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Privacy Policy
This Privacy Policy sets out how we, Twilight Brands collect, store and use information about you when you use or interact with our website, twilightbrands.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from August 8th 2019.
Contents
Summary
Our details
Information we collect when you visit our website
Information we collect when you contact us
Information we collect when you interact with our website
Information we collect when you place an order on our website
Our use of automated decision-making and profiling
How we collect or obtain information about you from third parties
Disclosure and additional uses of your information
How long we retain your information
How we secure your information
Transfers of your information outside the European Economic Area
Your rights in relation to your information
Your right to object to the processing of your information for certain purposes
Sensitive Personal Information
Changes to our Privacy Policy
Children’s Privacy
California Do Not Track Disclosures
Copyright, credit and logo
Summary
This section summaries how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
Data controller: Twilight Brands, INC
How we collect or obtain information about you:
When you provide it to us (e.g. by contacting us, placing an order on our website, sign up for our email newsletter, take a quiz, or create an account).
from your use of our website, using cookies and similar technologies, and
Occasionally, from third parties.
Information we collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), your answers to quizzes or surveys, and information about your internet connection.
How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyses your use of our website, and in connection with our legal rights and obligations.
Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, and to fulfil any contracts we enter into with you, and where required by law or to enforce our legal rights.
Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.?
How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled how long we retain your information.
How we secure your information: using appropriate technical and organizational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and by only trusted individuals that have been trained and briefed on appropriate handling of personal information.
Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional analytical and advertising cookies. For more information, please visit our cookies policy here: https://twilightbrands.com.com/pages/cookie-policy
Your rights in relation to your information
to access your information and to receive information about its use
to have your information corrected and/or completed
to have your information deleted
to restrict the use of your information
to receive your information in a portable format
to object to the use of your information
to withdraw your consent to the use of your information
to complain to a supervisory authority
Sensitive personal information: we do not collect sensitive personal information on you.
Our details
The data controller in respect of our website is Twilight Brands, 2200 S. Busse Road, Suite A.
Mount Prospect, IL 60056. You can contact the data controller by writing to Twilight Brands, or sending an email to info@twilightbrands.com
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party server to host our website called Shopify Inc., the privacy policy of which is available here https://www.shopify.com/legal/privacy . Our website server automatically logs the IP address you
use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our website servers are located in the United States of America and Canada and, accordingly, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area]].
Use of website server log information for IT security purposes
Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, We/we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1) (c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our and a third party’s legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical and advertising cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
Email and Contact Form
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1) (b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Mail
If you contact us by mail, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1) (b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Legal basis for processing:
Your consent (Article 6(1) (a) of the General Data Protection Regulation).
Consent:
You give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Information you submit to subscribe for our text messages will be stored outside the European Economic Area on our third party text message provider’s servers in Canada. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) in the texts we send to allow us to assess the level of engagement our texts receive by measuring information such as the delivery rates, open rates and click through rates which our texts achieve. We will only use web beacons in our texts if you have consented to us doing so. For more information on how we use web beacons in our texts, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
For more information about our third-party text message service provider, please see their privacy policy which is available here: https://www.chatkit.com/privacy-policy.
E-Newsletter
When you sign up for our e-newsletter on our website or opt to receive news, offers, updates on out-of-stock items from us by entering your name and email address and clicking subscribe or ticking a box at checkout indicating that they would like to receive your e-newsletter, we collect your email address, information about your browser, information about the page you signed up on, and any other additional information you may provide to us.
Legal basis for processing: your consent (Article 6(1) (a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and administer our mailing list, Klaviyo. Their privacy policy is available here: https://www.klaviyo.com/privacy .
Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails]
We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
or more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
[For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy
Registering on our website
When you register and create an account on our website, we collect the following information: Email address, IP address, and any other information you provide to us when you complete the registration form.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to provide access to content, secure access to order history and status for customers and to facilitate the running and operation of our business.
Transfer and storage of your information
Information you submit to us via the registration form on our website will be stored outside the European Economic Area on our third party hosting provider’s servers in The United States and Canada. Our third party hosting provider is Shopify with servers located throughout North America and where its sub-processors may be located. Their privacy policy is available here: https://www.shopify.com/legal/privacy
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Information we collect when you place an order on our website
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order
Mandatory information
When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), billing name, and information about your browser.
