(Last Updated May 25, 2018)
In order for 2wrap to provide services and specifically the 2wrap services outlined in the Terms of Service including but not limited to the 2wrap website at www.2wrap.com and family of websites and or blogs owned by 2wrap, we may store, collect, and process various forms of information. This site in its entirety is owned by 2wrap, Inc. doing business as “2wrap.” 2wrap (“2wrap,” “we” or “us”) provides an online service. The terms “you” and “user” means all individuals and entities that access the Service.
2wrap provides services to users throughout the world. If you use our services in the United States or in the European Union or elsewhere, 2wrap, Inc. is the data controller. The address for the data controller of the information you provide or that is collected by 2wrap or its affiliates is:
ATTN: Privacy Officer
3128 Via Colinas #100, Westlake Village, California, 91362
United States of America
Types of Information We Collect and How We Use Your Information
As part of the user experience, you may also exchange information with us that would be part of the personal information we collect. Examples include but are not limited to the following: (1) information provided when you download or use applications from us; (2) information you enter into our system and post as part of using our services (e.g. photos, videos, comments, voice recordings and other multimedia communication materials); (3) information you provide to us when contacting us for help; and (4) profile information you provide for your personal user profile (e.g. age, first and last name, picture, image or likeness, phone number, etc.).
1. Specific Use of Personal Information. The information we collect allows us to provide you with a relevant user experience as well as a mechanism to keep you informed on 2wrap’s latest product announcements, software updates, and promotional information. If you so desire, you can remove yourself from our mailing list by opting out by updating your profile preferences. In order to receive the benefits of the Services offered, your email address is shared with our third-party providers and you shall comply with their sensor registration requirements. However, you may opt out of uploading data to our third-party providers by updating your sensor preferences or by contacting us at email@example.com.
Other uses of personal information may be for validating a user account, fraud prevention, or other data safety precautions 2wrap may elect to implement. Additionally, we may use personal information for our internal purposes such as data analysis, auditing, and research to improve our services to you.
B. Non-Personal Information and Its Use. 2wrap collects information that in and of itself does not permit direct association with any specific person. In the case of non-personal information 2wrap has the right to collect, transfer, use, and disclose this information for any purpose. Examples of non-personal information and its intended use:
1. Device related information. We may collect information such as the user device identifier (IDFA), type of mobile device, IP address of your mobile device, mobile operating system, and type of mobile Internet browsers. The device identifier itself may deliver the information to us directly or we may obtain this information via a third-party partner and/or affiliate. We use the information for the express purpose of better understanding customer behavior and improving our products and services.
2. User activity with our services. We may collect and store details on how you interact with our services. This may help us improve our service offerings and to provide a better user experience.
3. Metadata. Metadata is unique technical data that is generally associated with User Content. Metadata allows one to make their User Content more searchable when interacting with our Service. An example of metadata would be a hashtag or some form of geotag that would allow others to more readily find your submitted content and/or its given location.
- Location Based Information. Use of the 2wrap services, permits us to collect precise information about the location of your particular device. Location may include but is not limited to background location information between Users. We may use your location information to provide requested location services and to allow tagging of files. You may opt out by changing your geo-location settings consistent with your device protocol.
D. Information from Other Sources. This may include:
1. User feedback;
2. Requesting services for or on your behalf;
3. Users or others providing information in relation to any claim or dispute;
4. 2wrap business partners including those with whom you may create or access your account, such as payment providers, social media users, or websites who use 2wrap’s APIs or whose API 2wrap uses;
5. Publicly available sources.
6. Marketing service providers.
2wrap may combine the information gathered from these other sources with other information in its possession.
Cookies and Other Tracking Technologies
“Cookies” are small data files that are sent to your web browser when you access a website, and the files stored on your device’s hard drive. We use “session” cookies to keep you logged in while you use the Site, to track your preferences and to track trends and monitor usage and web traffic information on the Site. These are erased when you close your browser. We use “persistent” cookies to relate your use of our Service to other information about you and store information about your preferences to make your user experience consistent and customized. For example, we may create a persistent cookie that includes some basic information about you, like your favorite website locations and whether customer support responded to your inquiry. These cookies stay on your hard drive until you erase them, or they expire and associate your information with your account even if you are logged out.
Certain features of the Site may use local shared objects (or “flash cookies”). Flash cookies are small files similar to browser cookies that collect and store information about your preferences and where you browse and what you look at on the Site. Flash cookies are not managed by the same browser or device settings that are used for browser cookies. You may adjust your Adobe Flash Player settings to prevent flash cookies from being placed on your hard drive.
We may use “clear GIFs” (aka “web beacons” or “pixel tags”) or similar technologies, on our Service or in our communications with you to enable us to know whether you have visited a part of our Service or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a website or in an email or other type of message, which is retrieved from a remote website on the Internet enabling the verification of an individual’s viewing or receipt of a website or message.
We do not automatically collect Personal Information, but we may tie Personal Information with the automatically collected information using the above tools or information collected from other sources.
