Last Updated: June 21, 2021
Traveling Twilley is committed to protecting your privacy when you visit travelingtwilley.com. You can access and browse travelingtwilley.com without disclosing any of your personal data. Travelingtwilley.com does not collect personal information about individuals, such as names and mailing or e-mail addresses, unless it is knowingly provided by the individual and he or she has agreed to the terms under which travelingtwilley.com will use it.
Collecting and Using Your Personal Data
Types of Data Collected
When you access this Blog, Traveling Twilley will learn certain information about you during your visit. While using this Blog, Traveling Twilley may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your e-mail address and your name.
Traveling Twilley will collect personal data from you in a number of ways, including:
(1) Opt-ins to E-mail Newsletters
If you opt to subscribe to Traveling Twilley’s e-mail newsletters, you will be asked to provide your name and e-mail address.
If you decide to post a comment on this Blog, your name, e-mail address, and comment will be collected by this Blog. Please note that by posting a comment on this Blog, you consent to the posting of any personal information that you provide. You should be aware that such personal information can be read, collected, or used by other visitors to these public areas. Traveling Twilley has no control over how other visitors use your personal information.
Usage data is collected automatically when using this Blog. Usage data may include information such as the Internet Protocol (IP) address for your device used to access this Blog, browser type, browser version, the pages of this Blog that you visit, the time spent on those pages, the time and date of your visit, unique device identifiers, and other diagnostic data.
When you access this Blog by or through a mobile device, Traveling Twilley may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, and other diagnostic data. Traveling Twilley may also collect information that your browser sends whenever you visit this Blog or when you access this Blog by or through a mobile device.
Tracking Technologies and Cookies
- Flash Cookies: Certain features of this Blog may use local stored objects (or flash cookies) to collect and store information about your preferences or your activity on this Blog. Flash cookies are not managed by the same browser settings as those used for browser cookies. For more information on how you can delete flash cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
- Web Beacons: Certain sections of this Blog and Traveling Twilley’s e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Traveling Twilley, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. Traveling Twilley may use both session and persistent cookies for the purposes set out below:
- Necessary / Essential Cookies
Type: Session Cookies
Purpose: These cookies are essential to provide you with services available through this Blog and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and Traveling Twilley only uses these cookies to provide you with those services.
- Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
- Tracking and Performance Cookies
Type: Persistent Cookies
Purpose: These cookies are used to track information about traffic to this Blog and how users use this Blog. The information gathered via these cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access this Blog. Traveling Twilley may also use these cookies to test new pages, features, or functionality of this Blog to see how users react to them.
- Targeting and Advertising Cookies
Type: Persistent Cookies
Purpose: These cookies track your browsing habits to enable Traveling Twilley to show advertising that is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, third party advertisers can place cookies to enable them to show adverts thought to be relevant to your interests while you are on third party websites.
How Traveling Twilley Uses Your Data
Traveling Twilley may use the above-described information collected from you in the following ways:
- to operate and maintain this Blog;
- to improve your experience on this Blog;
- to respond to your comments;
- to provide you with user support;
- to send you technical notices, updates, security alerts, and support and administrative messages;
- to communicate with you about products, services, surveys, offers, promotions, rewards, and events offered by Traveling Twilley and others, and to provide news and information Traveling Twilley thinks will be of interest to you;
- to monitor and analyze trends, usage, and activities in connection with this Blog; and
- to personalize and improve this Blog and provide advertisements, content, or features that match user profiles or interests.
Traveling Twilley will not sell your personal information to others.
Retention of Your Personal Data
Traveling Twilley will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of this Blog, or when Traveling Twilley is legally obligated to retain this data for longer time periods.
Disclosure of Your Personal Data
With Your Consent
Traveling Twilley may disclose your personal data for any purpose with your consent.
Under certain circumstances, Traveling Twilley may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other Legal Requirements
Traveling Twilley may disclose your personal data in the good faith belief that such action is necessary to:
- comply with a legal obligation;
- protect and defend the rights or property of Traveling Twilley;
- prevent or investigate possible wrongdoing in connection with this Blog;
- protect the personal safety of users of this Blog or the public; or
- protect against legal liability.
Security of Your Personal Data
The security of your personal data is important to Traveling Twilley, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While Traveling Twilley strives to use commercially acceptable means to protect your personal data, Traveling Twilley cannot guarantee its absolute security.
E-mail is not recognized as a secure medium of communication. For this reason, Traveling Twilley requests that you do not send private information to Traveling Twilley by e-mail. If you choose to send private information to Traveling Twilley via e-mail, you do so at your own risk.
