Privacy policy

This Policy applies as between you, the User of this Web Site and Twinxter Academy the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.

Article 1. General

In this privacy statement Twinxter and Twinxter Academy, hereinafter "Twinxter", provide information about the processing of personal data. You may contact Twinxter. For contact details, refer to article 12.1. This privacy statement applies to the visitors of the website of Twinxter, the users of the online services of Twinxter, the clients of Twinxter and all persons of whom Twinxter processes and uses personal data with the exception of the persons employed by Twinxter. This privacy statement applies in addition to any data processing agreements Twinxter concluded with its clients.

Article 2. Definitions

  • 2.1 This privacy policy uses the following definitions:
A. account:
B. agreement: the agreement between Twinxter and the data subject based on which the data subject makes use of the service offered by Twinxter;
C. data subject: the natural person who (on behalf of a company) has concluded an agreement with Twinxter, or the natural person who (on behalf of a company) has contacted Twinxter in relation to the conclusion and/or implementation of the agreement, or the natural person who (on behalf of a company) visits the website;
D. personal data: data that can be used to identify a natural person.
E. profiling: the processing of personal data during which certain personal aspects of the data subject are assessed in order to analyse or predict his personal preferences, interests, online search behaviour, or location;
F. Service: collectively any online facilities, tools, services or information that Twinxter makes available through the website either now or in the future;
G. System: online communications infrastructure that Twinxter makes available through the website either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
H. Twinxter: the user of this privacy policy: trading as Twinxter and Twinxter Academy.
     - Twinxter is located in The Netherlands and registered at the Dutch Chamber of Commerce with CoC number 82248524;
     - Twinxter Academy is located in The Netherlands and registered at the Dutch Chamber of Commerce with CoC number 82248524;
I. website: the www.twinxter.com and academy.twinxter.com websites, managed by Twinxter.

Article 3. Personal data

  • 3.1 Twinxter considers the careful handling of personal data very important. Twinxter acts in accordance with applicable laws and regulations when it processes personal data.
  • 3.2 Twinxter handles personal data with care and treats them confidentially.
  • 3.3 Twinxter collects personal data about the data subject when the data subject has provided these personal data to Twinxter (through the website) or when the data subject visits the website or has contacted Twinxter by email.
  • 3.4 Any personal data submitted by the data subject will be retained by Twinxter for as long as the data subject uses the Services and Systems provided on the website. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to one year.
  • 3.5 Twinxter collects and processes (depending on the use and need, such as requesting a quotation through the website, analytics, or the conclusion of an agreement) the following personal data:
A. first and last name;
B. address;
C. zipcode and city;
D. job title and profession;
E. telephone number;
F.  email address;
G. financial information such as credit / debit card numbers and bank account
H. IP address;
I.   operating system;
J.  web browser type and version;
K. browsing behaviour;
L. location details;
M. a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected);
N. Cookie information. Also refer to article 16 in this respect.

  • 3.6 Twinxter does not process any special personal data of data subjects.
  • 3.7 Personal data will not be transferred outside the EEU.
  • 3.8 The website and/or service does not aim to collect data about website visitors who are below the age of 16, unless a parent or guardian has given permission for this. However, Twinxter cannot verify whether a visitor is over the age of 16. Twinxter recommends parents to be involved in the online activities of their children in order to avoid the collection of data about children without parental consent. If the data subject is convinced that Twinxter has collected personal data about a minor without this permission, the data subject must contact Twinxter using the contact details provided in Article 12.1 to enable Twinxter to end the processing and remove the personal data.

Article 4. Grounds for and purposes of the processing

  • 4.1 The ground for the processing of personal data is the implementation of the agreement or the pre-contractual measures taken at the request of the data subject. Profiling will take place with the permission of the data subject. 
  • 4.2  Twinxter collects and processes personal data for the following purposes:
A. handling questions and/or comments from the data subject;
B. issuing a quotation and/or offer to the data subject;
C. concluding an agreement;
D. contacting the data subject in relation to the performance of the agreement;
E. maintaining a customer relationship with the data subject;
F.  expanding and updating a customer portfolio;
G. sending an invoice;
H. complying with administrative obligations;
I.  to offer personalised advertisements and content to the data subject (profiling). Also refer to Article 5 in this respect;
J. sending the data subject a newsletter. Also refer to Article 6 in this respect;
K. improving the website and services of Twinxter;
L. to generate statistics on the use of the website and/or online services of Twinxter and/or to analyse and/or improve the website and/or online services of Twinxter;
M. deliver online services;
N. sending the data subject mailings or other relevant information or invitations for events;
O. informing data subjects about products and services of Twinxter;
P.  informing data subjects about new developments and to share knowledge.

