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  2. Twin Galaxies Privacy Policy

This page is a chapter in 'Policy Official Book of TG Terms of Service, Privacy, Cookies, and Forum Use Policies'

TWIN GALAXIES PRIVACY POLICY
Effective Date: January 1, 2022 Last Updated on: January 11, 2022

Your privacy is critically important to us. At Twin Galaxies we have a few fundamental principles:
  • We don't ask you for personal information unless we truly need it.
  • We don't share your personal information with anyone except to comply with the law, develop our service, or protect our rights.
  • We don't store personal information on our servers unless required for the on-going operation of our services.
  • We aim to make it as simple as possible for you to control what's visible to the public, seen by search engines, kept private, and permanently deleted.
Twin Galaxies International LLC ("Twin Galaxies") operates several websites including TwinGalaxies.com and TwinGalaxiesLive.com (together, the "Websites"). It is Twin Galaxies' policy to respect your privacy regarding any information we may collect while operating our Websites.

This privacy policy, together with our Forum Policies and Terms of Service (the "Terms") sets out how we collect, store and use personal information about you (the "user"). For the purposes of applicable data protection laws, Twin Galaxies is the "controller" of personal information collected through the Websites.

Please read the following carefully to understand our practices regarding your personal information.

If you have any questions relating to this privacy policy or our use of personal information, please contact us at contact@twingalaxies.com or use the Contact Us page on the Website.

Please note that we provide different or additional privacy notices in connection with certain activities, programs, and offerings. For more information about our privacy practices in another jurisdiction, please refer to the privacy policy posted on our Websites, for that jurisdiction.

For additional disclosures for consumers in California, please click California Privacy Policy to read our INFORMATION FOR CALIFORNIA CONSUMERS: YOUR CALIFORNIA PRIVACY RIGHTS Policy.

If you are in the European Union, please click EU Privacy Policy to read our EU PRIVACY POLICY.
PERSONAL INFORMATION WE MAY COLLECT FROM YOU
Gathering of Personally-Identifying Information
Certain visitors to Twin Galaxies' Websites choose to interact with Twin Galaxies in ways that require Twin Galaxies to gather personally-identifying information. The amount and type of information that Twin Galaxies gathers depends on the nature of the interaction. For example, we ask visitors who sign up for an account at TwinGalaxies.com to provide a username and email address and sometime phone number. Those who engage in transactions with Twin Galaxies - are asked to provide additional information, including as necessary the personal and financial information required to process those transactions. In each case, Twin Galaxies collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor's interaction with Twin Galaxies. Twin Galaxies does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.

When you register for an account on our Websites
If you sign up for an account on our Websites, we will collect personal information about you including your name, email address, username, password, user score (if applicable) and telephone number. You may provide this information to us directly, or by signing into your account/service with a third party, including without limitation, Facebook (see "Third Party Data Collection" below).

We will use the information that we collect about you to:
  • - create and maintain your account;
  • - allow you to log in to the Websites;
  • - allow you to create Content on the Websites;
  • -contact you about your account, the services that we offer and any changes to the Websites;
  • - carry out our high score verification and adjudication process (if applicable)
  • -maintain administrative records relating to our business.
When you contribute Content to the Website:
If you operate a blog, comment on a blog, post material to the Websites, post links on the Websites, upload a video game score performance or otherwise make (or allow any third party to make) material available on the Website (any such material, "Content"), we will collect your username, email address, password and any information that you provide via the Content. We will use this information to administer the Websites and to monitor the Content you may post.

When you purchase a product or service on the Website:
If you purchase any products (including certificates of scores) or services on the Websites, we will collect your name, email address, telephone number, delivery address and information about the products you have ordered.

We will use this information to:
  • - communicate with you about your purchase;
  • - dispatch the products or provide the services that you have purchased;
  • - arrange for delivery of your order (if applicable);
  • - detect and prevent fraud or other crime;
  • - resolve legal claims or disputes involving you or us; and
  • - update our internal records and accounts.
When you contact us:
If you contact us via the Contact Us page on our Websites or by using another function offered by our Websites (including the 'Report an Error' page and the Stream Chat service), we will collect your name, email address and any information about you that you choose to give us. We will use this information to review, investigate and respond to any comment or question that you may raise.

