Updated: October 2023
- Services or Service refers to the Sites as well as Twenty20 Systems’ application integration and automation platform services, tools, mobile applications, documentation, educational systems, and related services.
- Sites include www.twenty20sys.com and other websites under the twenty20sys.com domain.
- Users include visitors who use or otherwise interact with the Sites.
2. Personal Information We Collect
We collect personal information about you when you provide information directly to us, when third parties such as our business partners or service providers provide us with personal information about you or when personal information about you is automatically collected in connection with your use of our Sites. The following subsections describe the types of data we collect:
- Contact and Related Information
We may collect contact information and related personal information, relating to website visitors from various sources, including offline marketing activities. This personal information may include:
- Phone number
- Company name
- Physical Address
- Additional/substitute email addresses
- Social media ids and profiles
- Photographs you submit to us
- IP address
- Device id
- Browsing and/or search history
For example, we may collect this information when you:
- Provide contact information online, for example, to download or subscribe to Twenty20 Systems content, register for a Twenty20 Systems event, or attend a webinar.
- Billing Information
For all paying Users such as enrollees in events or courses, as applicable, we maintain a record of the purchasing, invoices, billing and payment information.
For Users who pay by credit card, our third-party payment processor as listed on our subprocessor page will process your credit card information. We will collect and associate the payment information with a Subscription ID but we do not store any payment card information ourselves. If you have questions about how our processor or subprocessor protects the data it receives from Users, please refer to its websites as listed in https://www.twenty20sys.com/legal/sub-processors.
- Form, Email and Chat Data
You may voluntarily submit to us, and we will retain and process information from Web forms and other online communication systems including email and chat applications. This may include personal information, such as your name, job title, company name, address, phone number, email address.
The Sites offer publicly accessible blogs and community forums, to which you may submit content. If you elect to post in a public area of our Sites, any Personal Information or other content that you voluntarily disclose becomes available both to Twenty20 Systems and to the public.
- Usage Data
Twenty20 Systems also maintains system log files which may include internet protocol addresses, browser, internet service provider, pages visited within Twenty20 Systems’ Sites, referring/exit pages, search terms, operating system, date/time stamp, and clickstream data.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES (real name, alias, IP address, and email address have been collected)|
|Personal information categories listed in the California Customer statute(Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.||YES (name,physicalcharacteristicsin the form of aprofile picture,telephonenumber, andemploymenthave beencollected)|
|Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|Geolocation data||Physical location or movements.||NO|
|Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|Professional or employment-related information.||Current or past job history.||YES|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
3. Sources of Collection
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. You may voluntarily provide this information to us by submitting it. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Sites.
- From third-party sources. In some cases, we may collect information about you from other sources, including third parties from whom we purchase personal information and from publicly available information, such as information published on social media sites, to the extent permitted by applicable law, and we may combine that information with personal information provided by you.
4. Use of Personal Information
- Use by Twenty20 Systems
Twenty20 Systems collects and uses personal information for the following purposes:
- to fulfill or meet the reason you provided the information (For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.);
- to send you marketing information (depending on whether you have opted out of receiving such communications. For further information, please review Section 7 (‘Correcting, Updating or Deleting Your Information’);
- to respond to inquiries you submit to us;
- to analyze usage of our Site for internal purposes, to improve our marketing and outreach to visitors and potential customers, and to improve the content and functionality of the Site;
- to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- to protect our intellectual property rights, your or others’ privacy rights in connection with your use of our Sites, (including by making and defending legal claims);
- to audit our internal processes for compliance with legal requirements and internal policies; and
- to prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
If provided, Twenty20 Systems may use your cell phone number to call or text you in order to provide support to you.
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below in subsection 4.C.
We do not sell personal information. In the preceding twelve (12) months, Company has not sold personal information.
- Third-Party Service Providers
Twenty20 Systems shares personal information with its Affiliates and third-party service providers (such as learning management systems, support services, and hosting partners) to provide the necessary hardware, software, networking, storage, and other services we use to operate the Site and maintain a high-quality User experience.
Twenty20 Systems may store personal information in internal third-party marketing, customer relationship management (“CRM”) programs and mail-management software to facilitate interactions with Users or potential customers and for Twenty20 Systems’ sales and marketing purposes.
In all situations where Twenty20 Systems discloses personal information to third parties acting as service providers or “agents” acting on behalf of Twenty20 Systems, Twenty20 Systems requires the recipient to adequately protect personal information and treat it as confidential.
