Last Updated: 12/16/2020
When accessing the Website, TWA will learn certain information about you. This Policy applies to information we collect on the Website and in email, text, or other electronic messages between you and the Website.
Information We Collect and Process
When you access the Website, TWA will learn certain information about you (“Personal Information”) during your visit.
Personal Information may include any information you voluntarily provide to Us by filling out forms on the Website, communicating with us via contact forms, responding to surveys, search queries on our search feature, providing comments or other feedback, and providing information when ordering a Product or Service, such as:
· Personal Data. Your first and last name; address; phone number; email address; birthday; and similar information that is stored in a personally identifiable form and/or in such a form that allows you to be contacted – online or offline.
· Profile Information. We use and process the information you provide on your personal profile, including your name, address, date of birth, e-mail, phone number, photos, etc.
· Public Comments and Inquiries. This information may consist of any communications you send to us, including information that you publicly post on our Website, our member forums, group chats, customer service chats, on-line inquiry and website contact forms, or our blog, as well as any metadata associated with the communication.
The above information will be used by us to deliver any Product(s) or Service(s) purchased, to improve our performance and services, to facilitate our TWA Communities, and to provide you with offers, promotions, and information.
Personal Information may also include information we collect through automatic data collection technology such as Facebook pixel, Google Analytics and other automatic data collection tools that collect certain information about your equipment, browsing actions, and patterns, including but not limited to information regarding your location, your traffic pattern through our website, and any communications between your computer and the Website. Such information may include:
· Network, Device and Browsing Data: This may include website cookies; social media accounts; website chat threads and content; customer support content.
· Usage Data and Other Trackable Information: This may include IP addresses; operating system and device information; referral sources; passwords; shopping cart information; security questions and answers; point of sale data; browser activity; page views; websites visited; website navigation patterns; product descriptions viewed; user preferences selected; forms submitted; videos watched; the timing, frequency and other patterns of your use of our site and/or services; and location information.
The above information we collect automatically is used for statistical data and will not include personal information. We use this data to improve our Website and our service offerings. To the extent that you voluntarily provide personal information to us, our systems will associate the automatically collected information with your personal information.
How We May Collect User Information
We use the following methods to collect information in order to provide and improve our products and services:
1. We ask you for it. Some of the information we may ask our users to share with us includes:
§ Any information that you enter on our website to sign up for our e-mail lists and marketing and informational newsletters – usually your name and email;
§ Information that you provide to us in exchange for a free download – usually your name and e-mail address, and occasionally a phone number;
§ Information you provide in order to participate in a contest or questionnaire, or communicate with our customer service team – usually your name and e-mail, but may include your phone number address and credit card/billing information as well;
§ Information you provide us in order to sign up for a membership account – including your contact and billing information;
§ Information you provide as a condition of participating in our discussion boards, groups, and other community features – usually your name and e-mail;
§ Information submitted as a condition of leaving a review – usually your e-mail;
§ Information submitted by you in order to receive product availability alerts – usually your name and e-mail;
§ Shipping and delivery information for any orders you place through our site – your name, address, e-mail and phone number.
We use this information to respond to your requests; customize your usage and shopping experience; improve our products and services; analyze traffic and user behavior; and deliver your orders; and communicate with you.
You always have a choice about sharing your information with us. However, in certain cases, failure to provide the requested information will limit your ability to take advantage of some of our website’s many features.
2. We Collect it Automatically When You Interact With Our Site. Some information we receive and store automatically whenever you interact with our site. For example, we may use and collect IP addresses; login information including usernames and passwords used; email addresses; browser information (such as type, version, plug-ins, location and time zone settings); information about your operating system; your purchase history; pages visited on our site and time spent; searches performed; session information such as loading times, download errors, and page interaction information, all of which may be stored in log files on our servers.
In addition, we collect and record all information automatically when you use our website’s search function; buy one of our products or services; post something in response to a blog post or on our community forums; participate in a contest or questionnaire; or submit a form to communicate with our online customer service.
We may also collect information about your mobile device, in order to personalize the content you receive, and to provide you with location-based services and advertising. You may disable this by turning off the location setting on your device.
Some specific methods we use for automatic collection of information include the following:
§ Log Information. This is data concerning your use of the website, including your IP address; browser information (type, version, plug-ins); internet service provider (ISP) information; information about your operating system; referring pages; exit pages; date, time, location and similar data; all of which is stored in log files.
