PRIVACY POLICY

EFFECTIVE AS OF 01/14/2022

TwineSpot, Inc. and its subsidiaries, divisions, and affiliates (“TwineSpot”) recognize the importance of protecting the privacy of the personal information you provide to us. Accordingly, we have developed this Privacy Policy (“Policy”) in order for you to understand how we collect, use, communicate, disclose, and otherwise manage the personal information you entrust to us by engaging our services on the website, social media, email exchanges, mobile apps, and other online services on which this Policy is posted (the “Service”).

This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extent that any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.

1. COLLECTION OF PERSONAL INFORMATION

Information you provide to us

TwineSpot will collect personal information from you directly when you interact with our Service, contact us, use our services, create an account, complete any fillable forms, questionnaires, or surveys, subscribe, share product or service reviews, or sign up to receive offers or emails from us.

Information we obtain indirectly

We may receive personal information about you from our third-party affiliates or partners and from marketing companies that provide us with such information as a part of their relationship with us.

We may combine this with data that we already have collected about you. Such collected data could include contact details (such as email address) and previous search history or interests.

Information collected automatically

When you use our Service we collect certain information about you automatically through our use of cookies and similar technologies.

2. CATEGORIES OF PERSONAL INFORMATION COLLECTED

TwineSpot collects the following categories of personal information: (1) contact information including your name, email address, street address, city, state, zip code; (2) authentication information, including the user name and password that you use to register an account on the Service; (3) comments, reviews, suggestions; (4) personal characteristics including age, date of birth, gender, marital status, and nationality; (5) personal preferences including product preferences, online preferences, and interests; (6) online behavior information including online activity, preferences, and time spent viewing features; and (7) IP address or mobile network information.

TwineSpot does not collect, use, disclose, or sell sensitive personal information such as your social security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your precise geolocation; your racial or ethnic origin, religious or philosophical beliefs or associations, political opinions or membership, or union membership; the contents of your mail, email and text messages, unless we are the intended recipient of the communication; your genetic or biometric data; your mental or physical health or medical condition or diagnosis; your sex life or sexual orientation or practices; your criminal background; your citizenship or citizenship status; or any personal information about a known child. We ask that you not send nor disclose, any sensitive personal information to us.

3. PURPOSE FOR COLLECTION, USE, DISCLOSURE AND SALE OF PERSONAL INFORMATION

TwineSpot collects your contact information, personal characteristics, and personal preferences to generate consumer interest for our third-party clients’ products or services with the goal of turning that interest into a sale. In furtherance of this purpose, TwineSpot sells these categories of personal information it has collected to our third-party clients for their business and commercial purposes including for the purpose of providing direct services and enabling marketing and advertising campaigns.

TwineSpot collects and processes the minimum amount of personal information from you that is necessary to the purposes of our information processing activities and retains such information only if required to fulfill such purposes. Our information processing activities include conducting our business, customer communications and support, user verification, quality control services, Service maintenance and improvements, and complying with legal requirements.

Where applicable, if TwineSpot intends to further process your personal information for a purpose other than that for which the personal information was initially collected, TwineSpot shall, prior to such processing, provide you with any relevant information on such additional purpose, and, to the extent required by applicable law, obtain your consent for this.

4. PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION

TwineSpot may share, disclose, or sell your personal information to the following parties:
  • Third Party Clients. We may sell information to our third-party clients to generate consumer interest for our third-party clients’ products or services with the goal of turning that interest into a sale. Our third party clients include home service providers in a variety of fields including but not limited to solar energy, home improvement and maintenance, home warranty, home security, and home financing. TwineSpot does not sell personal information to individual consumers.
  • Third Parties Providing Services on Our Behalf. We may share information with Service Providers, such as the Payment Processor, who perform services and functions on our behalf to support our interactions with you. These Service Providers may assist with technical operation of our Service, provide analytics, or provide customer service. We may also share non-identifying information, such as aggregate statistics or usage information, with third parties.
  • Your Consent to Have Your Personal Information Shared. In connection with your use of the Service, you may be asked to opt-in to receive informational or marketing offers, or to otherwise consent to the sharing of your information with a third party, including social networking sites such as Facebook Instagram, or Twitter. If you agree to have your personal information shared with a third party, your personal information will be disclosed to the third party and will be subject to the privacy policy and business practices of that third party.
  • Legal Disclosure. We may transfer and disclose information, including your personal information, usage information and device identifier, (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our agreements, terms of use, or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Service, or the public.

