Privacy Policy

Effective Date: 1.09.2018

Twistellar ApS ("we" or "us") provides this policy to inform you of our personal data handling practices for personal data we collect from those who contact us by phone or email and visitors to our Website that link to this Privacy Policy ("Website").

This policy (together with our Terms of Use, Cookie Policy and any other documents referred to in it) sets out the basis on which any personal data, personally identifiable information, or personal data (“Personal Data”) we collect from you, or that you provide to us, through our Website that will be processed by us. This policy does not cover any personal data we collect offline or personal data we process on behalf of our clients while providing consulting, implementation, managed services or other professional services, where Twistellar acts as a data processor on behalf of its clients under applicable data protection laws.

Residents of the European Economic Area, the United Kingdom, or Switzerland, see our EEA+ Supplemental Data Protection Law Disclosures to this policy below.

Local laws may provide for various data subject rights that provide individuals with the right to request access to their personal data, correction of their personal data that is in the possession or under the control of Twistellar, and withdrawal of consent to process their personal data. This list is not exhaustive and may vary by local law and jurisdiction.

When you contact us or make an inquiry via our Website, your personal data will be collected and controlled by Twistellar ApS, a company incorporated under the laws of Denmark ("Twistellar"). Twistellar acts as the data controller for the personal data processed through this Website in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR"), where applicable. We may share your personal data with trusted service providers acting on our behalf where necessary for the purposes described in this Privacy Policy.

Information We Collect About You

We will collect and process the following data about you:

Information you give to us. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you request information about our Salesforce consulting, implementation, managed services, software products, or other professional services, and when you report a problem with our Website. 

The information you give us may include your name, company name, business email address, telephone number, job title, country, and any other information that you choose to provide. Providing such personal data is voluntary. However, without providing such personal data, we will not be able to provide you with information or certain services you request from us. You will know what personal data you provide because you will actively submit it to us.

Information we collect about you. In addition to the personal data that you actively provide, for us to monitor and maintain the performance of the Website and to analyze trends, usage and activities in connection with the Website, to measure the effectiveness of advertising we serve to you, and to deliver relevant advertising to you, the sites may automatically collect, process and store certain information from you, to the extent permitted and under the conditions set out under applicable law:

• technical information, including the domain and host name from which you access the Internet, the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone and country setting, browser plug-in types and versions, operating system and platform;
• information about your visit to our Website, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

More information about our use of cookies and similar technologies is available in our Cookie Policy.

Subject to your consent where required by applicable law, this information may be collected through cookies and similar technologies, including Google Analytics 4, Google Tag Manager, Hotjar, Cookiebot, LinkedIn Insight Tag, and Meta Pixel.

Information we receive from other sources. We are working closely with third parties (including, for example, technology partners, analytics providers, marketing service providers, CRM platforms, event platforms, and publicly available business sources) that may provide us with additional information about you.

If we are unable to collect this information, this may affect the provision of the services you have requested from us.

Cookies

To the extent permitted under applicable law, our Website uses cookies and similar technologies, including those provided by trusted third-party service providers, to enable website functionality, analytics, advertising, and consent management, distinguish you from other users of our Website, record and manage your cookie consent preferences, and enable us and our third-party providers to automatically collect information about how you access and use our Website and the device you use to access it. This helps us to provide you with a good experience when you browse our Website and also allows us to customize and improve our Website. For detailed information about the cookies and similar technologies we use, including Cookiebot, Google Analytics 4, Google Tag Manager, Hotjar, LinkedIn Insight Tag, and Meta Pixel, as well as the purposes for which they are used, please see our Cookie Policy. Some web browsers include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. You can make certain choices about cookies and similar technologies to communicate your choice not to be tracked online through the Cookiebot consent banner available on our Website. But we may not respond to DNT signals. As no uniform technology standard for recognizing and implementing DNT signals has been finalized yet, we may not be able to respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Where required by applicable law, non-essential cookies and similar technologies are only activated after you have provided your consent through our Cookiebot consent banner. You may change or withdraw your consent at any time through the cookie preferences available on our Website.

Uses Made of the Information

When processing personal data, Twistellar may use technologies provided by its trusted service providers where necessary to deliver, improve and secure its services. We use information held about you in the following ways: 

Information you give to us. To the extent permitted under applicable law, we will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, consulting services, implementation services, managed services, software products and other professional services that you request from us;
• to provide you with information about other services, solutions and resources we offer that are similar to those that you have already purchased or inquired about, when permitted by applicable law;
• to provide you, or permit selected third parties to provide you (where you have consented to such sharing when required by applicable law), with information about services, resources or content we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about services, products and resources similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so;
• to notify you about changes to our service;
• to ensure that content from our Website is presented in the most effective manner for you and for your computer.

Information we collect about you. To the extent permitted under applicable law, we will use this information:

• to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep our Website safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our Website about services, resources or content that may interest you or them.

Information we receive from other sources. To the extent permitted under applicable law, we will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of Your Information

To the extent permitted under applicable data protection law, Twistellar may share personal data with trusted service providers and business partners where necessary for the purposes described in this Privacy Policy.

Selected third parties including:

• service providers who act as our data processors are subject to contractual obligations to implement technical and organizational security measures to safeguard the personal data and to process the personal data only as instructed. These third-party service providers assist us in assessing our information security controls, maintaining our Website, managing cookie consent, analyzing our Website traffic, website analytics, and in providing services and information to us and to users of our Website. These service providers may include providers of analytics, consent management, cloud hosting, CRM and communication services, such as Cookiebot, Google Analytics 4, Google Tag Manager, Hotjar, LinkedIn Insight Tag and Meta Pixel;
• advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others. We may provide advertisers and advertising networks with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;
• analytics and search engine providers that assist us in the improvement and optimization of our Website;

To the extent permitted by applicable data protection law, we will also disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
• if we, or substantially all of our assets, are acquired by a third party by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or request of law enforcement, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our employees, customers, or others.

