Manor Lake uses Twilio to facilitate SMS communications. When you complete a contact form on our website, we may collect your phone number, and other information you provide. This information is used to contact you so we may expediently address your questions, concerns, or needs. Twilio's privacy policy, describes how Twilio processes your data. Manor Lake's privacy policy, details how we handle your data and your rights regarding your information.
In order to provide services to our residents and conduct our day-to-day business operations, including the operation of our websites, we collect, use and share, or otherwise process personal data about our residents, our website visitors, and business contacts.
Personal data is any information that directly identifies you, such as your name and email address, or that indirectly identifies you, for example a phone number or device identifier.
The personal data we may collect and process about you varies depending on our relationship with you. We may have a direct relationship with you because you have set up an account or consented to receive marketing communications from us, or we may have an indirect relationship with you via your relationship with one of our residents; for example you may be a friend or family member.
We take privacy, data protection and our legal obligations very seriously. We are committed to being transparent with you about how we use personal data. This Privacy Notice aims to describe our privacy practices in a clear, accessible and easy to understand way and to let you know how you can exercise your rights in relation to your data.
This Notice applies where Twilio processes personal data as a data controller, in connection with the Services we provide to our customers and the operation of our business, including our websites. As a data controller, we determine the purpose (why) and means (how) of personal data processing and are ultimately responsible for the correct handling of your data, in accordance with applicable law. This Notice describes our general privacy practices. Depending on how you interact with us or the specific services you use, additional privacy notices may apply. These supplemental notices will be provided to you at or before the time we collect your personal data. These supplemental notices should be read together with this Notice and are incorporated by reference.
This Notice does not apply to the Personal Data we process in relation to job applicants. This is covered by our Global Applicant Privacy Notice.
We also process personal data for most of our Services as a data processor. As a data processor, we process personal data related to our residents to provide Services to them in accordance with their instructions. These instructions are set out in our customer agreements, Data Protection Addendum, service specific terms or through a customer's use or configuration of a product feature. You should contact these organizations directly for information about how they process your personal data as a data controller and to exercise your rights in relation to that data.
The purposes for which we process personal depends on your relationship with us. We only use personal data that is necessary to fulfill the specified purposes listed below as applicable to you and in accordance with applicable data protection law.
Personal Data We Generate or Collect Automatically
Communications Usage Data - When you or our customers use Twilio communications products, we collect electronic communications metadata, such as phone numbers and routing information, the source and destination of a communication, location of the device generated in the context of delivering the communication, date, time, duration and type of communication, status of the message, error data and traffic records.
Personal Data Collected From Other Sources
Telecommunication Data - We receive communication-related data from telecommunications operators, aggregators and carriers that may include phone type, carrier history, SIM status and history, city and/or country where phone was first registered, contract and account type, IP address city and/or country and a validation result of personal data provided by our customer and whether it matches data held by the carrier.
We disclose personal data to third parties in limited circumstances in order to provide the Services and to otherwise run our business. Below are the different scenarios under which we may disclose your data to third parties.
Telecommunications Service Providers
Twilio’s communications products provide an easier way for developers to build applications that make use of the publicly switched telephone network ('PSTN') to send communications. Therefore, we engage with a global network of telecommunications operators, aggregators, carriers and other communication service providers (collectively, “telecommunications service providers”) as necessary to route and connect those communications from the sender to the intended recipient. How telecommunications service providers handle this data is generally determined by their own policies and local regulations.
Where telecommunications service providers transmit the content of a communication, they function neither as data controllers nor data processors, instead they act simply as a conduit to transmit communication content. In the event telecommunications services providers process any personal data for their own purposes such as communications metadata required to transmit the message, or for billing or fraud prevention purposes, they also act as data controllers.
We may have to share Subscriber Records with local government authorities or local telecommunications carriers that provide connectivity services. However, we don’t share subscriber records for purposes other than this, and we treat these records with our highest confidentiality.
Other Communications Service Providers
For proper routing and connectivity, Twilio also enables sending or receiving communications through communications service providers that do not use the PSTN, these are referred to as Over-the-Top ('OTT') communications service providers. If you or our customer chooses to use Twilio to send or receive communications by way of these providers, Twilio will disclose communications content and other data to these providers as necessary to route and connect those communications from the sender to the intended recipient. How those OTT communications service providers, as data controllers, handle this data is determined by their own policies and local regulations.
Compliance with Legal Obligations
We may disclose your personal data to a third party if:
If we reasonably believe that disclosure is compelled by applicable law, regulation, legal process, or a government request (including to meet national security, emergency services, or law enforcement requirements);
to enforce our agreements and policies;
to protect the security or integrity of our Services;
to protect ourselves, our other customers, or the public from harm or illegal activities, including security threats, spam and fraud; or
to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury.
