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Privacy policy

TwoHold manages the information that we collect from you in accordance with applicable privacy legislation. In this Policy, "TwoHold", "we", "our" and/or "us" means

  • (i) where you reside in any country in the European Economic Area, TwoHold UK Limited and
  • (ii) where you reside anywhere outside the European Economic Area: TwoHold Pty Limited, an Australian company.

Company details for each of the TwoHold companies is set out in the Contact Us section below.

This Privacy Policy describes how TwoHold collects, uses, shares and handles your personal data, and sets out the rights and obligations that both you and TwoHold have in relation to your personal data. Country specific terms in Appendix A shall also apply to this Privacy Policy.

TwoHold may, from time to time, modify this Privacy Policy (and update the web page on which it is displayed). If we materially change the ways in which TwoHold uses or shares your personal data previously collected from you through the Services, TwoHold will notify you through your TwoHold account, your registered email address or other communication. You should check your account regularly to stay up to date with any changes.

1. Collection of Your Personal Data

Information we collect directly from you

TwoHold collects personal data when you pre-register with TwoHold. This includes your full name, email address and location. In circumstances where the below information is not provided to us, we may be unable to provide the Services to you and carry out our contractual obligations with you.

TwoHold collects personal data when you register with TwoHold. This includes:

  • your name, address, email address, phone number and other contact details;
  • your birth date and gender;
  • your credit card and account details, which are processed by a third-party service provider that handles payments for us;
  • your location and the location where you are interested in performing tasks; and
  • your occupation, work experience, resume, qualifications, education, past (?) tasks, earn money preferences, skillset, interests and other information relevant for your fitness for tasks.

If you register in certain countries, we also give you the option of providing a photo or video to be associated with your TwoHold user ID. If your personal details change, it is your responsibility to update your TwoHold account with those changes, so that we can keep our records complete, accurate and up to date.

To enable us to improve our existing services, to create new service features, and to serve you and others with targeted marketing communications, TwoHold collects information about the way you use the Services, including the transactions you enter into on the Services, your feedback rating (including any references requested using our 'Reference' feature), the bids you make, the comments you post, and the transactions you enter into with our valued affiliate service providers. You may apply through our job application submission form provided by a third-party service provider. If you do so, we collect the information you make available to us through your application submission, such as your resume, links to other online profiles, and other information you choose to provide.

Information we collect automatically when you use the Services

TwoHold may also receive and record the following information from your internet browser and computer, including through cookies and similar technologies, when you use the Services:

  • Computer and connection information such as statistics on page views, traffic to and from the Services, referral URL, IP address, unique device ID, browsing history and web log information; and
  • Information about your use of the Services, including the date and time you visit the Services, the areas or pages that you visit, the amount of time you spend viewing or using the Services, the number of times you return to the Services, other clickstream or website usage information, and emails that you open, forward or click-through to the Services.

For more information on how we use cookies and other similar tracking technologies, please see the section on Cookies and Similar Technologies below.

What other information users can see about you

You are not anonymous to us when you log into the Services or post any content (including tasks, items to be supplied, bids, comments or feedback) on the Services or any associated forum.

When you:

  • use the Services to post a task or item to be supplied, or make a bid, or comment on a bid, or provide feedback on other users; or
  • otherwise communicate in a public forum on the Services,

your user ID and all the material that you post is visible and searchable to us, other TwoHold users and is also publicly available to other internet users. We strongly encourage you to use caution and discretion when posting, and carefully consider whether and what to post, or how you identify yourself on the Services.

TwoHold does not in any way control, and does not accept any responsibility or liability whatsoever for the disclosure or use of personal data which is voluntarily posted by you in a publicly accessible area of the Services.

2. How We Use Your Personal Data

TwoHold may use the information we collect for the following purposes:

Identification and authentication

Legal ground(s) for use: We need to perform this function in order to allow you to access the Services.

To protect TwoHold and the users of the Services

Legal ground(s) for use: It is in our (and users) legitimate interests to ensure that the Services are secure.

