TWILLORY PRIVACY POLICY

Last Updated: July 16, 2026

Thank you for visiting the Twillory.com website (“Website”). The Website is owned and operated by The Haberdash Group, Inc. d/b/a Twillory (“Twillory,” “we,” “us,” “our”). We respect your privacy and are committed to protecting it through our compliance with this policy. As explained below, we collect information from you in various ways when you interact with our Website.

We review and update this policy annually to ensure continued compliance with evolving privacy laws. Additionally, if we make material changes to how we process your personal information, we will notify you via email at the email address you provided us. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. This Privacy Policy covers all interactions with Twillory across all channels, including our website, retail locations, customer service interactions, marketing communications, and third-party platforms where we maintain a presence.

By utilizing our Website, you agree to the terms in this Privacy Policy. If you do not agree to this Privacy Policy, you must not use our Website.

Information We Collect

This section describes the types of personal information we may collect about you. Such information is generally collected either (i) directly from your voluntary submission of information to us; or (ii) automatically when you interact with the Website.

The following categories of personal information we may collect from you includes:

• Account Creation Information. In order to set up an account we may collect your name, e-mail address, company name, physical address, and phone number.
• Personalization Information. We may collect information you provide regarding your purchase history, browsing history, birth date, demographics such as gender and age to enhance your shopping experience with us.
• Purchase Information. To complete a purchase, we may collect your shipping address, billing address, and other order-related information, which is stored within our e-commerce platform. Your sensitive payment information is processed directly by our third-party payment processors and is not stored on our systems.
• Feedback Information. To receive and respond to your customer service requests or comments on your experience with Twillory, we may collect your name, phone number, address, email address, reviews, and any relevant history.
• Marketing Information. To update you with the latest promotions we may collect your email address when you create an account, make a purchase, or voluntarily sign-up for our mailing list. You may opt-out of these marketing communications at any time by reaching out to help@twillory.com or by managing your preferences through a link at the bottom of the relevant communications.
• Device Information. When you interact with our Website, we may automatically collect information about the computers, phones, and other devices you are using (e.g., IP address, WIFI information, device attributes, device type, browser type, operating system version, etc.) and what general geographic location you are using the device to access the Website from based on your IP address. This information helps us distinguish you from other users of the Website, offer you location customization, and auto-populate your information for easier log-in and checkout.
• Website Usage Information. So that we may understand and improve on the user experience and functionality of the Website, we may automatically collect information about how you interact with the Website, such as mouse movements, clicks, keystrokes, the dates of your visit, the time spent on pages of the Website, frequency of visits to the Website, or other actions. This information helps us measure traffic and offer you personalized recommendations.

Sources Of Personal Information

• Direct Collection. Information you provide through our website, stores, customer service, events, and marketing interactions.
• Third-Party Sources. Social media platforms (Facebook, Instagram, Pinterest, TikTok), data cooperatives, marketing partners, and publicly available sources.
• Automatic Collection. Cookies, pixels, web beacons, and similar technologies during website and service interactions. For more information about our automatic collection of information, please visit our Cookies and Other Tracking Technologies section of this policy.

How We Use Your Personal Information

Twillory may use and/or disclose your personal information for various business or commercial purposes, including, but not limited to, providing our services, maintaining your account, process orders, fulfilling your purchases and/or returns, marketing, providing customer service and support, analytics, service improvements, security and fraud prevention, sending policy updates, and giving you opportunities to provide us with feedback. We also use your information to better understand and improve the customer experience when accessing or using the Website.

We limit access to your personal information to our employees, contractors, service providers, and agents who have a legitimate need to use it. We may also share your information in order to comply with applicable law or respond to a valid legal process or to enforce or investigate potential violations of our Terms and Conditions or other policies. In some cases, we may work with third-party service providers to provide support, improvements, and technical infrastructure to the Website.

Interest-Based Advertising

We select third-party partners and use tracking technologies, including cookies, web beacons, and pixels, on our services to analyze usage data, determine content popularity, and improve our services. We allow third-party companies to collect certain information when you visit our properties. This data is used to provide Interest-Based Advertising and Tailored Advertising (as defined by the NAI and under Data Protection Laws).