If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.
Optional information
We also collect optional information from you, such as your phone number or information about how your experience was in the form of a survey. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.
If you do not supply the optional information requested at checkout, such as phone number. we will not be able to contact you by phone or SMS.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation.
Legitimate interests: finding out how a customer’s experience was to improve your business’ website or to be able to contact the customer by phone where (if necessary) in relation to their order.[2]
AND
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party payment processor (Shopify Payments) and a fraud gateway to ensure that your order is not fraudulent. Your payment will be processed by Shopify Payments.
Shopify Payments collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policy via the following link(s): Shopify Payments: https://pay.shopify.com/tos-privacy-policy
Transfer and storage of your information
Shopify Payments is located in Canada. Information relating to the processing of your payment is stored outside the European Economic Area on our [third party payment processor’s servers in Canada and the United States.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Marketing communications
At checkout and upon first arriving to the site you will have the option of receiving marketing communications from us.
Our similar goods and services
You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt out or clicking ‘unsubscribe’ in any email from us.
We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising our products and services.
Transfer and storage of your information
We use a third party service to administer our mailing list, Klaviyo, Inc. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons [and similar technologies] in emails
We use technologies such as web beacons (small graphic files in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy
Our goods and services
You can opt in to receiving marketing communications from us in relation to our goods and services by email ticking a box indicating that you would like to receive such communications during checkout or at any time while browsing the site by entering your email address into our newsletter sign-up form.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third party service to administer our mailing list, Klaviyo, Inc. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons [and similar technologies] in emails
We use technologies such as web beacons (small graphic files in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include partner companies who we are doing a joint promotion with.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Our use of automated decision-making and profiling[3]
We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: https://twilightbrands.com/pages/cookie-policy
Automated decision making
Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
Use of automated decision making for display advertising]
We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
Significance and envisaged consequences: cookies will be used to recognize the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behavior.
How to object: you can block these cookies by using the cookies control management tool on our site or by opting out of seeing personalized ads by following the instructions here:https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy: https://twilightbrands.com/pages/cookie-policy
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyses or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Use of profiling for web analytics
Collects information such as your location (based on your IP address) and your behavior (based on cookies) when you access our website (such as the pages you visit and what you click on) and how much you are spending on our site. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy. Information collected about you, once collected is anonymised and stored on an aggregate basis. IP addresses are anonymized at the point of collection on our site.
Logic involved: by automatically analyzing and categorizing information such as the location (based on IP address) as well as the behavior and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behavior and device on our website (unless you have opted out from receiving such cookies by using our cookie control tool and your location will be analyzed based on your IP address. We may target advertisements or content on our site based on the level of interest we receive from certain visitors and their behavior on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) and the basis upon you give us consent to use this by opting into cookie tracking.
[Legitimate interest: : improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires. Also to serve advertisements to you which seem most relevant to the visitor.
Use of profiling in marketing emails
We use web beacons in our marketing emails to analyze who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy (https://twilightbrands.com/pages/cookie-policy ).
Logic involved: by analyzing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
Significance and envisaged consequences: your behavior when you open our emails will be tracked using small gif files (web beacons), including open rates, click through rates, and what items you clicked on in an email.
How to object: You may object to this by contacting us at info@twilightbrands.com or you may opt out by using our cookie control tool.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: analyzing the level of engagement and effectiveness of our marketing emails and content
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
Email provider(s), including Klaviyo Inc. Their privacy policy is available here: com/privacy
Hosting provider(s), including Shopify Inc. Their privacy policy is available here: com/privacy
Our third party service providers are located in the United State and Canada.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display all the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email at info@twilightbrands.com and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Sharing your information within our business’ group of companies, including Seed Beauty for internal administrative purposes, including client, customer and employee information.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business effectively.
AND
Legal basis for processing: necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract., for example because of the services or information you have requested.
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal basis for processing: compliance with a legal obligation (Article 6(1) (c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of the United States of America.[4]
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United States’ legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods
Order information: when you place an order for goods and services, we retain that information indefinitely or until you request that we delete unless this conflicts with our compliance of a legal responsibility.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry and indefinitely afterward unless it is requested to be deleted AND it does not interfere with our compliance with laws and our legitimate business interest.
