Privacy Notice

Twin Marquis, Inc. its affiliates and respective brands (collectively, “Twin Marquis”) respect your privacy and are committed to protecting it through our compliance with applicable laws and this Privacy Notice (“Notice”).

This Notice describes how Twin Marquis collects, uses, discloses, transfers, stores, retains or otherwise processes your information when you (whether in your individual or business capacity) access or use, in any manner, any content, products, or related activities (collectively, “Offerings”), including offline events and through the Internet domains owned or operated by Twin Marquis, which include, but are not limited to:

https://www.twinmarquis.com/

We refer to the above website and all related websites as “sites” and to each of them as a “site.” When we refer to “we,” “us,” or “our,” we mean Twin Marquis, or the specific division, subsidiary, or affiliate that operates a site, provides its content, or processes information received through it, each as appropriate and applicable. When we refer to “you” or “your,” we mean the person accessing the site. If the person accessing the site does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.

Your access to and use of Twin Marquis sites, and their respective services, are also subject to the Terms of Service.

This Notice applies to your use of our Offerings, and covers information collected in connection with your access to and use of our Offerings, including those Offerings provided through our sites, offline events or point-of-sale and/or online. Please read this Notice carefully. By continuing to interact with our Offerings, you are consenting to the practices described in this Notice.

Please note that this Notice does not apply to employment-related personal information collected from employees, job applicants, contractors, or similar individuals.

I. OUR NOTICE INCLUDES:

• GENERAL DISCLOSURES
• WHAT INFORMATION WE COLLECT
• HOW WE USE YOUR INFORMATION
• WHEN AND WITH WHOM DO WE DISCLOSE YOUR INFORMATION
• THIRD-PARTY ADVERTISING AND ANALYTICS
• LINKING SITES
• SOCIAL MEDIA
• HOW LONG WE RETAIN YOUR INFORMATION
• MARKETING AND PROMOTIONAL COMMUNICATIONS
• CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION
• SECURITY
• CALIFORNIA CONSUMERS
• CHANGES TO THIS NOTICE
• CONTACT INFORMATION

II. GENERAL DISCLOSURES

This site is hosted in the United States. If you are visiting the sites from outside of the United States, please note that by providing your information it is being transferred to, stored or processed in the United States and other countries, where our data center and servers are located and operated. This section sets forth Twin Marquis’ general privacy practices with respect to consumer information for the United States. Depending on your state or country of residence, applicable privacy laws may provide you the ability to request access to, correction of or deletion of your information, as further outlined below. If you are outside the United States and do not wish to allow the transfer of your personal information to the United States, you should not use these sites and you should opt-out of the collection of cookies. View our COOKIES NOTICE.

We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.

III. WHAT INFORMATION WE COLLECT

1. Types of Information that May Be Collected

Twin Marquis may collect different information from or about you depending on the manner in which you use our sites or services. The following examples are provided to help you better understand the information we may collect through your access or use of the Offerings, including the sites.

• Identity Information – includes first name, middle initial, last name, date of birth, gender, social security number, marital status, household income, age range, household size.
• Sensitive Personal Information – can include Identity Information, Sensitive Information, Contact Information, Health Information and possibly Transaction Information.
• Contact Information – includes personal mailing address, email address, telephone number.
• Social Media Information – includes information gathered from a search of your social media accounts.
• Transaction Information – includes payments to and from you and details about products you have purchased from us.
• Health Information – includes health or biometric data that you have provided to us.
• Usage Information – includes information about how you use our sites and products, including usage statistics about your interaction with Twin Marquis sites, including pages accessed, referring website address(es) time spent on pages, pages visited, search queries, click data, date and time and other information regarding your use of Twin Marquis sites.
• User-Generated Information – includes information and content that you create and then share with Twin Marquis on third party social networks or by uploading it to one of our sites or apps, including through the use of third-party social media apps such as Facebook. Examples include photos, videos, personal stories, or other similar media or content.
• Technical Information – includes your internet protocol (IP) address, other information about your computer or wireless device, browser type and version, geolocation data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the sites.
• Marketing and Communications Information – includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2. Information You Provide To Us Directly

The ways we collect information form you directly include, but are not limited to:

• Information that you provide by filling in forms on our sites. This includes, but is not limited to, information provided: (a) when submitting a request on a site; (b) at the time of when you enter any Twin Marquis sponsored sweepstakes, contests or other promotions (“Promotions”); and (c) when you report a problem with a site.
• You also may provide information to us offline, such as during a Promotion, other Twin Marquis sponsored event, or at point-of-sale.
• Records and copies of your correspondence and/or claims (including email addresses and telephone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on our sites.

