1. Who We Are
TwinkleFlow ("we", "us", or "our") is a HubSpot consultancy that provides implementation, integration, data, automation, AI, and training services, and publishes apps on the HubSpot Marketplace. This Privacy Policy applies to twinkleflow.com (the "Website"), our services, and our apps.
2. Information We Collect
Information you provide
- Contact details such as your name, email address, phone number, company name, and job title when you fill out a form, book a call, or email us.
- Project information you share with us about your business, HubSpot setup, and goals.
- Billing information such as billing address and payment details, which are processed by our third-party payment providers. We do not store full card numbers.
Information collected automatically
- Usage data such as pages visited, time on page, referring URLs, and links clicked.
- Device data such as IP address, browser type, operating system, and approximate location.
- Cookies and tracking technologies, including the HubSpot tracking code, used to understand how visitors interact with our Website.
Information from our apps
When you install one of our HubSpot Marketplace apps, we receive OAuth access tokens and the HubSpot account (portal) ID needed to operate the app. Our apps access CRM data, such as contact, company, and activity records, only to the extent required to perform the functions you configure (for example, reading activity timelines and writing results to properties). We do not sell this data or use it for any other purpose.
3. How We Use Your Information
- To respond to inquiries and provide the services you request.
- To operate, maintain, and support our apps.
- To send invoices, process payments, and manage your account.
- To send newsletters or marketing communications, where you have opted in. You can unsubscribe at any time.
- To analyze and improve our Website, content, and services.
- To protect against fraud and abuse, and to comply with legal obligations.
4. Legal Bases for Processing
Where applicable data protection laws (such as the GDPR) require a legal basis, we rely on: performance of a contract with you; our legitimate interests in running and improving our business; your consent (for example, for marketing emails and non-essential cookies); and compliance with legal obligations.
5. How We Share Information
We do not sell your personal information. We share it only with:
- Service providers who help us run our business, such as HubSpot (CRM and marketing), hosting providers, scheduling tools, and payment processors, under appropriate confidentiality obligations.
- Professional advisers such as accountants and lawyers, where necessary.
- Authorities when required by law or to protect our rights, safety, or property.
- A successor entity in connection with a merger, acquisition, or sale of assets.
6. Cookies
We use cookies and similar technologies for essential site functionality, analytics, and marketing. You can control cookies through your browser settings, and where required we will ask for your consent before setting non-essential cookies. Disabling cookies may affect how parts of the Website work.
7. Data Retention
We keep personal information only as long as needed for the purposes described in this policy, including to meet legal, accounting, or reporting requirements. When you uninstall one of our apps, we delete the associated access tokens and app data within a reasonable period, unless we are required to retain it.
8. Data Security
We use reasonable technical and organizational measures to protect your information, including encryption in transit, access controls, and the principle of least privilege. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. International Transfers
Your information may be processed in countries other than your own. Where we transfer personal data internationally, we take steps to ensure it receives an adequate level of protection, such as relying on standard contractual clauses.
10. Your Rights
Depending on where you live, you may have the right to:
- Access the personal information we hold about you.
- Request correction of inaccurate information.
- Request deletion of your information.
- Object to or restrict certain processing.
- Request a copy of your data in a portable format.
- Withdraw consent at any time, where processing is based on consent.
- Lodge a complaint with your local data protection authority.
To exercise any of these rights, email us at hello@twinkleflow.com. We will respond within the timeframe required by applicable law.
11. Children's Privacy
Our Website and services are intended for businesses and are not directed to children under 16. We do not knowingly collect personal information from children.
12. Third-Party Links
Our Website may link to third-party websites. We are not responsible for their privacy practices, and we encourage you to review their policies.
13. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, notify you by email.
14. Contact Us
If you have questions about this Privacy Policy or how we handle your data, contact us at hello@twinkleflow.com or through our contact page.