Privacy Policy

This Privacy Policy (the “Policy”) is for Trans World Associates (Private) Limited(“TWA”) and its website, located at “Website”).This Policy has been formulated to assist TWA users to understand how their personal information will be treated by us when they access the Website or use our products and services, as our objective is to deliver a seamless experience and quality services to all users.

All users of the Website or Products and Services are advised to read and understand this Policy carefully, as by accessing the Website or using products and services you agree to be bound by the terms of this Privacy Policy and consent to the collection, use, disclosure, storage, and protection of your personal information in accordance with this Policy, or any changes made hereto. Please note that we may amend this Policy from time to time in accordance with the laws of Pakistan, without prior notice. The users are advised to check for any updates to this Policy on a regular basis or as required from time to time to keep up to date with any changes made.

References below to “you” or “user” shall mean any visitor, user, business partner, agent, supplier, vendor or customer of TWA or the Website. References to “we” or “us” shall mean TWA.

  1. When this Policy applies
    1. This Policy also covers the information generated when you use or subscribe to TWA’s products or services to which this Policy is linked. The products or services provided by TWA include but are not limited to IP Transit, IPLC, MPLS, I-Connect, Data Centre, DDoS Protection, System Integrated Solutions, and any other products or services to be provided by TWA from time to time (the “Products and Services”).
    2. This Policy applies to you and any person or entity that will access, sign-up, provide information, upload or supply documents or subscribe to TWA Products and Services, websites or networks, all of which are subject to this Policy, except where we identify for you that separate TWA privacy policies or terms and conditions apply. This Policy applies to other websites owned and operated by TWA. You are responsible for making sure that you understand this Policy.
    3. You must agree and be willing to accept the terms of this Policy before you may visit or use the Website, or any Product and Services offered therein.
    4. This Policy also applies even if you are not one of our customers and you interact with us through the Website or otherwise through an associated platform of TWA as part of running our business, such as by: 
      1. using one of our Products and Services;
      2. taking part in a survey or trial; 
      3. calling our helpdesk; or
      4. generally enquiring about our Products and Services. 
    5. If you need to give us personal information about someone else in relation to our Products and Services, this Policy will also apply to the personal information of such person(s).
    6. Depending on the Products and Services, users may also receive service-specific and/or region-specific terms. All Website users will be legally bound by both this Policy and the service/region-specific terms to the extent that the users have accepted them when signing up for a Product and Service; therefore, the users are required to read the terms of this Policy carefully.
    7. By using this Website or the Products and Services, users consent to the collection, storage, and use of the personal information for any of the services that we offer, and their consent to our collection of any changes or updates that they may provide that is collected by TWA.
    8. You are responsible for ensuring that all personal data submitted to TWA are correct. You are responsible for maintaining the accuracy and completeness of personal data and keeping the data up to date.
  2. What Information we collect

    1. We may collect certain non-personal information that your browser sends whenever you visit any of our websites (“Log Data“). This Log Data may include information such as your computer’s Internet Protocol (IP) address, operating system, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics. This type of information does not identify the user personally.
    2. We collect information when the user accesses the Website or uses our Products and Services or responds to advertisements on the Website. We may also collect personal information that you give to us when you make a purchase, use our services or websites, set up an account or otherwise interact with us or provide information, which includes but is not limited to, your name, father’s name, mother’s name, mailing address, email address, phone/mobile number, home country, occupation, and postal code. All users have the option and may also provide us with their fax numbers, gender, age if and when they choose to register. In case of any entity, which uses or registers with, accesses the Website or proceeds to use the Products and Services, the entity’s name, its corporate registration details, and details of its authorized representatives.
    3. We may also collect your information from outside sources like credit reports, marketing mailing lists, and commercially available geographic and demographic information, along with other available information, such as public posts to social networking sites. We may also collect additional information that our users provide.
    4. For your information “Personal information” is any information that can be used by itself to uniquely identify, contact, or locate a person, or can be used with information available from other sources to uniquely identify an individual. For the purpose of this Policy, sensitive personal data or information is considered as a part of personal information.
  3. Use of Cookies

    1. We may use cookies to manage our users’ sessions and to store preferences, tracking information, and language selection. Cookies may be used whether the users register with us or not. “Cookies” are small text files transferred by a web server to users’ hard drive and thereafter stored on their computer. The types of information a cookie collects include the date and time users visited, their browsing history, preferences, and username.
    2. In some instances, our third-party service providers may use cookies on the Website. We cannot control or access cookies used by third-party service providers. This Policy covers only cookies used by us, and not any cookies used by third parties. Users may have the ability to either accept or decline the use of cookies on your computer, whether registered with us or not.  Typically, you can configure your browser to not accept cookies. However, declining the use of cookies may limit your access to certain features of the Website.
    3. By using the Website and accepting this Policy, you consent to the use of Cookies as described above.
    4. We retain the above information to resolve necessary disputes, provide support to users and resolve issues permitted by law.
  4. How we use your information

