Privacy Policy

TwiConnect (by Websolutions Agency) is committed to protecting and respecting your privacy. Therefore, we developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data while on our websites, or services. Please read carefully and familiarize yourself with our privacy practices before using our website (or services) or providing your personal data.

This policy will help you understand the following:

I Definitions

II How We Use Cookies and Similar Technologies

III How We Collect and Use Your Personal Data

IV How Long We Keep Your Personal Data

V How We Disclose Your Personal Data

VI How We Protect Your Personal Data

VII Your Rights with Regards to Your Personal Data

VIII How We Process Children's Personal Data

IX Third-Party Service Providers and Their Services

X How Your Personal Data Is Transferred Globally

XI How This Privacy Policy is Updated

XII Product-Specific Details


I Definitions

Third Parties refer to companies or persons who do not have a related relationship arising out of joint ownership or control with Websolutions Agency (i.e., a non-affiliated company) or other non-related persons. Third parties can be financial or non-financial companies, or persons other than you and Websolutions Agency.

Personal Data refers to any information relating to an identified or identifiable natural person.

II How We Use Cookies and Similar Technologies

1. What are cookies?

Cookies are small text files which are transferred from our websites, applications or services and stored on your device. Websolutions Agency websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. Cookies may be stored on your computer for a short time (such as only while your browser is open) or for an extended period of time, even years. Cookies not set by this site will not be accessible to us.

2. Our cookie usage

(1) Websolutions Agency use cookies or similar tracking technologies to better understand the functionality of our website. We do not link the information we store within the analytics software to any personal data you may submit within the website.

(2) Websolutions Agency use cookies or similar tracking technologies to analyze trends, administer the websites, track users’ movements around the websites, and to gather demographic information about our user base as a whole.

(3) Many web browsers have Do Not Track function. Such function can issue Do Not Track request to websites. If Do Not Track is enabled on your browser, all of our websites will respect your choice.

(4) As true of most websites, we gather certain information automatically. This information may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.


3. Removing/disabling cookies

Managing your cookies and cookie preferences must be done from within your browser's options/preferences. Here is a list of guides on how to do this for popular browser software:

4. More information about cookies

For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.allaboutcookies.org website.


III How We Collect and Use Your Personal Data


Websolutions Agency collects data for efficient operations and to provide you with the best website experience. Our channels for collecting personal data include: (1) you provide us your data directly, (2) we record certain data about how you interact with our website, and/or we obtain certain data about you from third parties.


The data we collect depends on the environment in which you interact with Websolutions Agency, the choices you make, including your privacy settings and the website and features you use.


1. Personal data we collect

(1) Information directly provided by you

The services we provide for you require you to provide information directly to us. For instance:


a. Applying for a job at Websolutions Agency, filling out a web form or posting a comment on our website. In these services, we may ask you to provide personal data to or a personal profile. Types of personal data include name, date of birth, mobile number, email address, username and password created, photos, CVs, etc.

b. Some of our services allow you to communicate and share with others. The communicated or shared content may be transmitted through and stored in our system.

We may ask you to provide personal data and collect it under other circumstances, these circumstances include participating in prize draws or competitions, participating in promotional or marketing activities organized by us or our business partners, completing questionnaires, participating in user forums or blogs hosted by us or our business partners. The information you provide helps us design and improve the website. We may match your information with third-party data to better understand your needs.


(2) We record certain data about how you interact with our website, and/or we obtain certain data about you from third parties

Other information about your use of the service — such as the version of the application being used, the website visited, and how you interact with the content provided through the service.

Please note that we may cooperate with third-party service providers to achieve the above business functions, for instance, when a third-party service provider provides voice to text conversion services on our behalf, it may receive and store certain personal data. These third parties may not use this information for any other purpose.

2. How we use your personal data

We may process your personal information for the purposes described in this Privacy Policy with your consent, to perform our obligations to you under our user agreement and/or service contract, for compliance with a legal obligation to which Websolutions Agency is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Websolutions Agency or a third party to whom it may be necessary to disclose information. Websolutions Agency will strictly abide by the terms of this Privacy Policy and its updates to use your personal data. Your personal data will only be used for the purpose determined at the time of collection, which has been approved by you. If there is any use other than this, we will obtain your consent in advance. Examples of related usages are as follows:

· Provide and improve our products. The personal data we collect will be used to provide you with Websolutions Agency's products and services, process your orders or fulfill the contract between you and Websolutions Agency to ensure the functionality and safety of our products and services, to verify your identity, to prevent and investigate fraud or other improper use.