§ Pixels. Also known as web beacons, tracking pixels, internet tags or clear gifs, these are small image files embedded on pages of our site as well as e-mail messages we send out. They are used to count, track and monitor views of certain pages, time spent, and how users navigate the site in general. With this information, we are able to customize our informational and promotional content to what is most relevant to you and others.
§ Embedded Scripts. These are pieces of code that are temporarily downloaded to your device in order to collect information about your interaction with the site. Once you leave the site, they are deactivated or deleted. Like pixels, we use the data from our embedded scripts to make sure that we send you only the most relevant informational and promotional content.
§ Click-Through URLs. We may, on occasion, send informational and promotional e-mails with click-through URLs linked to certain content on our website(s). Clicking on these URLs will take you through a different server before arriving at the linked webpage. The data we collect in this process helps us determine the effectiveness of our communications, as well as user interest in certain topics.
§ Location-Identifying Tools. We may use GPS, geofiltering, and other location-identifying technologies to determine your location and send you relevant content based on the information gathered.
§ Application and Device Identifiers. Some of our mobile apps may include unique identifiers such as an app number to gather and analyze user activity on certain applications and devices.
3. We Collect it Automatically When You Call or E-mail Us. We collect and record your email address and available information transmitted when you e-mail us or call our customer service number. In addition, we may save confirmation data such as e-mail open rates, click-rates for links sent inside promotional e-mails, and other similar information.
Definition. Cookies are pieces of code that our website puts in your browser. They serve as unique identifiers that enable our systems to recognize your computer of mobile device, which enables us to provide you with more personalized advertisements; store your items in your shopping cart between visits; keep you signed in under your account; and help create a better user experience on our site.
Cookies may be either "persistent" (stored in your browser and valid until deleted or they expire), or "session" cookies (which expire when you close your browser).
“Cookies,” as the term is used in this Policy, also includes technological equivalents of cookies, including social media pixels, which allow social media sites to track visitors to outside websites and use the information gathered to tailor advertising shown to users while visiting that social media website. TWA reserves the right to use these pixels in compliance with the policies of the various social media sites.
Cookies and Personal Information. Normally, cookies do not contain any personally identifying information; however, we may gather and store certain personal data about you that may be linked to the information obtained from, and stored in your cookies. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, and your IP address.
Disabling Cookies. You can easily set your browser to disable cookies, prevent acceptance of new cookies, or to notify you when a new cookie is received. However, please note that if you disable cookies, parts of our site may not function properly on your device.
We do not own or control tracking technologies used by third parties such as Google. If you have any questions about an advertisement or other targeted content shown to you on a third party site or platform, such questions should be addressed to the provider of the advertisement.
Our Email Policy
If you choose to correspond with TWA through email (including signing up to receive emails using any of our online forms or by purchasing a Product or Service), We may retain the content of your email messages, your email address and our responses. We employ the same protections for email communications that we use in the maintenance of other personal information received by Us.
We will maintain the information you send via e-mail in accordance with applicable federal law and our communications will always comply with the CAN-SPAM Act and will include information on how to opt-out or unsubscribe from our mailing list, with a link to the unsubscribe page at the bottom of all e-mails.
How and Why We Use Your Information
We may collect, use and process your personal information for a variety of purposes, including:
§ Administering and authenticating your account;
§ Providing you with access to our products, services, and tools;
§ Customizing and providing the best customer experience possible;
§ Responding to your questions and comments;
§ Providing the products, services and transactions you request;
§ Sending you confirmations and administrative communications;
§ Communicating with you regarding orders, updates, offers, promotions, downloads, contests, and informational materials that you may sign up for;
§ Providing you with more relevant content and advertising;
§ Obtaining your feedback;
§ Tracking and analyzing user behavior, browsing patterns and purchasing behavior on our website as well as in connections with e-mails and advertisements we send;
§ Conducting market research, audits, and data analysis to improve our products, services, vendor relationships, systems, processes and communications;
§ Developing, customizing, and improving our products, services, content and advertising;
§ Sending you personalized e-mails in accordance with your indicated interests and preferences;
§ Protecting the rights, property and security of our company and our users and customers;
§ Preventing fraud and other criminal or illegal activities;
§ Obtaining insurance coverage and professional advice;
§ Protecting our company, users and the general public against safety, security and other risks;
How We May Share Your Information
The privacy policies of our partners and affiliates with whom we may share personal information can be viewed at:
Breach Secure Now! at https://www.breachsecurenow.com/
Atera at https://www.atera.com/
ID Agent https://www.idagent.com/
MailProtector at https://mailprotector.com/
OITVOIP at https://oit.co/
Actifile at https://actifile.com/
Lifecycle Insights at https://lifecycleinsights.io/
Barons Inc. at https://baronsinc.net/
Cytracom at https://www.cytracom.com/
L3 Data Services at https://www.lcubeddataservices.com/
§ Third Party Service Providers. We have a number of vendors who perform functions on our behalf, including fulfillment centers; mail carriers and product delivery services; data compilation and analysis; marketing and advertising services; customer relations management; software maintenance services; database management; web administration and analytics; processing of online payments via credit card or ACH transactions; and providing customer service.
