Last updated May 8, 2024
Our website address is: https://twinerlitellc.com.
This Privacy Policy describes the information that TwinerLite (“we,” “our,” or “us”) collects, how we use this information, with whom we
share it, and the choices you have in connection with this. This Privacy Policy applies
to TwinerLite-owned websites (the “Website”), and any other electronic or
digital products or services made available by TwinerLite that link to this
Policy (collectively, the “Services”).
Information Collection and Use
Through your use of the Services, we’ll collect personal information, which is
information that identifies you or relates to you as an identifiable individual. We
collect personal information directly and automatically as outlined below.
1. Information Collected Directly from You
When you engage with certain Services, we’ll collect your personal information. Except
as otherwise indicated, the personal information we collect is such that we need to
carry out the requested action. If you don’t provide us with your personal information,
we won’t be able to do so. We collect personal information when you:
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Complete the “Get Started”
form on our Website: When you complete the “Get Started” form on our
Website, we collect from you, your personal identifiers (name, email address,
telephone number, physical address, gender, DOB), type of insurance, and any other
information you choose to include. We use this personal information to communicate
with you regarding your request and other services that may be of interest to you,
and share your information with relevant third parties that can help you with your
project. If you consent (opt in) to receive promotional text messages to your
cellular telephone number, we’ll use your cellular telephone number to send you
automated promotional text messages. Message and data rates may apply. You may reply
“STOP” to any promotional text message to stop us from sending you future
promotional text messages, or “HELP” for further assistance. Your agreement to
receive promotional text messages isn’t a condition of any purchase from us. If you
provide your postal address to us through our Website, you may receive periodic
mailings from us. You may also receive mailings from other reputable companies.
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Use the search function on the
Website: When you use the search functionality on the Website, we’ll
collect any information you decide to include in the search field. We’ll use this
information to query our internal library of resources to identify relevant articles
to your search term(s).
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Contact us: When
you contact us through the Services, we collect from you, your personal identifiers
(name, email address, telephone number) and any other information you choose to
include in your correspondence. We use this personal information to respond to your
questions or inquiries, troubleshoot where necessary, and address any issues you may
have.
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Subscribe to marketing
emails: If you subscribe to our marketing emails, we’ll collect from
you, your email address to fulfill your request to receive information we feel may
be of interest to you. You can unsubscribe at any time by clicking on the
“unsubscribe” link in each email. Please note that we’ll continue to send you
notifications necessary to the Services or requested products or services. Our
communications may contain email tracking technologies to gain valuable insight into
behavior of recipients. With the help of these technologies, we can analyze whether
a predefined action took place by a recipient, such as opening our communications,
in order to better adapt and distribute our communications. When you opt-in to our
marketing communications, you’re opting into the use of these technologies. You can
disable tracking by disabling the display of images by default in your email
program. If you provide your postal address to us through our Website, you may
receive periodic mailings from us. You may also receive mailings from other
reputable companies.
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Participate in a survey,
promotion, or contest: If applicable, when you complete a form to
participate in a survey, promotion, or contest, we collect your personal identifiers
(name, physical address, telephone number, and email address). We use this personal
information to communicate with you regarding the promotion or contest, or analyze
your feedback or survey responses to improve our Services. If you haven’t opted out
of this when submitting your information, we also use your name and email address to
send you marketing communications we feel may be of interest to you. You may
unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of each
email.
TwinerLite may also use the personal information we collect as described in
this section to comply with the law, to efficiently maintain our business, and for other
limited circumstances as described in the How We Share Your Personal
Information section of this Policy.
2. Information Collected Automatically
In addition to the personal information you provide, we also collect information
automatically via cookies or other tracking technologies as you use the Services.
We may automatically capture information concerning your interaction with the Services
using third-party software embedded in the script of the Services to better understand
your interactions with the Services and/or for our compliance verification purposes.
Specifically, we’ll automatically collect from you your internet and other electronic
network activity information including IP address, device type (i.e. make and model),
unique device identification numbers, browser-type, time zone settings, broad geographic
location (e.g. country or city-level location) and other technical information as well
as keystrokes, mouse movements, and your interactions with the Services.
