Privacy Policy

About this Policy

This Policy describes how we process your personal data at MartianSpiderMedia.

It applies to your use of:

all Twisp streaming services as a user. This includes use of these services under our free or paid options (each a "Service Option"); and
other Twisp services which include a link to this Privacy Policy (e.g. Twisp websites).

From now on, we'll collectively call these the "Twisp Service".

From time to time, we may develop new or offer additional services. They'll also be subject to this Policy unless stated otherwise when we introduce them.

This Policy is not...

the Twisp Terms of Use. That's a separate document, outlining the legal contract between you and Twisp for using the Twisp Service. It also describes the rules of Twisp and your user rights.

Personal Data Rights and Controls

Privacy laws, including the General Data Protection Regulation ("GDPR"), give rights to individuals over their personal data.

It’s your right to:

Be informed of the personal data we process about you and to request access to it.

Request that we amend or update your personal data where it’s inaccurate or incomplete.

Request that we delete certain of your personal data.

Request that we temporarily or permanently stop processing all or some of your personal data.

Object to us processing your personal data at any time, on grounds relating to your particular situation.

Object to your personal data being processed for direct marketing purposes.

Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.

Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect

To request a copy of your personal data from Twisp, contact us via email at admin@martianspidermedia.com.

Erasure:

You can remove audio content from your profile by selecting the relevant content and choosing to remove it.
To request the erasure of your other personal data from Twisp (e.g. your User Data, Usage Data, and other data you may contact us directly via email, admin@martianspidermedia.com.

Your other rights: You can contact Twisp directly to exercise your rights at any time.

Personal Data we Collect

We collect personal data to create your Twisp account and enable you to use the Twisp Service.

The type of data collected depends on the type of Service Option you have, how you create your account, the country you are in, and if you use third party services to sign in. This may include your:

profile name
email address
phone number
date of birth
gender
street address
country

We receive some of this data from you e.g. from the sign up form or account page.

We also collect some of this data from your device e.g. country. We may ask for your street address for the following reasons:

to check eligibility for a Service Option
for tax administration
to deliver physical goods or gifts requested by you

In some cases, we may use a third party mapping application (such as Google Maps) to help you verify your address.

Other data we collect relates to information about how you use Blip.
Examples include:

Information about your Twisp Service Option.
Your actions with the Twisp Service (including date and time), such as:
- search queries
- listening history
- playlists you create
- your library
- browsing history
- account settings
- interactions with other Twisp users
- your use of third party services, devices and applications in connection with the Twisp Service
Inferences (i.e., our understanding) of your interests and preferences based on your usage of the Twisp Service.
Content you post to any part of the Twisp Service, such as images, text, communications, and other types of content.

Other technical data we collect includes, but is not limited to:

URL information
Online identifiers such as cookies and IP addresses
Information about the devices you use such as:
- device IDs
- network connection type (e.g. wifi, 4G, LTE, Bluetooth)
- provider
- network and device performance
- browser type
- language
- information enabling digital rights management
- operating system
- Twisp application version
Information (such as the device name, device identifiers, brand and version) which enables us to discover and connect with third party devices and applications such as those listed below:
- devices on your wifi network (such as speakers) which can connect to the Twisp Service
- devices made available by your operating system when connecting via Bluetooth, plugin, and installation
- Blip partner applications to determine whether the application is installed on your device

We may collect your general (non-precise) location. This may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency). We need this to meet geographic requirements in our agreements with the owners of content on the Twisp Service, and to deliver content and advertising that’s relevant to you.

Additional data you may choose to give us includes:

Voice Data
If voice features are available in your market and only where you’ve given permission, we collect voice data (audio clips of your voice). This makes it possible for us to provide and improve Twisp's voice features.

If you make any purchases from Twisp (including a paid Service Option) or sign up for a trial, we will need to process your payment data. The exact personal data collected will vary depending on the payment method, but will include information such as:

name
date of birth
credit or debit card type, expiration date, and certain digits of your card number (Note: For security, we never store your full card number)
ZIP/postal code
mobile phone number
details of your purchase and payment history

When you complete any forms, respond to a survey or questionnaire, or take part in a contest or sweepstake, we collect the personal data you provide.

If you register for or log into our services using another service, we’ll receive your information from them to help create your account with us.

If you connect your Twisp account to a third party application, service and/or devices, we may collect certain information from them to make the integration possible.

These third party apps, services or devices may include:

social media
devices including:
- audio (e.g. speakers and headphones)
- smart watches
- televisions
- mobile phones and tablets
- automotive (e.g. cars)
- games consoles
services or platforms such as voice assistants

We’ll ask your permission before we collect your information from certain third parties.