- Other Information Sharing
In addition to the purposes described above, we disclose personal information to respond to subpoenas, court orders, on legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such personal information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, (collectively a “Transaction”), your personal information and other information may be shared in the diligence process with representatives or counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
Additionally, we may share information, including personal information with our Affiliates, which include Twenty20 Systems Europe, S.A., and Twenty20 Systems Pte. Ltd., and other Affiliates as updated from time to time for administrative, operational, support and marketing purposes.
- Categories of Third-Party Recipients of Personal Information
|Personal Information Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|Identifiers||Affiliates, learning management systems, customer relationship management programs, mail-management software, and hosting partners||None|
|California Customer Records personal information categories.||Affiliates, learning management systems, customer relationship management programs, mail-management software, and hosting partners||None|
|Protected classification characteristics under California or federal law.||N/A||N/A|
|Commercial information.||Affiliates, learning management systems, customer relationship management programs, mail-management software, and hosting partners||None|
|Internet or other similar network activity||None|
|Professional or employment-related information.||None|
|Non-public education information.||N/A||N/A|
|Inferences drawn from other personal information.||None|
6. Links to Other Websites
The Sites contains links to websites and applications, including websites and applications operated by affiliates and other third parties. We do not determine and we are not responsible for the privacy practices or content of websites and applications owned or operated by third parties. Your browsing and interaction on any third-party website or service, including those that have a link on our Site, are subject to that third party’s terms and conditions and policies. We encourage you to read the privacy statements and other terms and conditions of third- party websites linked to the Sites.
7. Correcting, Updating or Deleting Your Information
We have established internal policies for the deletion of data that customers provide to us or that we obtain from other sources as describe in Section 3. We will also respond to requests to delete personal information that may be held within our systems, to the extent possible and with the limitation that some information may need to be retained for legal, accounting or archival purposes (see the “Data Retention” section of this Policy for details). Note that if you remove or request removal of information that you posted in a public area of the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. Therefore, in some cases, we may not be able to delete your
To request removal, deletion, correction or updates of your personal information, contact us at
Moreover, if you are a Twenty20 Systems Customer and would like to opt-out of marketing communications from Twenty20 Systems please contact us at email@example.com or follow the unsubscribe instructions included in the marketing emails. Users in the EU and some other jurisdictions have more specific and additional rights related to their personal information: see Sections 13-15 for more details.
8. Data Retention
Twenty20 Systems will retain your personal information for a period of time consistent with the original purpose of collection (see the “Use of Personal Information” section above) or as long as necessary to comply with our legal obligations, maintain accurate accounting, financial and other operational records, or to resolve disputes.
We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of the personal information being processed, the potential risk of harm from unauthorized use or disclosure of the personal information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your personal information will be deleted.
9. Incident Management and data breach notification
If Twenty20 Systems becomes aware of and determines that an incident involving personal information qualifies as a breach of security leading to the misappropriation, accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information that compromises the security, confidentiality or integrity of such personal information, Twenty20 Systems will report such breach to the Twenty20 Systems User within 48 hours.
10. International Transfers
Twenty20 Systems may host and process User data in specific, non-U.S. locations. Some personal information may be transferred to the U.S. or other locations and processed there, including chat messages, and e-mails you send to us. Please refer to Section 15 below for further information applicable to Users in the EEA and the UK.
11. Security Measures
We seek to protect personal information using appropriate technical and organizational measures based on the type of personal information and applicable processing activity, as detailed on our Security page. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to us may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. You are responsible for the selection and use of any privacy settings or security capabilities within the Sites or where applicable, third-party applications.
12. Children’s Personal Information
Twenty20 Systems does not knowingly collect any personal information from children under the age of 16. If you are under the age of 16, please do not submit any personal information through our Site. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Policy by instructing their children never to provide personal information on our Site without their permission. If you have reason to believe that a child under the age of 16 has provided personal information to Twenty20 Systems through our Site, please contact us, and we will use commercially reasonable efforts to delete that information from our databases.
13. Notice to California Residents
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: firstname.lastname@example.org or Twenty20 Systems Pvt. Ltd..,3 Lenmore Ct, Monroe Township, NJ 08831, Attn: Legal.