The information collected via cookies includes the following internet and other
electronic network activity information:
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Usage
information: We use essential, performance, and analytics cookies to
collect information about your interaction with our Services, such as what you
access, what you click on, the frequency of access, and how much time you spend on
the Services. We use this information to: (i) track you within the Services; (ii)
enhance user experience; (iii) conduct analytics to improve the Services; (iv)
prevent fraudulent use of the Services; and (v) diagnosis and repair Services
errors, and, in cases of abuse, track and mitigate the abuse.
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Device
information: We use essential, performance, and analytics cookies to
collect certain information about the device you use to access the Services, such as
hardware model, operating system, and device preferences. We use this information
to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct
analytics to improve the Services; (iv) prevent fraudulent use of the Services; and
(v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate
the abuse.
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Location
information: We use essential, performance, and analytics cookies to
collect information about your location, which may be determined through your IP
address. We use this information to: (i) track you within the Services; (ii) enhance
user experience; (iii) conduct analytics to improve the Services; (iv) prevent
fraudulent use of the Services; and (v) diagnosis and repair Services errors, and,
in cases of abuse, track and mitigate the abuse.
Particular cookies to note on the Services include:
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Google
Analytics: We use Google Analytics to conduct analytics. In doing
so, Google Analytics may set cookies on your browser, or read cookies that are
already there. Google Analytics may also receive information about you from
applications that partner with Google that you’ve previously downloaded. We don’t
combine the information collected through the use of Google Analytics with
personally identifiable information. Google will use and share the information
collected through Google Analytics in accordance with its Terms of Use and Privacy
Policy. To opt out, you can download the Google Analytics opt-out browser add-on. To
opt out of this cookie, follow the instructions in the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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Google Ads: We use
Google Ads to deliver advertisements to you and to track whether you’ve interacted
with an advertisement we’ve placed elsewhere on the internet. Google Ads stores a
conversion tracking cookie on your device when you click on our advertisement. The
information obtained through the cookie is used to generate statistics and allows us
to see the total number of users who clicked on our advertisements. We also use
Google Ads to present to users of our Website advertisements across the internet and
within the Google advertising network based on their visits to our Website. For more
information, please review Google’s privacy
policy. To opt out of targeted advertising by Google, you can go to Google’s ad settings. To opt out
of this cookie, follow the instructions in the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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Google Ad
pixel: We use Google AdWords Pixel to customize our advertising and
to serve you ads based on your browsing behavior. This allows your behavior to be
tracked after you’ve been redirected to our website. The global site tag is a web
tagging library for Google’s site measurement, conversion tracking, and remarketing
products. It’s a block of code that adds you to remarketing lists. For more
information, please review Google’s privacy
policy. To opt out of targeted advertising by Google, you can go to Google’s ad settings. To opt out
of this cookie, follow the instructions in the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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Facebook pixel: We
use Facebook Pixel to customize our advertising and to serve you ads on your social
media based on your browsing behavior. This allows your behavior to be tracked after
you’ve been redirected to our Website by clicking on the Facebook ad. The Facebook
Pixel stores a cookie on your device to enable us to measure the effectiveness of
Facebook ads for statistical and market research purposes. We don’t have access to
the information collected through the Facebook Pixel. However, the information
collected via the Facebook Pixel is also stored and processed by Facebook. Facebook
may link this information to your Facebook account and also use it for its own
promotional purposes in accordance with Facebook’s Data Usage Policy. The Facebook
Pixel also allows Facebook and its partners to show you advertisements on and
outside of Facebook. You can opt out of displaying Facebook ads and sharing by
visiting your Facebook Ad Settings, and you can clear and control the information
third parties share with Facebook in your Off-Facebook
Activity page. If you don’t have a Facebook account, you can opt out of
Facebook ads through the Digital Advertising
Alliance. To opt out of this cookie, follow the instructions in
the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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Google Tag
Manager: Google Tag Manager is a tag management system to manage
tags used for tracking and analytics on our Website. Tags are small code elements
that, among other things, are used to manage traffic and visitor behavior and to
test and optimize websites. We utilize Google Tag Manager to manage and organize all
third-party tags on our Website and to control when those tags are triggered. You
can view more information about Google Tag Manager’s privacy practices.