You also may provide User-Generated Information to be published or displayed (hereinafter, “posted”) on public areas of the site, transmitted to other third-party websites, or posted on third party websites. Your User-Generated Information is posted on and transmitted to others at your own risk. We cannot control the actions of other users of our sites or of third-party websites with whom you may choose to share your User-Generated Information. Therefore, we cannot and do not guarantee that your User-Generated Information will not be viewed by unauthorized persons.

3. Information Received Through Third-Party Platforms

You may access our sites through third-party platforms, such as Facebook or other social media platform. If you use our sites on or through a third-party platform, including via any mobile and/or other Internet connected devices (“Wireless Devices”), or click on third-party links, the collection, use, and disclosure of your information and your use of the sites will also be subject to the privacy policies and other terms of such third parties or third-party platforms. You should review such privacy policies, terms and other agreements.

4. Information We Collect From Third Parties

From time to time, we may receive commercially available demographic information, customer preferences data, and/or third-party business contact information collected from other sources. Business contact information may include names, phone numbers, and email addresses.

We may combine information collected offline, information collected through our sites or from other Twin Marquis affiliates, and/or from third-party providers if that third-party has the right to provide the information.

5. Collection Of Technical Information And Usage Information

When you access Twin Marquis sites, we automatically collect certain information. This information may include, without limitation, Technical Information and Usage Information (as such terms are defined in Section 1 of this Section III).

This Technical Information and Usage Information, which may be linked to your personal information, is collected through the use of server logs and tracking technologies, including: (i) cookies, which are small pieces of code that websites send to your computer or wireless device to uniquely identify your browser or mobile device or to store information in your browser setting; and (ii) web beacons, which are small objects that allow us to measure the actions of visitors using the Twin Marquis sites. For more detailed information regarding how we use cookies and other technology, please review the additional information in our COOKIES NOTICE.

IV. HOW WE USE YOUR INFORMATION

We may use information about you for a number of purposes, including:

1. Providing, Improving, And Developing Our Offerings

• Reviewing and analyzing user browser and wireless device technical information;
• Reviewing user activity across site(s) (for example, Twin Marquis analyzes trends, user traffic and usage information to determine the performance of content, research reports, or events);
• Otherwise providing you with the Twin Marquis Offerings you choose to use;
• Providing, maintaining, and improving our Offerings;
• Developing new products and Offerings;
• Delivering the information and support you request;
• Improving, personalizing, and facilitating your use of our Offerings; and
• Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Offerings.

2. Communicating With You About Our Offerings

• Responding to questions or concerns;
• Sending you information we think you may find useful or which you have requested from us about our Offerings and the industry we serve;
• Sending push notifications to your desktop or wireless device to provide updates on relevant Offerings, which can be managed through your computer or smartphone browser; and
• Conducting surveys and collecting feedback about our Offerings.

3. Protecting Our Offerings And Maintaining A Trusted Environment

• Enforcing our Terms of Use or other applicable agreements or policies;
• Verifying your identity;
• Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process;
• Fulfilling any other purpose disclosed to you in connection with our Offerings;
• Analyzing trends and user traffic, tracking purchases and usage information; and
• Contacting you to resolve disputes and provide assistance with our Offerings.

4. Advertising And Marketing

• Marketing our Offerings; and
• Communicating with you about opportunities, products, promotions, discounts, incentives and rewards offered by us and select partners.

If we send you marketing emails, each email will contain instructions permitting you to unsubscribe from receiving future marketing or other communications.

If we obtain any personal information from you, we will not sell it to third parties, nor will we allow third parties with whom we disclose your personal information to sell it.

5. Other Uses

• Auditing, detecting security incidents, debugging, internal research, quality control; and,
• For any other purpose disclosed to you in connection with our Offerings from time to time.

V. DISCLOSURE OF YOUR PERSONAL INFORMATION

We do not sell your personal information to third parties, and we also do not allow the third parties with whom we disclose your personal information to sell it. For the avoidance of doubt, Twin Marquis does not sell the personal information of minors under 16 years of age.

