2wrap Privacy Policy (Last Updated May 25, 2018)

In order for 2wrap to provide services and specifically the 2wrap services outlined in the Terms of Service including but not limited to the 2wrap website at www.2wrap.com and family of websites and or blogs owned by 2wrap, we may store, collect, and process various forms of information. This site in its entirety is owned by 2wrap, Inc. doing business as “2wrap.” 2wrap (“2wrap,” “we” or “us”) provides an online service. The terms “you” and “user” means all individuals and entities that access the Service.

This Privacy Policy describes how we use Personal Information (defined below) that we collect from you as part of you using our service. For EU users, please see our special provisions under the “Special Information for EU Users” section below. This Privacy Policy also describes the choices available to you regarding our use of your Personal and how you can access and update this information, and what information you provide that we will retain even if you decide to delete the App or stop using the Service. Our Privacy Policy is not a contract, and it does not create any legal rights or obligations.

You should also read our Terms of Service, available at www.2wrap.com/terms which contains important information about the scope and nature of the Service, and the rules that apply to your use of our Service. All capitalized terms used in this Privacy Policy that are not defined in this Privacy Policy have the meaning given to them in the Terms of Service for 2wrap.

Your use of the Service indicates that you consent to our collection, storage, use and disclosure of your personal information and other information as described in this Privacy Policy and the 2wrap www.2wrap.com/privacy  If you do not consent to the use of your Personal Information as described in this Privacy Policy or do not agree to the Terms of Service, do not use the Service.

Data Controller

2wrap provides services to users throughout the world. If you use our services in the United States or in the European Union or elsewhere, 2wrap, Inc. is the data controller. The address for the data controller of the information you provide or that is collected by 2wrap or its affiliates is:

ATTN: Privacy Officer

2wrap.com

3128 Via Colinas #100, Westlake Village, California, 91362

United States of America

info@2wrap.com

 

 

 

 

Types of Information We Collect and How We Use Your Information

 

  1. Personal Information. In order to access and utilize the 2wrap services, one is required to become a registered user. As part of the registration process, one is required to provide the following: (1) name; (2) email address; (3) user name; (5) password; (6) phone number; and (7) log in credentials from third party providers including Google. All registration information provided to us must comply with the 2wrap Terms of Use Agreement.

 

As part of the user experience, you may also exchange information with us that would be part of the personal information we collect. Examples include but are not limited to the following: (1) information provided when you download or use applications from us; (2) information you enter into our system and post as part of using our services (e.g. photos, videos, comments, voice recordings and other multimedia communication materials); (3) information you provide to us when contacting us for help; and (4) profile information you provide for your personal user profile (e.g. age, first and last name, picture, image or likeness, phone number, etc.).

 

  1. Specific Use of Personal Information. The information we collect allows us to provide you with a relevant user experience as well as a mechanism to keep you informed on 2wrap’s latest product announcements, software updates, and promotional information. If you so desire, you can remove yourself from our mailing list by opting out by updating your profile preferences. In order to receive the benefits of the Services offered, your email address is shared with our third-party providers and you shall comply with their sensor registration requirements. However, you may opt out of uploading data to our third-party providers by updating your sensor preferences or by contacting us at info@2wrap.com.

 

Other uses of personal information may be for validating a user account, fraud prevention, or other data safety precautions 2wrap may elect to implement. Additionally, we may use personal information for our internal purposes such as data analysis, auditing, and research to improve our services to you.

 

  1. Non-Personal Information and Its Use. 2wrap collects information that in and of itself does not permit direct association with any specific person. In the case of non-personal information 2wrap has the right to collect, transfer, use, and disclose this information for any purpose. Examples of non-personal information and its intended use:

 

  1. Device related information. We may collect information such as the user device identifier (IDFA), type of mobile device, IP address of your mobile device, mobile operating system, and type of mobile Internet browsers. The device identifier itself may deliver the information to us directly or we may obtain this information via a third-party partner and/or affiliate. We use the information for the express purpose of better understanding customer behavior and improving our products and services.

 

  1. User activity with our services. We may collect and store details on how you interact with our services. This may help us improve our service offerings and to provide a better user experience.

 

  1. Metadata. Metadata is unique technical data that is generally associated with User Content. Metadata allows one to make their User Content more searchable when interacting with our Service. An example of metadata would be a hashtag or some form of geotag that would allow others to more readily find your submitted content and/or its given location.

 

  1. Location Based Information. Use of the 2wrap services, permits us to collect precise information about the location of your particular device. Location may include but is not limited to background location information between Users. We may use your location information to provide requested location services and to allow tagging of files. You may opt out by changing your geo-location settings consistent with your device protocol.

 

  1. Information from Other Sources. This may include:

 

  1. User feedback;
  2. Requesting services for or on your behalf;
  3. Users or others providing information in relation to any claim or dispute;
  4. 2wrap business partners including those with whom you may create or access your account, such as payment providers, social media users, or websites who use 2wrap’s APIs or whose API 2wrap uses;
  5. Publicly available sources.
  6. Marketing service providers.

 

2wrap may combine the information gathered from these other sources with other information in its possession.

