Revision effective and last updated on July 1, 2020.
Twitchell Holdco and its affiliates including Twitchell Technical Products, LLC, Infinity Woven Products, LLC, and Quantum Materials, LLC (collectively, “Twitchell”, “we”, “us”, or “our”) and respects your privacy.
This Privacy Notice describes the types of personal data we may collect from you or that you may provide when you visit the website www.twitchellcorp.com and any other websites, applications, interactive features, widgets and resources websites offered through traditional Internet websites, mobile devices or other platforms that owned or operated by Twitchell or our brands (collectively referred to as the “Services”) and our practices for collecting, using, and disclosing your personal data.
Please read this Privacy Notice carefully to understand our policies and practices regarding your personal data and how we will treat it. By accessing or using the Services, you agree to this Privacy Notice.
2. WHAT INFORMATION DO WE COLLECT?
We collect a variety of personal data from and about you through the Services, including:
Information You Provide Directly to Us. We collect personal data from you when you provide it to us, including through website forms (including information entered into our search field), as part of the account registration process, processing orders, when you apply for jobs, and when you contact us.
For example, if you create an account on the Services, we may collect your first and last name, telephone number, email address, and password.
If you order products or services from us through the Services, you must provide us with information to process that order and/or enter into a contract, including but not limited to name, postal address, email address, telephone number, billing and shipping information, payment information, company name, order history, and other similar information.
You can choose to sign up for communications about us through the Services by providing us with your contact information, such as first and last name, email address, and interests.
If you contact us with questions, requests, or complaints, or to exercise your legal rights, we collect any personal data you choose to provide, including your name, email address, and personal data necessary for us to answer your questions and address the issue you are contacting us about.
Information Collected Automatically. When you browse or use the Services, we may collect other personal data through commonly-used logging and analytics tools, including Google Analytics, that collect information about your browser, your device, the network used to access the Services, and information about your use of the Services (such as how you navigate and move around the Services).
We also use certain technologies on the Services, including cookies and pixel tags, that allow us, our service providers, and other third parties to store information locally on your device, identify your device, track your interactions with other sites or with our email campaigns, and track activity over time and across websites. We also partner with third-party advertising companies. Advertisers sometimes include their own web beacons, cookies or pixels (or those of their other advertising partners) within their advertisements enabling them to set and read their own cookies. These third parties may place cookies on your computer and collect data about your online activities across websites or online services.
Information collected automatically includes the software and hardware attributes of the device and browser you use to access the Services, unique device ID information, regional and language settings, performance data about the Services, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected automatically in the form of log files and third-party analytics that record website activity. For example, log file entries and analytics data are generated every time you visit a particular page on our website, and track the dates and times that you use the Services, the pages you visit, the amount of time spent on specific pages, and other similar usage information, and general data (including the name of the web page from which you entered our website).
- Location Information: We may collect the precise or general location information provided by your device. See the “Your Choices” section below for more information about how to disable or limit the collection of GPS data.
- Please see the “Your Choices” section of this Privacy Notice for more information about how you can opt out of, limit, or prevent certain web tracking technologies and/or advertising providers from collecting information about you.
Information Obtained from Third Party Sources. We receive personal data from third parties that we have engaged to provide services to us, including website chat providers, as well as from third parties that provide web analytics and usage information to us such as Google Analytics.
These third-party sources may include:
- Data brokers from which we purchase demographic data to supplement the data we collect.
- Services that host applications for our open job positions, such as LinkedIn. If you submit employment inquiries or apply for a job with us through these services, we may collect personal data such as your name, email address, telephone number, resume, and other information regarding your employment history, qualifications, and interests.
- Services that make user-generated content from their service available to others, such as public social media posts.
- Communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks.
- Service providers that help us determine your device’s location.
- Partners with which we offer co-branded services or engage in joint marketing activities.
- Publicly-available sources, such as open government databases.
In addition, if you choose to interact with us or our partners on social media by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience. We may also collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. This data is not subject to this notice unless it is stored or otherwise associated with your personal data.
3. HOW DO WE USE AND SHARE PERSONAL DATA?
As a general matter, we collect, use, disclose, and store your information to provide you the Services or fulfill your requests. We may use the information we collect from you for the following purposes:
- Your Consent. We process personal data to the extent you provide your consent, such as when we request to process personal information for a purpose that is not already identified by this Privacy Notice. You have choices when it comes to the technology you use and the data you share. When you are asked to provide personal data or consent to processing, you can decline. Many of our products require some personal data to operate and provide you with a service. If you choose not to provide data necessary to operate and provide you with a product or feature, you cannot use that product or feature.
- Performance of a Contract. We process personal data to enter into, or perform under, the agreement between us, such as processing payments, shipping orders, and responding to support or warranty requests. If you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use the data will not work for you.