If you choose to purchase a Product or Service from TWA or participate in certain programs provided by Us, for example, signing up for a webinar, joining an e-mail list, web class, group, forum, TWA Community or other program/event, we may share your information with certain content providers, sponsors, and vendors for the purpose of delivering the program or content that you signed up for.
§ Third Party Advertising and Analytics. We may use certain third-party advertising and analytics services. These may include network advertisers, which we use to deliver marketing and advertising communications to you, including interest-based advertising, which facilitates the delivery of targeted advertisements on various pages anywhere on the Internet based on your browsing behavior and use of our site.
We may also use traffic measurement services to monitor, log, analyze and prepare reports for traffic analysis.
The advertisers, sponsors, network providers and traffic measurement and analytics providers may set up their own cookies, pixels, web beacons and other technologies on your device, in order to track certain browsing behaviors on those devices. This allows these third parties to deliver advertisements relevant to you, gauge the relevance of the advertising by your response, and to prevent you from having to see the same ads over and over again.
§ Risk Management and Professional Advice. We may disclose your personal information to any insurers and/or professional advisers we may deem necessary in order to manage risks, obtain professional advice, maintain insurance coverage, or defend legal proceedings.
§ With Your Consent or At Your Direction. We may from time to time ask you if you would like us to share your information with third parties for the purpose of a promotion, discount, or other purpose. You will always be given the option of consenting to or refusing the sharing of your information.
Specific Security Measures
We have implemented appropriate security measures, consisting of administrative, technical, and physical precautions, for the purpose of protecting your personal data from unauthorized access, alteration, use, disclosure, theft, loss, destruction, and other forms of misuse.
Please note, however, that while we have implemented various measures to protect your privacy and personal data, we make no guarantees or warranties as to the security of any information you disclose or transmit to us online, nor are we responsible for the loss, misappropriation, or inadvertent disclosure of your personal information.
Some of the ways we protect and keep your private information private include:
§ SSL. Using a Secure Sockets Layer (SSL) software to protect your information during transmission by encrypting all information you input.
§ Credit Card Details. Revealing only the last four digits of your credit card numbers when confirming an order.
§ Internal and Contractual Data Safeguards. Information collected and processed by TWA is subject to safeguards, including the use of binding contracts, data protection clauses, NDAs and corporate rules which apply to our relationships with vendors, partners, sponsors, and other affiliates, which you may obtain by submitting a written request to [email protected]
Your Rights and Options
You have certain rights under data protection laws regarding our collection and processing of your personal data. These laws are quite complex, so we are not including a detailed overview here. You are advised to read the relevant laws and industry guidance, or consult with an attorney for in-depth legal advice regarding your privacy rights.
As a brief summary, your privacy rights cover your right to access, restrict, edit, rectify, request erasure, prohibit processing, complain to the appropriate authorities, and withdraw consent to our use and processing of your personal information.
You may exercise any of the rights outlined below by sending a written request to [email protected]
Accessing Your Information. We have implemented systems, processes and technologies to help ensure the continued accuracy of our data. Part of these measures is to comply with your right to request, review, change, or delete any personal data we collected from you, by submitting your request in writing to [email protected]
Editing Your Personal Information. You have the right to correct inaccurate personal information, or request us to do it for you by sending a written request to [email protected]
Erasure of Personal Information. In certain cases you’re entitled to request us to promptly remove your personal information from our systems and databases. Some circumstances which entitle you to the erasure of your personal data include:
· You wish to prohibit the use of your personal information for direct marketing purposes;
· The information is no longer necessary to achieve the purposes for which it was collected or processes;
· You are withdrawing consent to the collection and processing of certain personal information that requires consent;
· You oppose the processing of your personal information pursuant to an applicable data protection law;
· You have not consented to the collection and/or processing of the personal data in question, or for the purpose for which it is being used.