· Customer Support. We use data to diagnose product issues, and provide other customer care and support services. Your device user identification information, device’s unique identifier, and geographic location information may be used to invite you to participate in surveys. We also use this information to improve our products and analyze the efficiency of our business operations. However, we will not use this information to track your location. We may also collect your email address to reply your questions or comments submittet through one of the webforms on our websites.

· Commercial Promotion Activities. If you participate in prize draws, contests or similar promotional activities held by Websolutions Agency, we will use the personal data you provide to manage such activities.

We will acquire your consent in advance when the information is to be used for a purpose that is not specified in this Privacy Policy. We will acquire your consent in advance when the information collected for a specific purpose is to be used for other purposes. Without consent of users, we will not provide third parties with users’ personal data and behavior data.

IV How Long We Keep Your Personal Data

Our retention period for personal data is the minimum time necessary to realize the purpose of collection unless a longer retention period is required by law. Beyond the above retention period, we will delete or anonymize your personal data.

V How We Disclose Your Personal Data

  1. Your information will not be shared with third parties for their own independent marketing or commercial purposes.

Where a merger, acquisition or bankruptcy liquidation takes place, if the transfer of personal data is involved, we will ask the new company or organization which obtains your personal data to be subject to this Privacy Policy, otherwise we will ask such company or organization to acquire your authorization and consent again.

We will only share your personal data for lawful, legitimate, necessary, specific and clear purposes, and only personal data necessary for service provision will be shared. Our partners are not allowed to use the shared personal data for any other purposes.

2. We will only disclose your personal data under the following circumstances:

(1) After we obtain your explicit consent;

(2) Disclose in accordance with laws: we may disclose your personal data if it is compulsorily required by laws, such as to comply with a subpoena or other legal proceedings, legal actions or government agencies, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

VI How We Protect Your Personal Data

1. We have taken reasonably practical and technical measures to protect the collected information related to the service. However, please note that although we have taken reasonable measures to protect your information, no websites, Internet transmissions, computer systems or wireless connections are absolutely secure.

2. We have taken safeguarding measures in accordance with industry standards to protect the personal data you provided and prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We take all reasonably practical measures to protect your personal data. In particular:

(1) We will de-identify your personal data to mitigate the risk that other organizations or individuals may identify you on the basis of that personal information. We use SSL to encrypt many services. We periodically review practices regarding information collection, storage and possessing (including physical security measures), to prevent various systems from unauthorized access.


(2) We only allow Websolutions Agency employees and personnel of authorized service companies who need the personal data to process it to access such personal data, and they are subject to strict contractual confidentiality obligations. If they fail to perform these obligations, they may be held liable or their relationship with Websolutions Agency may be terminated.

(3) The security of your information is extremely important for us. Therefore, we endeavor to ensure the security of your personal data and implement measures such as full security encryption during storage and transmission to prevent your information from unauthorized access, use, or disclosure. At the same time, no one can access the specific content of some encrypted data except the users themselves.

(4) When we transmit and store your special categories of personal data, we will use security measures such as encryption. When we store personal biometric information, we will treat it with technical measures before storage. For instance, storing only the digest of personal biometric information.


3. In case of personal data security incident, in accordance with the requirements of laws and regulations, we will promptly inform you the basic situations and possible influence of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc. We will inform you in a timely manner by email, post, telephone etc. regarding the relevant situations of the incident. When it is difficult to notify each personal data subject individually, we will issue a notice in a reasonable and effective manner. At the same time, we will take the initiative to report on the handling of personal data security incident in accordance with regulatory requirements.

VII Your Rights with Regards to Your Personal Data

Websolutions Agency will respect your legal rights to your personal data. Below are the rights that you have under law, and what Websolutions Agency does to protect those rights. Please note that for the sake of security, we may ask you to verify your identity before processing your request.


1. The right to be informed: Websolutions Agency is publishing this Privacy Policy to keep you informed as to what we do with your personal data. We strive to be transparent about how we use your data.

2. The right to access: If you wish to access your personal data, you can contact us and we’ll gather all the information that is collected and inform you about it.

