotional offers, emails, text messages and other messages. The messages may contain registration information, additional Service features or other Tweli information. Additionally, Tweli will notify its Users if any other User comments or otherwise interacts with their account information. As discussed herein, at any time the User may exercise its right to opt-out of the collection of information for these purposes. If a User no longer wishes to receive communications from Tweli, it may opt-out by following the instructions included in each communication or by accessing the Settings section of their User account.

Community: As Tweli is both a marketplace and a community, it offers Users the ability to connect and communicate in a variety of public or semi-public spaces. Users should employ common sense and good judgment when deciding what to post in these community spaces, including such things as Personal Information. Be aware that any Personal Information you submit on public spaces or to other Users may be accessible to be read or used by any other User for any purpose. Users may also use the Service to direct messaging communications to other Users, for example to discuss a purchase or sale transaction. Users are fully responsible for any Personal Information a User chooses to post through the Tweli Service, including via the Tweli messaging feature.

Cookies: Tweli may use software technology called “cookies” which consist of small text files stored in a computer’s Internet browsers to assist it in providing Users with a better experience. Users have the option of setting their Internet browser to accept, reject, or provide notification of the use of a cookie. Cookies do not consist of Personal Information per se but could be used to connect a User with Personal Information, such as an email address. Unless the User sets its Internet browser to reject the use of a cookie, Tweli may use them for various purposes including recording and saving password information, pages visited on the site and videos viewed, and determining number and retention of Users employing the Service. We do not link the information we store in cookies to any Personal Information you submit through the Service. Our Privacy Policy does not cover the use of cookies by third parties. We do not have access or control over these cookies.

Log Data: When you visit the Service, whether as a registered User or a non-registered User just browsing, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as the browser type or the webpage you were visiting before you came to our Service, pages of our Service that you visit, the time spent on those pages, information you search for on our Service, access times and dates, and other statistics. We use this information to monitor and analyze use of the Service and the Service’s technical administration, to increase our Service’s functionality and user-friendliness, and to better tailor our Service to our visitors’ needs.

4. Personal Information Shared:

Third Party Disclosure: It is the policy of Tweli not to share any Personal Information with a third party, other than an Affiliate, for the purposes of marketing. All pertinent information collected will only be used to provide the Service. From time to time Tweli may engage third parties for technical, processing or other activities related to the Service. However, Tweli will use reasonably commercial efforts to ensure that such parties are obligated to keep the information secure and confidential. Additionally, if a User inputs their real name as part of their public profile, the Service will publicly display a User’s name in connection with the User’s Tweli activity. Other Users will have the ability to see a User’s profile information and the date the User joined Tweli. Moreover, if a User sets its privacy settings to allow for display, other Users can view, for example, content marked as its favorites. In case of Sellers, other Users can see any videos uploaded to the Service, items listed for sale and seller information. The Service may allow its Users to connect with other third-party social networking services. If a User chooses to connect its Tweli account and use such third-party services, any information provided is no longer under the control of Tweli and may be subject to the terms of use and privacy policies of such third party services. Tweli may additionally disclose Personal Information to an Affiliate or to the extent necessary to enforce our terms of use, or to otherwise protect the rights of Users of the Service. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Moreover, to the extent necessary to comply with court orders or with requests by law enforcement or governmental agencies, Tweli may provide Personal Information to the required third parties. Additionally, we reserve the right to disclose your Personally Information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on Tweli.

Purchase and Sale Information: Tweli’s Service is designed to promote the purchase and sale of products between Users and allow for the sharing of information between its Users for such purposes. This includes User information provided directly to Tweli, as well as information that Users broadcast to other Users or to third parties or Affiliates using the Service, including feedback, ratings, profile information, items listed for sale, sold item listings, and comments in community spaces. Submitted User information will be available to other Users of the Service in accordance with the selected privacy settings. User names and public profiles will be generally searchable across the Service and may be available to third party search engines.

Sale of Business or Assets: In some cases, Tweli may choose to buy or sell assets. In these types of transactions, User information is typically one of the business assets that are transferred. In the event that all or substantially all of Tweli’s assets are sold, given, or otherwise transferred to another entity, all User information collected as part of access to and use of the Tweli Service would likely be transferred to that entity as well. By accessing the Service Users acknowledge that such transfers may occur, and that any acquirer of Tweli may continue to use its information as set forth in this policy. You will be notified via email or prominent notice on www.tweli.com of any such change in ownership or control of your personal information.

Hyperlinks: In addition to the Affiliates, the Service may contain hyperlinks, pointers or introductions to other sites on the Internet or services that may be maintained by third parties. These other sites may use cookies, collect data or solicit Personal Information using methods not conforming to Tweli’s Privacy Policy. Such links do not constitute an endorsement by Tweli of any Affiliate or other third-party site or any materials contained therein. Tweli does not control, and is not responsible for, the availability, accuracy, or currency of such Affiliate or other third-party site or any information, content, products or services accessible from such third-party site. Therefore, Tweli recommends that you fully review the Privacy Policy of any particular Affiliate or other site maintained by a third party provider.

5. Security:

Tweli has attempted to incorporate reasonably appropriate physical, electronic, and managerial procedures into its business and online systems to protect and prevent unauthorized use of the information it collects on its Users. Such methods include use of password-protection procedures, Affiliates’ authentication procedures and other commercially reasonable security measures. While Tweli exercises reasonable care and due diligence in providing a secure conduit of information between a User’s computer or other device and our servers, Tweli cannot and does not guarantee the security of materials or information transmitted to us or other Users over the Internet or wirelessly. Therefore, while Tweli will attempt to protect the transmission of any information using methods that comply with the industry standards, we accept no liability for any unintentional disclosure of same.

6. Financial Information:

For full access to all of the features of the Service, or to engage in purchase or sale transactions, Tweli or its Affiliates may require verification of age and/or that proper permission for the transaction has be obtained. Depending on which services Users make use of, Tweli may require additional information, such as a seller’s or purchaser’s name, billing information (including billing address, shipping address, phone number, and credit card information), a physical mailing address, and/or payment information. Specifically, Users selling items through the Service must choose one, or more, third party payment provider(s) (for example, PayPal and Authorize.Net), to process any payments for purchases. Likewise if a User makes any purchases through the Service, Tweli shall pass the required payment information to the respective seller and/or third party payment providers. Tweli may require additional information from its sellers such as business name and location, tax ID, bank or payment processor account information.

7. Contact Us:

If you need further assistance, please send an e-mail with your questions or comments to hello@tweli.com.

8. Access to Personal Information:

If your Personal Information changes, or if you no longer desire access to or use www.tweli.com or the Service, you may correct, update, or request deletion by making the change within your account.


Revision Date: September 13, 2012

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