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TUNE Pixel: We may
use TUNE for pixel or server postback tracking to collect certain performance
marketing information about you. This enables us to measure the performance of
marketing and advertising campaigns. Pixel tracking methods store a TUNE session
identifier in a user’s browser cookie on click. In postback tracking (also called
“server-side tracking”), TUNE directly sends a session identifier to the advertiser
on click. On conversion, the advertiser then communicates that identifier to TUNE
for validation. To opt out of this cookie, follow the instructions in the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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ActiveProspect’s Trusted
Form: We use ActiveProspect’s TrustedForm Script to independently
document users’ consent to be contacted. The TrustedForm Script is embedded on our
website and collects the following information when you interact with the page(s)
where the script is present: page URL, mouse movements and clicks, contact
information inputted by the user, a snapshot of the page, including IP address of
the user’s computer, time on the page, date and time that the TrustedForm Script was
loaded, as well as the date and time of the various user interactions with the page,
and HTTP headers from the user’s browser. For more information about
ActiveProspect’s data use and collection policies and practices, please review the
ActiveProspect Privacy Policy at https://activeprospect.com/privacy-policy/.
To opt out of this tracking technology, follow the instructions in the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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Jornaya: We use a
software script provided by Jornaya to (i) verify the origin and history of your
consent to be contacted, and (ii) help us offer services for which you may be
interested. Jornaya will also use the data shared with it to supplement its
services. Jornaya will use a persistent cookie to identify your browser in the
future and connect it to a LeadiD or other identifiers. For more information about
Jornaya’s data use and collection policies and practices, please review Jornaya’s Privacy
Policy. To opt out of this tracking technology, follow the instructions in
the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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SendinBlue: We use
this tracking technology to conduct email marketing lead generation from your
interaction with our marketing emails. In doing so, SendinBlue, may collect personal
information to conduct such analysis. SendinBlue will use and share the information
it collects in accordance with SendinBlue’s Privacy
Policy. To opt out of these cookies, follow the instructions in
the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
In general, to disable cookies and limit the collection and use of information through
them, you can set your browser to refuse cookies or indicate when a cookie is being
sent. When you opt out an opt-out cookie will be placed on your device. The opt-out
cookie is browser- and device-specific and will only last until cookies are cleared from
your browser or device.
How We Share Your Personal Information
TwinerLite will make the personal information identified in this Policy
available within TwinerLite’s corporate family, with service providers, or
with other third parties as set forth below. We also share non-personally identifiable,
aggregated, and/or public information with third parties. TwinerLite may
share the personal information identified in this Privacy Policy in the following
instances:
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With service
providers: We share your personal information with our service
providers that assist us in providing the Services, such as our IT support,
marketing provider, software service provider, telephony software provider,
communications provider, cloud and hosting provider, and email provider.
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With customers: We
share lead information with our customers so they can contact you regarding the
products and services they provide relevant to your project. We share this
information to provide our services and connect you to businesses that can help you
with your project.
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Within Innovation Direct
Group‘s corporate
family: Where necessary, we share your personal information within
TwinerLite’s corporate family for legitimate business purposes in order
to efficiently carry out our business and to the extent permitted by law.
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In the event of a corporate
reorganization: In the event that we enter into, or intend to enter
into, a transaction that alters the structure of our organization, such as a
reorganization, merger, acquisition, sale, joint venture, assignment, consolidation,
transfer, change of control, or other disposition of all or any portion of our
assets, we would share your personal information with third parties, including the
buyer or target (and their agents and advisors) for the purpose of facilitating and
completing the transaction. We would also share your personal information with third
parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
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For legal
purposes: We’ll share your personal information where we’re legally
required to do so, such as in response to tax obligations, court orders, law
enforcement or legal process, including for national security purposes; to
establish, protect, or exercise our legal rights, as required to enforce our terms
of use or other contracts; to defend against legal claims or demands; to detect,
investigate, prevent, or take action against illegal activities, fraud, or
situations involving potential threats to the rights, property, or personal safety
of any person; or to comply with the requirements of any applicable law.
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With your
consent: Apart from the reasons identified above, we may request
your permission to share your personal information for a specific purpose. We’ll
notify you and request consent before you provide the personal information or before
the personal information you’ve already provided is shared for such purpose. You may
revoke your consent at any time.