Interest-based advertising, also known as online behavioral advertising, is the practice of collecting information about users’ activities across sites over time and using it to deliver targeted advertising based on users’ interests. This can be achieved through automated means, including through the use of first- and third-party cookies, web server logs, pixels, web beacons, and other technologies to collect information about your use of our website and other websites, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and trusted third-parties such as Facebook, Google, and Pinterest, in order to analyze and track data, determine the popularity of certain content, better understand your online activity, deliver and tailor our advertisements to your individual interests on other websites or online services, and to inform you about new products or services.

The information collected and used in this manner is generally, on its own, anonymous and not personally identifiable (e.g. browsing history, demographic information, purchase history, media consumption, shopping habits, lifestyle preferences, or other similar information).

As a part of these ad campaigns, we or third-party platforms (e.g. Facebook or Google) may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us and others to serve you advertising that is customized to your interests. Note that the third-party platforms may offer your choices about whether you see these types of customized ads.

To learn more about interest-based advertising and your choices with respect to it in more detail, please visit the Network Advertising Initiative at www.networkadvertising.org and the Digital Advertising Alliance at www.aboutads.info/choices.

To opt-out of some of our advertising partners’ use of cookies in this manner, visit http://www.networkadvertising.org/managing/opt_out.asp.

Cookies and Other Tracking Technologies

Twillory may automatically collect information (as detailed above) about you when you interact with the Website by using technologies described below:

• Web Beacons. Some pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages of the Website and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer. Depending on your browser or mobile device, you may be able to change your settings to manage cookies or reject them entirely. However, if you select this setting or delete all cookies you may be unable to access certain parts of the Website or certain features of the Website will be disabled. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website. Cookies placed on your computer by the Website are called “first-party” cookies, and those placed by third-parties would be “third-party” cookies. Twillory uses cookies for authentication, session management and personalization of user experience.

We use different types of cookies for different purposes, specifically: strictly necessary cookies, performance cookies, and functionality cookies:

• Strictly necessary cookies. Are essential to fulfill an action requested by you, such as identifying your browser settings. If you delete these cookies, we cannot guarantee how our Website will perform during your visit.
• Performance cookies. Allow us to view analytic information about how users interact with our Website.
• Functionality cookies. Enhance the performance and functionality of our Website, such as remembering you or your preferences.

If applicable to your state, you may opt out of certain cookies and tracking technologies at any time. For California residents, you can exercise your right to opt out of the sale or sharing of your personal information by clicking the ‘Do Not Sell or Share My Personal Information’ link located here or at the footer of the site. This link allows you to manage your preferences regarding cookies and tracking technologies used for targeted advertising and other purposes. We also honor Global Privacy Control (GPC) signals for California residents. If you notify us of your opt-out preferences through GPC, we will process your request for the browser or device that sends the signal. Please note that disabling certain cookies may impact the functionality of the Website.

When We Share Information

We share your personal information with third parties in the following specific circumstances:

• Service Providers. We share information with vendors who provide website hosting, payment processing, order fulfillment, customer service, marketing, and analytics services under strict contractual protections.
• Business Partners. We may share information with co-sponsors of promotions, advertising partners, and other businesses that provide complementary services.
• Legal Requirements. We disclose information when required by law, court order, or to protect our rights and the safety of our customers.
• Business Transfers. Information may be transferred in connection with mergers, acquisitions, or asset sales.
• With Your Consent. We may share information for other purposes with your explicit consent.

Links to Other Sites

The Website may contain links to other sites for your convenience only. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the applicable privacy policy of these third-party websites. We have no control over, and assume no responsibility for the content, data security, privacy and security policies or practices of any third-party websites or services.

Data Retention

We process and store personal information for as long as required by the legitimate purpose it has been collected for, and in accordance with applicable law.

Twillory may be allowed to retain personal information for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, Twillory may be obliged to retain personal information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

We determine retention periods based on the nature and length of our customer relationship, the business purposes for which information was collected, legal, regulatory, or contractual obligations, and legitimate business needs for record-keeping and dispute resolution.

Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Twillory, in some cases, data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies or communications agencies) appointed, if necessary, as Data Processors by Twillory. The updated list of these parties may be requested from Twillory at any time.