To customise the content and any advertising displayed on the Services and permit content on the Services (such as postings, marketing or third party advertisements) to be targeted, on an aggregate basis, to the users for whom it is most likely to be relevant

Legal ground(s) for use: It is in our legitimate interest to provide you with content and advertisements that are tailored to your interests.

To improve the Services and develop new service features

Legal ground(s) for use: We need some of your personal data in order to provide the Services to you; it is in our legitimate interests to provide you the best possible Services.

To provide, maintain and protect the Services and to verify the identity of authorised users of the Services

Legal ground(s) for use: We need to perform this function in order to provide a safe and secure environment for our users and we have legitimate interests in protecting the integrity of the Services we offer.

Providing your information to a user with whom you have or had a contract facilitated by TwoHold

Legal ground(s) for use: We need to use your personal data in this way to provide the Services you request.

As required by law, order of a court, tribunal or regulator or if TwoHold reasonably believes that the use or disclosure of the information is reasonably necessary for enforcement related activities

Legal ground(s) for use: On such occasions, we are required by law to process your personal data.

To ensure that TwoHold receives payment of the fees due to it

Legal ground(s) for use: We need to use your personal data in this way to fulfil a contract between you and us.

To contact you to inform you about promotions or upcoming changes or improvements to the Services

Legal ground(s) for use: We only contact you for marketing purposes with your consent; we may contact you regarding changes in the Services because it is in our legitimate interests to keep you informed about service changes that may affect you. See section below for further detail about marketing.

To contact you to administer our User Agreement

Legal ground(s) for use: For example, we may notify you of a breach, or action a request for a take down notice in response to a claim of copyright infringement.

To generate data reports on an aggregated, non-personally identifiable basis, for both internal and third party use, but subject to any applicable laws (for example, we may show advertisers or investors trends relating to the general use of the Services) Legal ground(s) for use: It is in our legitimate interests (and the interests of our partners and affiliates) to understand how you and other users engage with the Services.

Your contact information may also be used for accounting, invoicing and billing purposes, marketing purposes, by third party service providers to TwoHold, and to respond to any enquiry you make Legal ground(s) for use: It is in our legitimate interests to engage service providers to assist us in delivering the Services you request.

When you contact TwoHold, we may keep a record of the communication(s) between you and TwoHold to help resolve any issues you might have Legal ground(s) for use: We retain information when we are required to do so by law and because it is in our legitimate interests to protect our legal rights.

If other user(s) of the Services already have your user ID (or other information identifying you), and you have chosen to upload a photo or other personal data to your TwoHold account, we may show those user(s) that personal data Legal ground(s) for use: We display your photo to other users who have your user ID only with your consent, which you supply by uploading your photo.

The Services allow you to review your experience dealing with others on the Services, who may in turn leave reviews about you. We compile these reviews to provide an aggregate rating for each user, which will publicly appear along with your profile. Please be aware that other users may rely on this rating when deciding whether to engage with you.

Profiling and data analytics

We (or our service providers on our behalf) may collate information about you and your preferences, to identify market segments and use that information for data analytics and direct marketing.

We (or our service providers on our behalf) may use your name, street address, email address, phone number, and data collected from cookies and similar technologies about how you use the Services (including tasks created and certain actions taken on the site) to conduct data analytics, including the creation of look-alike audiences. We use the results of data analytics for marketing, product and service development, and policy development.

We do not use sensitive information for data analytics.

3. Cookies and Similar Technologies

TwoHold uses cookies and similar tracking technologies for a number of purposes including to access your information when you sign in, keep track of your preferences, direct specific content to you, report on TwoHold's user base, and to improve TwoHold's services. We also use cookies or anonymous identifiers when you interact with our affiliate service providers (for example, when you integrate your TwoHold account with your Facebook profile) and as further described below.

We use the following types of cookies and similar technologies:

Strictly Necessary Cookies

We use cookies and similar technologies that are necessary to the operation of the Services. This includes technologies that allow you access to our website, services, mobile app or that are required to identify irregular site behaviour, prevent fraudulent activity and improve security, or that allow you to make use of our functions such as saved search or similar functions.