  • 4.3 The data subject has the contractual obligation to provide his name, address, telephone number, and email address. No agreement can be concluded without the name, address, telephone number, and email address.
  • 4.4 Twinxter will not keep the personal data longer than strictly necessary to fulfil the purposes for which the personal data are processed as described in Article 4.2.
  • 4.5 Twinxter only processes personal data that are absolutely required for the existing purposes. Twinxter strives for as little processing of data as possible.
  • 4.6 Twinxter will not process personal data for any other purposes than those described above.

Article 5. Profiling

  • 5.1 Profiling will only take place if the data subject has given Twinxter permission for this. This permission can be revoked by the data subject at any time. 
  • 5.2 Profiling has the following purpose:
A. showing advertisements or other content to the data subject on the website of which Twinxter suspects that these match the interests of the data subject;
B. marketing analyses;
C. sending a personalised newsletter. 
  • 5.3 Profiling can be done using a combination of the data provided by the data subject when creating an account and using data derived from various cookies.
  • 5.4 Twinxter can process the following data for profiling purposes:
A. sex;
B. age;
C. location details;
D. queries entered on the website;
E. browsing behaviour.

Article 6. Newsletters

  • 6.1 Newsletters will be sent to data subjects. The data subject can always unsubscribe from newsletters. Refer to Article 6.2 in this respect.
  • 6.2 The data subject can unsubscribe from newsletters in the following ways:
A. by clicking the relevant link included in the newsletter;
B. by contacting Twinxter using the contact details in Article 12.1.
  • 6.3 Each newsletter sent to the data subject will include a link that can be used by the data subject to unsubscribe from the newsletters.

Article 7. Deletion of personal data

  • 7.1 Twinxter will delete personal data from its systems without any unreasonable delay, if (inter alia):
A. the personal data are no longer necessary for the purposes for which they were processed;
B. the data subject objects to the processing of his personal data and this objection is justified; 
C. the personal data are incorrect or outdated.
  • 7.2 Twinxter is not required to delete personal data in situations in which the “right to be forgotten” as described by law does not apply.7.1 Twinxter will delete personal data from its systems without any unreasonable delay, if (inter alia):

Article 8. Disclosing personal data to third parties

  • 8.1 Twinxter will not disclose the personal data of the data subject to third parties until:
A. Twinxter has received explicit prior permission for this from the data subject;
B. one of the legal grounds exists based on which the disclosure of personal data to a third party is permitted;
C. this is necessary to implement the agreement;
D. the disclosure occurs to a processor hired by Twinxter for the purposes listed in this privacy policy with whom Twinxter has concluded an agreement which ensures that the processor offers sufficient guarantees concerning the technical and organisational security measures in relation to the processing.
  • 8.2 The data subject can always revoke his permission for the disclosure of personal data to third parties.

Article 9. Right to access, transferability, rectification, and deletion

  • 9.1 Twinxter will grant the data subject access to all personal data concerning him in the possession of Twinxter. Twinxter will also provide the data subject with a copy of these personal data to enable him to provide these personal data to a third party at no cost.
  • 9.2 Twinxter will give the data subject the opportunity to correct or delete any incorrect data concerning him in the possession of Twinxter at no cost. 
  • 9.3 The request for access, changes, or removal of data can be submitted to Twinxter by email. Refer to Article 12.1 for the contact details of Twinxter. Twinxter will respond to such request as soon as possible, at the latest within 4 weeks.

Article 10. Objections

The data subject can file an objection with Twinxter concerning the processing of his personal data if he has a good reason to do so considering the specific situation. Once Twinxter has received the objection, it will stop processing the personal data of the data subject, unless Twinxter has a legitimate interest in processing the personal data of the data subject which outweighs the interest of the data subject.

Article 11. Right to limitation

If the data subject has submitted a request to modify, supplement, or delete his personal data, or an objection to the processing of his personal data, and the handling, processing, and implementation of this request of objection takes some time, the data subject can request Twinxter to limit the processing of his personal data.