 

Cookies and Other Tracking Technologies

“Cookies” are small data files that are sent to your web browser when you access a website, and the files stored on your device’s hard drive. We use “session” cookies to keep you logged in while you use the Site, to track your preferences and to track trends and monitor usage and web traffic information on the Site. These are erased when you close your browser. We use “persistent” cookies to relate your use of our Service to other information about you and store information about your preferences to make your user experience consistent and customized. For example, we may create a persistent cookie that includes some basic information about you, like your favorite website locations and whether customer support responded to your inquiry. These cookies stay on your hard drive until you erase them, or they expire and associate your information with your account even if you are logged out.

Most browsers automatically accept cookies, but you can change your settings on the browser settings to refuse cookies or prompt you before accepting cookies. You can also use your browser settings or other tools to delete cookies you already have. However, if you disable or refuse cookies, then certain features of the Site may be inaccessible or not function properly.

Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Service and may associate that information with your account if you have one.

Certain features of the Site may use local shared objects (or “flash cookies”). Flash cookies are small files similar to browser cookies that collect and store information about your preferences and where you browse and what you look at on the Site. Flash cookies are not managed by the same browser or device settings that are used for browser cookies. You may adjust your Adobe Flash Player settings to prevent flash cookies from being placed on your hard drive.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

We may use “clear GIFs” (aka “web beacons” or “pixel tags”) or similar technologies, on our Service or in our communications with you to enable us to know whether you have visited a part of our Service or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a website or in an email or other type of message, which is retrieved from a remote website on the Internet enabling the verification of an individual’s viewing or receipt of a website or message.

We do not automatically collect Personal Information, but we may tie Personal Information with the automatically collected information using the above tools or information collected from other sources.

We may also log information using digital images called web beacons on our Site or in our emails. We may use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We may also use web beacons to tell if you open or act on our emails.

We also use third party analytics services to collect usage data from our Site in order to help us understand how users are interacting with our Site. Third party analytic services are used to track general location information, and events that occur without our Site, such as how often you use our Site. This information, including your IP address, is transmitted and stored by 3rd parties as determined by us.

IP Address Information and Other Information Collected Automatically

We automatically receive and record log file information from your web browser when you interact with the Site, including your IP address and cookie information. Generally, the Site automatically collects usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Service so that we can analyze and improve them.

Third-Party Sites and Services

 

2wrap products, services, and Site may contain links to third-party services (e.g. Facebook, Twitter, Google etc.), products, and websites. Information collected by third parties is governed by their privacy policies and practices. We encourage you to read and learn about their specific privacy practices.

 

Information Sharing and Disclosure

 

From time-to-time, 2wrap may make certain personal information available to product and service partners. Specific ways 2wrap shares with third parties are described below:

 

  1. Third-Party Service Providers. 2wrap may elect to outsource some of its technical and customer support, tracking and reporting functions, quality assurance testing, and other services that it may deem necessary. Examples of the service partners or third-parties we may provide your information to includes but is not limited to our vendors, marketing partners, research firms, and consultants. Additional examples may include:

 

  1. Payment processors and facilitators.
  2. Cloud storage providers.
  3. Data analytics providers.
  4. Research partners.
  5. Consultants, accountants, lawyers, and other professional service providers.

 

In these specific instances, we may share information about or from you in order for them to provide their services.

 

  1. Business Affiliates and Transfers. 2wrap may share information from or about you with its subsidiaries, joint ventures, or companies under common control, in which case we will require them to adhere to this Privacy Policy. In the event 2wrap, Inc. is acquired in total or by a substantial amount of its assets, we will make best efforts to ensure that the purchaser will assume the rights and obligations of this Privacy Policy. However, 2wrap cannot make any guarantees or promises with respect to a purchaser adopting the current rights and obligations of this Privacy Policy.

 

  1. Investigations. As described in the 2wrap Terms and Conditions of Use, 2wrap reserves the right to provide and/or disclose necessary information for investigatory matters. Examples include but are not limited to: 1) compliance with law enforcement or the necessary legal process; 2) behavior and/or use violative of the Terms and Conditions of Use, and 3) instances whereby it is necessary to protect our rights and obligations.

 

  1. User Request. This includes sharing your information with:

           

  1. 2wrap business partners. For example, we may share your location and/or that of the 2wrap sensor(s) when you engage the services we may make available to you through our business partners and their affiliates.

 

  1. General public when submitting content to a public forum. Use of our services may enable you communicate with public forums such as 2wrap blogs, social media, and features that may be offered with our services. If you communicate with use via these channels, your communications may be viewable by the public.

 

  1. With your consent. 2wrap may share your information other than as we have described in this policy if we notify you and you consent to the sharing.

 

Storage of Your Information

 

The information you provide 2wrap may be collected through our services and processed in the United States or any other country in which 2wrap, its subsidiaries, affiliates, and/or service providers maintain facilities.