We may disclose the personal information we collect or you provide as described in this Notice:

• To fulfill or meet the reason you provided the information;
• To our subsidiaries and affiliates;
• For testing, research, analysis, and product development, including to develop and improve our Offerings, including the sites;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of Twin Marquis or its subsidiaries, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Twin Marquis about site users is among the assets transferred. We will require any such purchaser, assignee, or other successor business entity to honor the terms of this Notice to the extent possible;
• To respond to law enforcement requests, to bring a legal action, and as required by applicable law, judicial proceedings, court order, or governmental regulations;
• With your consent;
• In an aggregated, anonymized or de-identified information for any purpose. Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual. Although such information may be derived from your personal information, it can no longer directly or indirectly reveal your identity; and
• To third parties for a business purpose, including to Service Providers. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In order to synthesize some of the information provided above, below is a table listing the general categories of consumer personal information that Twin Marquis currently collects, the sources from which that information may be collected, the categories of third parties to which Twin Marquis may disclose such personal information, and the business purpose for which the information may be disclosed to third parties. This table is intended to be read in conjunction with the information provided above.

Within the past 12 months, we may have disclosed your Personal Information in a merger or business asset transaction.

We will not use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

VI. THIRD-PARTY ADVERTISING AND ANALYTICS

We may use third-party service providers to provide site metrics and other analytics services. These third parties may use cookies, web beacons, and/or other technologies to collect information about you when you use our sites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. Such information may include your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our sites, webpages viewed, time spent on webpages, links clicked and conversion information (e.g., transactions entered into). This information may be used by Twin Marquis and third-party service providers on behalf of Twin Marquis to analyze and track usage of our sites, to determine the popularity of certain content and to better understand how you use our sites. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Notice does not apply to, and we are not responsible for, third-party cookies, web beacons or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices.

VII. LINKING SITES

The sites contain links to other websites. Twin Marquis is not responsible for the privacy practices or the content of such websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). We do not share information we gather with other websites or any other entities or individuals unless such sharing is disclosed to you in advance through this Notice. Other linked websites, however, may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the websites you may visit by linking from the sites. Please note that this Notice applies only to our sites, and not to other companies’ or organizations’ websites to which we link.

VIII. SOCIAL MEDIA

We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by such third-party websites or to whom it is disclosed. You should review the privacy policies and settings on any social media website that you subscribe to so that you understand the information they collect and may be sharing. If you do not want your social media websites to share information about you, you must contact that website and determine whether it gives you the opportunity to opt-out of sharing such information. Twin Marquis is not responsible for how these third-party websites may use information collected from or about you.

Further, our sites may include social media features, such as the Facebook Like button. Our integration of these features may allow third-party social media to collect certain information, such as your IP address and which page(s) you are visiting when using our sites, and to set a cookie to enable that feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing it.

IX. HOW LONG WE RETAIN YOUR INFORMATION

We generally retain your information as long as reasonably necessary to comply with applicable law and in accordance with our document retention policy. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. We may retain copies of information about you and any transactions or Offerings you have used for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Offerings, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. This allows the specific information collected (name, email, address, phone number, etc.) to become anonymous, but allows Twin Marquis to keep the transaction or engagement data. For example, Twin Marquis will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history. This will allow Twin Marquis to maintain a level of information that helps us develop and improve our Offerings, including the sites.

X. MARKETING AND PROMOTIONAL COMMUNICATIONS

You may unsubscribe from receiving marketing and promotional messages from Twin Marquis, if those messages are powered by Twin Marquis, by following the instructions in those messages. If you decide to unsubscribe, you will still receive non-promotional communications relevant to your use of our Offerings.

XI. CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION

Our site is not intended for children under 16 years of age. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 16. If you are under the age of 16, please do not supply any personal information through the sites. If you are under the age of 16 and have already provided personal information through the sites, please have your parent or legal guardian contact us immediately using the information provided under CONTACT INFORMATION so that we can remove such information from our files. If you believe we might have any information from or about a child under 16, please contact us at CONTACT INFORMATION.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see CALIFORNIA CONSUMERS for more information.

XII. SECURITY

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you both at our own premises and with the assistance of third-party service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under CONTACT INFORMATION. To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect your personal information in all aspects of their work.

XIII. CALIFORNIA CONSUMERS

The California Consumer Privacy Act of 2018 (“CCPA”), and as amended by the California Privacy Rights Act of 2020 (“CPRA”), permits residents of California to have additional rights provided in the following sections. For more information, or if you have questions, you can contact us using the information provided under CONTACT INFORMATION. For your protection, Twin Marquis is required to collect certain information from you to verify your identity before we respond to any request submitted by you. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by Twin Marquis for its files.

1. California Residents Have The Right To Request Twin Marquis to Disclose What Information It Collects, Uses And Discloses

California residents, upon identity verification, have the right to request that Twin Marquis disclose what personal information Twin Marquis collects, uses and discloses about them over the past 12 months. The general categories of personal information Twin Marquis collects about California residents are listed above under WHAT INFORMATION WE COLLECT. If you are a California resident and would like to request the personal information that Twin Marquis collects, uses and discloses about you, please complete this Request Form or use the information provided under CONTACT INFORMATION and contact Twin Marquis at the toll-free number listed below.