If you change the settings on your internet browser to block or restrict cookies (including cookies associated with the Services), or to indicate when a cookie is being set by TwoHold, the Services may not work as intended. You should remember that while you may still be able to use the Services if your cookies are disabled, the Services may not function properly on your device and you may not be able to take advantage of certain TwoHold features.

Functionality Cookies

We use cookies and similar technologies that allow us to offer you enhanced functionality when accessing or using the Services. This may include identifying you when you sign into our website, keeping you signed in as you browse or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our website and mobile app.

Performance Analytics Cookies

We use cookies and similar technologies to assess the performance of the Services. We use this information to analyse and help us understand how you and other visitors use the Services so we can improve the content or layout of the Services. We also use this information to track the number of our visitors and analyse the popularity of the features we offer.

Advertising Cookies

We may use first-party or third-party cookies and similar technologies to deliver content, including ads relevant to your interests. This includes using technologies to understand the usefulness of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

You may reject first-party advertising cookies and similar technologies through your browser settings (as described below). To learn more about the use of cookies or other technologies to deliver more relevant advertising and to control or opt out of the collection and use of the data by these third party tools, visit here.

Browser and System Controls

You may set your browser or operating system to limit certain tracking or to decline cookies, but you may not be able to use certain features on the Services which require such cookies. Each browser and operating system is a little different, so please check your browser or operating system's settings or help section to learn more about how to delete or disable cookies and tracking.

If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available here, and you can manage your Google accounts here.

4. How We Share Your Personal Data

TwoHold may disclose the information we collect from you as follows:

  • TwoHold Affiliates. We may share your personal data with our affiliated companies.
  • Service Providers. We share your personal data with third party service providers that provide business, verification, professional or technical support functions for us, help us operate our business and the Services, or administer activities on our behalf.
  • Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • Advertising Partners. We work with third party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalised ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalised ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalised ads in mobile apps.
  • Other Third Parties. We may share your personal data with other third parties who participate in TwoHold marketing initiatives, as authorised by you or on an aggregate basis, and with consultants, advisors and analytics providers as necessary to measure and improve the Services we provide to you. We do not rent, sell, or share information about you with non-affiliated third parties for their direct marketing purposes, unless we have your permission.
  • Sharing Between Users. We may share information, such as ratings and reviews about you, with other users who are looking for taskers on the Services.
  • Legal Matters & Safety. We may share your personal data to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted or required by law. We may also share your personal data if we believe there has been a violation of our Terms and Conditions, our rights, or the rights of any third party.
  • Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, or in the event of insolvency, bankruptcy or receivership, your personal data may be one of the assets sold or merged in connection with the transaction.
  • With Your Permission. We may share your personal data with any other third party with your consent or as necessary to deliver a service you requested.

5. Security

Your account is protected by a password for your privacy and security. We take reasonable steps to protect your personal data from unauthorised access, use and disclosure, however we cannot guarantee the absolute security of that information, or that our systems will be completely free from third party interception or are incorruptible from viruses. We cannot and do not guarantee that information you send from your computer to us over the Internet will be protected by any form of encryption (encoding software). In light of this, we cannot and do not ensure or warrant the security or privacy of your personal data, including payment and account details. You transmit your personal data to us at your own risk. You are entirely responsible for maintaining the security of your passwords and/or account information.

6. International Transfers

When you use the Services, some of your personal data may be transferred to other TwoHold group companies (such as our headquarters in Australia) outside the European Economic Area ("EEA") in countries that do not have equivalent data protection laws to the EEA. We may also engage service providers for the purposes detailed above that are located outside the EEA. We take steps to ensure your personal data is safe and secure when transferring it outside of your country of residence. For more information, please contact us as provided below. In particular if the recipient is in a country that is not subject to an adequacy decision by the European Commission, we may enter into the 'standard contractual clauses' with the recipient. For this reason, TwoHold UK Limited has entered into 'standard contractual clauses' with TwoHold Pty Limited. These are contractual clauses that contain standard commitments approved by the EU Commission protecting the privacy and security of the information transferred.