5. DO NOT TRACK SIGNALS, COOKIES, AND OTHER TECHNOLOGIES

We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity and interactions with our emails, online and mobile advertisements, and to allow us to keep track of analytics and certain statistical information that enables TwineSpot to improve our services and provide you with more relevant content and advertising offered by TwineSpot, or through or linked from our services. You may, however, disallow receiving cookies at any time through your web browser. It is not our intention to use cookies to retrieve information that is unrelated to our Service or your interaction with our Service.

At this time, we do not respond to browser “do not track” or “DNT” signals.

6. CHILDREN’S PRIVACY

TwineSpot’s Services, including this Service, are not targeted for use by children. TwineSpot will never knowingly request or collect personal information from any child. If you are under eighteen years old, please do not provide your information on our Service. Upon notification that a child has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records. If you believe we might have any information from a child, please contact us at contact@twinespot.com.

7. SPECIAL NOTICE TO CALIFORNIA RESIDENTS

If you would like to submit a Consumer Request, you can contact TwineSpot at contact@twinespot.com. If you choose to submit a Consumer Request to correct, access, know, or delete your personal information, please provide us with enough information to identify you and enough specificity to determine the nature of your request. TwineSpot will only use the information it receives to respond to your request. TwineSpot will not be able to disclose information if it cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf.  Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.

“Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal information” does not include publicly available information.

  1. Request to Correct. You may correct or update your personal information at any time by logging into your account or by contacting us.
  2. Request to Access. You may submit a Consumer Request to obtain a copy of or access to the personal information that TwineSpot has collected on you.
  3. Request to Know. You may submit a Consumer Request to receive information about TwineSpot’s data collection practices.
    1. Right to Know what Personal Information is being Collected. You may request information on the categories of personal information TwineSpot has collected about you; the categories of sources from which the personal information is collected; TwineSpot’s business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom TwineSpot discloses personal information, if any; and the specific pieces of personal information it has collected about you.
    2. Right to Know what Personal Information is Sold or Shared and to Whom. You may also request the categories of personal information that TwineSpot has collected about you; the categories of personal information that TwineSpot sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared; and the categories of personal information that TwineSpot disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
    3. Please note that the categories of personal information, sources, and disclosure will not exceed what is contained in this Policy. Additionally, TwineSpot is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. TwineSpot is also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.
  4. Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. Please include your name, email address, and mailing address so that we can identify the personal information we have collected about you. You do not need to be a registered user or have an account in order to opt out of the sale of your personal information.
  5. Request to Delete. You may request that TwineSpot delete personal information it has collected from you. Subject to certain exceptions set out below we will, on receipt of a verifiable Consumer Request, delete your personal information from our records, direct any service providers to do the same, and notify all third parties to whom TwineSpot has shared your personal information to delete it unless this proves impossible or involves disproportionate effort.
    1. Please note that we may not delete your personal information if it is necessary to:
  1. Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
  2. Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
  3. Debug to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  6. Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.
  7. To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.
  8. Comply with a legal obligation.

TwineSpot may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

8. SPECIAL NOTICE FOR COLORADO RESIDENTS

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified or identifiable individual.” “Personal data” does not include de-identified or publicly available information.

  1. Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that TwineSpot has collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with TwineSpot’s data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
  2. Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
  3. Request to Delete. You may request that TwineSpot delete the personal data it has collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
  4. Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. Please include your name, email address, and mailing address so that we can identify the personal information we have collected about you. You do not need to be a registered user or have an account in order to opt out of the sale of your personal information.
  5. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Colorado Attorney General.

If you like to make any of the above requests, you can contact TwineSpot at contact@twinespot.com or by mail at the address provided below. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity to determine the nature of your request. TwineSpot will only use the information it receives to respond to your request. TwineSpot will not be able to disclose information or comply with your request if it cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf.

9. SPECIAL NOTICE FOR NEVADA RESIDENTS

Personal information or “covered information” means “any information concerning a person . . . in combination with an identifier in a form that makes the information personally identifiable.”

  1. Request to Correct. You may correct or update your personal information at any time by logging into your account or by contacting us.
  2. Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. Please include your name, email address, and mailing address so that we can identify the personal information we have collected about you. You do not need to be a registered user or have an account in order to opt out of the sale of your personal information.

If you like to make any of the above requests, you can contact TwineSpot at contact@twinespot.com or by mail at the address provided below. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity to determine the nature of your request. TwineSpot will only use the information it receives to respond to your request. TwineSpot will not be able to disclose information or comply with your request if it cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf.