Sharing in the Last Twelve (12) Months
1. For a Business
Purpose: In the preceding twelve (12) months, TwinerLite
has disclosed the following categories of personal information for a business purpose to
the following categories of third parties:
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We’ve disclosed your personal identifiers, Internet and other network activity
information, and customer records information to service providers that perform
services on our behalf. These service providers include our software service
provider, telephony software provider, hosting service provider, communications
service provider, website development service provider, and cloud and hosting
provider.
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We’ve disclosed your internet or other electronic network information to our IT
support to detect security incidents, protect against malicious, deceptive,
fraudulent, or illegal activity, and to identify and repair website errors that
impair functionality.
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We’ve disclosed your internet or other electronic network information and location
information to our IT support and data analytics provider to maintain, improve, and
upgrade TwinerLite Services.
2. For a Sale:
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TwinerLite uses analytics, marketing, consent tracking, and marketing
email cookies and other tracking technologies on its Services. These tracking
technologies collect your internet and other electronic network activity and shares
it with the company that placed the tracking technology on our Services, e.g.
Facebook, Google, Jornaya, SendGrid, and Active Prospect. This use of your personal
information may be considered a sale under the California Consumer Privacy Act. To
opt out of this cookie, follow the instructions in the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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We may share with our customers/partners and affiliates your personal identifiers
(name, email address, telephone number, physical address), selected insurance type,
selected timeframe, and any other information you choose to include. Please see the
following link for a list of representative organizations to whom your personal
information may be shared so they may send you marketing communications relevant to
your interests, projects, or potential projects. If you’re a California or Nevada
resident and wish to opt out, please follow the instructions in the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
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We may share with our session recording vendor your internet and other electronic
network activity to help us analyze how you use our Services. This use of your
personal information may be considered a sale under the California Consumer Privacy
Act. To opt out of this cookie, follow the instructions in the Your Information
Choices section of this Policy or visit Do Not Sell My Personal
Information.
California Residents
The California Consumer Privacy Act (CCPA) entitles California residents to certain
rights. To the extent that the CCPA applies to our processing of your personal
information, you would be entitled to the following rights:
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Right to
access: You’ve the right to request what personal information we’ve
collected, used, disclosed, and sold about you within the preceding twelve (12)
months. You may only submit a request for access twice within a twelve-month period.
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Right to
deletion: You’ve the right to request the deletion of your personal
information that we collect or maintain, subject to certain exceptions.
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Right to opt
out: You’ve the right to opt out of the sale of your personal
information to third parties. TwinerLite doesn’t have actual knowledge
that it sells personal information of minors under the age of sixteen (16) years.
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Right to
nondiscrimination: You’ve the right to not receive discriminatory
treatment if and when you exercise your rights to access, delete, or opt out under
the CCPA.
To exercise your right to access or delete your personal information, you may submit a
request via email at contact@twinerlite.com or
via telephone by calling 321-837-9954. To opt out of the sale of your personal
information via cookies or for marketing purposes, please visit Do Not Sell My Personal
Information.
For requests submitted via email and telephone, you must provide us with sufficient
information that allows us to reasonably verify that you’re the person about whom we
collected the personal information and describe your request with sufficient detail to
allow us to properly evaluate and respond to it. If we’re unable to verify your identity
for access and deletion requests with the information provided, we may ask you for
additional pieces of information. The interactive web form contains the information that
we need to verify your identity and review your request.
Only you or a person registered with the California Secretary of State that you
authorize to act on your behalf may make a request related to your personal information.
If you’re an authorized agent making a request on behalf of another individual, you must
provide us with signed documentation that you’re authorized to act on behalf of that
individual.
Nevada Residents
If you’re a consumer in the state of Nevada, you may request to review the personal
information we maintain about you, make changes to the personal information we maintain
about you, or opt out of the current or future sale of your personal information by
submitting a request via email at contact@twinerlite.com.
Please include “Request Under Nevada Law” in the subject line of your message.
NonCalifornia and NonNevada Residents
To exercise your right to access or delete your personal information, you may submit a
request via email at contact@twinerlite.com or
via telephone by calling 321-837-9954. To opt out of the sale of your personal
information via cookies or for marketing purposes, please visit Do Not Sell My Personal
Information.