 

As a result, 2wrap its subsidiaries, affiliates, and/or service providers may transfer information we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. For example, you may reside in another country or region with differing data protection and privacy laws than the United States. Consequently, when you register to use the Service you acknowledge and consent to 2wrap transmitting your information to the United States or to any country in which 2wrap and/or its subsidiaries, affiliates, and/or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

 

In turn, 2wrap uses commercially reasonable standards, measures and/or protocol to keep the information collected through the Service secure and as a result we take cautionary steps to verify your identify before granting you Service access. Moreover, 2wrap cannot ensure the security of any information submitted or transmitted by you to 2wrap nor can we guarantee that said information may not be disclosed, destroyed, and/or altered.

Protection of Personal Information

2wrap preserves the security of your personal information with the utmost caution. As such, we follow the generally accepted industry standards to protect all user information submitted to us. Although we implement accepted industry standards, we cannot guarantee absolute security with respect to your personal information. Given the fact that no one method of transmission over the Internet or via mobile device is 100% secure, we urge you to take the utmost care when transmitting personal information.

When you use some of the features of the 2wrap services, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. Please take care when using these features.

Data Retention and Deletion

2wrap will retain your personal information for a minimum of 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. 2wrap thereafter deletes or anonymizes such information with applicable laws. Users may request deletion of their account at any time. Following such request, 2wrap deletes the information that it is not required to retain and restricts to or use of an information it is required to retain. You may request deletion of your account by contacting us here at info@2wrap.com.

 

2wrap may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if 2wrap shuts down a user’s account, 2wrap may retain certain information about that account to prevent that user from opening a new 2wrap account in the future.

Access to Personal Information

In order to ensure that your personal information is current and accurate, please log in to your account using 2wrap app and go to user profile.

Privacy Concerns

 

In the event you believe there to be a conflict and/or concern with the terms of this Privacy Policy, you may contact us directly at:

 

ATTN: Privacy Officer

2wrap.com

3128 Via Colinas #100, Westlake Village, California, 91362

United States of America

info@2wrap.com

 

Privacy Policy Modifications

 

2wrap reserves the exclusive right to change, modify, or alter the terms of this Privacy Policy. The most current version of this policy will govern our use of your information. Continued access and use of the 2wrap services after changes to our Privacy Policy occur indicate that you agree to be bound by the revised Privacy Policy.

 

Consent

 

Your continued access and use of the 2wrap services, subject to the Terms of Use and Conditions, signifies your unequivocal consent to the terms of this Privacy Policy.

 

 

 

Special Information for EU Users

 

Beginning May 25, 2018, the processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). This section summarizes 2wrap’s grounds for processing personal information under the GDPR, and the rights of EU users as relates to 2wrap’s handling of personal information. This section provides information as relates to EU users’ rights, and 2wrap’s responsibilities, under this regulation.

 

  1. EU User Rights

If you are an 2wrap user in the EU, you have the following rights with respect to 2wrap’s handling of your personal information. To exercise these rights, please see below or submit your request at info@2wrap.com.

Users outside the EU may also request explanation, correction, deletion or copies of their personal data by contacting us at info@2wrap.com.

 

  1. Explanation and copies of your data
    • You have the right to request an explanation of the information that 2wrap has about you and how 2wrap uses that information.
    • You also have the right to receive a copy of the information that 2wrap collects about you if collected on the basis of consent or because 2wrap requires the information to provide the services that you request.

 

  1. Correction

 

  1. Deletion

 

  1. Objections and complaints

 

 

 

 

 

ATTN: Privacy Officer

2wrap.com

3128 Via Colinas #100, Westlake Village, California, 91362

United States of America

info@2wrap.com

 

  1. Grounds for Processing

The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, 2wrap processes the information of EU users based on one or more of the grounds specified under the GDPR:

 

  1. The processing is necessary to provide the services and features you request

 

  1. The processing is necessary to protect the vital interests of our users or of others

 

  1. The processing is necessary for 2wrap’s legitimate interests

 

 

  1. The processing is necessary for the legitimate interests of other persons or parties

 

  1. The processing is necessary to fulfill 2wrap’s legal obligations

 

  1. Consent

 

 

Choice and Transparency

2wrap provides means for you to see and control the information that 2wrap collects, including through:

You may also request that 2wrap provide you with explanation, copies or correction of your data.

 

  1. DEVICE PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that websites cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the 2wrap website wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the 2wrap website seeks before you first use the website, and your use of the website constitutes your consent.

  1. EXPLANATIONS, COPIES AND CORRECTION

You may request that 2wrap:

You can make these requests by contacting 2wrap at info@2wrap.com.

You can also edit the name, phone number and email address associated with your account through the Settings menu in 2wrap’s website You can also look up your transactions, history, etc. in the 2wrap website.

  1. MARKETING OPT-OUTS

You may opt out of receiving promotional emails from 2wrap at info@2wrap.com. You may also opt out of receiving emails and other messages from 2wrap by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages, such as receipts for your rides or information about your account.

Privacy Policy Modifications and Updates

 

2wrap reserves the exclusive right to change, modify, or alter the terms of this Privacy Policy. The most current version of this policy will govern our use of your information. Continued access and use of the 2wrap services after changes to our Privacy Policy occur indicate that you agree to be bound by the revised Privacy Policy.