Our Personal Information Retention Criteria: The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) requires that we disclose the criteria we use to determine how long we will retain each category of personal information we collect. Oftentimes, our records contain several of these categories of personal information combined together and therefore we consider, on a case-by-case basis, a number of factors to assess how long personal information is retained. These factors include what personal information is reasonably necessary to (i) provide our products and services or administer our relationship with an individual; (ii) protect our business, employees, organization and others; (iii) fulfill our legal and regulatory obligations; and (iv) investigate and address issues which may include safety concerns, potential security incidents or policy violations.
We may collect your personal information in different ways. Below, you will find additional details and examples regarding how we may collect your personal information.
Here are more details and examples regarding how we may use your personal information:
Here are more details and examples regarding how we may disclose your personal information:
Based on your state or country of residence, you may have the rights listed below with respect to the personal information that we maintain about you. We may take steps to verify your identity, as permitted or required under applicable law, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.
Please note that we do not knowingly sell or share the personal information of consumers under 16 years.
If you wish to exercise your rights under this section, you can contact us at [email protected]. Please include your name, email address, and state of residence, and indicate you are making a “Privacy Rights” request. If we deny your rights request and you would like to appeal, you may contact us at [email protected]. You also have the right to make a complaint to the local supervisory authority in your state or country.
Agents. Agents that you have authorized to act on your behalf may also submit privacy requests as instructed above. The agent must also provide evidence that they have your permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.
Additional Information for California Residents. If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at [email protected]. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.
Our Platform is intended for general audiences and not for children under the age of 16. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, or from children under the age of 16, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU or UK residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU or UK resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
You have certain choices about how we collect, use and disclose your information in connection with our use of cookies and our provision of electronic communications. Certain choices you make are browser and device specific.
Cookies & Other Tracking Technologies:
Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to “do not track” signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
Marketing Communications:
You can opt out of receiving our marketing communications, which we may send by email. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.
TWG Global takes technical and organizational security measures to protect the information provided via the websites from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to TWG Global via the Internet.
Your information will be processed for the purposes described herein. As described above, we also may subcontract the processing of your data to, or otherwise share your data with, other members within TWG Global and its affiliates, service providers, and business partners in other countries (including countries outside of the United States, the UK and the EEA), in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of the website to you and the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.
If we provide any information about you to third party information processors, we will take appropriate measures to ensure such companies protect your information adequately and in accordance with applicable law. These measures may include entering into an appropriate data transfer mechanism in accordance with EU, UK and/or other data protection laws to govern the transfers of such data.
Our Platform may contain links to third-party websites such as social media sites. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third parties.
Please feel free to contact us if you have any questions about this Policy or our information practices. You can reach us via email at [email protected].
We reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our websites, or advances in technology. We will make the revised Policy accessible through the websites, so you should review the Policy periodically. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the websites, you are confirming that you have read and understood the latest version of this Policy.