Aggregated Statistics
Twin Galaxies may collect statistics about the behavior of visitors to its websites. For instance, Twin Galaxies may monitor the most popular blogs or forum posts on the TwinGalaxies.com site or use spam screened by a spam control service to help identify spam. Twin Galaxies may display this information publicly or provide it to others. However, Twin Galaxies does not disclose personally-identifying information other than as described below.
PERSONAL INFORMATION WE MAY COLLECT FROM THIRD PARTIES
Third Party Platforms
When you use or access the Websites by or through a third party platform such as Facebook, you allow us to access and/or collect information from the Third Party Platform (for example, your Facebook account) or via any cookies placed on your device by a Third Party Platform, as permitted by the terms of the agreement and depending on your privacy setting on the third party platform. The information we collect from a third party platform may include your name, gender, age and email address.

Third Party Advertisers
Third party advertisers that advertise on the Websites may provide us with information about you including your device identifier. We will use this information to help deliver and/or help third party advisers to deliver tailored adverts to you.

Third Party Service Providers
We also work closely with third party service providers including, for example, business partners, advertising networks, payment services providers (including PayPal), analytics providers and search information providers ("Third Party Service Providers"). We may receive information about you from Third Party Service Providers.

We may share some of the information We collect from you with Third Party Service Providers (see "Disclosure of Your Information" below).
PERSONAL INFORMATION WE AUTOMATICALLY COLLECT
When you use the Websites, we may automatically collect information including your Internet Protocol (IP) address, browser type, language preference, referring site, the date and time of your visit, geographical location data, operating system and cookies.

Cookies
Cookies are small text files that are stored on your computer. Cookies allow us to analyze the way the Websites is being used by you. You may prevent your browser from saving Cookies by adjusting the corresponding settings in your browser software. However, please be advised that in such case, you may not be able to use all functions on the Websites and/or on third-party sites to their full extent.

We use this information to perform internal analytics and improve the Websites for our users.
Entering into and performing a contract with you
If you create an account, post Content or place an order through our Websites, our legal basis for processing your personal information is that it is necessary for the performance of our contract with you.

Our legitimate business interests
If you contact us or simply browse the Websites, our legal basis for processing personal information is that it is necessary for our legitimate interests in conducting our business, meeting the requirements of our current and prospective users, and for administering and monitoring the Websites.
MARKETING
If you register for an account on the Websites, we may use your personal information to contact you from time to time with information about the Websites, our services and any Twin Galaxies news that we think may be of interest to you. You can opt out of receiving further marketing messages at any time by clicking the "Unsubscribe" link in any email you receive from us.

Ads
Ads appearing on any of our websites may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by Twin Galaxies and does not cover the use of cookies by any advertisers.
DISCLOSURE OF YOUR INFORMATION
Protection of Certain Personally-Identifying Information

Twin Galaxies discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Twin Galaxies' behalf or to provide services available on the Websites, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using the Websites, you consent to the transfer of such information to them. Twin Galaxies will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Twin Galaxies discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Twin Galaxies believes in good faith that disclosure is reasonably necessary to protect the property or rights of Twin Galaxies, third parties or the public at large. If you are a registered user of the Websites and have supplied your email address, Twin Galaxies may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what's going on with Twin Galaxies and our products. We expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Twin Galaxies takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

We may share your personal information with selected third parties including:
  • - Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them and/or you.
  • - Third party service providers to help us operate our business, the Websites or administer activities on our behalf.
  • - Third party advertisers to enable them to select and serve relevant adverts to you and others.
  • - Analytics and search engine providers including Facebook that assist us in the improvement and optimization of the Websites.
  • - Professional advisors such as attorneys, accountants, auditors, financial and other professionals.
  • - Regulatory authorities including tax authorities.
  • - Law enforcement agencies, courts and other relevant tribunals.
If you want more information regarding who we may share your personal information with and the purposes for which we share your personal information with selected third parties, please email privacy@twingalaxies.com

We may disclose your personal information to third parties:
  • - In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
  • - If we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our users will be one of the transferred assets.
  • - If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce our Terms or other agreements with you; or to protect our rights, property, or safety, or those of our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
We do not sell, trade, or rent your personal information to others

BUSINESS TRANSFERS
If Twin Galaxies, or substantially all of its assets, were acquired, or in the unlikely event that Twin Galaxies goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Twin Galaxies may continue to use your personal information as set forth in this policy.