E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
whether we have any legal basis to continue to process your information (such as your consent);
how valuable your information is (both now and in the future);
any relevant agreed industry practices on how long information should be retained;
the levels of risk, cost and liability involved with us continuing to hold the information;
how hard it is to ensure that the information can be kept up to date and accurate; and
Any relevant surrounding circumstances (such as the nature and status of our relationship with you).
How we secure your information
We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
using secure servers to store your information;
verifying the identity of any individual who requests access to information prior to granting them access to information;
using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
only transferring your information via closed system or encrypted data transfers
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area
We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we and our data processors process data may have laws which are different, and potentially not as protective, as the laws of your own country.
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organization in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Server log information
Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company, Shopify. You can access their privacy policy here: www.shopify.com/privacy
Country of storage: Canada and the United States
Safeguard(s) used: our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Contact form and Email
Information you submit to us via our contact form is transferred outside the EEA and stored on our third party email and customer service systems. Our email provider is Klaviyo Inc
E-Newsletter
Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Klaviyo. You can access their privacy policy here: www.klaviyo.com/privacy
[Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our[third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Payment Processor
Information you submit to us by our third party payment processor, Shopify Payments, is transferred outside the EEA and stored on their servers. You can access their privacy policy here: https://pay.shopify.com/tos-privacy-policy
Country of storage: The United States and Canada. These countries are not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our payment processor has self-certified its compliance with the EU-U.S. Privacy Shield.
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to info@twilightbrands.com
to request access to your informationand information related to our use and processing of your information;
to request the correction or deletionof your information;
to request that we restrict our useof your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format(e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
to object to the processing of your information for certain purposes(for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Twilight Brands, INC C/O GDPR Handling 1600 Westar Dr. Oxnard, CA 93033 USA or sending an email to: info@twilightbrands.com
to object to us using or processing your information where we use or process it in order to carry out a task in the public interestor for our legitimate interests, including ‘profiling’ (i.e. analyzing or predicting your behavior based on your information) based on any of these purposes; and
To object to us using or processing your information for direct marketing purposes(including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
clicking the unsubscribe linkcontained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://twilightbrands.com/pages/cookie-policy
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@twilightbrands.com
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user.
For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
Copyright, credit and logo
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy.
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.
Contents
Summary
Our details
Information we collect when you visit our website
Information we collect when you contact us
Information we collect when you interact with our website
Information we collect when you place an order on our website
Our use of automated decision-making and profiling
How we collect or obtain information about you from third parties
Disclosure and additional uses of your information
How long we retain your information
How we secure your information
Transfers of your information outside the European Economic Area
Your rights in relation to your information
Your right to object to the processing of your information for certain purposes
Sensitive Personal Information
Changes to our Privacy Policy
Children’s Privacy
California Do Not Track Disclosures
Copyright, credit and logo
Summary
This section summaries how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
Data controller: Twilight Brands, INC
How we collect or obtain information about you:
When you provide it to us (e.g. by contacting us, placing an order on our website, sign up for our email newsletter, take a quiz, or create an account).
from your use of our website, using cookies and similar technologies, and
Occasionally, from third parties.
Information we collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), your answers to quizzes or surveys, and information about your internet connection.
How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyses your use of our website, and in connection with our legal rights and obligations.
Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, and to fulfil any contracts we enter into with you, and where required by law or to enforce our legal rights.
Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.?
How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled how long we retain your information.
How we secure your information: using appropriate technical and organizational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and by only trusted individuals that have been trained and briefed on appropriate handling of personal information.
Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional analytical and advertising cookies. For more information, please visit our cookies policy here: https://twilightbrands.com.com/pages/cookie-policy
Your rights in relation to your information
to access your information and to receive information about its use
to have your information corrected and/or completed
to have your information deleted
to restrict the use of your information
to receive your information in a portable format
to object to the use of your information
to withdraw your consent to the use of your information
to complain to a supervisory authority
Sensitive personal information: we do not collect sensitive personal information on you.
Our details
The data controller in respect of our website is Twilight Brands, 2200 S. Busse Road, Suite A.
Mount Prospect, IL 60056. You can contact the data controller by writing to Twilight Brands, or sending an email to info@twilightbrands.com
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party server to host our website called Shopify Inc., the privacy policy of which is available here https://www.shopify.com/legal/privacy . Our website server automatically logs the IP address you
use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our website servers are located in the United States of America and Canada and, accordingly, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area]].