Article 12. Contact

  • 12.1 The data subject can use the contact details listed below to contact Twinxter to ask questions about the way in which Twinxter processes personal data, to revoke his permission for the processing of his personal data, to request access to the personal data concerning him, to request a copy of his personal data, to request modification or deletion of his personal data, to request to limit the processing of his personal data, or to submit an objection against the processing of his personal data.  
    - Contact details Twinxter:
       E-mail: [email protected]
    - Contact details Twinxter Academy:
       E-mail: [email protected] 
  • 12.2 Twinxter will inform the data subject if it modifies, supplements, or removes his personal data, if it ends or limits the processing of his personal data, or if it has processed a revoked permission in response to a corresponding request.

Article 13. Security measures

Twinxter has applied suitable technical and organisational measures to protect personal data from loss or unlawful processing, e.g. encrypting personal data, the use of passwords, sending personal data via a secured connection and the use of physical security for locations and rooms where personal data are stored.

Article 14. Privacy policy of third parties

This privacy policy does not apply to third-party websites or applications, such as social media websites, connected to this website by means of links. Twinxter does not accept any liability or responsibility concerning the manner in which these websites handle personal data. For more information about the way in which these third parties treat personal data and the like, make sure to consult the privacy policy of the website or application in question.

Article 15. Data breach

  • 15.1 If a security incident has occurred at Twinxter which affected personal data of a sensitive nature, or which had a serious adverse impact on the protection of the processed personal data for any other reason, Twinxter will inform the Dutch Data Protection Authority within 72 hours of discovering the data breach, and act in accordance with the data breach notification duty policy rules of this authority.
  • 15.2 Twinxter will immediately inform an affected data subject in case of a data breach at Twinxter with adverse consequences for his privacy.

Article 16. Cookies

  • 16.1 The websites and the online services of Twinxter use functional and analytical cookies. Cookies are small (text)files that are stored on your computer, tablet or smartphone when using a website.
  • 16.2 The functional cookies are used to facilitate easy use and experience of the website and online services of Twinxter and to adapt the use to personal preferences. The analytical cookies are used to keep track with statistics of the use of the website and the online services of Twinxter. Twinxter uses Google Analytics van Google, Inc. to this end. Twinxter has installed Google Analytics cookies in a ‘privacy friendly’ mode, in line with the user manual of the Dutch Data Protection Authority (‘Autoriteit Persoonsgegevens’). This implies that the data collected by using Google Analytics are made anonymous as much as possible and that Google will never process the full IP, always masking the last octet of the IP-address.  Google will not use the collected data for its own purposes as Twinxter has not granted its permission to do so. Twinxter does not use other Google-services in combination with the Google Analytics-cookies. The collected data are stored by Google on servers in the USA. Twinxter has concluded a processing agreement with Google, Inc. For more information: read the privacy policy of Google Analytics. If you do not want to accept Google Analytics cookies please click here. You can also switch off cookies in the settings of your browser and refuse all or only specific cookies. Please take into account that when you do not accept specific cookies, you might not be able to use specific functionalities of the website and/or the online services and this can limit the user friendliness of the website and/or the online services.
  • 16.3 Twinxter can change its cookie policy at any time, for example, in response to a change in legislation. Amendments or additions to the cookie policy of Twinxter will be published here. Twinxter recommends the visitor to check this policy regularly. 

Article 17. Submitting a complaint

If the data subject believes that the personal data processed by The Maritime Marketeer do not comply with this privacy policy and/or applicable laws and regulations, the data subject can submit a complaint to the Dutch Data Protection Authority.

Article 18. How Twinxter contacts you

  • 18.1 Sometimes Twinxter may contact you for various purposes. Despite the specific purpose, we will never ask you to send us personal data via email, text messages or a website. We will also not ask you to share login details with us.
  • 18.2  Should you doubt the authenticity of a message you received from us, please contact us via email: [email protected].
  • 18.3 We recommend you to manually type the hyperlink to a webpage that you receive via an email or another electronic communication source in address bar of your web browser.

Article 19. Changes of Business Ownership and Control

  • 19.1 Twinxter and/or Twinxter Academy may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Personal data provided by the data subject will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this policy, be permitted to use the personal data for the purposes for which it was supplied by the data subject.
  • 19.2 In the event that any personal data submitted by the data subject will be transferred in such a manner, the data subject will be contacted in advance and informed of the changes. When contacted the data subject will be given the choice to have his personal data deleted or withheld from the new owner or controller.

Article 20. Amendments

  • 20.1 Twinxter reserves the right to unilaterally make changes to this privacy policy. The latest version of the privacy policy of Twinxter can be found on the website. 
  • 20.2 The current privacy statement had been updated on 5 may 2022.