    1. We use your information to power our services and to improve your experiences. We use your information to provide, support, improve, protect, analyze and bill for our product, service and network; to communicate with you about your Products and Services; to market our services; to detect and avoid fraud; for advertising; and for research purposes. We may use information we collect from you when you purchase Products and Services from us, sign up for our newsletter, respond to a survey or marketing communication, surf the Website or use certain other site features in the following ways:
      1. To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
      2. To improve our Website in order to better serve you;
      3. To allow us to better service you in responding to your customer service requests;
      4. To administer a contest, promotion, survey or other site feature;
      5. To ask for ratings and reviews of our Products and Services; and
      6. To follow up with them after correspondence (live chat, email or phone inquiries).
    2. This means we may:

      1. record details about the Products and Services you use or order from us;
      2. send you Products and Services information messages (we may send you messages to confirm your order and tell you about any changes that might affect your service, like when we have infrastructure work planned or need to fix something);
      3. update you on when we will deliver, connect or install your Products and Services; 
      4. let you create and log in to the online accounts we run;
      5. charge you and make sure your payment reaches us; and
      6. give information to someone else (if we need to for the Products and Services you have ordered) or to another communications provider if you are buying some services from them and us (if we do this, we still control your personal information and we have strict controls in place to make sure it is properly protected).
      7. In addition, we use the following information to provide Products and Services and manage your account:

      8. your contact details and other information to confirm your identity and your communications with us. This includes your name, gender, address, phone number, date of birth, email address, passwords and credentials (such as the security questions and answers we have on your account);
      9. your payment and financial information, as applicable;
      10. your communications with us, including emails, and phone calls.  We will also keep records of any settings or communication preferences you choose;
      11. information from cookies placed on your connected devices that we need so we can provide a service; or
      12. such details to be provided of an authorized representative of a legal entity which is accessing the Website or the Products and Services therein.
  5.  Communications with Users

    1. By providing their phone numbers using their account to us, the user impliedly agree to receive communication on the provided phone number from our side which may include but not be limited to automated calls or text messages.
    2. We may also send you any legally required notifications including but not limited to, service-related notices or notices regarding a change to any of our policies. For example, we may send you a notice regarding server problems or scheduled maintenance to the Website. We will not change your preferences without your consent. You cannot opt out of receiving transactional communications from TWA related to your Product and Services.
  6. User’s Privacy Rights

    1. Please find below a non-exclusive list of privacy rights that users could exercise whilst entrusting us with their information:

      1. Right to withdraw consent

        Where a user has consented for us to use, process, or share their personal information, they can withdraw that consent any time, unless the information is required for us to perform our services or provide our products.

        In case you do not provide your information or consent for usage of personal information or later on withdraw your consent for usage of the personal information so collected, TWA reserves the right to deny provision of the services or withdraw the services or provision of products for which the said information was sought.

      2.  Right to access Website User’s information

        To the extent required by applicable laws, you have the right to access your personal information collected and the details of the treatment and request a copy of the personal information that we hold about them as well as rectify them if they are inaccurate or cancel their use through written request at any time by contacting us through the following email address [email protected] there is any change in personal information made by you, you must provide supporting documents to the change of personal information for verification by TWA.

      3. Right to erasure

        All users may request that we erase some of the personal information we hold about them, provided that:

        1. the information is no longer needed by us and there is no legal requirement for us to retain the information and it is not necessary for a user to comply with a previously applicable binding obligation on such user;
        2. the user objects to our profiling of their information, including profiling conducted for direct marketing purposes; or
        3. other legal grounds which permit users to do so

      4. Please note that deleting or withdrawing information may affect the Products and Services we provide to you.

  7. Children’s Privacy

    We respect the privacy of your child and do not intend to collect personal information from children under the age of eighteen (18) years. Although the users of all ages may navigate through the Website, we do not knowingly collect personal information from anyone underage eighteen (18) years. If we learn that a child under age eighteen (18) years has improperly provided us with information, we will notify the child’s parent or legal guardian and thereafter delete the child’s personal information from our records. If you think that we have inadvertently collected information about someone under the age of eighteen (18) years, please contact us at our UAN no. 111 111 891and we will promptly delete or anonymize this information.