Use of website server log information for IT security purposes
Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, We/we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1) (c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our and a third party’s legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical and advertising cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
Email and Contact Form
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1) (b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
If you contact us by mail, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1) (b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Legal basis for processing:
Your consent (Article 6(1) (a) of the General Data Protection Regulation).
Consent:
You give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Information you submit to subscribe for our text messages will be stored outside the European Economic Area on our third party text message provider’s servers in Canada. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) in the texts we send to allow us to assess the level of engagement our texts receive by measuring information such as the delivery rates, open rates and click through rates which our texts achieve. We will only use web beacons in our texts if you have consented to us doing so. For more information on how we use web beacons in our texts, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
For more information about our third-party text message service provider, please see their privacy policy which is available here: https://www.chatkit.com/privacy-policy.
E-Newsletter
When you sign up for our e-newsletter on our website or opt to receive news, offers, updates on out-of-stock items from us by entering your name and email address and clicking subscribe or ticking a box at checkout indicating that they would like to receive your e-newsletter, we collect your email address, information about your browser, information about the page you signed up on, and any other additional information you may provide to us.
Legal basis for processing: your consent (Article 6(1) (a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and administer our mailing list, Klaviyo. Their privacy policy is available here: https://www.klaviyo.com/privacy .
Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails]
We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
or more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
[For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy
Registering on our website
When you register and create an account on our website, we collect the following information: Email address, IP address, and any other information you provide to us when you complete the registration form.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to provide access to content, secure access to order history and status for customers and to facilitate the running and operation of our business.
Transfer and storage of your information
Information you submit to us via the registration form on our website will be stored outside the European Economic Area on our third party hosting provider’s servers in The United States and Canada. Our third party hosting provider is Shopify with servers located throughout North America and where its sub-processors may be located. Their privacy policy is available here: https://www.shopify.com/legal/privacy
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Information we collect when you place an order on our website
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order
Mandatory information
When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), billing name, and information about your browser.
If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.
Optional information
We also collect optional information from you, such as your phone number or information about how your experience was in the form of a survey. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.
If you do not supply the optional information requested at checkout, such as phone number. we will not be able to contact you by phone or SMS.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation.
Legitimate interests: finding out how a customer’s experience was to improve your business’ website or to be able to contact the customer by phone where (if necessary) in relation to their order.[2]
AND
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party payment processor (Shopify Payments) and a fraud gateway to ensure that your order is not fraudulent. Your payment will be processed by Shopify Payments.
Shopify Payments collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policy via the following link(s): Shopify Payments: https://pay.shopify.com/tos-privacy-policy
Transfer and storage of your information
Shopify Payments is located in Canada. Information relating to the processing of your payment is stored outside the European Economic Area on our [third party payment processor’s servers in Canada and the United States.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Marketing communications
At checkout and upon first arriving to the site you will have the option of receiving marketing communications from us.
Our similar goods and services
You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt out or clicking ‘unsubscribe’ in any email from us.
We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising our products and services.
Transfer and storage of your information
We use a third party service to administer our mailing list, Klaviyo, Inc. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons [and similar technologies] in emails
We use technologies such as web beacons (small graphic files in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy
Our goods and services
You can opt in to receiving marketing communications from us in relation to our goods and services by email ticking a box indicating that you would like to receive such communications during checkout or at any time while browsing the site by entering your email address into our newsletter sign-up form.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third party service to administer our mailing list, Klaviyo, Inc. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons [and similar technologies] in emails
We use technologies such as web beacons (small graphic files in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include partner companies who we are doing a joint promotion with.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Our use of automated decision-making and profiling[3]
We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: https://twilightbrands.com/pages/cookie-policy
Automated decision making
Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
Use of automated decision making for display advertising]
We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
Significance and envisaged consequences: cookies will be used to recognize the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behavior.
How to object: you can block these cookies by using the cookies control management tool on our site or by opting out of seeing personalized ads by following the instructions here:https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy: https://twilightbrands.com/pages/cookie-policy
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyses or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Use of profiling for web analytics
Collects information such as your location (based on your IP address) and your behavior (based on cookies) when you access our website (such as the pages you visit and what you click on) and how much you are spending on our site. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy. Information collected about you, once collected is anonymised and stored on an aggregate basis. IP addresses are anonymized at the point of collection on our site.
