Last Updated: April 10, 2021
Summary
The following Website Privacy Policy (“Privacy Policy”) sets forth our policy with respect to the collection, storage and use of your personal information and other information that we collect from you when you access the website(s) located at www.pathevolution.com (“ Path Evolution Site”) and/or www.twyne.io (“Twyne Site,” and together with the Path Evolution Site, the “Sites”). The Sites are owned and operated by Ifficient Inc. (“Company,” “we,” “ our” or “us”). Please note, if you are a resident of a European Union Member State, you are not permitted to use either Site and/or any Company Offerings.
Background
This Privacy Policy covers our treatment of personal information and other information that we collect when an end-user visitor to a Site (“ User,” “you” or “your”): ( a) accesses or uses a Site; (b) accesses and/or views any of the videos, audio, stories, testimonials, text, photographs, graphics, artwork, knowledge base, information and/or other content featured on a Site, as made available by Company (collectively, the “Content”); (c) accesses information pertaining to Company’s performance marketing and/or website services Platforms, and related services provided by Company in connection therewith (“Company Services”); and/or (d) utilizes a contact form and/or other functionality as a means to request being contacted by Company (collectively, “Contact Services,” and together with the Sites, Content, Company Services and Platforms, the “ Company Offerings”).
IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY, IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE COMPANY OFFERINGS.
Your California Privacy Rights
Company will never share, sell, rent, exchange or barter your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) to or with any third-party for financial gain or marketing purposes. Nevertheless, we may, in certain limited instances, share your personal information with third parties who perform administrative functions on our behalf.
If you are a resident of the State of California and would like to learn how your personal information is shared with third parties, what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please call us at: 800-619-9870; email us as at: compliance@ifficient.com; or send us U.S. Mail to: 1500 W 38 th Ave., Denver, CO 80202.
Your Nevada Privacy Rights
If you are a resident of the State of Nevada and would like to opt-out from the sale of your personal information to any third party data broker, please call us at: 800-619-9870; email us as at: compliance@ifficient.com; or send us U.S. Mail to: 1500 W 38 th Ave., Denver, CO 80202.
Personal Information Collected
In connection with obtaining access to the Company Offerings and/or otherwise completing the applicable Site registration process, Company will collect the following information applicable to the User: (a) the name of the User or User’s business entity (“Entity”); (b) the e-mail address of the User or the Entity’s primary contact ; (c) the telephone number of the User or the Entity’s primary contact; and/or (d) any other information requested on the applicable Form.
Use of Personal Information
Company will never share, sell, rent, exchange or barter your personal information to or with any third party for financial gain or marketing purposes. By making that personal information available to Company, you grant Company the right, subject to applicable law, to use that personal information to contact you regarding your use of the Company Offerings and/or other Company products and/or services that we think may be of interest to you. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such e-mail message or see the “Opt-Out/Unsubscribe” section below.
Where you submit personal information, we use the personal information that you make available to personalize your experience with the Sites and to facilitate the provision of the applicable Company Offerings to you, including in connection with customer service and to otherwise respond to any inquiries made by you. You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Company Offerings.
We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our Users’ personal information as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.
We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Company Offerings. We may also combine the information we have gathered about you with information from other sources.
By submitting your personal information by and through the Company Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.
Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Company, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide consent under the TCPA in order to obtain access to the Company Offerings, and your consent simply allows Company to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (a) have your telephone number reassigned to another person or entity; (b) give up your telephone number so that it is no longer used by you; (c) port your telephone number to a landline or vice versa; or (d) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Company of the Phone Number Change via e-mail at: support@twyne.io, or by using one of the methods set forth in the “Contact Us” section below.
We reserve the right to release current or past personal information: (i) in the event that we believe that the Company Offerings are being or have been used in violation of any Site-related agreement or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; (iii) if we are sold, merge with a third-party or are acquired by a third-party (collectively, “M&A Transactions”) (including where we share your personal information in connection with the due diligence process associated with a potential M&A Transaction); or (iv) if we are the subject of bankruptcy proceedings; provided, however, that if Company is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via e-mail and/or a prominent notice on the Sites of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.
You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be required by applicable law, including sharing your e-mail address with third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and other e-mail marketing laws. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission.
Non-Personal Information Collection and Use
IP Addresses/Browser Type
We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Sites. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Company Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Company Offerings.
Cookies
When a User visits a Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable User’s computer. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Sites. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Company Offerings, including for storing User preferences and tracking Site-User trends (such as pages opened and length of stay at the applicable Site).
Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a User rejects a Cookie, she or he may still use the Company Offerings; provided, however, that certain Company Offerings-related functions may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.
Behavioral Tracking
Neither Company, nor any third party, uses cookies, pixels or other tracking technology on the Sites for purposes of tracking Users’ activities after they leave a Site. Nevertheless, most Internet browsers and mobile devices contain a “do-not-track” setting. In general, when a “do-not-track” setting is active, the end-user’s Internet browser or mobile device notifies other websites or mobile applications that the end-user does not want her/his information and online behavior to be tracked and used, for example, for behavioral advertising.
Cross Device Tracking
Company may track Users’ use of the Company Offerings across multiple devices, including personal computers and mobile devices, for security purposes and in order to optimize and personalize your Company Offerings experience.
Aggregate Data
Company reserves the right to transfer and/or sell aggregate or group data about Users of the Company Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Company Offerings Users as a group, without disclosing personally identifiable information.
Third-Party Websites
The Sites may contain links to third-party owned and/or operated websites. Company is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Company has no responsibility or liability relating to them.
Security
We endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts Users to enter sensitive data (such as credit card information) and when we store and transmit such sensitive data, that personal information is encrypted with advanced TLS (Transport Layer Security).
Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our Users’ personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need User personal information to perform a specific job are granted access to User personal information. Our employees are dedicated to ensuring the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store User personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.
Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Sites, other Company Offerings or otherwise via the Internet or wireless networks, is done at your own risk.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
Minors
Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Sites. Company does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Company encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
Opt-Out/Unsubscribe
To opt-out of receiving e-mail and other forms of communications from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: support@twyne.io.
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Company Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Company Offerings-related and/or inquiry response-related messages from Company, you must cease requesting and/or utilizing the Company Offerings and/or cease submitting inquiries to Company, as applicable.
Individual Rights: Deleting, Modifying and Updating Your Personal Information
At your request, we will: (a) inform you of what personal information we have on file for you, in a machine-readable format; (b) amend the personal information that we have on file for you; and/or (c) completely remove personal information that you have provided to us, or that we have collected, from our servers/databases. You may make such a request by e-mailing us at: compliance@twyne.io. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests.
Please be advised that deleting your personal information may terminate your access to certain of the Company Offerings. If you wish to continue using the full complement of Company Offerings, you may not be able to delete all of the personal information that we have on file for you.
Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
Transfer of Personal Information Internationally
If you are visiting either Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of personal information across international boundaries. By visiting a Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.
Changes to this Privacy Policy
Company reserves the right to change or update this Privacy Policy at any time by posting a notice on the Sites that we are changing our Privacy Policy. If the manner in which we use personal information changes, Company will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner, and we will only use your information in this different manner where you affirmatively consent to such use.
Contact Us
If you have any questions about this Privacy Policy or our privacy practices in general, please call us at: 800-619-9870; e-mail us at: compliance@twyne.io; or send us U.S. Mail to: 1500 W 38th Ave., Denver, CO 80202.
Filing a Complaint with the Federal Trade Commission
To file a complaint regarding our privacy practices, please click here.