PRIVACY POLICY OF TWILLORY.COM

Last Updated:  May 8, 2023

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.

By utilizing the Website, you agree to the terms in this policy as dictated herein. If you do not agree to this Privacy Policy you must not use our Website. This policy may change from time to time and is effective as of the date stated at the top of this page. 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.

Information We Collect and How We Use It

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 and payment information, including your billing address, credit card, or other payment method at the point of purchase. Note that Twillory does not itself collect that information. Instead, we pass that information on to our payment processors.

 

• 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.

For more information about our automatic collection of information please visit our Cookies and Other Tracking Technologies section of this policy. 

We may also collect information about you from other sources including information about you that is available on the Internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers. The information we receive from these third-parties depends on, and is subject to, that third-party’s policies. 

What We Do With Your Information.

Twillory may use and/or disclose your personal Information to provide our services, maintain your account, fulfill your purchases and/or returns, provide customer service and support, policy updates, and chances for you to give us 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 offer support, improvements, and technical infrastructure to the Website. 

Interest-Based Advertising.

 

Interest-Based advertising, also known as online behavioral advertising, is the practice of collecting information about users’ activities across sites over time, and using such information to deliver targeted advertising based on such users’ interests. This can be achieved through automated means, including through the use of first and third-party cookies, web server logs, pixels, web beacon, 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. 

We currently do not honor Do Not Track signals from internet browsers; when a universal standard for processing them emerges, we will follow it.

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, privacy policies or practices of any third-party websites or services.

Data Retention and Security.

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.

Twillory takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of data.

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 orcommunications agencies) appointed, if necessary, as Data Processors by Twillory. The updated list of these parties may be requested from Twillory at any time. Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

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 to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

International Transfers.

The personal information we collect may be transferred to and stored in countries outside the jurisdiction where you are and where we or our third-party service providers have operations. 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:

• Be informed.
• 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.
• 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 the 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.
• Restrict the processing of your Data.You have the right, under certain circumstances, to restrict the processing of your data. In this case, Twillory will not process your data for any purpose other than storing it.
• Have your Personal Information deleted or otherwise removed.You have the right, under certain circumstances, to obtain the erasure of your personal information from Twillory.
• 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 which Twillory is part of or on pre-contractual obligations thereof.
• Lodge a complaint.You have the right to bring a claim before their competent data protection authority.
• Not to be subject to automated decision-making including profiling.

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.

Additional Information for California Residents.

If you are a California resident, certain rights may be accorded to you under the California Consumer Privacy Act (CCPA). At this time, Twillory respects the privacy rights of its customers but understands that Twillory is currently not subject to the CCPA and therefore not required to carry out CCPA data requests at this time.  If you are a California resident and would like more information regarding the CCPA, please refer to the California Attorney General website: https://oag.ca.gov/privacy/ccpa or consult with a data privacy attorney.

 

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 we have collected or received Personal Information from a child under 18 without verification of 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 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:

help@twillory.com

or via our number:

(516) 444-3420

Additional Information about Your Personal Information.

In addition to the information contained in this Privacy Policy, this Website may provide you with additional and contextual information concerning particular services or the collection and processing of Personal Information upon request.