Detailed Information on the Processing of Your Personal Data
Traveling Twilley may share your personal data with Service Providers to monitor and analyze the use of this Blog, to show advertisements to you to help support and maintain this Blog, and to contact you.
“Service Provider” means any natural or legal person who processes the data on behalf of Traveling Twilley, and the term refers to third-party companies or individuals employed by Traveling Twilley to facilitate this Blog, to provide this Blog on behalf of Traveling Twilley, to perform services related to this Blog, or to assist Traveling Twilley in analyzing how this Blog is used. Service Providers have access to your personal data only to perform their tasks on Traveling Twilley’s behalf and are obligated not to disclose or use it for any other purpose.
Traveling Twilley may use third-party Service Providers to monitor and analyze the use of this Blog.
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of this Blog. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
Traveling Twilley may use Service Providers to show advertisements to you to help support and maintain this Blog.
If you opt to subscribe to Traveling Twilley’s e-mail newsletters, Traveling Twilley may use your personal data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from Traveling Twilley by following the unsubscribe link or instructions provided in any e-mail Traveling Twilley sends or by contacting Traveling Twilley.
Commitment to Children’s Privacy
Protecting the privacy of the very young is important to Traveling Twilley. For that reason, this Blog does not collect or maintain information from those Traveling Twilley actually knows are under 18, and no part of this Blog is structured to attract anyone under 18. If you are under 18, do not use this Blog, do not provide any information on this Blog or through any of its features, do not make any purchases through this Blog, and do not use any of the interactive or public comment features of this Blog or provide any information about yourself to Traveling Twilley, including your name, address, telephone number, e-mail address, or any screen name or user name you may use.
If Traveling Twilley learns that Traveling Twilley has collected or received personal information from a child under 18 without verification of parental consent, Traveling Twilley will delete that information. If you believe Traveling Twilley might have any information from or about a child under 18, please contact Traveling Twilley at email@example.com.
Links to External Websites
Traveling Twilley has no control over and assumes no responsibility for the content, privacy policies, or practices of any third party sites or services.
Your Rights Under the GDPR
If you are within the European Union, you are entitled to certain information and have certain rights under the GDPR (General Data Protection Regulation). Those rights include the following:
- Request access to your personal data: You have the right to request access to the personal data Traveling Twilley holds about you.
- Request correction of the personal data that Traveling Twilley holds about you: You have the right to request the correction of any incomplete or inaccurate information Traveling Twilley holds about you.
- Object to processing of your personal data: You have the right to object to, and seek restrictions on, the processing of your personal data by Traveling Twilley. You also have the right to object where Traveling Twilley is processing your personal data for direct marketing purposes.
- Request erasure of your personal data: You have the right to ask Traveling Twilley to delete or remove the personal data Traveling Twilley holds about you.
- Request the transfer of your personal data: You have the right to request the transfer of your personal data to you or to a third party you have chosen.
- Withdraw your consent: You have the right to withdraw your consent to Traveling Twilley’s processing of your personal data. Note, however, that if you withdraw your consent, Traveling Twilley may not be able to provide you with access to certain specific functionalities of this Blog.
Exercising Your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation, and opposition by contacting Traveling Twilley at firstname.lastname@example.org and submitting a request. Please note that Traveling Twilley may ask you to verify your identity before responding to such requests. If you make a request, Traveling Twilley will try to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about Traveling Twilley’s collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
Categories of Personal Information Collected
Traveling Twilley collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which Traveling Twilley may collect or may have collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Traveling Twilley, but rather reflects Traveling Twilley’s good faith belief to the best of Traveling Twilley’s knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to Traveling Twilley.
- Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account name, or other similar identifiers.
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, address, telephone number, credit card number, debit card number, or other financial information.
- Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
- Category F: Internet or other similar network activity.
Examples: Interaction with this Blog or advertisements.
- Category G: Geolocation data.
Examples: Approximate physical location.
Under CCPA, personal information does not include the following:
- publicly available information from government records;
- deidentified or aggregated consumer information; and
- information excluded from the CCPA’s scope.
Sources of Personal Information
Traveling Twilley may obtain personal information from the categories listed above from the following sources:
- Directly from you (for example, from the forms you complete on this Blog and preferences you express or provide through this Blog);
- Indirectly from you (for example, from observing your activity on this Blog);
- Automatically from you (for example, through cookies Traveling Twilley or Traveling Twilley’s Service Providers set on your device as you navigate through this Blog);
- From Service Providers (for example, third-party vendors to monitor and analyze the use of this Blog, third-party vendors to provide advertising on this Blog, or other third-party vendors that Traveling Twilley uses to provide this Blog to you).
