Information We Collect and Use
When we refer to “Personal Data,” we mean any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly, or indirectly, by reference to an identifier such as a name, an identification number, location data, or an online identifier.
TWLB directly and through third-parties collects information that you provide to us from your use of the Services, and from other sources. The information we collect and how we process it depends on how you use and access the Services and we combine all of the information we have about you so that we can analyze it and provide better Services to you. We collect information, including Personal Data, as follows:
- Your Submissions to Us– TWLB will collect your Personal Data when you sign up for an online newsletter or contact us with a question or request. For example, if you submit a request to advertise with us, you may provide us with your name, email address, telephone number, address, and company. We use this information as necessary to respond to your request or inquiry and to provide and improve the Services and our products. We process this Personal Data as long as we have a legitimate interest or based on your consent.
- Your Content Submissions– TWLB allows users to submit content, such as comments and images, on some or all of our sites which we post on the Services with your consent. Users who choose to sign up for this service must provide a user name and email address. We receive any Personal Data in the comments or images you submit to us. We process this Personal Data as long as we have a legitimate interest and based on your consent. If, in addition to you, other persons are identifiable in the content you provide, you must obtain consent from those persons prior to publication.
- Your Location – “Location Data” is collected with your consent or inferred as you use the Services. Such information will include the location of the mobile device or computer used to access the Services derived from GPS or WiFi use, your device’s IP Address, or the geographic information you provide to us (e.g. your city). We use this information to analyze the use of the Services, customize and improve the content for you on the Services, send you location-specific content, and show you events or businesses near you. We use and retain the Personal Data for as long as necessary and useful to provide personalized and improved services to you or until you withdraw consent.
- Your Social Media Interactions– We receive Personal Data about you when you interact with us using the social media aspects to our Sites, on our social media pages and channels, or on other channels and content. The Personal Data includes profile name, profile identifier, and the content of your submissions. We use this information to communicate with you and for internal purposes until you withdraw consent or we do not use the social media pages anymore. Please review the privacy policies and settings of any websites, mobile applications, or social networks should you have any questions about their privacy practices. Please note that any content (e.g. comments, photographs, information and other materials) that you post directly to our Sites, including our social media pages, is public and can be read, collected or used by others. Please be cautious when disclosing any Personal Data through public activities or submissions.
- Marketing and Other Informational Updates – With your consent and as otherwise permitted by law, we use your email address and other information we receive from and about you to contact you with information about our products and services and others’ products and services, provide special offers and promotions that may be of interest to you. You may withdraw your consent at any time by unsubscribing from such marketing communications. Withdrawing your consent will not affect the lawfulness of the processing before the withdrawal. We may also notify you periodically about important changes to the services. Withdrawing consent from marketing communications does not affect our ability to send you these communications, such as those related to providing services to you or responding to your requests.
- We may link this data with other information we have collected from and about you. Our vendors may also collect and combine information collected on our Services and emails with other information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same vendors. Our vendors use the information they collect according to their privacy policies. For example, we currently use Google Analytics to collect and process certain website Usage Data for the above purposes and to facilitate our use of other Google tools (e.g. Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting). To learn more about Google Analytics and how to opt out, please visit www.google.com/policies/privacy/partners/. You may be able to change browser settings to block and delete cookies when you access the Services through a web browser. However, if you do that, the Services may not work properly. Our Sites are not set up to respond or process web browser “Do Not Track” (“DNT”) signals but they do respond to browser cookie settings. You can learn to decline or opt-out of cookies by reading the section on Cookies below.
How We Share Information
Enabling Services on the Sites – We offer a variety of services and functions through the Services. Personal Data that is collected through the Services will be used/and or disclosed to third-parties in order to enable us to provide the Services. For example, the Services allow you to interface with third-party websites, content, advertising, and features. To facilitate that interaction, we use your Personal Data and/or disclose your Personal Data to the third-party operating the websites and features.