  8. TWA’s Undertaking

    1. We will process the user’s personal information in accordance with this Policy and all applicable laws.
    2. We will do our best to remain transparent on how we handle our user’s personal information.
    3. We will only process their personal information for legitimate purposes, and only for as long as it is necessary to achieve those purposes. We will dispose of the user’s personal information safely and securely once it is no longer required, subject to the applicable laws on retention of data or in accordance with clause 2.5 of this Policy.
    4. We will inform users about their privacy rights, respect them and help them to exercise those rights.
    5. We will make sure that user’s personal information is safe through appropriate security measures.
    6. We will take steps to ensure that user’s personal information is adequately protected.
    7. We take adequate steps to ensure that our third parties adopt reasonable level of security practices and procedures to ensure security of personal information.
    8. When we dispose of your personal information, we use reasonable procedures to erase it or render it unreadable (for example, shredding documents and wiping electronic media).
    9. We build privacy and data protection into our Products and Services by design and by default. This means that we prioritize the privacy of our user’s data, and we will endeavor to build privacy safeguards in everything we develop.
  9. Security Practices
    1. We adopt reasonable security practices and procedures, to include technical, operational, managerial and physical security controls in order to protect your personal information from unauthorized access, or unauthorized disclosure while it is under our control. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
    2. Our security practices and procedures limit access to personal information on need-only basis. Further, our employees are bound by code of conduct and confidentiality policies which obligate them to protect the confidentiality of personal information.
    3. We maintain the security of our internet connections, however for reasons outside of our control, security risks may still arise. Any personal information transmitted to us or from our online products or services will therefore be your own risk. However, we will strive to ensure the security of your information. We observe reasonable security measures to protect your personal information against hacking and virus dissemination.
    4. We, however, assure you that TWA does not disclose your personal information to unaffiliated third parties which could lead to invasion of your privacy.
  10.   Notification of Changes

    We reserve the right to change these terms and conditions of this Policy from time to time, and at our sole discretion. We shall upload any and all material changes to these terms, including the Policy or the Website.

  11.    Disputes

    1.    Any disputes regarding user’s privacy are subject to this Policy, including but not limited to any provisions related to indemnification, limitations on damages, and choice of law and forum. We ask you to first submit any such complaints directly to us at: [email protected]

    2. If within thirty (30) days following the date on which the complaint is made, the dispute, controversy or claim cannot be resolved, such dispute or claim shall be finally settled by arbitration in accordance with the Arbitration Act 1940 or any subsequent amendment/replacement thereto in force.
    3. The seat of arbitration shall be Islamabad, Pakistan. The number of arbitrators shall be one (1) and the arbitration proceedings shall be conducted in English language.
  12. Governing Law
    1. This Policy shall be governed and construed in accordance with the laws of Pakistan.

  13. Disclosures

    1. We may be required to disclose user’s personal information to comply with legal or regulatory requirements. In such circumstances, we reserve the right to disclose user’s personal information as required by law, in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, subpoenas, service of process requirements, or discovery requests.
    2. We may also disclose your information to any local or international law enforcement officers or others, in the good faith belief that such disclosure is reasonably necessary to enforce this Policy; respond to claims that any content violates the rights of third parties; or protect the rights, property, or personal safety of TWA, our users or the general public. The user agrees and acknowledges that we may not inform them prior to or after disclosures made according to this section.
    3. We may also disclose or transfer your personal information to third parties in the event that:
      1. TWA is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. This Policy will apply to your information as transferred to the new entity.
      2. In order to enforce any terms and other agreements or to investigate potential breaches; report defaulters to any credit bureau or for the purpose of publishing statistics relating to the use of Website or Products and Services, in which case all information will be aggregated and made anonymous.
    4. We may also disclose your information to our corporate affiliates in order to help provide, understand and improve our services and our affiliates’ services, including the delivery of advertisements.
    5. We may use other third-party companies to monitor site traffic, which may, in some instances, store user information. Where we use another organization, we still control your personal information, and we have strict controls in place to make sure such personal information is properly protected.
  14.  Indemnity

    You agree to defend, indemnify and hold harmless TWA, its officers, subsidiaries, affiliates, successors, assigns, directors, officers, agents, service providers, affiliates, suppliers and employees, from and against any and all claims, damages, obligations, losses, liabilities, settlements, judgements, costs or debt, and expenses (including but not limited to attorneys’ fees) whether or not relating to a third party claim, which arises out of or relate to any act or omission of TWA arising from:


    1. User’s use of and access to this Website and/or the Products and Services;
    2. any violation by the user including but not limited to any term of this Policy, any breach of applicable laws, regulations, or obligations;
    3. any third party claims arising out of or in connection with users use of the website, Products and Services including any violation of third party right, including without limitation any copyright, trademark, trade secret or other property, or privacy right; or
    4. any claim that user’s content causes damage to a third party.

      The user is solely responsible for proper maintenance of its computer system(s) like installation of anti-virus software, etc., while accessing this Website. Any loss incurred by you due to your own negligence is your own responsibility. TWA will not be held liable for such acts or omissions. This defense and indemnification obligation will survive termination, modification or expiration of this Policy and your use of the Website and the Products and Services.

  15. Link to other websites
    1. The Website may contain links to other websites not owned or managed by TWA. These other websites may collect your personally identifiable information. We are not responsible for the privacy practices or content of these linked websites and only deal with the disclosure and use of the information we collect through the Website as stated in this Policy. Kindly ensure to review privacy policies of websites that you visit which have been linked on the Website to ensure safety of your personally identifiable information.

  16. Contact us

    Please contact us if you require any help or support:

    Company name: Trans World Associates (Private) Limited

    Contact us by email: [email protected]

    Contact us by phone: +92 51 111 111 891

    Service Timing: 9:00 am to 6:00 pm (PST)

    Address: #24, Retalia Building, G-6 Markaz, Islamabad, Pakistan