Twise Victory Publishing B.V. (“Twise”), trading as The Wonder Weeks, having its registered office at St. Walburgisplein 45 (6811BZ), in Arnhem, Netherlands (KvK: 58223169) is a data controller and processor within the meaning of the General Data Protection Regulation (“GDPR”) for the purpose of processing your personal data.
This privacy statement applies to the processing of personal data of:
- Website visitors
- Customers
Twise values the protection of your privacy, and we take our responsibility to protect your personal data seriously. Twise has therefore prepared, among other things, this privacy statement for customers and website visitors.
The purpose of this privacy statement is to be transparent about how Twise collects, uses and protects your personal data in accordance with Articles 13 and 14 GDPR.
What is personal data?
Based on the GDPR, personal data is any information about an identified or identifiable natural person. This means that information is either directly about someone or can be traced back to that person.
For what purposes do we process personal data?
We process your personal data only for specified, explicit and legitimate purposes. We inform you by adding this privacy statement to the (license) agreements we conclude with you and by placing this privacy statement on our website. Below you will find more information about the various purposes.
WEBSITE VISITORS
- For handling questions/comments/complaints
What does this purpose entail?
For all your questions, comments or complaints you can contact our customer service. In order to answer all questions we need certain data. What data we need varies for each question. When you contact us, we process the personal data you provide in order to contact you and answer your question. The legal basis is our legitimate interest in the efficient handling of questions, comments and complaints (Article 6 (1) (f) GDPR).
What personal data do we process for this purpose?
We process your name, email address, phone number and any other information you share with us during contact with our customer service.
- For sending our newsletter
What does this purpose entail?
You can sign up for our newsletter through our website. You will only receive our newsletter if you have given us permission to send it to you. Do you prefer not to receive our newsletter anymore? Unsubscribing is easy: either in the email itself by clicking on ‘unsubscribe’ or by emailing us at [email protected] with a request to do so.
The legal basis is your consent (Article 6 paragraph (1) (a) GDPR), which you give when signing up for the newsletter on our website.
What personal data do we process for this purpose?
We process your email address for this purpose.
- For analysis and to develop our website, products and services
What does this purpose entail?
We also process data provided indirectly by you. This is because our website uses cookies for functional, analytical and marketing purposes. Functional cookies are necessary for the use of the website.
We refer to our cookie statement for more information about cookies. The legal basis is consent, which you give by agreeing to our cookie terms in the cookie banner on the website (Article 6 (1) (a) GDPR) or, in the case of functional and/or analytical cookies with limited impact on your privacy, our legitimate interest in a properly functioning website (Article 6 (1) (f) GDPR).
What personal data do we process for this purpose?
We process your location data, IP address or app IDs, Internet browser and device type, and website language.
CUSTOMERS
- To create a customer account in “The Wonder Weeks” app or “The Wonder Weeks – Back To You” app
What does this purpose entail?
After you have downloaded The Wonder Weeks app, you can take out a subscription and subsequently create an account. We do not store any of your data before you have created an account, and any data you enter will be stored only on your phone.
If you have bought or received the Back To You book, the unique code will give you free access to The Wonder Weeks – Back To You app, including unique content. To do this, you need to create an account with your email address and a password. If you use the premium version of The Wonder Weeks – Back To You app, you do not need to create an account with us, but you do require an Apple or Google account. We do not receive any (payment) data about you from Apple or Google. Nor do we receive access to your account information at Apple or Google. We only receive a unique identifier for administrative purposes in our relationship with Apple or Google.
The basis for processing the personal data for this purpose is the execution of the (license) agreement you conclude with us by agreeing to the terms of use of the application (Article 6 (1) (b) GDPR).
What personal data do we process for this purpose?
When creating an account in The Wonder Weeks app, we process your email address, device ID, child’s name, due date and a profile picture of you and possibly your child. When creating an account in The Wonder Weeks – Back To You app, we process your email address.
- Use of the forum in The Wonder Weeks app
What does this purpose entail?
If you have purchased a subscription and created an account in The Wonder Weeks app, you can use the forum in the app during your subscription period.
The forum allows you to exchange messages with other users of the forum. Because as a rule, we want to process as little personal data about you as possible, you have the option to use the forum with another name (alias). You can also link a profile picture to your alias for the forum. This does not have to be a picture of yourself.
