WHAT INFORMATION ABOUT ME IS COLLECTED?

In connection with your use of the Service, we may collect information about you, such as when you subscribe to our newsletter. Such information may include your name, e-mail address, and any information you choose to provide when you contact us. We may also collect demographic information, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Service.

WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We will collect information that you submit to us. In addition, we may obtain your information from you if you identify yourself to us by communicating with us including by sending us an e-mail with questions or comments.

Cookies and Action Tags.
We may collect information passively using “cookies” and “action tags.” “Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Service and other websites. Cookies can be used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service), to allow us to statistically monitor how you are using the Service to help us improve our offerings, and to determine the popularity of certain content.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to provide analytics-related services or to collect information in order to provide analytics-related services. In the course of providing analytics-related services, such third-party analytics service providers could place or recognize unique cookies on your browser.

You do not have to accept cookies to use the Service. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar. However, if you reject cookies, certain features or resources of the Service may not work properly or at all and you may experience some loss of convenience.

For the avoidance of doubt, the Service uses third-party service platforms (including to help analyze how users use the Service). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third party” cookies, you may be able to turn them off by going to the third party’s website.

Here is a link to the main third-party platform we use: https://www.google.com/policies/privacy/

“Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, or e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Service and measure the effectiveness of our marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete. Information collected from some cookies placed on the website is used to deliver advertisements to Twin Oak Site visitors when such visitors are visiting other websites, such as Facebook and LinkedIn.

Finally, you should be aware that third parties may use their own cookies or action tags when you click on their a link to their websites or services on or from the Service. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services.

Log Files.
We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.

DOES TWIN OAK COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. The Service is not designed for or directed to children under the age of 13. We do not collect information from any person we actually know is under the age of 13.

WHAT DOES TWIN OAK DO WITH THE INFORMATION IT COLLECTS?

We use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service and billing purposes, to facilitate the delivery of analytics-related services, and, unless you “opt out” (to the extent permitted by applicable law), so that we and third parties acting on our behalf can contact you about products and services that may be of interest to you.

We may use your information to send you a welcoming e-mail that may confirm your user name and password. Unless you “opt out” (to the extent permitted by applicable law), we and third parties acting on our behalf may subsequently send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: privacy@twinoak.com.

If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.

We may also use the information collected to send announcements and updates regarding the Service or, if applicable, about your billing account status. You will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service and are necessary for the performance of our contract with you.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to other information for internal purposes or to improve your experience with the Service.

WHEN DOES TWIN OAK DISCLOSE INFORMATION TO THIRD PARTIES?

We generally disclose information we gather from or about you to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you.

Laws and Legal Rights.
We may disclose your information if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Service or the general public.

Third Parties Generally.
We may provide information to third parties, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. In addition to the above, when users use our Service, third parties (including without limitation third-party analytics service providers) may directly collect information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect information may include analytics services providers, website tracking services, affiliates and other actual or potential commercial partners, and other similar parties. Please note in particular that the Service uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics.

For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at https://policies.google.com/technologies/partner-sites.

For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Professional Advisors.
We may provide your information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Outside Contractors.
We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to the Service, such as hosting and maintaining the Service, and developing applications for the Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your information.

Sale of Business.
We reserve the right to transfer information to a third party in connection with a sale, merger, general corporate reorganization, or other transfer of all or substantially all of the assets of Twin Oak or any of its Corporate Affiliates (as defined below), or that portion of Twin Oak or any of its Corporate Affiliates to which the Service relates, or in connection with a strategic investment by a third party in Twin Oak, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

Affiliates.
We may disclose information about you to our Corporate Affiliates. For purposes of this Privacy Policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Twin Oak, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

DOES THIS PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEBSITES OR SERVICES?

Our Service may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Service. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us or on our behalf, including through the Service.

IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?

We want your information to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.

Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

If you are a user accessing the Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Service are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location.

FOR HOW LONG WILL MY INFORMATION BE KEPT?

We will only retain your information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted or required by applicable law and regulation.

To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?

We generally use your information as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must “opt in” and give us permission to use your information for any other purpose. You may also change your preference and “opt out” of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting privacy@twinoak.com.

If you want to review, verify, correct, or request erasure of your information, object to the processing of your information, or request that we transfer a copy of your information to another party, please contact privacy@twinoak.com.

Such updates, corrections, changes, and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

Do Not Track.
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Service.

WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?

If you have any questions or comments about this Privacy Policy, please contact us at privacy@twinoak.com.