International Data Transfers

Your personal data may be disclosed to employees, representatives, or other third parties operating outside the country where you are located who work for, or are engaged by, Twistellar, as well as to our service providers located in other countries. These persons and third parties may store, transfer, or access your personal data outside the country where you are located, including outside the European Economic Area ("EEA"), the United Kingdom, or Switzerland, where applicable.

Where personal data is transferred outside the European Economic Area ("EEA"), the United Kingdom, or Switzerland, Twistellar will ensure that appropriate safeguards are implemented in accordance with applicable data protection laws. These safeguards may include the European Commission's Standard Contractual Clauses (SCCs), adequacy decisions, or other lawful transfer mechanisms. 

When transferring your personal data internationally, we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal data in accordance with applicable laws. For any further information on the safeguards we adopt to ensure the protection of your personal data, you can contact us using the contact details indicated below.

Contacts and Complaints

We rely on personal data provided by you. In order to ensure that personal data provided to us is current, complete and accurate, please update us if there are any changes to the personal data provided to us.

Questions, comments or requests regarding this Privacy Policy are welcomed and should be addressed to hello@twistellar.com or by mail at Twistellar ApS, Ny Vestergade 17, 1,
1471 Copenhagen, Denmark, CVR 42114979. Similarly, if you have any complaints about our privacy management practices, you can contact us at the same details. You may also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

Changes to Our Privacy Policy

We may make changes to this notice, including material changes, from time to time. We will inform you of any changes to the processing activities described in this notice before we start that new processing.

Effective Date: September 1, 2018.

EEA+ Supplemental Data Protection Law Disclosures

Twistellar ApS provides to residents of the European Economic Area, Switzerland and the United Kingdom (EEA+) the following disclosures to supplement the Website Privacy Policy.

Data Controller: The data controller is Twistellar ApS, a company incorporated under the laws of Denmark with its registered office at Ny Vestergade 17, 1, 1471 Copenhagen, Denmark.

Legal Bases for Processing under European Union and United Kingdom law: Legal bases for the processing of your personal data by Twistellar ApS are:

• (i) performance of a contract, where we have entered into a contract with you and need to process your personal data to fulfil our contractual obligations to you (Art. 6 (1) lit. b GDPR/UK GDPR);
• (ii) our legitimate interests (Art. 6 (1) lit. f GDPR/UK GDPR) for the transfer of your personal data within Twistellar which are the following: for internal administrative and support purposes;
• (iii) compliance with a legal obligation to which Twistellar is subject (Art. 6 (1) lit. c GDPR/UK GDPR), for example if we are required by law to disclose personal data to law enforcement agencies, or governmental authorities;
• (iv) our legitimate interests for the purposes of exercising our legal rights or defending legal claims;
• (v) our legitimate interests (Art. 6 (1) lit. b GDPR/UK GDPR) for the transfer of your personal data in connection with a transfer of all or part of our organization or assets which are the following: the orderly transition of all or part of our business;
• (vi) our legitimate interests to protect and defend the rights or property of us or third parties, including enforcing agreements, policies and terms of use, and in an emergency including to protect the safety of our employees or any person which are the following: to protect the property, rights, and safety of any person and to prevent fraud. Information on the balancing test is available upon request;
• (vii) your consent to the processing (art. 6 (1) lit. a GDPR/UK GDPR) for marketing and advertising purposes, as required by applicable laws.

Recipients in Third Countries: Personal data may be transferred to trusted service providers located outside the European Economic Area ("EEA"), including providers of cloud infrastructure, analytics, marketing, CRM and communication services. Where such transfers occur, Twistellar will ensure that appropriate safeguards are implemented in accordance with applicable data protection laws, including the European Commission's Standard Contractual Clauses (SCCs), adequacy decisions, or other lawful transfer mechanisms. 

Period of Data Storage: Personal data will be retained only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes and enforce our agreements. When Twistellar no longer needs to use your personal data to comply with contractual obligations, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information, including personal data, to comply with statutory retention periods e.g. for tax purposes for a legally prescribed time period thereafter, or if we need it to preserve evidence within statutes of limitation. With regard to personal data collected through cookies or similar technologies, details are provided in the Cookie Policy.

Data Subject Rights Under applicable law, you may have the following rights in relation to your personal data. These may be limited under applicable data protection law.

• (i) Right to request from us access to personal data: You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. You have the right to obtain a copy of the personal data undergoing processing. However, this is not an absolute right and the interests of other individuals may restrict your right of access.
• (ii) Right to rectification: You have the right to obtain from us rectification of inaccurate or incomplete personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• (iii) Right to erasure of your personal data (right to be forgotten): You have the right to ask us to erase personal data concerning you.
• (iv) Right to restriction of processing: In limited circumstances, you have the right to request that we restrict processing of your personal data.
• (v) Right to data portability: You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that personal data to another entity without hindrance from us.
• (vi) Right to object: Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we may be required to no longer process your personal data.

Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.

You also have the right to lodge a complaint with the competent supervisory authority, including the Danish Data Protection Agency (Datatilsynet), where applicable. If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can exercise your rights by contacting us as set out in the contact section.

Failure to Provide Personal Data: Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the services you have requested from us. In this case, we may have to cancel the provision of the relevant services to you, in which case we will notify you.

Contact Us

If you have any questions or comments about these disclosures or our practices, please contact us at:
Email address: hello@twistellar.com
Ny Vestergade 17, 1,
1471 Copenhagen,
Denmark, CVR 42114979

Last Updated: July 29, 2026