Description of Users and Acceptance of Terms
GDPR and Privacy Shield Notice
Natural persons located in the European Economic Area (“EEA”) should review the General Data Protection Regulation (“GDPR”) and Privacy Shield Notice here.
In addition, the Privacy Shield Notice should be reviewed if your personal information is transferred from the EEA or Switzerland to the US, pursuant to the E.U.-U.S. or Swiss-U.S. Privacy Shield.
The Information We Collect/or Receive; the Purpose of Collection and Use
In the course of operating the Websites and/or interacting with you, we will collect (and/or receive) the following types of information.
1. Contact Information.
When you sign up to receive any of our newsletters, respond to a survey, register for a class, purchase any product or service, or sign up to become our affiliate partner, you may be required to provide us with certain information about yourself, such as your name, address, e-mail address, social media information, phone number, PayPal address (only if you sign up to become our affiliate partner) and SSN#/Tax ID# (only if you sign up to become our affiliate partner) (the “Contact Information”). The Contact Information is used to provide the requested product or service or information and to contact you for purposes of direct marketing of our current and future products and services.
2. Order Information.
When you place an Order, you must provide us with certain information about the products and services you are seeking to purchase. Such information is collectively called the “Order Information.” The Order Information is used to fulfill your Order.
3. Billing Information.
When you wish to purchase a product or service, you will be required to provide certain information in addition to the Personal Information and Order Information noted above. Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information. Such information is collectively called the “Billing Information.” Billing Information is collected and processed by our third-party payment processor operating as our agent (see, Onward Transfers to Third Parties). We do not directly obtain or process any Billing Information.
4. Other Information.
In addition to the information noted above, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:
a. From You. Additional information about yourself that you voluntarily provide to us (e.g., via a survey), such as household income range, gender, product and service preferences, and other information that does not identify you personally.
b. From Your Activity. Information that we automatically collect when you use the Websites, including, without limitation:
IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Websites you visit; and similar data; and
Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.
Below is a list of analytics providers that we use; however, such list may be subject to change based on how we wish to understand the user experience and we will endeavor to update it diligently. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their analytics collection.
For Google Analytics, please visit: https://www.google.com/analytics
e. From Other Sources. We also may collect or receive information from third parties, such as Facebook and/or other third-party social media sites.
Information Collected by or Through Third-Party Advertisers/Remarketers
Below is a list of advertising/remarketing providers that we use; however, such list may be subject to change based on the campaigns that we run and we will endeavor to update it diligently. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their targeted ads or other personalization features. Please note you will not necessarily be opted-out of advertising or content generally; you may still receive generic ads or content.
For Facebook, please visit: http://www.facebook.com/about/privacy
For Twitter, please visit: https://twitter.com/en/privacy
For Google, please visit: https://support.google.com/ads/answer/2662922?hl=en
Information Collected Through the Facebook Community Group
In an ongoing effort to better understand our visitors, customers, and our products and services, we may analyze the Order Information and Other Information in aggregate form in order to operate, maintain, manage, and improve the Websites and/or our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
Sharing with Third Parties
Like many businesses, we contract with other companies to perform certain business-related services. We may disclose your information, including personal information in some cases, to certain types of third-party companies, but only to the extent needed to enable them to provide such services, including, without limitation, technical assistance, order fulfillment, customer service, marketing assistance, payment processing, survey collection, promotional and marketing assistance, and business operations. These other companies will have access to your information, including personal information in some cases, only as necessary to perform their functions and to the extent permitted by law. We may also disclose your information, including any personal information, to any of our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control with us in order to support delivery of our products and services.
Disclosures to Public Authorities
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Opt-Out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by e-mailing the instructions to this email address: firstname.lastname@example.org. Please allow us a reasonable time to process your request.
Accessing and Modifying Personal Information and Communication Preferences
In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Twirl Connect LLC marketing email. Customers cannot opt out of receiving transactional e-mails related to their account or their Orders. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.
Information You Share on Public Forums
You should think carefully before disclosing any information in any Public Forum.
How We Protect the Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Retention of Personal Information
Important Notice to Non-U.S. Residents
It is important to note that the Websites and their servers are operated in the United States. If you are located outside of the U.S., please be aware that any information provided to or collected by us, including personal information, will be transferred from your country of origin to the U.S. Except in the case of data transfers under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or allow us to collect such data through our Websites, constitutes your consent to this data transfer.
Twirl Connect LLC does not monitor, recognize, or honor any behavioral advertising opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
California residents should review their specific rights under the California Consumer Privacy Act (CCPA) here.
How to Contact Us
Write to us at:
Twirl Connect LLC
1225 W. 62nd Street
Kansas City, MO 64113