Moreover, we are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide this CCPA Notice to California residents to explain how we collect, use and share their personal information, and the rights and choices we offer California residents regarding our handling of their personal information, which the CCPA currently defines as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”
This CCPA Notice does not apply to individuals with whom Twenty20 Systems engages in the individuals’ capacity as representatives of businesses that may provide services to Twenty20 Systems, or to which Twenty20 Systems may provide its Services.
- California Privacy Rights: To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the personal information we collect:
- Right to know what categories of personal information Twenty20 Systems has collected about you, categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties with whom Twenty20 Systems shares personal information, and the specific pieces of personal information Twenty20 Systems has collected about you.
- Right to request deletion of any personal information collected by us about you.
- Right to correct inaccurate personal information that we maintain about you.
- Right to opt-out of the sale of personal information. Please note that we do not sell personal information we collect from you, in accordance with the definition of sell in the CCPA and its supplemental regulations.
- Right against discrimination because you exercised the rights available to you.
- Right to protection against waiver of rights.
You can exercise the rights described above, by sending an email to email@example.com or calling +1-609-619-0021. You may exercise these rights by yourself or via an authorized agent who meets the agency requirements of CCPA. Once you exercise your rights, you agree to receive communication from us seeking information from you in order to verify your identity as the consumer from whom we have collected the personal information and such other information as reasonably required to enable us to fulfill your request. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify that you are the consumer from whom we collected the personal information, as well as sufficient details necessary to help us handle the request.
14. Notice for other US State Residents
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
- Colorado, Connecticut, and Virginia also provide their state residents with rights to:
- Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights please send an email to firstname.lastname@example.org or call +1-609-619-0021. To appeal a decision regarding a consumer rights request please email email@example.com.
Nevada provides its residents with a limited right to opt-out of certain personal information sales.
Residents who wish to exercise this sale opt-out rights may submit a request by phone by calling: +1-609-619-0021. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
15. Notice to European Users
A. Legal Bases For Processing
We are required to identify the legal bases for processing personal data about you. We process personal data as follows:
- Legitimate Interest: We process the following categories of personal data when we believe it furthers our legitimate interests or those of third parties, or your legitimate interest. We will rely on our legitimate interests for processing personal data only after balancing our interests and rights against the impact of the processing on individuals.
- Profile Data
- Online Form, Email and Chat Data
- Usage Data
These legitimate interests include:
- Providing the Sites to Users
- Responding to your inquiries, comments, feedback or questions
- Managing our relationship with Users, which includes sending administrative information to Users relating to our Sites and changes to our policies, and asking Users to leave a review or take a survey
- Providing personalized and customized content and information to Users
- Gaining insights about and making improvements to our business, products and services
- Administering and protecting our business, preventing fraud, criminal activity, or misuse of our Sites, and ensuring the security of our IT systems, infrastructure and networks (including troubleshooting, testing, system maintenance, support and hosting of data)
- Providing information to current and prospective users of our products and services
- Compliance with legal obligations and legal process and protecting our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties
- Other Processing Grounds: From time to time, we may also need to process personal data to comply with a legal obligation.
B. Your Rights Regarding Your Personal Data
You have certain rights with respect to your personal data, including those set forth below, subject to certain conditions and exceptions. For more information about these rights, or to submit a request, please email firstname.lastname@example.org. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the processing of personal data we hold about you and request a copy of such personal data by contacting us at email@example.com.
- Rectification: If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data by contacting us at firstname.lastname@example.org.
- Erasure: You can request that we erase some or all of your personal data from our systems by sending a request to email@example.com.
- Withdrawal of Consent: If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. However, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of our Sites.
- Portability: You can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible, if the processing of your data is based on your consent or on contractual necessity, and if the processing is carried out by automated means.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your personal data for certain purposes by sending a request to firstname.lastname@example.org.
- Restriction of Processing: You can ask us to restrict further processing of your personal data by sending a request to email@example.com.
- Right to File Complaint: You have the right to raise a complaint about Twenty20 Systems’ practices with respect to your personal data to your local regulator. If you are a resident of the United Kingdom and believe that we maintain your personal data within the scope of the applicable laws relating to personal data in the UK, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.
C. Transfer of Personal Data
17. Contact Us
If you have questions regarding this Policy or about Twenty20 Systems’ privacy practices, or to file any complaints, please send your inquiries to:
Twenty20 Systems, Pvt. Ltd.
Attention: Privacy Team
3 Lenmore Ct, Monroe Township, NJ 08831, United States
Email address: firstname.lastname@example.org