Revision effective and last updated on 8\/20\/2024<\/p>\n\n\n\n
Compliance with Legal Obligations and Protection of Individuals. We
may process personal data to comply with the law and our legal obligations,
as well as to protect you and other individuals from certain harms.<\/p>\n\n\n\n
\u2022 We may share personal data to enforce our Terms of Use and to protect
our and our partners\u2019 rights, property, or safety, and the rights, property,
and safety of our users and other third parties;
\u2022 We may share personal data to protect and secure the Services,
including against fraud and other misuse, and our and our partners\u2019
rights, property, or safety, and the rights, property, and safety of our
users and other third parties;
\u2022 We may share personal data with third parties when we believe it is
required by, or necessary to comply with, applicable law, a court order,
legal process, or other governmental or regulatory requests.
\u2022 We may share personal data with a buyer or other successor or
organization in the event of an actual or potential merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of
some or all of our assets, including as part of bankruptcy, liquidation, or
similar proceedings; and
\u2022 We may share personal data for such purposes as you may authorize or
direct us.
4. PROTECTING PERSONAL DATA
We recognize the importance of safeguarding the confidentiality of your
personal data. Accordingly, we employ reasonable measures designed to
protect your information from unauthorized access, disclosure and use.
However, no data transmission over the Internet or other network can be
guaranteed to be 100% secure. As a result, while we strive to protect
information transmitted on or through the Services, we cannot and do not
guarantee the security of any information you transmit on or through the
Services, and you do so at your own risk.
5. RETENTION OF PERSONAL DATA
We retain personal data for as long as necessary to carry out the processing
activities described above, including but not limited to providing the Services
or content, products, or other services we make available through the
Services, compliance with applicable laws, regulations, rules and requests of
relevant law enforcement and\/or other governmental agencies, and
protecting our and our business partners\u2019 and customers\u2019 rights, property, or
safety, and the rights, property, and safety of our users and other third parties.
6. YOUR CHOICES
You have choices about certain information we collect, how we communicate<\/p>\n\n\n\n
with you, and how we process certain personal data. When you are asked to
provide information, you may decline to do so; but if you choose not to
provide information that is necessary to provide any aspect of our Services,
you may not be able to use those Services.
Communications Opt-Out. You may opt out of receiving marketing or other
communications from us at any time through a given communications
channel (such as email or telephone) by following the opt-out link or other
unsubscribe instructions provided in any email message received, by
contacting us as provided at the end of this Privacy Notice, or by informing
our customer service representatives of your desire to opt out. If you wish to
opt out by sending us an email to the address provided below, please include
\u201cOpt-Out\u201d in the email\u2019s subject line and include your name and the email
address you used to sign up for communications in the body of the email.
Note that if you do business with us in the future, you may not, subject to
applicable law, opt out of certain automated notifications, such as order or
subscription confirmations, based on business transactions (e.g. e-
commerce).
Location Information. If you want to limit or prevent our ability to receive
location information from you, you can deny or remove the permission for
certain Services to access location information or deactivate location services
on your device. Please refer to your device manufacturer or operating system
instructions for instructions on how to do this.
Do Not Track. We use analytics systems and providers and participate in ad
networks that process personal data about your online activities over time
and across third-party websites or online services, and these systems and
providers may provide some of this information to us.
7. OTHER INFORMATION ABOUT PERSONAL DATA AND THE SERVICES
Our Privacy Notice also includes information about other practices with
respect to personal data, including:
\u2022 Collection of personal data from children;
\u2022 Location of personal data processing; and
\u2022 Links and references to third-party websites and services on our
Services.<\/p>\n\n\n\n
Collection of Personal Data from Children. We do not knowingly collect
personal data from children under the age of 13. If we become aware that we
have inadvertently received personal data from a child under the age of 13,
we will delete such information from our records. If you are the parent or
guardian of a child under the age of 13 and you believe we have inadvertently
received information about that child, please contact us as described in the
\u201cContact Information and Assistance\u201d section below. In addition, we
encourage parents to take an active role in their children\u2019s online activities
and to talk with their children about disclosing personally identifiable
information to web sites.