Use of Personal Information for Business Purposes or Commercial Purposes
Traveling Twilley may use or disclose personal information Traveling Twilley collects for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
- to operate this Blog and provide this Blog to you;
- to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve this Blog.
- to fulfill or meet the reason you provided the information (for example, if you share your contact information to ask a question about this Blog, Traveling Twilley will use that personal information to respond to your inquiry);
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- as described to you when collecting your personal information or as otherwise set forth in the CCPA;
- for internal administrative and auditing purposes;
- to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
Traveling Twilley may use or disclose, and may have used or disclosed in the last twelve (12) months, the following categories of personal information for business or commercial purposes:
- Category A: Identifiers;
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
- Category F: Internet or other similar network activity.
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects Traveling Twilley’s good faith belief to the best of Traveling Twilley’s knowledge that some of that information from the applicable category may be and may have been disclosed.
When Traveling Twilley discloses personal information for a business purpose or a commercial purpose, Traveling Twilley enters 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.
Sale of Personal Information
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. You have the right to opt-out of the sale of your personal information.
Sharing of Personal Information
Traveling Twilley may share your personal information identified in the above categories with the following categories of third parties:
- Service Providers;
- third party vendors to whom you or your agents authorize Traveling Twilley to disclose your personal information in connection with products or services Traveling Twilley provides to you.
Personal Information of Minors Under 16 Years of Age
If you have reason to believe that a child under the age of 16 has provided Traveling Twilley with personal information, please contact Traveling Twilley at email@example.com with sufficient detail to enable Traveling Twilley to delete that information.
Your Rights Under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to request. Under CCPA, you have the right to request that Traveling Twilley disclose information to you about Traveling Twilley’s collection, use, sale, disclosure for business purposes, and sharing of personal information. Once Traveling Twilley receives and confirms your request, Traveling Twilley will disclose to you:
- the categories of personal information Traveling Twilley collected about you;
- the categories of sources for the personal information Traveling Twilley collected about you;
- Traveling Twilley’s business or commercial purpose for collecting that personal information;
- the categories of third parties with whom Traveling Twilley shared that personal information;
- the specific pieces of personal information Traveling Twilley collected about you;
- if Traveling Twilley sold and/or disclosed your personal information for a business purpose, Traveling Twilley will disclose to you the categories of personal information categories sold and/or disclosed.
- The right to say no to the sale of Personal Data (opt-out). You have the right to direct Traveling Twilley to not sell your personal information. To submit an opt-out request please contact Traveling Twilley.
- The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once Traveling Twilley receives and confirms your request, Traveling Twilley will delete (and direct Traveling Twilley’s Service Providers to delete) your personal information from Traveling Twilley’s records, unless an exception applies. Traveling Twilley may deny your deletion request if retaining the information is necessary for Traveling Twilley or Traveling Twilley’s Service Providers to:
- complete the transaction for which Traveling Twilley collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of an ongoing business relationship with you, or otherwise perform a contract with you;
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- debug products to identify and repair errors that impair existing intended functionality;
- exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Traveling Twilley;
- comply with a legal obligation;
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
- denying goods or services to you;
- charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties;
- providing a different level or quality of goods or services to you;
- suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact Traveling Twilley by e-mail at firstname.lastname@example.org
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.
Your request to Traveling Twilley must:
- provide sufficient information that allows Traveling Twilley to reasonably verify you are the person about whom Traveling Twilley collected personal information or an authorized representative; and
- describe your request with sufficient detail that allows Traveling Twilley to properly understand, evaluate, and respond to it.
Traveling Twilley cannot respond to your request or provide you with the required information if Traveling Twilley cannot:
- verify your identity or authority to make the request; and
- confirm that the personal information relates to you.
Traveling Twilley will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures Traveling Twilley provides will only cover the 12-month period preceding the verifiable request’s receipt.
For data portability requests, Traveling Twilley will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Information
You have the right to opt out of the sale of your personal information. To exercise your right to opt-out, please contact Traveling Twilley.
Traveling Twilley does not sell your personal information. However, the Service Providers Traveling Twilley partners with (for example, Traveling Twilley’s analytics or advertising partners) may use technology on this Blog that sells personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by Traveling Twilley’s Service Providers by following the instructions presented on the following websites:
- The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA’s opt-out platform http://www.youronlinechoices.com/
- The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.