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Privacy Policy

We care about confidentiality and privacy of information entrusted to. We comply with applicable data protection regulations including in particular the Swiss Federal Act on Data Protection (FADP) and where applicable the EU’s General Data Protection Regulation (GDPR). Please read this Privacy Policy to learn about your rights, what information we collect, how we use and protect it. This website is operated by Twelwe Holdings OÜ (“Twelwe/ ” we” or “us”), a private Estonian company. 

1. How we collect personal data

  • Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to our newsletters and preference centre, register for webinars, attend meetings or events we host.We may also obtain personal data directly when, for example, establishing a business relationship, performing professional services through a contract or request of providing services.

  • Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including marketing agencies,  recruitment services and our clients.

2. What information we collect

We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Policy.

  • Personal data. 

    • Contact details (e.g., name and surname, company name, job title, work and mobile telephone numbers, work and personal email and work and personal postal address)

    • Professional details (e.g., job and career history, educational background and professional memberships, published articles, pitch decks, business cases).

  • Location-based data. We may process geographical locations, e.g. when you are using our website to locate an office near you.

  • Information we collect automatically when you use the Services

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

  • Profile Information
    In order to ensure a smooth and enjoyable experience when using our services, we collect information about you concerning your profile preferences including your language preferences, notification and marketing preferences. These can be stored in the form of cookies, little files that are kept on your browser and which then tell us your preferences the next time you visit our website or use our Services. Some cookies are optional, others not, and are explained in further detail in our Cookies Policy below.


3. What lawful reasons we have for processing personal data

We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:

  • Contract – We may process personal data in order to perform our contractual obligations.

  • Consent – We may rely on your freely given consent at the time you provided your personal data to us.

  • Legitimate interests – We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include: 

    • Delivering services and products – To deliver the services and products our clients have engaged us to provide.

    • Marketing – To deliver timely industry insights and professional knowledge, offerings and invitations we believe are welcomed by our business clients, prospects, subscribers and other individuals.

  • Legal obligations and public interest – We may process personal data in order to meet regulatory and public interest obligations or mandates.

4. Why we need personal data

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:

  • Providing professional advice and delivering reports and services related to our professional services and products.

  • Promoting our professional services, products and capabilities to existing and prospective business clients.

  • Sending invitations and providing access to guests attending our events and webinars.

  • Personalising online landing pages and communications we think would be of interest based on interactions with us.

  • Processing online requests, including responding to communications from individuals or requests for proposals and quotations. 

5. How we share information we collect

We do not share or sell your personal and business information.

We may share personal data and business information (including e.g. pitch decks) only with trusted third parties (recipients) and only to help us deliver you efficient and quality services and products you contracted. This means that we do not share personally identifiable information with other parties without your consent.

These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:

  • Member firms of the Twelwe network, where necessary for administrative purposes and to provide professional services to our clients.

  • Parties that support us as we provide our services and products (e.g. providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services, scanning services).

  • Our professional advisers, including but not limited to lawyers, auditors and insurers.

  • Potential investors and their advisers based on the service you contracted.

  • Payment services providers.

  • Marketing services providers.

  • Law enforcement or other government and regulatory agencies.

6. How we store and secure information

We store information on Wix data hosting, by using AWS Cloud and with data centers in US, Ireland and Israel Some information and data will also be stored in Switzerland. Your information is securely stored behind levels of encryption and security through means of using verified methods including access limitation, industry-standard Transport Layer Security (TLS) encryption technology to safeguard sensitive information, data encryption, and firewalls. While the security of your information is of utmost importance to us, please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.

7. How we use cookies

In some instances, we and our service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of Twelwe's online presence, and to measure the effectiveness of our marketing activities. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our Cookie Policy below.

8. Your data protection rights

If Twelwe processes personal information about you, you have the rights listed below. Before responding to your request, we may ask for proof of identity. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. We may also ask you for sufficient information about your interactions with us so that we can locate your personal information.

  • Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.

  • Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you. 

  • Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected and no retention requirements exist

  • Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it.

  • Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data in electronic form if technically feasible.

  • Right to Object to Marketing including Profiling – You can object to our use of your personal data for marketing purposes, including profiling.

  • Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes of processing your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.

If you have questions or comments about this Privacy Policy, how we handle personal data or to submit a data request please direct your correspondence to:


9. How long we retain personal data

We retain personal data to provide our services, make offerings, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. We retain personal data for so long as the personal data is needed for the purposes for which it was collected or in line with legal and regulatory requirements or contractual arrangements. We will dispose of personal data when we no longer need it.

10. Changes to this Privacy Policy

We regularly review this Privacy Policy and will post any updates to it on this webpage. This Privacy Policy was last updated on 13 of June 2022.


Cookie Policy


1. Automatic collection of personal information

In some instances, Twelwe and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of Twelwe's online presence, and to measure the effectiveness of our marketing activities.


1.1 IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

1.2 Cookies

Cookies exist at various levels, and serve a variety of purposes. Some of the cookies we use are at system level. These maintain a session user ID for security reasons. We process and store data collected via our website only for the purpose for which it was provided by clients or potential clients. Clients' or potential Client’s data, for example, is used only for contacting and responding to their requests. The following types of cookies may be used when you visit the website:


Advertising Cookies

Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you. 


Analytics Cookies

Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved. 


Our Cookies

Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won't work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.


Personalization Cookies

Personalization cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site. 

Security Cookies

Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.


Site Management Cookies

Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.


Third-Party Cookies

Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser. 

Some cookies are classed as essential in that they are needed to allow you to navigate the website, access the most relevant version (e.g. mobile) and let you use some of the features we provide, such as polls and surveys. We also use visitor or performance cookies to understand what interests our users, help us improve how our website works, and measure how effective our website is. For example, these cookies track how many users access our site and how often, show how you entered our site, navigated through the site, and what information was of interest to you, and measure any errors you may have encountered. They also identify categories of visitors by items such as IP address, domain, and browser type pages visited. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Controlling or disabling cookies


If you are not comfortable with our use of cookies, you can control and manage your cookie settings in various ways. Most browsers give you the option to see what cookies you have, and allow you to accept or reject all, or certain, cookies. This is usually set through your privacy settings. Please bear in mind that if you remove or block cookies, it might affect how you use our site, and make parts of it less accessible or usable.

1.3 Google Analytics


We track the usage of our website through Google Analytics. You can opt-out of having your browsing activity within websites recorded by analytics cookies without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics visit this  Google page. If you would like more detailed information, please contact us using the contact details on our website.

1.4 Changes to this Cookie policy

We regularly review this Cookie Policy and will post any updates to it on this webpage. This Cookie Policy was last updated on 13 June 2022.

Cookie Policy
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