1. Who we are
Tway Global Communications Limited operates TGC Diversao. Depending on the activity, we act as a controller of website and account data or as a processor of communications data on behalf of a business customer.
2. Data we collect
We collect information you provide, such as your name, business details, email address, phone number, account credentials, support requests, and consent choices. When services are used, we may process sender and recipient identifiers, routing information, timestamps, delivery events, call records, message content when required to deliver it, device and network data, API logs, and security events.
3. How we use data
We use personal data to create and secure accounts, deliver communications, route traffic, provide support, bill for services, prevent fraud and abuse, comply with carrier and legal obligations, maintain service reliability, and improve the platform. We send product or promotional communications only where permitted and honor opt-out requests.
4. Legal bases
Where applicable, we rely on performance of a contract, legitimate interests in operating and securing the service, compliance with legal obligations, and consent. Customers are responsible for choosing a lawful basis and providing required notices for recipients they contact through the platform.
5. How data is shared
We share data only as needed with carriers, channel providers, hosting and security providers, payment and support vendors, professional advisers, and public authorities when legally required. We do not sell personal data. Providers are required to protect data and use it only for the relevant service.
6. International processing
Communications may cross borders because recipients, carriers, and service providers operate in different countries. Where required, we use contractual, organizational, and technical safeguards for international transfers.
7. Retention
We keep account, billing, consent, security, and communications records only for as long as needed for the purposes described here, contractual commitments, dispute resolution, fraud prevention, and legal requirements. Retention periods vary by data type, service, and jurisdiction. We delete or de-identify data when it is no longer required.
8. Security
We use access controls, encryption, logging, monitoring, secure credential handling, and operational safeguards designed to protect personal data. No system is completely secure, so customers must also protect their credentials, applications, recipient lists, and integrations.
9. Cookies and account sessions
Our website uses essential cookies to maintain secure account sessions and remember necessary service state. We do not require advertising cookies to create or use an account. Browser settings can block cookies, but essential account features may then stop working.
10. Your choices and rights
Depending on your location, you may request access, correction, deletion, restriction, portability, or an objection to certain processing. You can withdraw consent for future marketing messages at any time. Communications recipients should first contact the business that sent the message; we support our customers in responding to valid requests.
11. Children
The platform is designed for businesses and is not directed to children. We do not knowingly collect personal data from children through direct account registration.
12. Updates and contact
We may update this policy when our services or legal obligations change. We will publish the revised date on this page. Privacy questions and rights requests can be sent to [email protected].