This Privacy Notice ("Privacy Notice") describes the privacy practices of The TW Group LLC and its subsidiaries and affiliates (collectively, "TW Group" or "us" or "we").
TW Group provides technology based services to other businesses - our clients. To take advantage of our services, our clients share with us information about their individual consumers, including contact details and shopping histories. We analyze that information the best serve the needs of our clients. We may also collect personal data for our own business purposes in connection with our business. We do not collect data in the EU or Switzerland, or transfer such information either into or out of the EU or Switzerland.
We may collect information:
The types of information we collect include:
We may collect information about individual consumers from our clients or - at clients' request- from their service providers. Our clients determine the scope of the information transferred to us, and the information we receive may vary by client. Typically, we may collect clients' consumers' contact details and demographic data, shopping histories, and details about consumers' interactions with marketing communications.
We, our service providers, and our business partners, may collect certain information about the use of our websites by automated means, such as cookies, web beacons and other technologies. Likewise, as part of our services, we may offer our clients the ability to install these types of technologies on their websites or in the emails they send to their customers; and if a client does so, we collect information on its behalf. A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We and our service providers and business partners may collect information about your online activities over time and across third-party websites when you use our websites and mobile applications.
Because there is not yet a consensus on how companies should respond to web browser-based do-not-track ("DNT") mechanisms, we do not respond to web browser-based DNT signals at this time. Please see the "Privacy Preferences, Rights and Choices" section below for information about how you may opt out of, or limit the use of, your browsing behavior for online behavioral advertising purposes.
The information we collect by automated means varies based on whether we are collecting information for our own business purposes or whether we are collecting information from or on behalf of our customers to provide our services.
The information collected by automated means for our own business purposes includes:
Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.
The information collected by automated means on behalf of our clients may include:
We may use personal information to:
We may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
We use personal information we collect from or on behalf of our clients to provide services to our clients at their direction. We do not use this information for TW Group's own purposes. We use personal information only as directed or authorized by our client. Typically, we are directed or authorized to use personal information collected on behalf of the client to:
We may share personal information for the purposes set out in this Privacy Notice with:
Service providers that perform services on our behalf, such as technology providers (including providers of payment processing, technology support, web hosting, and email communications)
Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will - where required by applicable law - make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.
In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
Individuals have certain rights and choices regarding TW Group's processing of their personal information. Please note, however, that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.
Individuals whose personal information TW Group processes on behalf of a client should contact that client to exercise the rights and choices described in this section.We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. For information about the rights and choices users have with respect to cookies and online tracking, please see the "Cookies and Other Information Collected by Automated Means" section of this Privacy Notice.
To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to TW Group's use or disclosure of your personal information will mean that TW Group will not be able to provide products or services to you or to otherwise engage with you.Access to Personal Information
You may request access to correct, amend, or delete the personal information that we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal information. We may reject your request to access or correct your information, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection. If you wish to exercise this right please contact us here at email@example.com
To limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
You may request that we delete your personal information. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
You may unsubscribe from receiving marketing or other commercial emails from TW Group by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms)
We may transfer personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where TW Group is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information.
We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we maintain against accidental, unlawful, or unauthorized access, disclosure, alteration, use, loss, or destruction. However, we cannot guarantee that the safeguards we maintain will ensure the security of the personal information.
We may provide links to websites and other third-party content that is not owned or operated by TW Group. The websites and third-party content to which we link may have separate privacy notices or policies. TW Group is not responsible for the privacy practices of any entity that it does not own or control.
TW Group reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.
We will retain personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. We will then destroy the personal information or anonymize the information, in accordance with applicable law.
You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or if you wish to access, delete or correct you information, by emailing email@example.com.