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.
• 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.
• 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.
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.
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.
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.
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.
• 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.
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.
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
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.
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 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.
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
By continuing, 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.