Logic involved: by automatically analyzing and categorizing information such as the location (based on IP address) as well as the behavior and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behavior and device on our website (unless you have opted out from receiving such cookies by using our cookie control tool and your location will be analyzed based on your IP address. We may target advertisements or content on our site based on the level of interest we receive from certain visitors and their behavior on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) and the basis upon you give us consent to use this by opting into cookie tracking.
[Legitimate interest: : improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires. Also to serve advertisements to you which seem most relevant to the visitor.
Use of profiling in marketing emails
We use web beacons in our marketing emails to analyze who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy (https://twilightbrands.com/pages/cookie-policy ).
Logic involved: by analyzing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
Significance and envisaged consequences: your behavior when you open our emails will be tracked using small gif files (web beacons), including open rates, click through rates, and what items you clicked on in an email.
How to object: You may object to this by contacting us at info@twilightbrands.com or you may opt out by using our cookie control tool.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: analyzing the level of engagement and effectiveness of our marketing emails and content
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
Email provider(s), including Klaviyo Inc. Their privacy policy is available here: com/privacy
Hosting provider(s), including Shopify Inc. Their privacy policy is available here: com/privacy
Our third party service providers are located in the United State and Canada.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display all the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email at info@twilightbrands.com and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Sharing your information within our business’ group of companies, including Seed Beauty for internal administrative purposes, including client, customer and employee information.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business effectively.
AND
Legal basis for processing: necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract., for example because of the services or information you have requested.
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal basis for processing: compliance with a legal obligation (Article 6(1) (c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of the United States of America.[4]
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United States’ legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods
Order information: when you place an order for goods and services, we retain that information indefinitely or until you request that we delete unless this conflicts with our compliance of a legal responsibility.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry and indefinitely afterward unless it is requested to be deleted AND it does not interfere with our compliance with laws and our legitimate business interest.
E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
whether we have any legal basis to continue to process your information (such as your consent);
how valuable your information is (both now and in the future);
any relevant agreed industry practices on how long information should be retained;
the levels of risk, cost and liability involved with us continuing to hold the information;
how hard it is to ensure that the information can be kept up to date and accurate; and
Any relevant surrounding circumstances (such as the nature and status of our relationship with you).
How we secure your information
We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
using secure servers to store your information;
verifying the identity of any individual who requests access to information prior to granting them access to information;
using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
only transferring your information via closed system or encrypted data transfers
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area
We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we and our data processors process data may have laws which are different, and potentially not as protective, as the laws of your own country.
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organization in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Server log information
Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company, Shopify. You can access their privacy policy here: www.shopify.com/privacy
Country of storage: Canada and the United States
Safeguard(s) used: our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Contact form and Email
Information you submit to us via our contact form is transferred outside the EEA and stored on our third party email and customer service systems. Our email provider is Klaviyo Inc
E-Newsletter
Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Klaviyo. You can access their privacy policy here: www.klaviyo.com/privacy
[Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our[third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Payment Processor
Information you submit to us by our third party payment processor, Shopify Payments, is transferred outside the EEA and stored on their servers. You can access their privacy policy here: https://pay.shopify.com/tos-privacy-policy
Country of storage: The United States and Canada. These countries are not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our payment processor has self-certified its compliance with the EU-U.S. Privacy Shield.
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to info@twilightbrands.com
to request access to your informationand information related to our use and processing of your information;
to request the correction or deletionof your information;
to request that we restrict our useof your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format(e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
to object to the processing of your information for certain purposes(for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Twilight Brands, INC C/O GDPR Handling 1600 Westar Dr. Oxnard, CA 93033 USA or sending an email to: info@twilightbrands.com
to object to us using or processing your information where we use or process it in order to carry out a task in the public interestor for our legitimate interests, including ‘profiling’ (i.e. analyzing or predicting your behavior based on your information) based on any of these purposes; and
To object to us using or processing your information for direct marketing purposes(including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
clicking the unsubscribe linkcontained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://twilightbrands.com/pages/cookie-policy
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@twilightbrands.com
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user.
For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: https://twilightbrands.com/pages/cookie-policy
Copyright, credit and logo
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy.
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.
- Choosing a selection results in a full page refresh.