All your posts or comments are visible to all other users of the forum. You have the freedom to actively participate in the forum, and you decide which information you want to share with other users through the forum. You always have the possibility to edit or delete the messages or comments you post. Also, you can always ask us to delete all your messages and comments on the forum.
If you delete your account, your posts will remain visible to other users for another two years, but we will remove your alias and replace it with “inactive” or “deleted” user. In this way, we still keep our forum as informative as possible for all users. The basis for processing personal data for this purpose is the performance of the contract (i.e. the license agreement for the use of the app and more specifically the subscription you enter into with us to use the forum), Article 6 (1) (b) GDPR, our legitimate interest in keeping the forum up to date and as complete as possible in order to provide all users with an informative platform (6 (1) (f) GDPR) and, if you share special personal data with other users via our forum, the exception that the processing relates to personal data that is manifestly made public by you (Article 9 (2) (e) GDPR).
What personal data do we process for this purpose?
We process for this purpose all messages, comments and photos you post on the forum. We also process your alias if you do not want to use your real name and the profile picture you use for the forum.
- For product enhancement of ‘The Wonder Weeks’ app and ‘The Wonder Weeks – Back To You’ app
What does this purpose entail?
Once you have downloaded, installed and used our app, we process technical/analytical data about the use of the app. The data about the use of our apps is not linked to an individual user. We track at an aggregate level how often certain buttons are pressed, what content is read and whether the content connects to the baby’s development and leaps. This allows us to track which content is viewed and used frequently and to continuously improve our apps and the content within them to better suit the needs of our users. The legal basis is our legitimate interest in improving our product (Article 6 (1) (f) GDPR).
What personal data do we process for this purpose?
We process aggregated data on the use of (the content of) our app for this purpose.
- Communication purposes, including customer service
What does this purpose entail?
For all your questions, comments or complaints you can contact our customer service. In order to answer all questions we need certain data. The data we need varies for each question. When you contact us, we process the personal data you provide in order to contact you and answer your question.
In addition, contact during our service may also be important or occur in other areas, for example, to handle questions about the forum/app or our agreement. The legal basis is our legitimate interest in the efficient handling of questions, comments and complaints (Article 6 (1) (f) GDPR).
What personal data do we process for this purpose?
We process your name, email address, phone number, app version, iOS/Android version, device version, app language, location country, time zone and any other data you share with us during contact with our customer service. In exceptional cases, we may process your date of birth and your bank account number (if we need to make a refund).
- For marketing purposes
What does this purpose entail?
You can sign up for our newsletter through our site. You will only receive marketing messages from us if you have given us permission to do so, have requested it or are a customer of ours and have not opted out of receiving marketing messages. Do you prefer not to receive newsletters, marketing messages or survey invitations anymore? Unsubscribing is easy: either in the email itself by clicking on ‘unsubscribe’ or by emailing us at [email protected] with a request to do so.
Through our newsletter or app, we can also bring to your attention relevant products and services that we have developed (possibly with a partner). For example, toys that fit in exactly with your baby’s development or an offer from one of our partners that you wouldn’t want to miss.
To understand the effectiveness of our marketing campaigns, we also track our conversion rate. We can do that (depending on the platform where we buy ads) in two ways. Namely, by keeping track of how many of our links in ads are clicked on and whether someone has subsequently become a customer, or through integration with a social media platform that provides us with this information about conversions and the effectiveness of our marketing campaigns.
The legal basis is your consent (Article 6 (1) (a) GDPR), which you give when returning questionnaires, signing up for the newsletter or, if you are our customer, our legitimate interest in an effective marketing campaign (Article 6 (1) (f) GDPR).
What personal data do we process for this purpose?
To do this, we process your email address, the use of our application and for measuring the effectiveness of our marketing campaigns, your IP address.
- (Scientific) research and focus groups
We find it important to improve and further develop the products, services and information we share with you. But also to contribute to knowledge about baby development through (scientific) research. We may conduct research together with third parties, such as a partner’s research department, a research center, individual researchers or a university. For research, we may use, for example, survey responses from our focus groups and/or information about the use of our application. If we use usage data from our application for (scientific) research, we aggregate and/or anonymize the data as much as possible.
We may approach you to participate in focus groups. Through focus groups we also want to get to know our target group even better. If you participate, we will send you a questionnaire from time to time with all kinds of questions or an email with questions (if you have also consented to contact with on an individual basis). You are of course free not to answer questions. We will always inform you additionally when sending a survey and/or questionnaire by email about what we may use your answers for and/or whether we may want to use (anonymized) answers for research purposes.
Do you prefer not to receive invitations for surveys or focus groups anymore? Unsubscribing is easy: either in the email itself by clicking on ‘unsubscribe’ or by emailing us at [email protected] with a request to do so. The legal basis is our legitimate interest in better understanding the experiences of our customers so that we can improve the content of our products and contribute to the knowledge about the development of babies (Article 6 (1) (f) GDPR) and possibly your consent (Article 6 (1) (a) GDPR) if we ask questions that may contain (indirect) health data.
What personal data do we process for this purpose?
We process your name, phone number, email address, use of our application and the answers and/or information you provide as part of the focus groups for this purpose.
- To perform content moderation
What does this purpose entail?
The Digital Services Act (DSA) creates new obligations for intermediary services like us to act against illegal content on our platform. We consider it important to protect the users of our platform (including our forum) and proactively detect and combat illegal content. In this context, we carry out content moderation on our own initiative, checking posts posted on our forum for the presence of content that violates the law or our applicable terms and conditions. For this purpose, we process personal data of users who post messages on our forum. The legal basis is our legitimate interest in carrying out content moderation on our own initiative to combat illegal content on our platform (Article 6 (1) (f) GDPR).
What personal data do we process for this purpose?
We process your name, account information, profile picture and the content of the messages you post on the forum for this purpose.
- For handling notifications and/or complaints about illegal content (decisions)
What does this purpose entail?
The DSA allows you to inform us of the presence of illegal content on our service through our illegal content mechanism. For more information on this, please see our terms and conditions. In the case of such a notification, we will check the alleged illegal content to determine whether we need to take action (such as removing the information). In doing so, we process personal data of the reporting party and of the user who posted the message on our forum. We will inform the person/organization that made the report (if we have the relevant electronic contact information) about the decision we have taken as a result of the report, as well as the means of redress. We will also inform the relevant forum user if we take action as a result of the report.
The legal basis is the fulfillment of a legal obligation (Article 6 (1) (c) GDPR) and/or our legitimate interest in efficiently handling reports about alleged illegal content on our service (Article 6 (1) (f) GDPR).
In addition, we have an internal complaint handling system. Through this system, complaints can be submitted about certain decisions we have made in response to reports we have received about alleged illegal content. We process the complaints received and, if necessary, check (again) the information to which the complaint relates to determine whether the complaint is justified. In doing so, we process personal data of the complainant and (if relevant/other) of the user who posted the message on our forum.
We inform the complainant of the decision we have taken as a result of the complaint, as well as the means of redress. We also inform the affected user of our forum if we take action as a result of the complaint. The legal basis is the fulfillment of a legal obligation (Article 6 (1) (c) GDPR) and/or our legitimate interest in efficiently handling complaints resulting from our decisions regarding (alleged) illegal content (Article 6 (1) (f) GDPR).
What personal data do we process for this purpose?
To handle reports/complaints, we process your name, contact information (such as your e-mail address) and the information contained in the report/complaint.
To handle reports/complaints, we process from you as the user who posted the relevant message on our forum your name, account details and the information in the message you posted on our forum.
- For taking action against illegal content and/or abuse
What does this purpose entail?
If, through investigation on our own initiative or in response to a report, we determine that there is illegal content on our service, we are obliged to take action against it. We can take various measures against this, such as removing the information or restricting its visibility. If we impose restrictions on the information provided by you, we will contact you to inform you about this. In taking these measures and contacting you, we process personal data. The legal basis is the fulfillment of a legal obligation (Article 6 (1) (c) GDPR) and/or our legitimate interest in taking adequate action against illegal content (Article 6 (1) (f) GDPR).
In addition, we may also impose a suspension if it appears that you are abusing our service by frequently providing illegal content and/or submitting reports/complaints that you know or should have known were unfounded. Before we impose a suspension for this, you will receive a warning from us. In doing so, we process personal data. The legal basis is the fulfillment of a legal obligation (Article 6 (1) (c) GDPR) and/or our legitimate interest to take adequate action against abuse on our service (Article 6 (1) (f) GDPR).
What personal data do we process for this purpose?
We process your name, account information, any previous reports/complaints and/or the information you post on our forum when taking action/imposing suspensions.
Your rights
You have the right to be properly informed about what we do with your data and why we need your data. We do this through this privacy statement. In addition to the right to be transparently informed, you have the following rights:
- Right to access (if you want to know what data we collect from you);
- Right to rectification (we are happy to amend any data that is no longer correct);
- Right to be forgotten (in some cases you can ask us to delete your data);
- Right to restrict processing (in some cases, you may ask us to restrict the processing of your data);
- Right to data portability (if you want, we can transfer your data to another party or give you a copy of your data);
- Right to object (in some cases you may object to the use of your data).
If you would like to exercise any of your rights, please contact us by emailing [email protected]. We always respond to your request within one month.
Who do we share data with and where do we store it?
In some cases we provide your data to third parties, for example with processors who help us process your personal data or, if necessary, with our accountant.
We may also share (personal) data with third parties with whom we collaborate for the purpose of (scientific) research. If we share data with third parties for (scientific) research, we will do so as much as possible on an anonymous basis, for example by aggregating or anonymizing data. Prior to sharing data with third parties for (scientific) research, we will always inform you about the party with whom we share data and offer you the opportunity to ensure that your personal data is not shared. We conclude agreements with possible research partners to ensure that they also use your (personal) data carefully and in accordance with the GDPR. However, we will never sell your data to other parties.
Processors who help us process your personal data may only use your data on our behalf and to perform the relevant services they provide to us. They may not use or transfer your data independently.
We work with various applications to process certain data. To ensure your privacy, we choose our suppliers carefully and these applications are bound by strict rules. Most data is stored within the European Union.
For data processed outside the EU, we only cooperate with parties that offer adequate protection according to European rules and regulations. If we process your data (possibly through our external service providers) outside the EU, we ensure adequate protection of your personal data. For example, by using special contracts to ensure this (e.g., EU model contractual clauses).
Consent
If we process your data based on your consent, you always have the right to withdraw your consent. This can easily be done by sending an email to [email protected]. In that case, if we have no other basis for processing, we will no longer use your data for this purpose.
For how long do we keep your data?
We keep your data for as long as necessary for the purpose for which we use your data and/or for as long as the law requires us to keep the data. The exact length of time varies. From a few months to many years, for example, when it is necessary for our accounting purposes.
We will keep your data at least for as long as your account remains active unless you ask us to delete data or your account at [email protected]. You can always view and/or change some of your personal data in your own account.
How do we protect your data?
Under Article 32 GDPR, we are obliged to take appropriate technical and organizational measures to prevent the loss of personal data or unlawful processing. With us, the security of your personal data is well regulated by physical, administrative, organizational and technical measures.
Only employees authorized by us to do so have access to the data. They have also signed a confidentiality agreement. We therefore have an appropriate level of protection. We also periodically update this level of protection when necessary.
Our organization is designed to do everything possible to prevent security breaches, a so-called data breach. If there is a data breach, we will act according to the Data Breach Protocol.
Contact and complaints
If you have any questions about this privacy statement or wish to exercise your rights as a data subject, please contact us at [email protected].
In case of complaints about, for example, how we use your data or how we respond to privacy-related questions, you can file a complaint with the Personal Data Authority.
Content moderation procedure
We believe it is important that our platform is and remains free of information that is unlawful or violates our terms and conditions. Therefore, we conduct content moderation. Our content moderation procedure sets out how we moderate content posted by users on Twise’s forum. We explain what measures we can take and why, what you can do about it if you, as the poster of that information, do not agree with it, and how you can report suspected unlawful content. In applying this procedure, Twise always acts in a careful, objective and proportionate manner with due consideration for the rights and interests of our users.
What are the requirements for user content?
Twise makes every effort to prevent illegal or unlawful information. Information is illegal or unlawful if it violates the law or any other terms of Twise.
How does Twise control the information users post?
Although Twise has no general obligation to monitor the information it transmits/stores or to actively investigate illegal activities on our platform, we are free to voluntarily investigate or take other measures to counter illegal/unlawful content on our platform. Hence, we proactively monitor our forum for posts that do not comply with the law or our terms and conditions.
In addition, individuals may make a report to Twise when they suspect that certain content is unlawful or in violation of applicable terms and conditions. If an individual reports information on Twise’s forum as unlawful or in violation of applicable terms and conditions, we review that information and evaluate it based on the substantiation of the report, the applicable terms and conditions, and the law. We do not pre-check users’ information and use only human review.
Measures
If, after a review, we determine that the information is not unlawful or does not violate applicable terms and conditions, we will leave it up and take no action.
If, after an audit, we determine that the posted information is (potentially) unlawful or in violation of our terms and conditions, we may take action.
We may also receive an order from a judicial or administrative authority to take action against illegal content or to provide specific information about one or more specific user(s). We will notify the user who posted the information as soon as possible, but no later than at the time when the order is acted upon (unless this differs from the time specified in the order), of the order received and the action taken thereon.
We can take the following measures:
- Information may be temporarily blocked/deleted
This will happen, for example, if further investigation into the legitimacy of the information is needed. We may request additional information from the user who posted the information or the person who reported the information. Until we receive a response, we may decide to temporarily block/remove the information. We will do this sooner if it is likely that the information is unlawful or in violation of our terms and conditions. Depending on the additional information we receive, we will either reinstate the information or keep it blocked/deleted.
- The user may be requested to modify the content
This will happen, for example, if only one part of the message can be considered unlawful or in violation of our terms. In that case, we will contact the user who posted the information and explain how the message should be modified in order to no longer be considered unlawful or in violation of our terms. If the user refuses to modify the message, we may take additional action.
- The message or certain information from the message may be deleted
This will happen, for example, if it is determined that the message (or certain information from the message) can be considered unlawful or in violation of our terms and conditions, and if modification of the content is not adequate/possible in our opinion.
- The user’s account may be (temporarily) suspended (for example, for repeatedly posting unlawful information or repeatedly making unfounded reports)
This will happen, for example, if the same user repeatedly posts unlawful information, or information that violates Twise’s applicable terms and conditions, or if the same user repeatedly submits obviously unfounded reports or complaints to Twise. The user will always receive a warning prior to suspension. A suspension can last for a maximum of twelve months. The duration of the suspension depends, among other things, on the severity of the unlawful information. Indecent language, for example, will result in a shorter suspension than discriminatory or hate speech. The amount of unlawful information posted may also affect (the duration of) any suspension.
- The user’s ability to file reports and/or complaints may be (temporarily) suspended
This will happen, for example, if a user repeatedly submits obviously unfounded reports or complaints to Twise several times. Twise may decide – after issuing a warning – not to handle the reports and complaints of this user for a period of up to twelve months. The period of this suspension depends, among other things, on the severity and intensity of the abuse of the reporting and complaint facilities. The higher the number of unfounded reports or complaints, the sooner/longer a suspension may be imposed.
We will inform both the person who posted the information and the person making the report (to the extent we have his/her contact information) of our decision to leave the information in place or remove it. Twise reserves the right to remove the information or otherwise limit its visibility at any time.
Filing a complaint or making a report
Do you suspect that certain information on our platform is unlawful or in violation of our terms and conditions, or do you disagree with a decision to remove a rating or a response to it, to leave it in place, or a suspension decision due to abuse? Then you can report this to Twise or file a complaint up to six months after the decision. If we agree with the complaint, we will reverse the decision. If we disagree with you, we will uphold the decision.
If you want to report illegal content or file a complaint, you can follow the following roadmap:
- Send your report/complaint to Twise by emailing to [email protected];
- Please state “DSA notification of illegal content” in the subject line of the email if you wish to report suspected illegal content, and “DSA complaint” if it is a complaint;
- In the case of a report of suspected unlawful information: please state in your email the reasons why you believe that the content is unlawful. Include as much relevant information as possible (such as the type of content, if possible, the name of the content provider, the date/time the content was provided, etc.).
In the case of a complaint: please state in your email your reasons for disagreeing with our decision. Include as much relevant information as possible;
- Indicate the country in which you think the content violates the law;
- If possible, provide a specific law or other legal basis for your report;
- Please include your contact information;
- Send us your email.
Once we receive your report/complaint, we will review it and take action if necessary. We will notify you via email (if you have provided your contact information) of the outcome of our review.
Transparency and reporting
We believe that it is important to keep you well informed about how we conduct content moderation. That is why we publish a report on our website once a year. We also always inform you of important changes to this procedure.
Contact and questions
If you have any questions about the content of this procedure or content moderation or wish to contact us for any other reason, please send an email to [email protected] using the contact form on our website. You can contact us in any language.
Arnhem, November 2024
