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PRIVACY POLICY

Last updated: October 27, 2025

1. INTRODUCTION

This Privacy Policy describes how Twisty ("we", "our", or "us") collects, uses, and shares your personal information when you visit or make a purchase from our website (the "Service").

We are committed to protecting your privacy and ensuring that your personal data is handled in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. INFORMATION WE COLLECT

Automatically Collected Information

When you visit the Service, we automatically collect minimal, anonymized analytics data through Umami (a privacy-focused analytics tool):

  • Page views and basic usage statistics (anonymized)
  • General geographic location (country level only)
  • Referrer information (which website you came from)
  • Browser type and device information (anonymized)

Important: This data cannot be used to identify you personally and no cookies are stored on your device for tracking purposes.

Order Information

When you make a purchase, we collect:

  • Name
  • Billing and shipping address
  • Payment information (processed securely by our payment providers)
  • Email address
  • Phone number

Account Information

When you create an account, we collect:

  • Username
  • Email address
  • Password (encrypted)
  • Profile information you choose to provide

3. HOW WE USE YOUR INFORMATION

We use the information we collect to:

  • Process and fulfill your orders
  • Communicate with you about your orders or account
  • Provide customer support
  • Improve and optimize our Service
  • Screen our orders for potential risk or fraud
  • Send you marketing communications (with your consent)
  • Comply with legal obligations

4. LEGAL BASIS FOR PROCESSING (GDPR)

Under GDPR, we process your personal data based on:

  • Contract: To fulfill our obligations under any contract we have with you
  • Legitimate interests: To operate our business, prevent fraud, and improve our services
  • Consent: For marketing communications and non-essential cookies
  • Legal obligation: To comply with applicable laws and regulations

5. SHARING YOUR INFORMATION

We may share your personal information with third parties to help us operate our business:

  • Payment processors: To process your payments securely
  • Shipping companies: To deliver your orders
  • Email service providers: To send you emails
  • Legal authorities: When required by law or to protect our rights

Note: We use Umami for privacy-focused analytics, which collects only anonymized data that cannot be linked to individual users.

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. Specifically:

  • Order information: 7 years for accounting and tax purposes
  • Account information: Until you request deletion or after 3 years of inactivity
  • Marketing communications: Until you unsubscribe

7. YOUR RIGHTS UNDER GDPR

If you are a resident of the European Economic Area, you have the following rights:

  • Right to access: Request copies of your personal data
  • Right to rectification: Request correction of inaccurate personal data
  • Right to erasure: Request deletion of your personal data
  • Right to restrict processing: Request restriction of processing your personal data
  • Right to data portability: Request transfer of your data to another organization
  • Right to object: Object to processing based on legitimate interests
  • Right to withdraw consent: Withdraw consent where processing is based on consent

To exercise these rights, please contact us through our contact page. We will respond within one month.

8. ANALYTICS AND TRACKING

We use Umami, a privacy-focused analytics tool that does not use cookies or store personally identifiable information. Umami collects only basic, anonymized website usage statistics such as:

  • Page views and visitor counts (anonymized)
  • General traffic patterns and popular content
  • Browser types and screen resolutions (aggregated data)
  • Referrer websites (where visitors came from)

Privacy Note: No personal data, IP addresses, or tracking cookies are stored. The data collected cannot be used to identify individual users and is purely for understanding general website usage patterns.

We may use essential session cookies only for website functionality (such as maintaining your login session and shopping cart), but these are not used for tracking purposes.

9. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet is 100% secure.

10. INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers.

11. CHILDREN'S PRIVACY

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

13. CONTACT US

If you have any questions about this Privacy Policy or our data practices, please contact us through our contact page.

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

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