2. California Residents Have The Right To Request Twin Marquis To Correct Their Inaccurate Personal Information Maintained by Twin Marquis

California residents, upon identity verification, have the right to request a business that maintains inaccurate personal information about the consumer to correct that inaccurate personal information. If you are a California resident and would like to request the correction of your personal information, please submit this Request Form or use the information provided under CONTACT INFORMATION and contact Twin Marquis at the toll-free number listed below.

To verify any request to correct personal information, you will be required to provide information to verify your identity. Failure to do so could result in Twin Marquis’ inability to comply with your request.

3. California Residents Have The Right To Request Deletion Of Their Personal Information Maintained By Twin Marquis

California residents, upon identity verification, have the right to be forgotten and request that Twin Marquis delete the personal information Twin Marquis maintains about them. Twin Marquis will make every effort to comply with California residents’ requests to delete their personal information; including notifying any third party(ies) whom Twin Marquis has shared the personal information to delete the information; however, certain laws or other legal requirements might prevent some personal information from being deleted. If you are a California resident and would like to request the deletion of your personal information, please submit this Request Form or use the information provided under CONTACT INFORMATION and contact Twin Marquis at the toll-free number listed below.

To verify any request to delete personal information, you will be required to provide information to verify your identity. Failure to do so could result in Twin Marquis’ inability to comply with your request.

4. California Residents Have The Right to Opt Out of Sale or Sharing of Personal Information, and The Right to Limit The Use and Disclosure of Sensitive Personal Information

Twin Marquis has not, in the last 12 months, sold your information, nor does Twin Marquis have plans to sell your information in the future. However, California residents have the right to direct Twin Marquis to not share their personal information to third parties for cross-context behavioral advertising purposes. Further, California residents have the right to direct Twin Marquis to limit the use of their Sensitive Personal Information to that use which is necessary to perform or provide the Offering to the California resident. Twin Marquis will only use Sensitive Personal Information as necessary as described in this Notice.

5. California Residents Have The Right To Non-Discrimination For The Exercise Of Their Privacy Rights Under The CCPA

Under the CCPA, California residents have the right not to receive discriminatory treatment by Twin Marquis for the exercise of their privacy rights. However, the exercise of certain privacy rights by California residents will make it so that Twin Marquis is no longer able to provide those residents with certain aspects of the Offerings. For example, if, at the request of a California resident, Twin Marquis erases all of the California resident’s personal information that it maintains, Twin Marquis will no longer be able to send marketing communications to that California resident.

6. California Residents Can Designate An Authorized Agent To Make A Request Under The CCPA On Their Behalf

California residents can designate an authorized agent to make requests under the CCPA related to the residents’ personal information. Twin Marquis can deny any request made by an agent who does not submit proof that he or she has been authorized by the California resident to act on the California resident’s behalf. For more information on submitting a request on behalf of a California resident as an authorized agent, you can contact us using the information provided under CONTACT INFORMATION.

7. Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. Twin Marquis does not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available third-party tools, we offer you the choices described in this Notice to manage the collection and use of information about you.

Twin Marquis does track some activity across websites (including your search terms, the website you visited before you visited or used the sites and other clickstream data) and we may continue to collect information in the manner described in this Notice from web browsers that have enabled DNT signals or similar mechanisms.

XIV. CHANGES TO THIS NOTICE

This Notice may be revised from time to time as we add new features and Offerings, as laws change and as industry privacy and security best practices evolve. We display an effective date on this Notice at the bottom of this Notice so that it will be easier for you to know when there has been a change. If we make any material change to this Notice regarding use or disclosure of personal information, we will provide notice on our sites. Changes will apply to information collected after the change is effective. Please check this Notice periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of any site constitutes acceptance of the provisions of this Notice and your continued usage after such changes are posted constitutes acceptance of each revised Notice. If you do not agree to the terms of this Notice or any revised Notice, please exit the site immediately. If you have any questions about this Notice, the practices of the sites, or your dealings with the sites, you can contact us by using the information provided under CONTACT INFORMATION.

XV. CONTACT INFORMATION

Please contact Twin Marquis with any questions or concerns regarding this Notice

TOLL-FREE NUMBER: 1-855-550-0007

CONTACT US FORM

If you have any questions or concerns regarding our Notice, or if you believe our Notice or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with Twin Marquis using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution. 

Last Revised: December 13, 2021