IMPORTANT NOTE
We reserve the right to use or disclose any information without notice or consent for the following purposes: as needed to satisfy any law, regulation or legal request; to conduct investigations of consumer complaints or possible breaches of law; to protect the integrity of our Websites and our property; to protect the safety of our visitors or others; to fulfill your requests; or to cooperate in any legal investigation.

DATA SECURITY
The transmission of information via the internet is not completely secure or private. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites. If you have any questions about the security of personal data collected by us, please contact us via the Contact Page or at privacy@twingalaxies.com
DATA TRANSFERS OF YOUR PERSONAL INFORMATION
For the reasons and purposes set forth in this Privacy Policy, the personal data that we collect may be transferred to and stored or otherwise processed in the United States and, Canada and other locations. We also transfer personal data to service providers that process personal data for us in the United States, Canada and other locations. While in another jurisdiction for processing, your personal data may be accessed by the courts, law enforcement, and national security authorities of that jurisdiction. These jurisdictions may not provide the same level of data protection as your home jurisdiction.

If you would like more information about how your personal information is transferred and the safeguards applied, please contact us via the Contact Page or at privacy@twingalaxies.com. If you are in the European Union, please see our EU PRIVACY POLICY for more information.
RETENTION OF YOUR PERSONAL INFORMATION
The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation.

For example, if you have an account with us, we will store your personal information for as long as you maintain that account and, after you cease holding an account for as long as we are required to by laws and regulations that are applicable to us.

COMMENTS
Comments and other content submitted to our selected anti-spam service are not saved on our servers unless they were marked as false positives, in which case we store them long enough to use them to improve the service to avoid future false positives.
YOUR RIGHTS
You may have certain rights in relation to the personal information we collect about you. These may include the right to request access to your personal information, to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing to privacy@twingalaxies.com. You also have the right to complain about the use of your personal information to a local supervisory authority.
THIRD PARTY WEBSITES
The Websites contain links to and from the websites of our partners, affiliates, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content on these websites and we are not responsible for the practices employed by them. If you follow a link to any of these websites, please note that these websites have their own privacy and customer support policies and we do not accept any responsibility or liability for these policies. Please carefully check these policies before you submit any personal information to these websites.
TWIN GALAXIES PRIVACY POLICY FOR CALIFORNIA RESIDENTS
Effective Date: January 1, 2022
Last Updated on: January 11, 2022

This Privacy Policy for California Residents supplements the information contained in Twin Galaxies’ Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
  • - Publicly available information from government records.
  • - Deidentified or aggregated consumer information.
  • - Information excluded from the CCPA's scope, like:
  • - 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), clinical trial data, or other qualifying research data;
  • - personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
In particular, our Website has collected the following categories of personal information from consumers within the last twelve (12) months:

· Categories of Personal Data Collected: In the preceding 12 months, we have collected the following categories of personal data: identifiers, characteristics of protected classifications under California or U.S. law, internet and electronic network activity, and other categories of personal data that relates to or is reasonably capable of being associated with you. For examples of the precise data points we collect, please see “What Information We Collect About You” above.
· Business or Commercial Purpose for Collecting and Using Data: We collect personal data for the business purposes described in the “What Do We Do With Collected Information” section above.
· Categories of Sources of Personal Data: We collect personal data from your use of the Website. For more information, please see “What Information We Collect About You” above.
· Categories of Personal Data Disclosed: In the preceding 12 months, we have not disclosed any personal information from you.
· Categories of Third Parties With Whom We Share Personal Data: We will not share your personal data with any third party.
· Sale of Personal Data: We do not sell your personal data.

Our Website obtains the categories of personal information listed above from the following categories of sources:
· Directly from you. For example, from forms you complete or products and services you purchase.
· Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
· To provide, support, personalize, and develop our Website, products, and services.
· To create, maintain, customize, and secure your account with us.
· To process your requests, purchases, transactions, and payments and prevent transactional fraud.
· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
· To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
· For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
· 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.
· 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, in which personal information held by us about our Website users is among the assets transferred.

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

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Twin Galaxies has not disclosed personal information for a business purpose.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
· sales, identifying the personal information categories that each category of recipient purchased; and
· disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
· The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

· Emailing us at privacy@twingalaxies.com
· Visiting twingalaxies.com

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by emailing us at privacy@twingalaxies.com.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. [However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.]