- Legitimate Interests. We process personal data for our legitimate interests, consistent with your rights and appropriate to the context, for:
- Processing and fulfilling your orders for our products or services, including processing payments;
- Providing you with information tailored to your requests, responding to inquiries, and communicating with you about your account, purchases, orders, and use of the Services, including responding to your comments, questions, and concerns and otherwise administering customer service;
- Delivering and providing the Services and other products to our customers;
- Storing information about your preferences and customizing your experience on the Services;
- Operating, maintaining, modifying, and improving the quality of the Services and such content, products and/or services as we may make available through the Services, including understanding our audience size and usage patterns and identifying and repairing issues impairing intended functionality;
- Performing analytics;
- Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies and for other administrative and fraud detection purposes;
- Endeavoring to protect and secure the Services, including against fraud and other misuse, and our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties;
- To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research for technology development;
- For marketing and advertising purposes, including sending messages about us, our partners, and the products and services we and our partners offer, which may from time to time include contests, rewards, events, and special offers for products and services, and personalizing those messages;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; and
- For other purposes, as permitted or required by law or as authorized or directed by you.
4. Compliance with Legal Obligations and Protection of Individuals. We may process personal data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.
Sharing of Personal Data. We may share personal data with third parties, including service providers, affiliates, and other partners as described below.
- We may share personal data among our affiliated entities and with our subsidiaries;
- We may share personal data with our service providers, including payment processors, software and Web developers, order processing and fulfillment services, commercial email providers, security consultants, and other vendors we engage;
- We may share personal data we collect with certain partners, prospective partners, and service providers;
- We may share personal data to communicate with you and others, including for marketing purposes;
- We may share personal data to protect and secure the Services, including against fraud and other misuse, and our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties;
- We may share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law, a court order, legal process, or other governmental or regulatory requests.
- We may share personal with a buyer or other successor or organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings; and
- We may share personal data for such purposes as you may authorize or direct us.
4. PROTECTING PERSONAL DATA
We recognize the importance of safeguarding the confidentiality of your personal data. Accordingly, we employ reasonable measures designed to protect your information from unauthorized access, disclosure and use. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Services, we cannot and do not guarantee the security of any information you transmit on or through the Services, and you do so at your own risk.
5. RETENTION OF PERSONAL DATA
We retain personal data for as long as necessary to carry out the processing activities described above, including but not limited to providing the Services or content, products, or other services we make available through the Services, compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and protecting our and our business partners’ and customers’ rights, property, or safety, and the rights, property, and safety of our users and other third parties.
6. YOUR CHOICES
You have choices about certain information we collect, how we communicate with you, and how we process certain personal data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Services, you may not be able to use those Services.
Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Notice, or by informing our customer service representatives of your desire to opt out. If you wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email.
Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g. e-commerce).
Location Information. If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.
Do Not Track. We use analytics systems and providers and participate in ad networks that process personal data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us.
7. OTHER INFORMATION ABOUT PERSONAL DATA AND THE SERVICES
Our Privacy Notice also includes information about other practices with respect to personal data, including:
- Collection of personal data from children;
- Location of personal data processing; and
- Links and references to third-party websites and services on our Services.
Collection of Personal Data from Children. We do not knowingly collect personal data from children under the age of 13. If we become aware that we have inadvertently received personal data from a child under the age of 13, we will delete such information from our records. If you are the parent or guardian of a child under the age of 13 and you believe we have inadvertently received information about that child, please contact us as described in the “Contact Information and Assistance” section below. In addition, we recommend encourage parents to take an active role in their children’s online activities and to talk with their children about disclosing personally identifiable information to web sites.
Processing in the United States. Please be aware that your personal data and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using our Services, you agree that the collection, use, transfer, and disclosure of your personal data and communications will be governed by the applicable laws in the United States.
Third-Party Websites and Services. As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk This Privacy Notice does not apply to any third-party services; please refer to the Privacy Notices or policies for such third-party services for information about how they collect, use, and process personal data.
8. MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE
9. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION
If you are located in the European Union, you may have rights with respect to your personal data. These rights may include, depending on the circumstances surrounding the processing of personal data:
- The right to object to or request restriction of processing of personal data or object to processing of personal data carried out pursuant to (i) a legitimate interest or (ii) performance of a task in the public interest;
- The right to access your personal data and other information about our processing of your personal data;
- The right to correct inaccurate personal data about you that we process;
- The right to data portability, which means that you can request that we provide certain personal data we hold about you in a format you can more readily use;
- The right to erasure, which means that you can request deletion or removal of certain personal data we process about you;
- Where processing of personal data about you is based on consent, the right to withdraw your consent to such processing; and
- The right to lodge a complaint with a supervisory authority.
You may exercise these rights, to the extent they apply, by contacting us as provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you. Please be prepared to provide reasonable information to identify yourself and authenticate your requests.
10. ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA
This section of the Privacy Notice applies solely to consumers who reside in the State of California (“consumers” or “you”), and generally to the personal data of a particular consumer or household (“California Personal Data”). Provided, however, that California Personal Data does not include, and this section of the Privacy Notice does not apply to:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Publicly available information from government records;
- Deidentified or aggregated consumer information;
- Personal data, emergency contact information, and benefits administration information we collect about a California resident in the course of that California resident acting as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor to the extent we use that information within the context of that California resident’s role as our job applicant, employee, owner, director, officer, medical staff member, or contractor; and
- Other information, including:
- personal data that we collect, process, sell, or disclose pursuant to the federal Gramm-Leach-Bliley Act, and implementing regulations, or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code); and
- personal data covered by other sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”) and the Driver’s Privacy Protection Act of 1994.
- California Personal Data We Collect. We have collected the following categories of California Personal Data regarding consumers within the last 12 months:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
- Identifiers such as your real name, alias, postal address, zip code, telephone number, email address, account name, Social Security number, driver’s license number, payment card numbers, passport number, or other similar identifiers
- Unique and online identifiers such as device identifiers, internet protocol addresses, cookie identifiers, beacon identifiers, pixel tags or mobile ad identifiers or similar technology, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device
- Commercial information that identifies or could reasonably be linked to you, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- Internet or other electronic network activity information identifies or could reasonably be linked to you, such as browsing history, search history and information regarding an individual’s interaction with an internet website, application, or advertisement
- Professional or employment-related information, such as current or past job history or performance evaluations
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) related to a student and maintained by an educational institution or party acting on its behalf, such as grades, transcripts, and class lists
- Biometric information, such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns
- Geolocation information, such as your specific, real-time physical location or precise movements while you access our sites or apps if you have enabled location services on your device
- Sensory data, such as audio, electronic, visual, thermal, olfactory, or similar information
- Protected classification characteristics under California or federal law, which includes age if 40 years or older, race, color, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information)
- Inferences drawn from personal information, such as person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.Sources of California Personal Data. We may obtain the categories of California Personal Data that we collect as indicated above from the following categories of sources.
- Directly from you. For example, through website forms you complete or ordering our products and services.
- Automatically and indirectly from you, such as through logging and analytics tools, cookies, pixel tags, and other automatic data collection.
- From third parties, such as our service providers, consumer data resellers, services that make user-generated content available to others, communications services, social networks and social media online services, affiliates, and other business partners.
Use of California Personal Data. We may use the categories of California Personal Data that we collect, as described above, for one or more of the business purposes and commercial purposes described in the “How Do We Process Personal Data?” section above.
Sharing California Personal Data. We may disclose the categories of California Personal Data that we collect as indicated above to the categories of third parties described in the “How Do We Process Personal Data?” section above. In the preceding 12 months, we may have disclosed categories of California Personal Data that we collected, as described above, for a business purpose.
In the preceding 12 months, we have not sold California Personal Data. We do not and will not sell your California Personal Data.
California Personal Data Rights and Choices. The California Consumer Privacy Act of 2018 (“CCPA”) provides consumers with specific rights regarding their California Personal Data. This section describes the rights you may have and explains how to exercise those rights.
- Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your California Personal Data over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will disclose one or all of the following depending on the scope of the request:
- The categories of California Personal Data we collected about you over the past 12 months.
- The categories of sources for the California Personal Data we collected about you over the past 12 months.
- Our business or commercial purpose for collecting California Personal Data about you over the past 12 months.
- The categories of third parties with whom we shared California Personal Data over the past 12 months.
- The specific pieces of California Personal Data we collected about you over the past 12 months.
- The categories of California Personal Data about you that we disclosed for a business purpose, to the extent we have made such disclosures.
Deletion Request Rights. Subject to certain exceptions, you have the right to request that we delete the California Personal Data that we collected about you. Once we receive and confirm your verifiable consumer request, we will delete your California Personal Data from our records, unless an exception applies.
Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Emailing us at: email@example.com
Only you, or an authorized agent registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your California Personal Data. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Data, or an authorized representative of that person. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal Data if we cannot verify your identity or authority to make the request and confirm the California Personal Data relates to you.
If you have an online account with us, we will deliver our written response to that online account. If you do not have an online account with us, we will deliver our written response by mail or electronically.
Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to personal information associated with that specific account.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized representative. For data portability requests, we will select a format to provide your California Personal Data that is readily usable.
If your request is manifestly unfounded, repetitive, or excessive, including if you have made several repetitive requests, we may charge a reasonable fee to respond. We also may decline to respond, in which case we will notify you.
Non-Discrimination. You have a right to not receive discriminatory treatment for exercising your access, data portability, and deletion rights described above. Except to the extent permitted by the CCPA, we will not discriminate against you for exercising the access, data portability, and deletion rights described above.
11. APPLICABILITY OF THIS PRIVACY NOTICE
This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.
12. CONTACT INFORMATION AND ASSISTANCE
If you have any questions about this Privacy Notice, or if you have submitted or another person has submitted personally identifiable information about you through this web site, and you would like to have that information changed or deleted, please contact: