Terms of Service / Privacy Policy

Twistbox Entertainment, Inc. and its subsidiaries (collectively, “Twistbox” or “we”) recognize privacy as an important issue and have adopted this Privacy Policy to inform you of our data collection and use practices and confirm our commitment to keep your personal information secure. Twistbox provides a broad mix of products and services through many different distribution channels. We provide products and services through our own Web sites and WAP sites and the Web sites and WAP sites of our business partners (collectively, the “Twistbox Sites”). Our mobile content and data products and services are primarily provided through the WAP sites and Web sites of our mobile operator partners and handset manufacturer partners. Additionally, we distribute some mobile products and services through other Web sites, WAP sites and point of purchase arrangements. We provide general information about the company, our products and services and communications regarding press releases, employment opportunities, and other company news through this Web site. Please note that this policy only applies to our data collection and use practices for the Twistbox Sites and does not apply to the data collection and use practices of other companies or organizations whose products, services, Web sites, WAP sites you may use or gain access through the Twistbox Sites. For information on the data collection and use practices of those third parties, please refer to their respective policies and procedures.

Definitions

“Agent” shall mean a third party that processes PII solely on behalf of and under the instructions of Twistbox. “Internet Protocol” shall mean the method or protocol by which data is sent from one computer to another on the Internet. Each computer (known as a host) on the Internet has at least one IP address that uniquely identifies it from all other computers on the Internet. “Personal Identifiable Information” or “PII” shall mean any information or set of information that identifies or can be reasonably used to identify an individual. PII does not include information that is encoded or rendered anonym, or publicly available information that has not been combined with non-public personal information. “Uniform Resource Locator” or “URL” shall mean the unique address for a file that is accessible on the Internet. “User” shall mean a customer of Twistbox and/or our partners who resides who provides information under this Privacy Policy.

General Policy

Twistbox collects PII in order to create or enhance our relationship with you. When we collect PII from you it is because you are voluntarily submitting the information to us in order to participate in certain activities including (i) registration for certain services and tools such as downloads or chat rooms; (ii) registration for special communication such as SMS, MMS, emails updates and newsletter; (iii) subscription registration; (iv) purchase products or services from or through the Twistbox Sites; (v) surveys; (vi) participation to events, sweepstakes, contest, promotions; and (vii) registration for online multiple or single player gaming. We may obtain PII from reputable third parties. We may also receive on the Twistbox Sites user-generated content or information of any type or medium, which may include PII, including but not limited to audio conversation, text chat and video images from chat rooms, user reviews, and game guide submissions. Please keep in mind that whenever you voluntarily disclose PII in public areas of Twistbox Sites, such as message boards, your information can be viewed and possibly used by others. We advise you to be especially careful in such public areas about disclosing PII, such as full name, address or phone number.

Types of Information We Collect and Use

1.Anonymous Information. We collect anonymous (i.e. non-personally identifying) information that your browser and mobile phone make available each time you visit a Twistbox Site. The browser information includes your originating Internet Protocol (IP) address, browser type and operating system, the date and time of your visit, the duration and activity of your visit and the URL of the referring and exiting Web sites. We generally use log files to collect and store this anonymous information. The cell phone information we collect includes type of handset, menu selection and other anonymous information. Additionally, for our mobile gaming tournaments, we collect anonymous demographic data including age, sex, type, and number of repeat subscriptions. We use this information for a variety of purposes, including but not limited the administration and operation of the Twistbox Sites, designing and developing new products and services and generally improving the overall quality of your experience. 2.Personal Information. In addition to the anonymous information, we occasionally request from you or you may voluntarily provide to us information that may identify you personally. Twistbox receives PII through its different partners and a broad range of activities, including, but not limited to surveys, contests, personalization of services, public record services, user groups, referral services, mobile data transmission and general correspondence. We may also receive PII from third party service providers as part of our mobile products and services. Depending on the product or service used, the PII we collect typically includes contact information (name, address, email address, telephone number), demographic information (such as age, gender, occupation) and billing information (shipping and billing address, credit card information). When we request PII from you, we will inform you of the type of information we need and the purpose of our use. Except as specifically described in this Privacy Policy and the associated privacy policies of our various Twistbox Site, we will generally only use your PII for the purpose it was collected. 3.Mobile Information. As part of our mobile products and services, we receive personal information from wireless carriers and operators in order to provision the specific content and data services requested by a User. All such PII is acquired from either the wireless carrier, the User’s cell phone, or directly from the User. This PII is usually limited to the User’s name and cell phone number. In certain cases, such as for gaming tournament prize fulfillment, the User’s mailing address is also provided. The User must explicitly “opt in” thorough the wireless carrier in order for any of this information to be collected and its use is governed by this Privacy Policy and any policies or procedures of the wireless carrier. We only use PII we receive as part of our mobile products and services for the purpose of providing those products and services to the User.

How We Use Your Personal Information

In general, we only use your PII for the purpose it was collected, including internally to serve you the products and services you requested, to enhance and extend our personal relationship with you and to improve our products and services. We may also use your PII for fulfillment and billing purposes, to complete transactions you have requested, to anticipate and resolve problems with our products and services, to respond to customer support inquiries, to create and inform you of new products and services, and to comply with applicable laws. We use information collected from cookies and web beacons to track which pages our Users view, which browsers they use and other information about User activity when visiting the Twistbox Sites. We may also use cookies to help us provide you with personalized features and preferences in a manner that is linked to personal information you may elect to share with us. We use action tags to compile statistics and other data about our Users on an aggregate basis.