7. Marketing

When you register on the Services you may be given the opportunity to elect ("opt-in") or decline (“opt-out”) to receive updates on our latest services, news and special offers, and those of our valued affiliate service providers ("Marketing Material"), via your TwoHold account, personal email address, post or telephone. If you conclude a transaction on the Services, you may also be given the opportunity to opt- in to receive Marketing Material from TwoHold and our valued affiliate service providers.

Once you opt-in to receive Marketing Material, you may, at any time, opt-out of receiving Marketing Material. To opt-out go to the 'Manage Account' link on the Services, choose 'Settings', then 'Notification Settings' and update your preferences. You can also click on the "unsubscribe" link in any email containing Marketing Material that we send you, or you can request an opt-out by emailing TwoHold using the contact information provided on the Services. If you no longer consent to receiving Marketing Material then you must opt-out in one of these ways.

TwoHold may contact you as the result of a referral by another user of the Services who has provided us with contact information, such as your name and email address. The use of contact information received in connection with a referral will be governed by this Privacy Policy. You may, at any time, opt-out of TwoHold's referral system by emailing TwoHold using the contact information provided on the Services.

TwoHold reserves the right to send you administrative and account-related messages even if you opt out of receiving Marketing Material.

9. Your Rights and Choices

Rights in Certain Countries. In the European Economic Area and certain countries, users have the right to access, edit, update, restrict processing and/or delete the personal data that we hold about you or to receive a copy of it in a portable format by contacting us here. Where we process your personal data with your consent, you may withdraw it at any time. You also have a right to object to processing based on legitimate interests. These rights may be limited in some circumstances, for example, if:

  • We are legally permitted or required to deny you access to, and/or to retain, the information because we are subject to a legal requirement or have a compelling legitimate interest; or
  • You make a request that is unreasonably repetitive, requires TwoHold to make a disproportionate effort, risks the privacy of others, or there are other valid reasons why we cannot comply.

We need to prevent information in our systems from being accidentally or maliciously destroyed. This means that, where you delete information from the Services, residual copies of that information on our active servers, as well as any corresponding information on our back-up systems, may not be immediately deleted.

If you have concerns about how we handle your personal data or require further information, please email TwoHold using the contact form provided on the Services. If you have unresolved complaints, you have the right to complain to a data protection authority.

Location Information. You can prevent your device from sharing precise location information at any time through your device’s operating system settings.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

10. Retention

We retain your personal data for as long as is necessary with regard to the purposes for which it was collected or lawfully further processed, or for as long as may be necessary in light of our legal obligations, or in order to allow us to pursue, defend or exercise legal claims.

11. Children’s Privacy

We do not knowingly collect, maintain, or use personal data from children under 18 years of age, and no part of the Services are directed to children. If you learn that a child has provided us with personal data in violation of this Privacy Policy, please alert us using our contact information below.

12. Contact us

If you have any questions about this Privacy Policy or about the manner in which we process your personal data, please contact us: hello@two-hold.com

APPENDIX A:

COUNTRY SPECIFIC TERMS

1. Australian Privacy Terms

If you are a user who has your TwoHold Platform account in (or the Services are performed in) Australia then the following terms will also apply to or may vary this Privacy Policy, to the extent specified:

a. a reference to 'personal data' shall also mean 'personal information' as defined in the Privacy Act 1988 (Cth);

b. a reference to 'sensitive information' has the same meaning given to it in the Privacy Act 1988 (Cth); and

c. if we collect, use or disclose any information from you in accordance with this Privacy Policy that is also sensitive information (such as information relating to police checks conducted on users), then we will seek consent directly from you each time we collect, use or disclose your sensitive information, including for direct marketing purposes. We will not use or disclose your sensitive information for any other purpose unless the purpose is directly related to the primary purpose for which your sensitive information was collected.