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Last updated: May 28, 2019

 

TWI Group Privacy Notice

 

This Privacy Notice governs the manner in which TWI Group, Inc. (“TWI,” “we,” or “us”) collects, uses, maintains, and discloses information we may collect from users of our website, www.twigroup.com (the “Site”), or through other conventional means when using our event shipping services that include an authorized link to this Privacy Notice (collectively, the “Services”). 

 

For purposes of the European Union’s General Data Protection Regulation (the “GDPR”), TWI may be a data processor and is located at 6425 Montessori Street, Las Vegas, Nevada 89113.   

 

PRIVACY PRINCIPLES

 

TWI follows the following principles in order to protect your privacy:

  • We do not collect any more personal data about you than is necessary to facilitate business to business transactions;[1]
  • We only use your personal data for the purposes we specify in this Privacy Notice, unless you agree otherwise;
  • We do not keep your personal data if it is no longer needed; and
  • Other than as we specify in this Privacy Notice, we do not share your personal data with third parties.

 

INFORMATION WE COLLECT

  • Personal Data.  TWI may collect personal data from users in a variety of ways, including, but not limited to, when you visit or register on our Site, purchase products from us, subscribe to our newsletters, respond to a survey, fill out a form, and in connection with other activities, services, features, or resources we make available through our Services.  You may be asked for, as appropriate, name, business email address, business mailing address, and business phone numbers.  You can always refuse to supply the personal data that we request, except that it may prevent you from engaging in certain Site-related activities and receiving certain information.
  • Non-Personal Data. TWI may collect non-personal data about you when you interact with our Site. Non-personal data may include your browser name, type of computer, the files viewed on the Site, clickstream data, and technical information about your means of connection to the Site, such as the operating system and the internet service providers utilized.  To the extent that we link this non-personal data with your personal data, this Privacy Notice shall govern our use of such information.
  • Processor.  Responsible for processing, analyzing, storing, and deleting personal data on behalf of the controller.
  • Controller.  Responsible for decisions about the collection, use, and protection of personal data.  

 

[1] All reference to “personal data” in this Notice refers to data that is collected and/or processed to facilitate business-to-business transactions.  TWI does not use or process the personal data it collects for other purposes.

HOW WE USE PERSONALLY IDENTIFIABLE INFORMATION

 

TWI may collect and use personal data for the following purposes:

  • To process transactions.  Information you provide allows us to process transactions made on the Site or otherwise as necessary for performance of our contractual obligations to you, including as applicable, order confirmation, billing, and delivering products or services.  We will do this on the basis of business necessity and to fulfill our contractual obligations to you.
  • To improve customer service.  Information you provide helps us respond to your customer service requests and support needs more efficiently.  We will do this on the basis of our legitimate business interests.
  • To improve our Services.  We may use feedback you provide to improve our Services.  We will do this on the basis of our legitimate business interests.
  • To run a promotion, contest, survey, or other Site feature.  With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, text, web or telephone about our products and services including tailored special offers, discounts, promotions, events, competitions and so on.  Of course, you are free to opt out from hearing from us by any these channels at any time.
  • To respond to your inquiries.  We will use your personal data to respond to your inquiries, questions and/or other requests.  We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests.  
  • To share offers from third parties that may be of interest to you.  With your consent, we may use your information to let you know about offers, programs, products, or services third parties that may be of interest to you.
  • As required by law.  To send you communications required by law or which are necessary to inform you about our changes to the services we provide you.  For example, updates to this Privacy Notice and other legally required notices or information.  These service messages will not include any promotional content and do not require prior consent when sent by email or text message.  If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
  • To comply with our legal or contractual obligations to share data with law enforcement.
  • To fulfill any other purpose for which you provide personal data.  We may use your personal data for purposes that we make known to you at the time of collection of such information or otherwise upon your consent.

 

 

WHERE WE STORE YOUR INFORMATION

 

TWI is headquartered in the United States of America and the personal data we collect from you is collected and stored by us in the United States of America, which may have different data protection laws than those in the country in which you reside. 