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at privacy@twingalaxies.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we 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.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time
EU PRIVACY POLICY
Personal Data Processed
When you provide your personal information to Twin Galaxies, the retains that information for contact purposes, as per section 6.1(b) of the General Data Protection Regulation ("GDPR").

The personal data processed by Twin Galaxies are your contact details. Such personal data is processed by Twin Galaxies only for specified, explicit and legitimate purposes as indicated above and for no other purpose whatsoever.

Personal data will be processed and stored by Twin Galaxies for as long as it is needed or for the duration of any statute of limitation of any action legal right or action that may be lodged by any of the parties against the other. Any other processing of your personal data will be made only with your prior written consent.

Twin Galaxies will not provide any of your personal data to any third party without your prior written consent.

Personal Data Processed for Marketing Purposes

Any collection and processing of personal data for marketing purposes will be performed by Twin Galaxies only with your prior written consent (section 6.1(a) GDPR), even if you are already a customer of Twin Galaxies. Twin Galaxies may also profile your personal data for marketing purposes. You may withdraw your consent at any time by sending an email to privacy@twingalaxies.com. Any communication by Twin Galaxies using your personal data for marketing purposes will include an active http link to unsubscribe to such direct prospection. By clicking on the unsubscribe link, you will withdraw your consent and all your personal data will be erased from our marketing data base.

Right to Access Your Personal Data (Section 15 GDPR)

You have the right to access your personal data processed by Twin Galaxies (section 15 GDPR). The exercise of the right to access and receive a copy of your data is free if you exercise it under reasonable conditions. In addition to a complete copy of your personal data, Twin Galaxies will also provide you with the complete list of information provided for in section 13 of the GDPR. If your requests are manifestly unfounded or excessive, in particular because of their repetitive nature, Twin Galaxies may either refuse to answer you or charge you for the provision of this information.

You may exercise your right to access your personal data anytime by sending an email to privacy@twingalaxies.com.

Right to Rectification (Section 16 GDPR)

You can at any time ask Twin Galaxies to rectify, as soon as possible, your personal data if this data is inaccurate.

Transparency Requirement

If Twin Galaxies does not take action when you exercise your right to object, access, or rectify, Twin Galaxies will inform you without delay and, at the latest, within one month of receipt of your request, of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Security

Twin Galaxies implements appropriate technical and organizational measures to ensure your personal data are adequately protected. In particular, our Website’s bunker security system is armed with a sentry system to monitor activity and prevent any unauthorized disclosure of credit card numbers or other personal information. In addition, we utilize a licensed system for credit card authorization and fraud detection. We use industry standard SSL (Secure Sockets Layer) encryption to protect the confidentiality of your personal data stored in our information system.

Your personal data are stored and processed within the information system of Twin Galaxies, operated only by Twin Galaxies. In case Twin Galaxies decides to subcontract all or part of the processing/storage of your personal data, Twin Galaxies shall impose to its subcontractor security obligations at least as strict as those described in the present section. Any subcontractor of Twin Galaxies shall have no right to subcontract any right or duty agreed upon with Twin Galaxies, except with the prior written consent of Twin Galaxies.

Notification of Personal Data Breach

"Personal data breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed by Twin Galaxies.

In case of breach of your personal data, Twin Galaxies shall notify such data breach without delay to the relevant Supervisory Authority in the EU. In addition, when the personal data breach is likely to result in a high risk to the rights and freedoms of its EU Customers or prospects, Twin Galaxies shall inform you of the personal data breach without undue delay.

Applicable Law

This Privacy Policy shall be governed by the law of the country where we will deliver you the products/services you order from Twin Galaxies. Any litigation relating to the enforcement of such Privacy Policy shall be of the jurisdiction of the supervisory authority of the country where Twin Galaxies delivers you the product/service sold.
CHANGES TO OUR POLICY
This policy will be reviewed from time to time to take account of changes to our operations and practices. If we make changes, we will notify you by revising the date at the top of this policy, and if the changes are significant, we may provide you with additional notice, such as adding a statement to the homepage of the Websites or sending you an email with the update. Any personal information held will be governed by our most current policy.
CONTACT US
If you have any questions or requests regarding this privacy policy, the practices of the Websites or your dealings with the Websites, or if you need to access this Policy in an alternative format due to having a disability, please contact us at privacy@twingalaxies.com, use the Contact Us page on the Websites, or call us at [COMING SOON].

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