Security

Twillory implements comprehensive security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, and destruction. Our security program includes technical, administrative, and physical safeguards appropriate to the sensitivity of the information we collect and process.

While we implement robust security measures and follow industry best practices, no method of transmission over the internet or electronic storage is completely secure. We continuously monitor and update our security practices to address evolving threats but cannot guarantee absolute security against all possible risks.

US State Privacy Rights

This section applies exclusively to Personal Information collected from consumers residing in the United States, including, residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. You have specific privacy rights under applicable state laws. “Personal Information” refers to any data that can be linked to an individual or household. Key rights include accessing, correcting, and deleting personal information; obtaining copies of collected data; opting out of data sales, sharing, and targeted advertising; and receiving special protections for sensitive personal information.

Twillory collects and processes personal information in accordance with this policy. We do not gather sensitive data to infer user characteristics. We may share personal information in ways that may be considered a ‘sale’ or ‘sharing’ under certain U.S. state privacy laws. Where required, we provide opt-out mechanisms. Consumers may request specific notices regarding their rights under applicable laws. Please note that these rights vary by state and are subject to certain exceptions and limitations.

Sensitive Personal Information

We do not collect or process sensitive personal information, as defined by applicable US state privacy laws, for inferring characteristics or use or disclose sensitive personal information for purposes other than those permitted by law.

California Residents

Notice to California Residents / Your California Privacy Rights

California Civil Code Section 1798.83, otherwise known as California’s Shine the Light law, permits customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. You have the right to opt out of the sale of your personal information at any time by managing your consent preferences by clicking the Do Not Sell or Share My Personal Information link below. To make such a request, please review the “How to Exercise Your Rights” section below:

How To Exercise Your Rights

• Do Not Sell or Share My Personal Information link: here
• Email: help@twillory.com (Subject: “State Privacy Rights Request”)
• Phone: (516) 444-3420

Your Privacy Rights

• Right to Know and Access. Request information about our data collection, use, and sharing practices, including specific pieces of personal information we have about you.
• Right to Delete. In certain situations, you can request that we delete your personal information. This applies particularly when: (1) We originally collected the data based on your consent; (2) You’ve withdrawn that consent; and (3) We have no other legal basis for keeping your information.
• Right to Correct. If you find any errors in your personal information, please contact us to have them corrected.
• Right to Obtain Copies. Users can request copies of the Personal Information collected about them, where feasible.
• Right to Opt-Out of “Sales/Sharing”. Opt-out of the sale or sharing of your personal information for targeted advertising. To opt out of this, click the Do Not Sell or Share My Personal Information link located in the footer of the Site.
• Right to Limit Sensitive Information. We do not collect Sensitive Information other than what is permitted by law.
• Right to Opt-Out of Profiling. Opt-out of automated decision-making and profiling activities.
• Right to Non-Discrimination. We will not discriminate against you for exercising your privacy rights.
• Right to Opt-out of Automated Decisions. You have the right not to be subject to automated decision-making that: (1) creates legal effects concerning you; and (2) significantly impacts you.
• Authorized agents. You may designate an authorized agent to make a request on your behalf. We will require verification of the agent’s authority and may require you to verify your identity directly.
• Right to Non-Discrimination For The Exercise Of Your Privacy Rights. You have the right to be protected from discrimination for exercising your CCPA rights. We will not discriminate against you for exercising your rights under the CCPA.

Categories of Personal Information (Prior 12 Months)

• Verification Process. We will verify your identity using information associated with your account. Authorized agents must provide written permission and may be required to verify their authority.
• Response Timeframes. We will respond within 45 days (extendable by 45 days for complex requests) and provide free responses for up to two requests per year.
• Right to Appeal. If you are a California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Oregon, Rhode Island, Texas, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Virginia, Tennessee, or Utah resident and we were unable to fulfill your request, you may appeal our decision by emailing us at help@twillory.com within fourteen (14) days of our decision, including “Appeal Request” in the subject line, with a detailed reason for your appeal, as well as your state of residence.
• Exercising These Rights. We’re here to help you understand and use your data privacy rights. If you have questions about these rights or want to exercise them, please contact us at help@twillory.com.