 

The personal information collected by TWI may be transferred to, processed and stored, to organizations in countries within the European Economic Area, and to organizations in select countries outside of the European Economic Area.  Personal data of EU residents collected by TWI will only be transferred to organizations in countries within the European Economic Area or to organizations in countries outside the European Economic Area in compliance with GDPR articles regulating transfer of personal data. 

 

TWI may transfer personal data to Canada under GDPR Article 45 on the basis of the adequacy decision set forth in 2002/2/EC: Commission Decision of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data provided by the Canadian Personal Information Protection and Electronic Documents Act (notified under document number C(2001) 4539).  TWI occasionally transfers personal data to a business partners in Russia subject to a legally-enforceable agreement under GDPR Article 46.  You may request a copy of this agreement by mailing a written request to TWI at the contact address provided near the end of this Notice.

 

HOW WE PROTECT YOUR INFORMATION

 

The security of your personal data is important to us.  We have adopted generally accepted industry standards in connection with our data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data, username, password, transaction information, and data stored on the Site.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Mobile Information Sharing

 

At TWI Group, we are dedicated to protecting the privacy of our clients and website visitors. This section explains our practices for handling mobile information.

 

No Mobile Information Sharing for Marketing / Promotional Purposes

 

We want to assure our clients that we do not share mobile information with third parties or affiliates for marketing or promotional purposes. This commitment applies to all categories except for text messaging originator opt-in data and consent. Specifically:

  • Mobile Information Excluded: We do not share any mobile information (such as phone numbers) with third parties or affiliates for marketing or promotional purposes.
  • Exception for Text Messaging Originator Data: Text messaging originator opt-in data and consent are excluded from this restriction. We do not share this information with third parties.

 

DISCLOSURE OF YOUR PERSONAL DATA

 

We may disclose aggregated, or other non-personal data or information about our users without restriction.  We may disclose personal data about you in the following ways and/or to the following third parties:

  • Affiliates.  To our parents, affiliates, joint venturers, or promotion partners, for their use in a manner consistent with the purpose described in this Privacy Notice.
  • Agents and Service Providers.  To contractors, service providers, and other third parties we use to support our business, provide the Services, and who complete transactions or perform services on our behalf or for your benefit.
  • Marketing.  With your consent, to third parties for their own direct marketing purposes, to provide you with information about products that may be of interest to you, and for other purposes as specifically set forth in this Privacy Notice.
  • Legal Process.  As required by law, such as to comply with a subpoena or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • Certain Business Transfers.  As part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. It may also be disclosed in the event of insolvency, bankruptcy, or receivership. We will use reasonable efforts to direct any such transferee to use your personal data in a manner that is consistent with our Privacy Notice.
  • Consent.  In additional ways upon your consent.

 

YOUR RIGHTS

  • Request a Copy of your Personal Data.  You have the right to request a copy of any personal data that we hold about you.  If you would like a copy of your personal data, please contact us using the contact information below.  We may request proof of your identity before sharing such information.  If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information by contacting us using the contact information below.
  • Cease Processing or Delete Personal Data.  You may ask us to stop processing, or delete, the personally identifiable data we hold about you in certain circumstances.  It may not be possible for us to processing or delete all of the information we hold about you where we are fulfilling a transaction or have a legal basis to retain the information, however please contact us to discuss how we can assist you with your request.
  • Withdraw Consent.  When we process your information on the basis that you have consented to such processing, you have the right to withdraw your consent, or ask us to stop or restrict processing the personal data we have about you, at any time by contacting us using the contact information below.
  • Portability.  You may also ask us to transfer your personal data to a third party in certain circumstances.  If you would like any further information about your rights or how to exercise them, please contact us using the contact information below.
  • Complaints.  If you are in the European Union, you have the right to make a complaint at any time to the relevant data protection authority in your country.
  • Retention.  We will retain your information for as long as needed to fulfill your requests, provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.
  • Unsubscribe.  If you receive marketing emails from us, you can unsubscribe to our emails by clicking "unsubscribe" within each email.  You may not opt-out of service-related communications, which are not promotional in nature.