We may work with technical service partners that give us certain data, such as mapping IP addresses to non-precise location data (e.g., city, state). This makes it possible for Twisp to provide the Twisp Service, content, and features.

If you choose to pay Twisp by invoice, we may get data from our payment partners.
This allows us to:

send you invoices
process your payment
give you what you’ve purchased

We may get data about you from certain advertising or marketing partners.

This may include:

cookie id
mobile device id
email address
inferences (i.e., our understanding) of your interests and preferences

This allows us to deliver more relevant ads and marketing.

Our Purpose For Using Your Data

This sections sets out:

our purpose for processing your personal data
our legal justifications (each called a "legal basis") under data protection law, for each purpose
categories of personal data which we use for each purpose

Here is a general explanation of each "legal basis" to help you understand the table:

Performance of a Contract: When it's necessary for Twisp (or a third party) to process your personal data to:
- comply with obligations under a contract with you, e.g. Blip's obligations under the Terms of Use to provide the Twisp Service to you
- or verify information before a new contract with you begins.
Legitimate Interest: When Twisp (or a third party) has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Twisp users. For example, using your Usage Data to improve the Twisp Service for all users. Contact us if you want to understand a specific justification.
Consent: When Twisp asks you to actively indicate your agreement to Twisp's use of your personal data for a certain purpose(s).
Compliance with Legal Obligations: When Twisp must process your personal data to comply with a law.

Categories of personal data used:

To provide the personalized Twisp Service.

Performance of a Contract
Legitimate Interest
Consent

User Data
Usage Data
Payment and Purchase Data
Street Address Data
Voice Data

To understand, diagnose, troubleshoot, and fix issues with the Twisp Service.

Performance of a Contract
Legitimate Interest

User Data
Usage Data

To evaluate and develop new features, technologies, and improvements to the Twisp Service.

Legitimate Interest
Consent

User Data
Usage Data
Voice Data

For marketing, promotion, and advertising purposes.

Legitimate Interest
Consent

User Data
Usage Data
Contests, Surveys and Sweepstakes Data

To comply with legal obligations and law enforcement requests.

Compliance with legal obligations
Legitimate interest

User Data
Usage Data
Payment and Purchase Data
Street Address Data
Voice Data
Contests, Surveys and Sweepstakes Data
Fulfill contractual obligations with third parties, for example our agreements with owners of content on the Twisp Service, and
Take appropriate action with reports of intellectual property infringement and inappropriate content.
Legitimate interest
User Data
Usage Data
Payment and Purchase Data

To establish, exercise, or defend legal claims.

Legitimate interest

User Data
Usage Data
Payment and Purchase Data
Street Address Data
Contests, Surveys and Sweepstakes Data

To conduct business planning, reporting, and forecasting.

Legitimate Interest

User Data
Usage Data
Payment and Purchase Data

To process your payment.

Performance of a Contract
Compliance with legal obligations
User Data
Payment and Purchase Data

To detect and prevent fraud, including fraudulent payments and fraudulent use of the Blip Service.

Performance of a Contract
Compliance with legal obligations
Legitimate Interest

User Data
Usage Data
Payment and Purchase Data
Street Address Data

To conduct research, contests, surveys, and sweepstakes.

Performance of a Contract
Legitimate Interest
Consent
User Data
Usage Data
Contests, Surveys and Sweepstakes Data

In jurisdictions where legitimate interest is not recognized as a legal basis, we rely on contractual necessity or consent.

Sharing Your Personal Data

This section sets out the categories of recipients of the personal data collected or generated through your use of the Twisp Service.

The following personal data will always be publicly available on the Twisp Service:

Your profile name
Your profile photo
Your public bios (including publisher, narrator, and illustrator bios)
Your public pseudonyms
Your profile details such as narrator accents, voice type, and illustrator styles

We will only share the following personal data:

where sharing of particular personal data is needed for the use of a Twisp Service feature, or a third party application, service or device, which you have chosen to use; or
if you otherwise grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Twisp Service or by giving your consent

We may share your data to connect your Twisp account, and/or allow you to use the Twisp Service in connection with third party applications, services or devices. Examples of such third party applications, services and devices include: social media applications, speaker devices, televisions, automotive platforms, or voice assistants, which interact with the Twisp Service.

We may share your data to receive news or promotional offers directly from other partners.
You may choose to share personal data (for example, your email address) for this purpose. You’ll always have the option to change your mind and withdraw your consent at any time.

We may share your information with other parties. These service providers may include those we hire to:

give customer support
operate the technical infrastructure we need to provide the Twisp Service
assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)
help market Twisp's (and our partners’) services, events and promotions

We may share your information with payment processors so they can process your payments, and for anti-fraud purposes.