Processing in the United States. Please be aware that your personal data
and communications may be transferred to and maintained on servers or
databases located outside your state, province, or country. If you are located
outside of the United States, please be advised that we process and store all
information in the United States. The laws in the United States may not be as
protective of your privacy as those in your location. By using our Services, you
agree that the collection, use, transfer, and disclosure of your personal data
and communications will be governed by the applicable laws in the United
States.
Third-Party Websites and Services. As a convenience, we may reference or
provide links to third-party websites and services, including those of
unaffiliated third parties, our affiliates, service providers, and third parties with
which we do business. When you access these third-party services, you leave
our Services, and we are not responsible for, and do not control, the content,
security, or privacy practices employed by any third-party websites and
services. You access these third-party services at your own risk This Privacy
Notice does not apply to any third-party services; please refer to the Privacy
Notices or policies for such third-party services for information about how
they collect, use, and process personal data.
8. MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE
At any time, we may change this Privacy Policy. If we decide to change this
Privacy Policy, we will inform you by posting the revised Privacy Policy on the
Site. The changes will go into effect on the Revision Date shown in the revised
Privacy Policy. Your continued use of our Site or Services constitutes your
consent to the revised Privacy Policy.<\/p>\n\n\n\n
9. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION
If you are located in the European Union, you may have rights with respect to
your personal data. These rights may include, depending on the
circumstances surrounding the processing of personal data:
\u2022 The right to object to or request restriction of processing of personal
data or object to processing of personal data carried out pursuant to (i)
a legitimate interest or (ii) performance of a task in the public interest;
\u2022 The right to access your personal data and other information about our
processing of your personal data;
\u2022 The right to correct inaccurate personal data about you that we
process;
\u2022 The right to data portability, which means that you can request that we
provide certain personal data we hold about you in a format you can
more readily use;
\u2022 The right to erasure, which means that you can request deletion or
removal of certain personal data we process about you;
\u2022 Where processing of personal data about you is based on consent, the
right to withdraw your consent to such processing; and
\u2022 The right to lodge a complaint with a supervisory authority.
You may exercise these rights, to the extent they apply, by contacting us as
provided at the end of this Privacy Notice, or by following instructions
provided in this Privacy Notice or in communications sent to you. Please be
prepared to provide reasonable information to identify yourself and
authenticate your requests.
10. ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA
This section of the Privacy Notice applies solely to consumers who reside in
the State of California (\u201cconsumers\u201d or \u201cyou\u201d), and generally to the personal
data of a particular consumer or household (\u201cCalifornia Personal Data\u201d).
Provided, however, that California Personal Data does not include, and this
section of the Privacy Notice does not apply to:
\u2022 Health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPAA) and the California
Confidentiality of Medical Information Act (CMIA) or clinical trial data;
\u2022 Publicly available information from government records;
\u2022 Deidentified or aggregated consumer information;<\/p>\n\n\n\n
\u2022 Personal data, emergency contact information, and benefits
administration information we collect about a California resident in the
course of that California resident acting as our job applicant, our
employee, our owner, our director, our officer, or our contractor to the
extent we use that information within the context of that California
resident\u2019s role as our job applicant, employee, owner, director, officer, or
contractor; and
\u2022 Other information, including:
\u2022 personal data that we collect, process, sell, or disclose pursuant to
the federal Gramm-Leach-Bliley Act, and implementing
regulations, or the California Financial Information Privacy Act
(Division 1.4 (commencing with Section 4050) of the Financial
Code); and
\u2022 personal data covered by other sector-specific privacy laws,
including the Fair Credit Reporting Act (\u201cFCRA\u201d) and the Driver\u2019s
Privacy Protection Act of 1994.