 

THIRD-PARTY WEBSITE

 

You may find advertising or other content on the Site that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from the Site.  In addition, these websites or services, including their content and links, may be constantly changing.  These websites and services may have their own privacy policies and customer service policies. Browsing on and interacting with any other website, including websites which have a link to the Site, are subject to that website’s own terms and policies.

COOKIES AND OTHER TRACKING TECHNOLOGIES

 

As is true of most websites, we gather certain information automatically and store it in log files.  This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Site.

  • We use cookies or similar technologies to store session information, analyze trends, administer the Site, track users' movements around the Site, and to gather demographic information about our user base as a whole.  A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive.
  • The length of time a cookie stays on your device or computer depends on its type.  “Persistent” cookies stay on your device or computer until they expire or are deleted.  “Session” cookies will only stay on your device or computer for so long as you are on our Site.
  • We use first-party cookies and third-party cookies on our Site.  First-party cookies belong to us. These cookies are essential for enabling user movement around our website and providing access to features such as your account and profile, resources restricted to customers, and other secure areas of the website. These cookies do not gather information about you that could be used for marketing purposes and do not remember where you have been on the internet. This category of cookies cannot be disabled. The table below provides more information about these cookies.

    Cookie Name

    Cookie Owner

    Purpose

    Expiration
    twigroup twigroup.com

    Session cookies allow users to be recognized within a website so any page changes or item or data selection you do is remembered from page to page.

    End of browser session
    twi_policy_accepted twigroup.com

    Safeguarding the acceptance of this privacy policy.

    6 months from set/update
  •  Third-party cookies are placed on your device or computer by a third party, such as an advertiser through our Website for purposes such as collecting information on user behavior, demographics, or personalized marketing. The table below provides more information about third-party cookies on our Website.

    Cookie Name

    Cookie Owner

    Purpose

    Expiration
    _ga

    Google Analytics

    Used to distinguish users.

    2 years

    _gid

    Google Analytics

    Used to distinguish users.

    24 hours

    _gat_gtag_UA_89364716_1

    Google Analytics

    Used to throttle request rate.

    1 minute
  • You can modify your cookie setting by following the instructions provided by your browser. These instructions are usually found in the “Tools,” “Help” or “Edit” tabs.  If you set your browser to disable cookies you may not be able to fully access and use our Site.  You can learn more about the choices provided by advertisers for individuals to decide how their information is collected and used by visiting the Digital Advertising Alliance (www.aboutads.info), the Network Advertising Initiative (www.networkadvertising.org/managing/opt_out.asp) or the European Digital Advertising Alliance (www.youronlinechoices.eu).

NOTICE

 

We have the discretion to update this Privacy Notice at any time.  When we do, we will revise the updated date at the top of this page.  If we make material changes to this Privacy Notice, we will notify you here, by email, or by means of a notice on the Site prior to the change becoming effective.  We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal data we collect.  You acknowledge and agree that it is your responsibility to review this Privacy Notice periodically and become aware of modifications.

 

CHILDREN UNDER THE AGE OF 16

 

The Site are not directed to, and we do not knowingly collect or solicit personal data from, children under the age of 16.  If we learn we have collected or received personal data from a child under the age of 16, we will delete that information.  If you believe we might have any information from or about a child under the age of 16, please contact us using the contact information below.

 

CALIFORNIA PRIVACY RIGHTS

 

California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes.  To make such a request, please contact us using the contact information below.

 

CONTACTING US

 

If you have any questions about this Privacy Notice, the practices of the Site, or your dealings with us, please contact us at:

 

TWI Group, Inc.
c/o Buflene Gephardt
6425 Montessori Street,
Las Vegas, Nevada 89113,
USA

 

YOUR ACCEPTANCE OF THESE PRIVACY NOTICE TERMS

 

By clicking “agree” below, you unconditionally agree to be bound by this Privacy Policy.  If you wish to withdraw your consent, you may contact us using the information provided above.  If you do not agree or later withdraw your consent, you may not be able to have full access to all of the features of the Website and we may not be able to provide you with all available Services or to personalize your experience and tailor our Services for you.

 

Additionally, your use of the Website or our Services constitutes your unconditional agreement to be bound by this Privacy Policy.

 

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