If Twilio is required by law to disclose any personal data about you, we will notify you or our customers of the disclosure requirement to the extent legally permitted and where Twilio determines such disclosure will not interfere with an ongoing investigation. Further, we object to information requests we do not believe were issued properly.
To protect personal data from loss, or unauthorized use, access or disclosure, Twilio uses reasonable and appropriate security measures designed to protect the security of your personal data both online and offline. These measures vary based on the sensitivity of the personal data we collect, process and store and the current state of technology. All systems used to support our business are governed by Twilio’s Information Security Policy and Standards which are built on industry standards and best practices such as the ISO 27001 and NIST standards. More information about our security measures can be found in our Security Overview.
We endeavor not to retain personal data in a form which permits identification of individuals for longer than is necessary for the purposes for which that data is processed. We retain personal data in accordance with Twilio's record retention policies and guidelines as revised and updated from time to time.
Twilio will store your Customer Account Data as long as needed to provide you or our customer with the Services and to operate our business. If you ask Twilio to delete specific personal data from your Customer Account Data (see ‘Your Rights and Choices About Your Data’ below), we will honor this request, unless deleting that information prevents us from carrying out necessary business functions, such as billing for our services, calculating taxes, or conducting required audits.
Twilio uses common information gathering tools such as cookies, web beacons, pixels and other similar tracking technologies to automatically collect information as you navigate our websites, your account or when you interact with emails we send to you.
Cookies
A cookie is a small text file that is stored in your browser or elsewhere on your hard drive. Cookies allow Twilio to identify your device as you navigate our websites or your account. This makes navigating and interacting with our websites or your account more efficient, easy and meaningful for you.
Twilio uses both session and persistent cookies. Session cookies are cookies that disappear from your computer or browser when you turn off your computer. Persistent cookies stay on your computer even after you’ve turned it off.
The cookies on our websites fall into three categories: (1) Required Cookies, (2) Functional Cookies, and (3) Advertising Cookies. To learn more about each category of cookie, you can visit our cookie consent tool by clicking on the “Cookie Preferences” link on the bottom right of the Twilio website you are visiting.
Manage Your Cookie Preferences
Twilio uses a cookie consent tool, which you can utilize to customize your cookie preferences. When you visit our website for the first time, a cookie consent banner will pop up and ask you to customize your cookie preferences. If you decide to change your preferences at a later date, you can easily do so by clicking on the “Cookie Preferences” link on the bottom right of the Twilio website you are visiting. Please note that Required Cookies cannot be disabled and if you decide to opt-out of Functional Cookies, certain functionality of our websites or your account may be impacted. Any choices concerning cookies are browser and/or device specific. If you clear your cookies from your browser on any of your devices, your choices will need to be reset.
Manage Cookies Using Your Browser
In addition to using our Cookie Consent tool, you can use your browser settings to opt out of Functional Cookies and Advertising Cookies. For more information on how to do that, click here. To manage privacy and storage settings for cookies, click here.
Universal Opt-Out Mechanisms
Global Privacy Control (GPC) and Do Not Track (DNT) are tools that you can use to inform websites of your privacy preferences in regard to ad trackers. To set up GPC, you can visit the Global Privacy Control page. To set DNT, you can visit the All About DNT page. Please note that this may impact the functionality of our websites or your account.
Opt Out of Advertising Cookies
To learn more about how to opt out of targeting and advertising cookies, you can go to the Your Online Choices page, the Network Advertising Initiative page, and the Digital Advertising Alliance’s Consumer Choice page. These opt-out tools are provided by third parties, not Twilio. We do not control or operate these tools or the choices that advertisers and others provide through these tools.
Web Beacons
Twilio also uses web beacons to gather data about your use of our websites, your account, and how you interact with emails we have sent to you. Web beacons are clear electronic images that can recognize certain types of data on your computer, like when you view a particular website tied to the web beacon, and a description of a website tied to the web beacon. Additionally, we may put web beacons in marketing emails that notify us when you click on a link in the email that directs you to a Twilio website.
If you have any questions, concerns or complaints about this Notice or our data protection practices, please do not hesitate to contact us by emailing us at contact@manorlakemgt.com.
We will periodically review this Notice and may change it to address legal, technical or business development requirements or make clarifications. If we make material changes that affect your rights, we will provide you with advance notice by sending an email to the address we have on file for you. We will comply with applicable law with respect to any changes we make to this Notice. We will also seek your consent to material changes, where required by applicable law.