For requests submitted via email and telephone, you must provide us with sufficient
information that allows us to reasonably verify that you’re the person about whom we
collected the personal information and describe your request with sufficient detail to
allow us to properly evaluate and respond to it. If we’re unable to verify your identity
for access and deletion requests with the information provided, we may ask you for
additional pieces of information. The interactive web form contains the information that
we need to verify your identity and review your request.
Your Information Choices
All users of our Services have the following choices and rights:
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Marketing
emails: You may opt out of receiving marketing emails from us by
clicking the “unsubscribe” link provided with each email. Please note that we’ll
continue to send you emails necessary to the Services or any assistance you request.
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Opt Out of email
tracking: You can disable this tracking by blocking automatic
loading of images in your email.
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Marketing text
messages: You may opt out of receiving marketing text messages from
us by responding “STOP” or “Opt-out” to any of our text messages.
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Opt out of Google
Analytics: To prevent your data from being used by Google Analytics,
you can download the Google Analytics opt-out browser or visit Do Not Sell My
Personal Information.
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Opt out of other
cookies: All session cookies are temporary and expire after you
close your web browser. Persistent cookies can be removed by following your web
browser’s directions. To find out how to see what cookies have been set on your
computer or device, and how to reject and delete the cookies, please visit https://www.aboutcookies.org/.
Please note that
each web browser is different. For information on reviewing or deleting cookies from
specific browsers, click on the appropriate browser: Firefox, Firefox IOS, Firefox
Android, Safari, Safari Mobile, Chrome, Internet Explorer, Microsoft Edge, Opera.
To find information relating to other browsers,
visit the browser developer’s website and mobile application. If you reset your web
browser to refuse all cookies or to indicate when a cookie is being sent, some
features of our website and mobile application may not function properly.
If you choose to
opt out, we’ll place an “opt-out cookie” on your computer. The “opt-out cookie” is
browser-specific and device-specific and only lasts until cookies are cleared from
your browser or device. The opt-out cookie won’t work for essential cookies. If the
cookie is removed or deleted, if you upgrade your browser or if you visit us from a
different computer, you’ll need to return and update your preferences.
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Opt out of online
advertising: Some of the companies that provide advertising services
on our Services may participate in industry-developed programs designed to provide
consumers with choices about whether to receive tailored ads that are based on your
online activities. To learn more and to opt out of such targeted advertising from
participating companies, please visit the websites of the Network Advertising
Initiative, the Digital Advertising Alliance. To
successfully opt out, you must have cookies enabled in your web browser (see your
browser’s instructions for information on cookies and how to enable them). Your opt
out only applies to the web browser you use, so you must opt out of each web browser
on each device you use. Once you opt out, if you delete your browser’s saved
cookies, you will need to opt out again.
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Opt out of sharing with
partners: If you’re a California resident and wish to opt out of us
sharing your personal identifiers with our partners for marketing purposes, please
follow the instructions in the California
Residents section of this Policy to allow us to facilitate the
opt-out. If you’re a Nevada resident and wish to opt out of us sharing your personal
identifiers with our partners for marketing purposes, please follow the instructions
in the Nevada
Residents section of this Policy to allow us to facilitate the
opt-out.
Do Not Track
We don’t support Do Not Track (DNT). DNT is a preference you can set to inform websites
and applications that you don’t want to be tracked.
Information Security
We implement and maintain reasonable security measures such as access controls and
encryption, to protect the personal information we collect and maintain. However, no
security measure or modality of data transmission over the Internet is 100% secure and
we’re unable to guarantee the absolute security of the information we’ve collected from
you.
Age Restriction
The Services aren’t intended for individuals under the age of eighteen (18). If we learn
that we’ve collected or received personal information from a child under the age of
eighteen (18), we’ll delete that information. If you believe we might have information
from or about a child under the age of eighteen (18), please contact us at contact@twinerlite.com.
Changes to This Privacy Policy
We may change this Privacy Policy from time to time. We’ll post the changes to this page
and will indicate the date the changes go into effect. We encourage you to review this
Policy to stay informed. If we make changes that materially affect your privacy rights,
we’ll notify you with a prominent post on our Services and obtain your consent, if
required.
Contact
If you’ve any specific questions about this Privacy Policy, you can contact us via email
at contact@twinerlite.com.