Additional Information for European Union (“EU”) Residents

Legal Basis for Processing

We process your personal information based on one of the following legal conditions:

• Your consent (e.g., to place cookies which process personal information, or marketing)
• To perform our agreement with you (e.g., to process your payment or shipping information to process your purchase)
• To comply with a legal obligation to which Twillory is subject
• Our legitimate interests, provided they do not override your fundamental rights and freedoms

In any case, Twillory will gladly help clarify the specific legal basis for the processing, and whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

International Transfers

Our digital operations are conducted primarily in the United States. By using our services, you consent to the transfer, processing, and storage of your personal information in the United States and other countries where our service providers or we operate. If you are located in the EEA, United Kingdom or Switzerland, your personal information may be processed outside of those regions, including in the United States. In the event of such a transfer, we will ensure that: (i) the personal information is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate and approved safeguards, such as standard contractual clauses adopted by the European Commission.

The Rights of EU Residents

If you are a resident of the European Economic Area you may exercise certain rights regarding your personal information processed by Twillory. In particular, you have the right to:

• Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your personal information.
• Right to Erasure (Right to be forgotten). In certain situations, you can request that we delete your personal information. This applies particularly when: (1) We originally collected the data based on your consent; (2) You’ve withdrawn that consent; and (3) We have no other legal basis for keeping your information. If you would like to delete your account information and statistics tied to your usage, please contact us at help@twillory.com.
• Object to processing of your data. You have the right to object to the processing of your personal information if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access your Data. You have the right to learn if your data is being processed by Twillory, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data undergoing processing.
• Verify and Seek Rectification. You have the right to verify the accuracy of your personal information and ask for it to be updated or corrected.
• Move Your Data. You have the right to: (1) Receive your personal information in a structured, commonly used, machine-readable format; and (2) Have your data transferred to another organization (where technically feasible).
• Correct Your Data. If you find any errors in your personal information, please contact us to have them corrected.
• Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your data, especially when: (1) You’re questioning the accuracy of your data; (2) You need us to maintain data even if we no longer need it temporarily; and (3) You’ve objected to our use of the data, and we’re verifying the situation.
• Receive your Data and have it transferred to another controller. You have the right to receive your data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract of which Twillory is part, or on pre-contractual obligations thereof.
• Lodge a complaint. You have the right to bring a claim before the competent data protection authority. here
• Protection from Automated Decisions. You have the right not to be subject to automated decision-making that: (1) Creates legal effects concerning you; and (2) Significantly impacts you.

To exercise any of these rights, please reach out to us at help@twillory.com or (516) 444-3420.

These requests can be exercised free of charge and will be addressed by Twillory as early as possible and within thirty (30) days. However, we may refuse or charge for any request that is unfounded or excessive or if we cannot verify your identity, in accordance with applicable law. We will notify you of the refusal and the basis of that refusal and will have the right to complain to the supervisory authority and seek a judicial remedy within one month of the request.

Children’s Privacy Policy

Our Website is not intended for children under 18 years of age. No one under age 18 may provide information to or on the Website. We do not knowingly collect personal information from anyone under 18. If you are under 18, do not provide any information on this Website, including your name, address, telephone number, or email address that you may use. If we learn that we have collected or received Personal Information from a child under 18 without verifying parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at help@twillory.com.

SMS/MMS Mobile Messaging Marketing Program

We respect your privacy. We will only use information you provide to transmit your mobile messages and respond to you, if necessary. This includes, but is not limited to, sharing information with platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages. WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO ANY THIRD PARTY.

Nonetheless, we reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property. When you complete forms online or otherwise provide us with information, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in our sole discretion, we believe that any such information is untrue, inaccurate, or incomplete, or you have opted-in for an ulterior purpose, we may refuse you access and pursue any appropriate legal remedies.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

By Email: help@twillory.com (Subject: Privacy Policy Questions)

By Mail: The Haberdash Group, Inc. d/b/a Twillory, 181 S. Franklin Ave, Suite 203, Valley Stream, NY 11581, Attn: Privacy Officer

By Phone: (516) 444-3420