We may also log information using digital images called web beacons on our Site or in our emails. We may use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We may also use web beacons to tell if you open or act on our emails.
We also use third party analytics services to collect usage data from our Site in order to help us understand how users are interacting with our Site. Third party analytic services are used to track general location information, and events that occur without our Site, such as how often you use our Site. This information, including your IP address, is transmitted and stored by 3rd parties as determined by us.
IP Address Information and Other Information Collected Automatically
We automatically receive and record log file information from your web browser when you interact with the Site, including your IP address and cookie information. Generally, the Site automatically collects usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Service so that we can analyze and improve them.
Third-Party Sites and Services
2wrap products, services, and Site may contain links to third-party services (e.g. Facebook, Twitter, Google etc.), products, and websites. Information collected by third parties is governed by their privacy policies and practices. We encourage you to read and learn about their specific privacy practices.
Information Sharing and Disclosure
From time-to-time, 2wrap may make certain personal information available to product and service partners. Specific ways 2wrap shares with third parties are described below:
A. Third-Party Service Providers. 2wrap may elect to outsource some of its technical and customer support, tracking and reporting functions, quality assurance testing, and other services that it may deem necessary. Examples of the service partners or third-parties we may provide your information to includes but is not limited to our vendors, marketing partners, research firms, and consultants. Additional examples may include:
1. Payment processors and facilitators.
2. Cloud storage providers.
3. Data analytics providers.
4. Research partners.
5. Consultants, accountants, lawyers, and other professional service providers.
In these specific instances, we may share information about or from you in order for them to provide their services.
C. Investigations. As described in the 2wrap Terms and Conditions of Use, 2wrap reserves the right to provide and/or disclose necessary information for investigatory matters. Examples include but are not limited to: 1) compliance with law enforcement or the necessary legal process; 2) behavior and/or use violative of the Terms and Conditions of Use, and 3) instances whereby it is necessary to protect our rights and obligations.
D. User Request. This includes sharing your information with:
1. 2wrap business partners. For example, we may share your location and/or that of the 2wrap sensor(s) when you engage the services we may make available to you through our business partners and their affiliates.
E. General public when submitting content to a public forum. Use of our services may enable you communicate with public forums such as 2wrap blogs, social media, and features that may be offered with our services. If you communicate with use via these channels, your communications may be viewable by the public.
F. With your consent. 2wrap may share your information other than as we have described in this policy if we notify you and you consent to the sharing.
Storage of Your Information
The information you provide 2wrap may be collected through our services and processed in the United States or any other country in which 2wrap, its subsidiaries, affiliates, and/or service providers maintain facilities.
In turn, 2wrap uses commercially reasonable standards, measures and/or protocol to keep the information collected through the Service secure and as a result we take cautionary steps to verify your identify before granting you Service access. Moreover, 2wrap cannot ensure the security of any information submitted or transmitted by you to 2wrap nor can we guarantee that said information may not be disclosed, destroyed, and/or altered.
Protection of Personal Information
2wrap preserves the security of your personal information with the utmost caution. As such, we follow the generally accepted industry standards to protect all user information submitted to us. Although we implement accepted industry standards, we cannot guarantee absolute security with respect to your personal information. Given the fact that no one method of transmission over the Internet or via mobile device is 100% secure, we urge you to take the utmost care when transmitting personal information.
When you use some of the features of the 2wrap services, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. Please take care when using these features.
Data Retention and Deletion
2wrap will retain your personal information for a minimum of 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. 2wrap thereafter deletes or anonymizes such information with applicable laws. Users may request deletion of their account at any time. Following such request, 2wrap deletes the information that it is not required to retain and restricts to or use of an information it is required to retain. You may request deletion of your account by contacting us here at firstname.lastname@example.org.
2wrap may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if 2wrap shuts down a user’s account, 2wrap may retain certain information about that account to prevent that user from opening a new 2wrap account in the future.
Access to Personal Information
In order to ensure that your personal information is current and accurate, please log in to your account using 2wrap app and go to user profile.
ATTN: Privacy Officer
3128 Via Colinas #100, Westlake Village, California, 91362
United States of America
Special Information for EU Users
Beginning May 25, 2018, the processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). This section summarizes 2wrap’s grounds for processing personal information under the GDPR, and the rights of EU users as relates to 2wrap’s handling of personal information. This section provides information as relates to EU users’ rights, and 2wrap’s responsibilities, under this regulation.
A. EU User Rights
If you are an 2wrap user in the EU, you have the following rights with respect to 2wrap’s handling of your personal information. To exercise these rights, please see below or submit your request at email@example.com.
Users outside the EU may also request explanation, correction, deletion or copies of their personal data by contacting us at firstname.lastname@example.org.
1. Explanation and copies of your data
- You have the right to request an explanation of the information
that 2wrap has about you and how 2wrap uses that information.
- You also have the right to receive a copy of the information that 2wrap collects about you if collected on the basis of consent or because 2wrap requires the information to provide the services that you request.
- If 2wrap has information about you that you believe is inaccurate, you have the right to request correction of your information. Please see the section titled “Explanation, Copies and Correction” below for more information on correcting, or requesting correction of, your information.