We may share your information with advertising partners so our ad partners can help us deliver more relevant advertising to you on the Twisp Service.

For example, our ad partners help us facilitate tailored advertising:

This is when we use third party information to tailor ads to be more relevant to you (also known as interest based advertising).
An example of a tailored ad is when an ad partner has information suggesting you like cars, which could enable us to show you ads about cars.

We share some personal data with these partners where necessary to:

enable you to participate in Blip promotions, including trials or other bundled offers
to promote Blip in media and advertising published on other online services
help us and our partners to measure the effectiveness of Twisp promotions

Examples of partners include:

marketing or sponsorship partners
websites and mobile apps who sell us advertising space on their services
device, app and mobile partners who also offer Twisp promotions

Our partners may also combine the personal data we share with them with other data they collect about you (e.g. your use of their services). We and our partners may use this information to present you with offers, promotions, or other marketing activities that we believe will be relevant to you.

We may share personal data with partners to help us understand and improve the performance of our products and partnerships.

We may share your information with academic researchers for activities such as statistical analysis and academic study, but only in a pseudonymised format. Pseudonymised data is where your data is identified by a code rather than your name or other information that directly identifies you.

We may share your information with law enforcement and other authorities when we believe in good faith it’s necessary for us to do so, for example:

to comply with a legal obligation
to respond to a valid legal process (such as a search warrant, court order, or subpoena)
for our own or a third party’s justifiable interest, relating to:
- national security
- law enforcement
- litigation (a court case)
- criminal investigation
- protecting someone’s safety
- preventing death or imminent bodily harm.

We may provide your information to purchasers of our business where we sell or negotiate to sell our business to a buyer or possible buyer. In this situation, Twisp will continue to ensure your personal data is kept confidential. We’ll give you notice before your personal data is transferred to the buyer or a different privacy policy starts to apply.

Data Retention and Deletion

We keep your personal data only as long as necessary to provide you with the Twisp Service and for Twisp's legitimate and essential business purposes, such as:

maintaining the performance of the Twisp Service
making data-driven business decisions about new features and offerings
complying with our legal obligations
resolving disputes

If you close or request that we close your account, we'll delete or anonymize your personal data so it no longer identifies you, unless we're required to keep something or we still need to use it for a legally justifiable reason.

Here are some examples of situations where we're legally allowed or required to keep some of your personal data:

if there's an unresolved issue relating to your account, such as an outstanding credit or unresolved claim or dispute
for our legal, tax, audit and accounting obligations
for our legitimate business interests such as fraud prevention or to maintain security.

Transfer to Other Countries

When carrying out the activities described in this Policy, Odyssey shares your personal data internationally with, subcontractors and partners in order to provide the Odyssey Service to you. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or those in your country, e.g. they may not give you the same rights over your data.

Whenever we transfer personal data internationally, we use tools to:

make sure the data transfer complies with applicable law
help to give your data the same level of protection as it has in the EU

You may contact us or the third party who processes your personal data to handle disputes.

Keeping Your Personal Data Safe

We're committed to protecting our users' personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

We have implemented various safeguards including pseudonymization, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

To protect your user account, we encourage you to:

use a strong password that is unique to your Odyssey account
never share your password with anyone
limit access to your computer and browser
log out once you have finished using the Odyssey Service on a shared device

If other individuals have access to your Odyssey account (for example if you've given them permission to use your account on a shared device), then they can access personal data, controls and the Odyssey Service available in your account.

It's your responsibility to only provide individuals with permission to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your Odyssey account may impact your personalised recommendations and be included in your data download.

Children

The Twisp Service has a minimum "Age Limit" in each country. The Twisp Service is not directed to children whose age:

is under the age of 13 years
or, makes it illegal to process their personal data
or, requires parental consent to process their personal data

We do not knowingly collect personal data from children under the applicable Age Limit. If you're under the Age Limit, please do not use the Twisp Service, and do not provide any personal data to us.

If you're a parent of a child under the Age Limit and become aware that your child has provided personal data to Twisp, please contact us.

If we learn that we've collected the personal data of a child under the applicable Age Limit, we'll take reasonable steps to delete the personal data. This may require us to delete the Twisp account for that child.

When using a shared device on the main Twisp Service, you should be cautious about playing or recommending any content to individuals under 18 years old which could be inappropriate for them.

Changes to this Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Twisp Service or send you an email or device notification.

How to Contact Us

For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:

Use our website contact form
Email admin@martianspidermedia.com

MartianSpiderMedia is the data controller of personal data processed under this Policy.