Inter-Company Transfer

We may internally transfer the information we collect, including PII, to and from the United States and other countries in which we or our agents maintain facilities fro the purposes identified above, as well as storage, processing or other permitted business use. By accessing or using a Twistbox Site, you consent to the transfer of your PII among these facilities, including those located outside of your country of residence.

Sharing Information With Third Parties

We will not sell, rent or otherwise trade your personal information with third parties for compensation. However, we may disclose and share your personal information with third parties under the following circumstances: consent: we have received your expressed consent; third party licensors: we occasionally share our data with our licensors for the purpose to enhance Users’ experience and improve the products and services requested by Users; transaction processing: as necessary to complete a requested transaction, such as verification of your credit card information; third party service providers: occasionally, we engage third parties to provide us with products and services, such as support, consulting, statistical analysis and marketing research that may require access to or use of your personal information. In such event, the third party will be obligated to maintain the privacy of any personal information disclosed or shared and only use such information for the limited purpose of providing us with the product or service; business transfers: information about our Users and the Twistbox Sites is one of our most important business assets. As such, information about our Users, including personal information, may be disclosed and transferred as a part of any merger or acquisition, sale or pledge of Twistbox’s assets, as well as in the event of insolvency, bankruptcy or receivership in which personal information could be transferred as one of the business assets; protection of Twistbox and compliance with applicable legislations: we will disclose personal information or remove, destroy or alter personal information in our possession or control when we believe it is necessary to comply with legal process, respond to claims, or to protect the rights, property or safety of Twistbox, its employees, customers, Agents, or the public. Twistbox will only transfer personal information to an Agent where the Agent has provided assurances that the Agent provides at least the same level of privacy protection as is required by this Privacy Policy. Where we have knowledge that an Agent is using or sharing personal information in a way that is contrary to these principles, Twistbox shall take immediate steps to prevent or stop such processing.

Information Storage and Security

We have implemented and use a variety of industry accepted physical, electronic and managerial policies and procedures to safeguard and secure the information we collect to help prevent unauthorized access, disclosure, alteration or destruction of the information and to maintain its accuracy and correct use. We generally store the information and data we collect on our own servers in a secure environment and restrict access to your personal information to employees and Agents who need to know that information in order to provide you with access and use of the Twistbox Sites and as otherwise set forth and in accordance with this Privacy Policy. While we have taken all reasonable efforts to safeguard and secure your personal information, we cannot guarantee that your information may not be disclosed, altered, or destroyed by accidental circumstances or by unauthorized acts of others.

Third Party Information Collection and Use

The Twistbox Sites may use and provide Users access to products, services and content from third party (collectively the “Third Party Properties”), such as third party search results, directory listings, links and advertisements. Please be aware that we do not control and are not responsible for the information collection and use practices and policies of these third parties, and that by accessing or using Third Party Properties they may collect information regarding your use and access. We encourage you to be aware when you use Third Party Properties or leave the Twistbox Sites and review any third party’s policies regarding data collection and use.

Choice

Typically you will have the choice of whether or not to provide us with personal information. However, you may not be able to access or use some features of the Twistbox Sites or download some products and services if you chose not to provide us with the information required for those products and services. You may decide to “opt-out” at any time to any Twistbox Sites, products and services to which you subscribes by notifying us.

Access

Upon request, we will provide to a User a copy of all the information we have about him/her. Users can correct inaccurate information we have by contact us at the address, number or email hereunder.

Safe Harbor Statement

Twistbox complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Twistbox has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Twistbox’s certification, please visit http://www.export.gov/safeharbor/
1.Mobile Services. In general, we receive PII through our EU partners. In such capacity, we do not personally collect the PII directly from the Users and do not own the PII. Our EU partners transfer the PII and we merely process it on their behalf, pursuant to their directives. We may also directly collect PII from Users for the provision of products and services such as age verification, subscription/registration, and customer support. In such capacity, we collect the PII for specific purposes. We inform the User about the purposes for which we collect and use the PII. We do not use the PII for any other purposes without the express consent of the Users. 2.Safe Harbor Verification. Twistbox verifies that this Privacy Policy is accurate, comprehensive, and completely implemented, including implementation of appropriate employee training and other internal procedures. Twistbox further verifies that its Privacy Policy conforms to the Safe Harbor Principles issued by the US Department of Commerce on July 21, 2000, which concerns compliance with European Union privacy protection requirements by U.S. organizations.

Enforcement

Twistbox has put in place mechanisms to verify our ongoing adherence to these privacy principles. We encourage any individuals covered by this Privacy Policy to raise any concerns that they have about the way we process their PII by contacting us at the address below, and we will take reasonable steps to resolve them. We also agree to participate to the dispute resolution program of the European Data Protection Authorities Panel.

Changes to the Privacy Policy

We may change, amend and update this Privacy Policy and the privacy policies of the various Twistbox Sites from time to time to reflect changes in our privacy practices, technology, products and services, general business operations and the industry. In the event of such change, we will post a revised policy on this Web sites and/or the Twistbox Site(s) of the respective products or services. We will revise the “last updated” date of such policy. We reserve the right to change, amend and update this Privacy Policy, including all our associated privacy policies, at any time in our sole and absolute discretion, and such changes will be effective upon posting of the revised policy. In the event of a material change in our information collection and use practices, we will provide more prominent notice of such change along with the revision effective date of the policy. You should check the Privacy Policy and the policies of the Twistbox Sites you may access and use on a regular basis to ensure you have reviewed and are familiar with the most current policy.

This Privacy Policy was last updated on 07/05/2007

Contact Us

Please contact us with any issues regarding this Privacy Policy:

Twistbox Entertainment, Inc.
14011 Ventura Boulevard, Suite 210E
Sherman Oaks, CA 91423
USA
Tel: +1 818-301-6200