California Personal Data We Collect. We have collected the following
categories of California Personal Data regarding consumers within the last 12
months:
\u2022 Personal information categories listed in the California Customer
Records statute (Cal. Civ. Code \u00a7 1798.80(e)), such as name, signature,
Social Security number, physical characteristics or description, address,
telephone number, passport number, driver\u2019s license or state
identification card number, insurance policy number, education,
employment, employment history, bank account number, credit card
number, debit card number, or any other financial information, medical
information, or health insurance information. Some personal
information included in this category may overlap with other
categories.
\u2022 Identifiers such as your real name, alias, postal address, zip code,
telephone number, email address, account name, Social Security
number, driver\u2019s license number, payment card numbers, passport
number, or other similar identifiers.
\u2022 Unique and online identifiers such as device identifiers, internet
protocol addresses, cookie identifiers, beacon identifiers, pixel tags or
mobile ad identifiers or similar technology, or other forms of persistent<\/p>\n\n\n\n
or probabilistic identifiers that can be used to identify a particular
consumer or device.
\u2022 Commercial information that identifies or could reasonably be linked to
you, such as products or services purchased, obtained, or considered, or
other purchasing or consuming histories or tendencies.
\u2022 Internet or other electronic network activity information that identifies
or could reasonably be linked to you, such as browsing history, search
history and information regarding an individual\u2019s interaction with an
internet website, application, or advertisement.
\u2022 Professional or employment-related information, such as current or
past job history or performance evaluations.
\u2022 Non-public education information (per the Family Educational Rights
and Privacy Act (20 U.S.C. \u00a7 1232g, 34 C.F.R. Part 99)) related to a student
and maintained by an educational institution or party acting on its
behalf, such as grades, transcripts, and class lists.
\u2022 Biometric information, such as genetic, physiological, behavioral, and
biological characteristics, or activity patterns used to extract a template
or other identifier or identifying information, such as, fingerprints,
faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other
physical patterns.
\u2022 Geolocation information, such as your specific, real-time physical
location or precise movements while you access our sites or apps if you
have enabled location services on your device.
\u2022 Sensory data, such as audio, electronic, visual, thermal, olfactory, or
similar information.
\u2022 Protected classification characteristics under California or federal law,
which includes age if 40 years or older, race, color, citizenship, religion
or creed, marital status, medical condition, physical or mental disability,
sex (including gender, pregnancy or childbirth and related medical
conditions), veteran or military status, genetic information (including
familial genetic information).
\u2022 Inferences drawn from personal information, such as person\u2019s
preferences, characteristics, psychological trends, predispositions,
behavior, attitudes, intelligence, abilities, or aptitudes.
Sources of California Personal Data. We may obtain the categories of
California Personal Data that we collect as indicated above from the following
categories of sources.<\/p>\n\n\n\n
\u2022 Directly from you. For example, through website forms you complete
or ordering our products and services.
\u2022 Automatically and indirectly from you, such as through logging and
analytics tools, cookies, pixel tags, and other automatic data collection.
\u2022 From third parties, such as our service providers, consumer data
resellers, services that make user-generated content available to others,
communications services, social networks and social media online
services, affiliates, and other business partners.
Use of California Personal Data. We may use the categories of California
Personal Data that we collect, as described above, for one or more of the
business purposes and commercial purposes described in the \u201cHow Do We
Use and Share Personal Data?\u201d section above.
Sharing California Personal Data. We may disclose the categories of
California Personal Data that we collect as indicated above to the categories
of third parties described in the \u201cHow Do We Use and Share Personal Data?\u201d
section above. In the preceding 12 months, we may have disclosed categories
of California Personal Data that we collected, as described above, for a
business purpose.
In the preceding 12 months, we have not sold California Personal Data. We do
not and will not sell your California Personal Data.
California Personal Data Rights and Choices. The California Consumer
Privacy Act of 2018 (\u201cCCPA\u201d) provides consumers with specific rights
regarding their California Personal Data. This section describes the rights you
may have and explains how to exercise those rights.