Please note that, we may, in some limited circumstances, be legally obligated to retain your data despite your delete request. For example, we are not required to erase your personal information if doing so would infringe upon the rights of another person; or if we need to retain the information in order to comply with a legal obligation; or if the information is necessary to establish, prosecute, or defend a legal claim. We will notify you in writing if this is the case.
Restricting Processing of Your Personal Information. The same way you can instruct us to remove your personal information, you may also be legally entitled to restrict or limit our processing of your personal information. Sometimes, you may have grounds to request erasure of your data, but you only want us to stop processing it or use it for a specific purpose, rather than removing it from our systems altogether. For example, you always have the right to tell us not to use your personal information for marketing and advertising purposes. In these cases, you may request that we keep your personal data intact, but stop processing it.
If you request that we restrict the processing of your personal data, we may continue to store your information in our systems; however, we will not process it unless we receive your express consent to do so, or unless we need to do so to establish, exercise or defend a legal claim, or to protect the life, health, safety and security of our company and other natural or legal persons; or for similar grounds based on an important public interest.
Verifying Your Identity. Please note that we may require additional personal information to verify your identity (including requesting copies of government-issued identification documents such as passports, drivers licenses and the like).
Not Providing Personal Information. As discussed above, you can always choose not to provide us with your personal information, though it may affect your ability to use some of our Products and Services, set up an account, and/or participate in our newsletters, offers, promotions and TWA Communities.
Opting Out. If you wish to restrict the type and amount of communications you receive from us, or you do not want to receive mail, email or other correspondence from us, you can opt-out adjust your preferences in the membership area, or contact us at: [email protected]
If you do not want us to use the personal information we gather to permit our third party partners to customize ads visible to you, send us an email to [email protected].
You may also be able to automatically transmit a “Do Not Track” signal from your browser to certain websites and online services. As there is virtually no industry guidance as to how site and software operators should respond to such signals, we are not actively monitoring or responding to “Do Not Track” signals and similar mechanisms.
You can prevent the collection of personal information on your mobile device by uninstalling our application. You may also disable certain features in your device settings, such as turning off location-based services. Please note that some features of our products/services may not function properly if certain permissions are disabled.
Please note that, even if you opt out of certain types of Interest-based Advertising, you may continue to receive other types of ads, including targeted ads from other ad networks. We are not responsible for any third party’s opt-out programs and procedures, nor are we responsible for the accuracy of information distributed by third parties regarding their programs and opt-out procedures.
EU Residents. If you are a resident of the European Union, and would like us and/or our third party partners, vendors and affiliates not to use or process your personal information, please send us an e-mail to [email protected], or send us a letter to the following address: 801 Barton Springs Ave., Austin TX 78704, USA.
Requests must include your name, address (city, state, zip), and e-mail address you used to sign up for our services and mailing lists. All emails must have “EU Privacy Rights Request” as their subject line, and all physical mail should have “EU Privacy Rights Request” clearly visible at or near the top of the first page.
Our Details. TWA is a Texas limited liability company with our central office located at and principal place of business located at 801 Barton Springs Ave., Austin TX 78704. You can contact us by:
· Sending a letter to 801 Barton Springs Ave., Austin TX 78704;
· Sending and e-mail to [email protected];
Children’s Privacy. The Website and TWA Assets are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information as defined under the U.S. Children’s Privacy Protection Act (“COPPA”) from children under 13. Additionally, we do not target our website, products, services, marketing, or advertising to children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features or make any purchases or Products or Services, use any available interactive or public comment features of the Website or provide any information about yourself to us, including your name, address, email address, telephone number, username, or financial information.
If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will immediately delete that information.
We urge all parents and guardians to take monitor their children’s online activities, and if a minor under 13 is believed to have collected information from our site or service in a manner not authorized under COPPA, please contact us and we will take appropriate measures, to the extent required by law, to remove such information.