Legal and Other Similar Uses – Though we make every effort to preserve user privacy, TWLB may need to disclose Personal Data when required by law when we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on TWLB or its affiliates. If we intend to turn over information related to you for any of these reasons we will use commercially reasonable efforts to provide you with advance notice, unless we are prohibited from doing so by law or court order.
We use industry standard website tracking and delivery technology to serve you relevant advertising on and off the Services. Our services display advertisements to you via targeted advertising methods. This permits us to show you certain advertising about products and services tailored to your individual interests based on information we receive from visitors of the Services and by third-parties. You may also see certain ads through your use of the Services because we participate in advertising networks. Ad networks allow us to target our advertising to users through the use of click-stream, demographic, behavioral and contextual information. The use of third-party tracking technologies to collect this information is often subject to their own privacy policies.
- Ad Serving – The ads appearing on our Sites are delivered to you by advertising vendors and/or by TWLB’s own proprietary advertising delivery software. In order to serve ads to you, we may use information collected during your searches or visits to our websites and information that we specifically acquire from third parties.
- Advertising and Cookies – Some of our third party advertising partners may distribute cookies to users in advertisements that are provided to us. TWLB has no access to or control over these cookies once we have received the advertisements. Some of these advertisers and services we use to deliver advertising may be engaging in online behavioral advertising as defined by the Digital Advertising Alliance (DAA) and Federal Trade Commission (FTC).
Cookies – TWLB places small data files called cookies on your device to ensure that the Sites function properly, to track how you use our Sites, to improve our Sites and your user experience, and to tailor our Sites to your interests. Cookies are small text files that are saved on your computer or mobile device when you visit the Sites. They enable the Sites to record and/or remember your actions and preferences. TWLB uses the following cookies on our Sites:
- Performance Cookies: These cookies collect information about how you use the Sites (e.g. which pages you go to most often) to improve how the Sites work.
- Functionality Cookies: These cookies allow the Sites to remember the choices that you make (e.g. language or the region you are in) and provide enhanced, more personal features.
- Targeting/Advertising Cookies: These cookies are used to deliver online advertisements on and off the Sites that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. The cookies remember that you have visited the site and this information may be shared with other organizations, e.g. advertisers.
- The cookies used by TWLB are either first party or third party cookies. First party cookies like the ones used when you log in to your account, are set by TWLB and share the same domain. Third party cookies, on the other hand, are stored by third party providers and organizations with different domains.
- Opt-out – As part of our commitment to transparency and your privacy, we provide the following links to opt-out of cookies provided by both our first party ad server and many third party advertising partners who may be engaging in online behavioral advertising:
- First Party Opt-out – Please visit this link to opt-out of cookies from our first party ad serving vendor, Google: http://www.google.com/privacy/ads/
- Third Party and Interest-Based/Online Behavioral Advertising Opt-out – Please visit this link to opt-out of cookies from over 50+ major third party behavioral advertising providers: http://www.aboutads.info/choices/
Merger, Sale or Other Asset Transfers -In the event TWLB goes through a business transition, such as a merger, acquisition by another company, or sale of a portion of its assets, your information may be disclosed in connection with the negotiation of such transaction and/or sold or transferred as part of such a transaction as permitted by law and/or contract.
We care about the privacy of children. Accordingly, we do not direct our Sites to children under the age of 16 or knowingly collect Personal Data from them. If we learn that a user is under 16, we will promptly delete any Personal Data that the individual has provided to us.
How We Protect Personal Data
TWLB has technical, administrative and physical safeguards in place to help protect against unauthorized access to, use or disclosure of Personal Data we maintain. Under our security practices, access to personally identifiable information is authorized only for those who have a business need for such access, and sensitive records are to be retained only as long as necessary for business or legal needs and destroyed before disposal. Although we work hard to protect personal information that we collect and store, no program is one hundred percent secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal information.
If you become aware of a security issue, please email us at email@example.com. We will work with you to address any problems.
How Long We Keep Personal Data
We retain the information we collect about you for as long as necessary to fulfill the purpose we collected it for and for the purpose of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.