\u2022 Access to Specific Information and Data Portability Rights. You have
the right to request that we disclose certain information to you about
our collection, use, and disclosure of your California Personal Data over
the past 12 months. If we receive and confirm a verifiable consumer
request from you pursuant to the \u201cExercising Access, Data Portability,
and Deletion Rights\u201d section below, we will disclose one or all of the
following depending on the scope of the request:
\u2022 The categories of California Personal Data we collected about you
over the past 12 months.<\/p>\n\n\n\n
\u2022 The categories of sources for the California Personal Data we
collected about you over the past 12 months.
\u2022 Our business or commercial purpose for collecting California
Personal Data about you over the past 12 months.
\u2022 The categories of third parties with whom we shared California
Personal Data over the past 12 months.
\u2022 The specific pieces of California Personal Data we collected about
you over the past 12 months.
\u2022 The categories of California Personal Data about you that we
disclosed for a business purpose, to the extent we have made
such disclosures.
\u2022 Deletion Request Rights. Subject to certain exceptions, you have the
right to request that we delete the California Personal Data that we
collected about you. Once we receive and confirm your verifiable
consumer request, we will delete your California Personal Data from
our records, unless an exception applies
\u2022 Exercising Access, Data Portability, and Deletion Rights. To exercise
the access, data portability, and deletion rights described above, please
submit a verifiable consumer request to us by emailing us at:
compliance@twitchellcorp.com.
Only you, or an authorized agent registered with the California Secretary of
State that you authorize to act on your behalf, may make a verifiable
consumer request related to your California Personal Data. You may also
make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data
portability twice within a 12-month period. Your request must provide
information sufficient to permit us to reasonably verify you are the person
about whom we collected California Personal Data, or an authorized
representative of that person. Your request also must include sufficient detail
for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal
Data if we cannot verify your identity or authority to make the request and
confirm the California Personal Data relates to you.<\/p>\n\n\n\n
If you have an online account with us, we will deliver our written response to
that online account. If you do not have an online account with us, we will
deliver our written response by mail or electronically.
Making a verifiable consumer request does not require you to create an
account with us. However, if you have a password-protected account with us
we consider requests made through that account sufficiently verified when
the request relates to personal information associated with that specific
account.
Any disclosures we provide will only cover the 12-month period preceding our
receipt of the verifiable request. If we cannot fulfill, or are permitted to
decline, your request then we will alert you or your authorized representative.
For data portability requests, we will select a format to provide your California
Personal Data that is readily usable.
If your request is manifestly unfounded, repetitive, or excessive, including if
you have made several repetitive requests, we may charge a reasonable fee
to respond. We also may decline to respond, in which case we will notify you.
Non-Discrimination. You have a right to not receive discriminatory treatment
for exercising your access, data portability, and deletion rights described
above. Except to the extent permitted by the CCPA, we will not discriminate
against you for exercising the access, data portability, and deletion rights
described above.
11. APPLICABILITY OF THIS PRIVACY NOTICE
This Privacy Notice is subject to the Terms of Use that govern your use of the
Services. This Privacy Notice applies regardless of the means used to access
or provide information through the Services.
This Privacy Notice does not apply to information from or about you collected
by any third-party services, applications, or advertisements associated with, or
websites linked from, the Services. The collection or receipt of your
information by such third parties is subject to their own privacy policies,
statements, and practices, and under no circumstances are we responsible or
liable for any third party\u2019s compliance therewith.<\/p>\n\n\n\n
12. CONTACT INFORMATION AND ASSISTANCE
If you have any questions about this Privacy Notice, or if you have submitted
or another person has submitted personally identifiable information about
you through this web site, and you would like to have that information
changed or deleted, please contact:
To ask questions or comment about this privacy policy and our privacy
practices, contact us at: compliance@twitchellcorp.com.<\/p>\n\n\n\n
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