- Users may request deletion of their accounts at any time. Users
may request via 2wrap’s website at email@example.com. We may retain certain
information about you as required by law and for legitimate business purposes
permitted by law.
- Please see the “Data Retention & Deletion” section above for more information regarding 2wrap’s retention and deletion practices.
4. Objections and complaints
- Users in the EU have the right to object to 2wrap’s processing of personal data, including for marketing purposes based on profiling and/or automated decision making. 2wrap may continue to process your information notwithstanding the objection to the extent permitted under GDPR.
- You may also submit questions, comments or complaints to 2wrap directly at
ATTN: Privacy Officer
3128 Via Colinas #100, Westlake Village, California, 91362
United States of America
B. Grounds for Processing
The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, 2wrap processes the information of EU users based on one or more of the grounds specified under the GDPR:
1. The processing is necessary to provide the services and features you request
- 2wrap must collect and use certain information in order to provide
its services. This includes:
- User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about the products you order from us, orders and accounts; and to enable you to make payments.
- 2wrap sensor locations which will enable you to use the services with us and/or our service partners.
- Usage information, which is necessary to maintain, optimize and enhance 2wrap’s services, including to determine, sometimes in combination with other information, incentives, etc.
- Collection and use of this information is a requirement for using 2wrap’s website and services.
2. The processing is necessary to protect the vital interests of our users or of others
- 2wrap may process personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.
3. The processing is necessary for 2wrap’s legitimate interests
- 2wrap collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:
- To prevent, detect and combat fraud in connection with the use of
our services. For example, 2wrap uses user profile, location, device and usage
information, to identify and prevent circumstances when users attempt to
defraud 2wrap or other users.
- To inform law enforcement officials regarding criminal acts or threats to public safety.
- To provide customer support.
- To optimize our service and develop new services.
- For research and analytical purposes. This includes, for example, analyzing usage trends to improve the user experience and enhance the safety and security of our services.
- For direct marketing purposes. This includes, for example, analyzing data to identify trends and tailor marketing messages to user needs.
- To enforce 2wrap’s Terms of Service.
4. The processing is necessary for the legitimate interests of other persons or parties
- 2wrap collects and uses personal information to the extent
necessary for the interests of other persons or the general public. This
includes sharing information in connection with legal or insurance claims, to
protect the rights and safety of others.
- 2wrap may also process personal information when necessary in regard to a substantial public interest, on the basis of applicable laws.
5. The processing is necessary to fulfill 2wrap’s legal obligations
- 2wrap is subject to legal requirements in the jurisdictions in
which it operates that require us to collect, process, disclose and retain your
personal data. For example, 2wrap is subject to laws and regulations in many
cities and countries that require it to collect and retain information about
the 2wrap products, to retain such information for extended periods of time,
and to provide copies of such information to governmental or other authorities.
2wrap uses your information to comply with such laws to the extent they apply
to your use of the 2wrap apps.
- 2wrap may also share information with law enforcement, or requests by third parties pursuant to legal processes. For more information about such sharing, please see
- 2wrap may collect and use your information on the basis of your
consent. You may revoke your consent at any time. If you revoke your consent,
you will not be able to use any service or feature that requires collection or
use of the information we collected or used on the basis of consent.
- 2wrap relies on consent in connection with data collections or
uses that are necessary to enhance the user experience, to enable optional
services or features, or to communicate with you. If you are an EU user, the
following types of data collections or uses are done on the basis of your
- Location Information (Users and 2wrap products)
- Notifications: Account Updates
- Notifications: Discounts and News
- Address Book / Contacts
- 2wrap relies on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you. If you are an EU user, the following types of data collections or uses are done on the basis of your consent.
- Please see the Choice & Transparency section below for further
information about these data collections and uses, how to opt in or out of
them, and the effect of opting out of these on your use of 2wrap’s apps.
- 2wrap may also collect personal information about you through voluntary surveys. Your responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.
Choice and Transparency
2wrap provides means for you to see and control the information that 2wrap collects, including through:
- device permissions
- marketing opt-outs
You may also request that 2wrap provide you with explanation, copies or correction of your data.
A. DEVICE PERMISSIONS
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that websites cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the 2wrap website wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the 2wrap website seeks before you first use the website, and your use of the website constitutes your consent.
B. EXPLANATIONS, COPIES AND CORRECTION
You may request that 2wrap:
- Provide a detailed explanation regarding the information 2wrap has collected about you and how it uses that information.
- Receive a copy of the information 2wrap has collected about you.
- Request correction of any inaccurate information that 2wrap has about you.
You can make these requests by contacting 2wrap at firstname.lastname@example.org.
You can also edit the name, phone number and email address associated with your account through the Settings menu in 2wrap’s website You can also look up your transactions, history, etc. in the 2wrap website.
C. MARKETING OPT-OUTS
You may opt out of receiving promotional emails from 2wrap at email@example.com. You may also opt out of receiving emails and other messages from 2wrap by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages, such as receipts for your rides or information about your account.