10. SPECIAL NOTICE FOR VIRGINIA RESIDENTS

Personal information or “personal data” means “any information that is linked or reasonably linkable to an identified or identifiable natural person.” “Personal data” does not include de-identified data or publicly available information.

  1. Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that TwineSpot has collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with TwineSpot’s data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
  2. Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
  3. Request to Delete. You may request that TwineSpot delete the personal data provided by or obtained about you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
  4. Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. Please include your name, email address, and mailing address so that we can identify the personal information we have collected about you. You do not need to be a registered user or have an account in order to opt out of the sale of your personal information.
  5. Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Virginia Attorney General or submit a complaint online at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint

If you like to make any of the above requests, you can contact TwineSpot at [EMAIL] or by mail at the address provided below. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity to determine the nature of your request. TwineSpot will only use the information it receives to respond to your request. TwineSpot will not be able to disclose information or comply with your request if it cannot verify that the person making the request is the person about whom we collected information, or if such person is a known child, that child’s parent or legal guardian.

11. LINKED SITES

The Service may contain links to third-party owned or operated websites, including, without limitation, social media websites (each a “Linked Site”), as a convenient method of accessing information that may be useful or of interest to you. This Policy and the practices that we follow under this Policy do not apply to Linked Sites. We are not responsible for the content, accuracy, or opinions expressed on any Linked Site or for the privacy practices or security standards used by third parties on such Linked Sites. These Linked Sites have separate privacy and data collection practices, and we have no responsibility or liability relating to them.

You understand and agree that by clicking on a link to a Linked Site, you have left our Service and this Policy, as stated on the Service, is no longer in effect.

12. USER CONTENT

Some features of the Service may now or in the future allow you to provide content, such as written comments or reviews, or interactive responses to content such as quizzes, to be published or displayed on public areas of the Service (“User Content”). Be careful about giving out information in public areas of the Service, such as commenting on our blog. The information you share in public areas may be viewed by any user of the Service. We cannot control the actions of other users of the Service with whom you may choose to share your User Content.

13. OPTING OUT OF EMAILS

When you register, subscribe create an account, sign up to receive offers or emails from us, or otherwise communicate with us through our Service, you may “opt out” of receiving future communications from us for direct marketing purposes by indicating that you decline such communications. You may choose to have your name taken off of our email list after you have registered or provided additional information by clicking “Unsubscribe” on the email you receive or by emailing us at contact@twinespot.com.

14. SECURITY OF YOUR INFORMATION

If you choose to provide us with your personal information, you understand that we are transferring it to TwineSpot’s locations and systems in the United States or to the locations and systems of TwineSpot’s service providers around the world. TwineSpot has safeguards and security controls in place to protect your personal information. This includes appropriate technical and organizational measures to protect the personal information (i) from accidental or unlawful destruction, and (ii) loss, alteration, unauthorized disclosure of, or access to the data.  Please be advised, however, that while we take reasonable security measures to protect your personal information, such measures cannot be guaranteed to be secure. TwineSpot cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information.

The security of your TwineSpot website account relies on your protection of your user profile information. You are responsible for maintaining the security of your user profile information, including your password and for all activities that occur under your account. You may not share your password with anyone.  We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on a TwineSpot Service. Any email or other communication purporting to be from one of our websites requesting your password or asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to us immediately. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and report it immediately by using the “Contact Us” feature of our website or by emailing contact@twinespot.com.

15. CONSENT TO PROCESSING & INTERNATIONAL TRANSFERS

TwineSpot may process, transfer, and store information about users of the Service on servers located in a number of countries, including the United States. As a result, your personal information may be subject to data protection and other laws that may differ from your country of residence. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate. By using the Service, or by providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside or are a citizen.

16. CHANGES TO THE PRIVACY POLICY

We may amend this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Service or sending you an email. A user is bound by any changes to our Policy when he or she uses the Services after such changes have been first posted.

17. HOW TO CONTACT US

We want to assure you that TwineSpot is dedicated to protecting the confidentiality and security of your personal information. Please feel free to contact us at any time if you have any questions or comments about this Policy.

You can contact us or otherwise communicate your privacy concerns by emailing us at contact@twinespot.com or by mail at:

TwineSpot, Inc.

c/o Data Protection Officer

3005 Del Monte Street, San Mateo CA 94403