Privacy Policy

PRIVACY POLICY

The following privacy policy (“ Policy”) is designed to inform visitors (“you”, “your”, “customers”, “visitors” or “users”), of the policies and procedures that will apply to the collection, security, use and disclosure of any of your personal data collected by Twinsetter, LLC (“Twinsetter”, “we”, “us”, “company” or “our”) through www.twinsetterproluxe.com .  It also describes your choices regarding use, access and correction of your Personal Data (defined below) and any of the data related to products and services (collectively, "Services") is collected, protected and used. This Policy also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy is a legally binding agreement between You and Twinsetter LLC. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Agreement. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

BY PROCEEDING TO USE OUR SITE, TRANSACTING WITH US, AND/OR ACQUIRING MERCHANDISE, YOU CONSENT THAT WE MAY PROCESS THE PERSONAL DATA THAT WE COLLECT FROM YOU IN ACCORDANCE WITH THIS PRIVACY POLICY.

CHANGES AND AMENDMENTS

We reserve the right to modify this Policy or its terms relating to the Website and Services from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

COLLECTION OF PERSONAL INFORMATION

You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features on the Website, you may be asked to provide certain Personal Information or Personal Data. “Personal Data” means data that allows someone to identify or contact you, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill any online forms on the Website. When you give us your information.  You may give us your Personal Data in the following ways: (i) signing up for newsletters, (ii) sending us an email, (iii) acquiring merchandise, and/or (iv) participating in a special promotion. When required, this information may include the following:

Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources such as public databases and our joint marketing partners. You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.

USE AND PROCESSING OF COLLECTED INFORMATION

In order to make the Website and Services available to you, or to meet a legal obligation, we need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

AUTOMATIC COLLECTION OF NON-PERSONAL INFORMATION

When you open the Website, our servers automatically record information that your browser sends. “Non-Personal Data” may include information such as your device's IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, information you search for on the Website, access times and dates, and other statistics.

Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

We may also use your Non-Personal Data, Log Data and Personal Network Information to: (i) administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; (ii) improve our Site to ensure that content is presented in the most effective manner for you and for your device; (iii) allow you to participate in interactive features of our service, when you choose to do so; (iv) keep our Site safe and secure as part of our on-going efforts to do so and ensure a safe visit for all our Site visitors.

We collect Device Information using the following technologies:

    - “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

    - “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

    - “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

We may use Google Analytics to help analyze how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to our Site. We use the information we get from Google Analytics only to improve our Site. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Site, this particular Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Site is governed by the Google Analytics’ Terms of Use and Privacy Policy.

DISCLOSURE RETENTION AND SHARING OF INFORMATION

(a) Service Providers. We may from time to time use certain third-party business partners, suppliers, and sub-contractors (including companies and individuals) to perform Site-related services (for example, without limitation, website hosting, maintenance services, database management, Web analytics, and improvement of the Site's features) (“Service Providers”). These Service Providers may have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

(b) Compliance with laws and law enforcement. Twinsetter cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your Personal Data to government or law enforcement officials or private parties in response to lawful requests if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation (such as to meet national security or law enforcement requirements), to enforce or apply our Terms and Conditions or respond to claims and legal process, to protect the property and rights of Twinsetter or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal activity (including for the purposes of fraud protection).

Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Website and Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements.

In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Information will likely be among the assets transferred.

MANAGING INFORMATION

You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account on the Website or simply by contacting us.

THE RIGHTS OF USERS

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

BILLING AND PAYMENTS

In case of services requiring payment, we request credit card or other payment account information, which will be used solely for processing payments. Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. Where necessary for processing future payments and subject to your prior consent, your financial information will be stored in encrypted form on secure servers of our reputed payment gateway service provider who is beholden to treating your Personal Information in accordance with this Policy. All direct payment gateways adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Website and Services are also in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users. Scans for malware are performed on a regular basis for additional security and protection.

COOKIES

The Website and Services use "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

We may use cookies to collect, store, and track information for statistical purposes to operate the Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To learn more about cookies and how to manage them, visit internetcookies.org. Users can control the use of Cookies at the individual browser level. If you reject Cookies, you may still use our Site, but your ability to use some features or areas of our site may be limited.

DO NOT TRACK SIGNALS

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. The Website and Services do not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

ADVERTISEMENTS

We may permit certain third party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These coAs described in this Privacy Policy, we use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising from third parties we utilize by:

    -FACEBOOK - https://www.facebook.com/settings/?tab=ads

    -GOOGLE - https://www.google.com/settings/ads/anonymous

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info/.

 

We may share your Personal Data with third parties in connection with marketing and promotional material distribution related to Twinsetter, but note that we never share your payment information with third-party marketer companies may deliver ads that might place cookies and otherwise track user behavior.

EMAIL MARKETING

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

INFORMATION SECURITY

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

DATA BREACH

In the event we become aware that the security of the Website and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email

PRIVACY OF CHILDREN

We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us. You must also be at least 16 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).

CALIFORNIA PRIVACY RIGHTS

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of the information disclosure provided by us pursuant to Section 1798.83 of the California Civil Code, please contact us at the below address:

Twinsetter, LLC
Attn: Privacy Policy Request
_________________________
________________________________
Email: info@twinsetter.com - Subject “PRIVACY POLICY REQUEST”

INTERNATIONAL TRANSFERS OF INFORMATION

Information, including information collected in the European Economic Area ("EEA") may be transferred, stored and processed by us and our Services Providers in the United States and other countries whose data protection laws may be different than the laws of your country. We will protect your Personal Data in accordance with this Privacy Policy wherever it is processed and take appropriate steps to protect the information in accordance with applicable laws. If you live in the EEA, or a similar international area, you may have additional privacy rights available to you under applicable laws. We will process your requests in accordance with applicable data protection laws. If you would like to exercise any of the below rights, please contact info@twinsetter.com so that we may consider your request in accordance with applicable law.

In certain circumstances, you have the following data protection rights:

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

CONTACTING US

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to info@twinsetter.com or write a letter to Twinsetter, LLC, to Twinsetter LLC, P.O. Box 9085 Westwego, Louisiana 70096.

 

Updated: November 22, 2021