3. The right to rectification: If you find that there is a mistake with your personal data we process, you are entitled to ask us to make rectifications. You can rectify your information via the by contacting our Data Protection Officer: [email protected]

4. The right to erasure: You can submit a request to us to delete personal data if we do not have a legal reason to continue to process and hold it. You can delete your information by contacting our Data Protection Officer: [email protected]

5. The right to restriction of processing: You have the right to ask Websolutions Agency to restrict how we process your personal data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. You can realize your right to restriction of processing by contacting our Data Protection Officer: [email protected]

6. The right to data portability: To the extent permitted by laws and regulations, you have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format. For example, if you decide to switch to a new provider, this enables you to move copy or transfer your personal data easily between our IT systems and theirs safely and securely, without affecting its usage. You can exercise your right to the restriction of processing by contacting our Data Protection Officer: [email protected]

7. The right to object: You have the right to object to Websolutions Agency processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics. You can object Websolutions Agency processing your data by contacting our Data Protection Officer: [email protected]

8. The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time, and Websolutions Agency must stop processing your data. You can withdraw your consent by contacting our Data Protection Officer: [email protected]

9. The right to object automated individual decision-making: You have right not to be subject to a decision based solely on automated processing, including profiling. If these decisions significantly affect your lawful rights, you are entitled to ask for an explanation by contacting our Data Protection Officer: [email protected], which we will respond to and take appropriate measures to resolve, as necessary.

10. The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority.

We will respond and reply to your above requests as soon as possible, and generally within seven days and no later than one month upon receipt of your request. (If necessary and as permitted by law, we may extend it by an additional two months. We will inform you the reason for the extension within the aforementioned one month, for example, if the request is complex or involves a large volume of data). If you are not satisfied with a response you received, you can refer the complaint to the relevant regulatory authority in your jurisdiction.


VIII How We Process Children’s Personal Data


1. Our website and services are mainly adult-oriented. We treat anyone under 16 years old (or equivalent minimum age in relevant jurisdiction) as a child.

2. When we find that a child’s personal data is collected, we will delete the relevant data as soon as possible.

IX Third-Party Services Providers and Their Services

1. Websolutions Agency websites, products, applications, and services may contain links to third-party websites, products, and services. You can choose whether to access websites, products and services provided by third parties or not. For example, the “share” function in the official website will lead you to access to our official accounts in social network platforms (e.g. Facebook, Instagram, LinkedIn, Twitter and etc.) where you can be aware of the marketing or promotional information published by Websolutions Agency.

2. We have no control over third-party privacy and data protection policies and such third parties are not bound by this Privacy Policy. Before submitting personal data to third parties, please refer to the privacy protection privacy of such third-parties.


X How Your Personal Data Is Transferred Globally

1. In principle, the personal data collected and produced anywhere in the world is stored within the territory of the European Union.

2. Nevertheless, we provide products and services based on our resources and servers around the world, which means to ensure the uniqueness of your account so that it can be used globally without duplication, after acquiring your authorization and consent, your personal data (i.e. IMEI, mobile phone number, email address, and user name information) might be transmitted to a jurisdiction or accessed from jurisdictions outside of the country/region where you use the products or services after de-identification.

3. In case your personal data is transferred to countries located outside of the EEA, we will ensure that appropriate safeguards are taken, such as:

  • The country to which the personal data are transferred has benefited from an adequacy decision by the European Commission under Article 45 of the GDPR; or
  • Standard data protection contractual clauses as approved by the European Commission pursuant to Article 47 of the GDPR have been established.


In the absence of the above appropriate safeguards, we will ask you for your explicit consent for cross-border transmission of your personal data. In the meantime, security measures such as encryption or de-identification will be adopted for the safety of your personal data.

For more information about the safeguards relating to personal data transfers outside of the EEA, please contact our Data Protection Officer: [email protected]

XI How This Privacy Policy Is Updated

We reserve the right to update or modify this Privacy Policy from time to time. We will send you update notices through different channels. If we make any material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) if an email address is provided by you, otherwise we will notify you by posting notice on this website prior to the change becoming effective.

This Privacy Policy allows adjustments, but we will not diminish your rights under this Privacy Policy without your express consent.

If you have questions or concerns regarding our Privacy Policy or practices, please contact our Data Protection Officer at the following address:

WEB rješenja d.o.o. 

Svetice 21, 10000 Zagreb, Croatia

Email: [email protected]