Your privacy is important to us.
It is Twirling Umbrellas Ltd.’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, https://twirlingumbrellas.com, and other sites we own and operate.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.
This policy is effective as of 2 February 2024.
Information We Collect
The information we collect falls into one of two categories:
- “Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.
- “Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even at the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services and ensuring that you do not inadvertently make your own personal information available via our platform.
For example, if you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
How Long We Keep Your Personal Information
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal information about children under 13.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
- a parent, subsidiary or affiliate of our company,
- third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators,
- our employees, contractors, and/or related entities,
- our existing or potential agents or business partners,
- credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you,
- courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights,
- third parties, including agents or sub-contractors who assist us in providing information, products, services, or direct marketing to you,
- third parties to collect and process data and
- An entity that buys or to which we transfer all or substantially all of our assets and business.
Third parties we currently use include:
- Google Analytics
Your Rights and Controlling Your Personal Information
Marketing permission: If you have previously agreed to use your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example, providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer and accesses each time you visit so we can understand how you use our site. This helps us serve you content based on the preferences you have specified.
- when visitors leave comments on the site, we collect the data shown in the comments form, as well as the visitor’s IP address and browser user agent string to help spam detection.
- An anonymized string is created from your email address (also called a hash) and may be sent to Gravatar to see if you are using their service. If your comment is approved and you are using Gravatar, your profile picture may be made visible to the public in the context of your comment.
- If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
- If you request a password reset, your IP address will be included in the reset email.
- When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
- If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
- For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
- If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
Our website may link to external sites that we do not operate. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
Additional Disclosures for Personal Information Protection and Electronic Documents Act (PIPEDA) Compliance (Canada)
Additional scope of personal information
In accordance with PIPEDA, we broaden our definition of personal information to include any information about an individual, such as financial information, information about your appearance, your views and opinion (such as those expressed online or through a survey), opinions held about you by others, and any personal correspondences you may have with us. While this information may not directly identify you, be aware that it may be combined with other information to do so.
Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. When you contact us, we assume your consent based on your positive action of contact, therefore you consent to your name and email address being used so we can respond to your enquiry. Under PIPEDA, consent is only valid if it is reasonable to expect that an individual to whom the organisation’s activities are directed would understand the nature, purpose, and consequences of the collection, use, or disclosure of the personal information to which they are consenting.
Where you agree to receive marketing communications from us, we will do so based solely on your indication of consent or until you instruct us not to, which you can do at any time.
International Transfers of Information
While Twirling Umbrellas Ltd. endeavours to keep, store and handle customer data within locations in Canada, it may use agents or service providers located in the United States (U.S.), European Economic Area (EEA) or United Kingdom (UK) to collect, use, retain and process personal information as part of providing services to you. While we use all reasonable efforts to ensure that personal information receives the same level of security in any other jurisdiction as it would in Canada, please be aware that privacy protections under U.S. laws may not be the same adequacy.
Customer Data Rights
Although PIPEDA does not contain an extensive set of consumer rights, it does grant consumers the right to:
Access the personal information organizations hold about them;
Correct any inaccurate or outdated personal information the organization hold about them (or, if this is not possible, delete the inaccurate personal information)
Withdraw consent for any activities for which they have consented (e.g. direct marketing or cookies
Right to Withdraw Consent
Where you give us consent to collect and use your personal information for a specific purpose. Subject to some restrictions, you can, at any time, refuse to consent, or continue to consent to the collection, use or disclosure of their personal information by notifying us using the email address below in the ‘Contact Us’ section. Withdrawal of consent may impact our ability to provide or continue to provide services.
Customers cannot refuse collection, use and disclosure of their personal information if such information is required to:
- be collected, used or disclosed as required by any law;
- fulfil the terms of any contractual agreement, and
- be collected, used or disclosed as required by any regulators, including self regulatory organisations
Right of Access under PIPEDA
PIPEDA gives you a general right to access the PII held by businesses subject to this law. Under PIPEDA, you need to make your access request in writing and pay a minimal fee of $30.00.
If any organizational fees seem unjust, you have the right to complain about this. We retain the right to decide how we disclose the copies of your PII to you. We will take all necessary measures to fulfil your request within 30 days from receipt. Otherwise, we must inform you of our inability to do so before the 30-day timeframe if:
- Meeting the time limit would unreasonably interfere with our business activities or
- the time required to undertake consultations necessary to respond to the request would make it impractical to meet the time limit.
We can also extend the time limit for the length of time required to convert the personal information into an alternative format. In these circumstances, we will advise you of the delay within the first 30 days and explain the reason for it.
Right of rectification under PIPEDA
You may request a correction to any factual errors or omissions within your PII. We would ask you to provide some evidence to back up your claim. Under PIPEDA, an organization must amend the information, as required, if you successfully demonstrate that it’s incomplete or inaccurate.
If we cannot agree on changing the information, you have the right to have your concerns recorded with the Office of the Privacy Commission of Canada.
Compliance with PIPEDA’s Ten Principles of Privacy
Accountability. Twirling Umbrellas Ltd. is responsible for the PII under its control and will designate one or more persons to ensure organizational accountability for compliance with the ten principles of privacy under PIPEDA, whose details are included below. All personnel are accountable for the protection of customers’ personal information.
Identifying purposes. Twirling Umbrellas Ltd. identifies the purposes for which personal information is collected at or before the time the information is collected.
Consent. Consent is required for Twirling Umbrellas Ltd.’s collection, use or disclosure of personal information, except where required or permitted by PIPEDA or other law. In addition, when customers access a product or service offered by us, consent is deemed to be granted. Express consent may be obtained verbally, in writing or through electronic means. Alternatively, consent may be implied through the actions of customers or continued use of a product or service following Twirling Umbrellas Ltd.’s notification of changes.
Limiting collection. Personal information collected will be limited to that which is necessary for the purposes identified by Twirling Umbrellas Ltd.
Limiting use, disclosure and retention. We will not use or disclose personal information for purposes other than those for which the information was collected, except with your consent or as required by law. We will retain personal information only for as long as is necessary to fulfil the purposes for collecting such information and compliance with any legal requirements.
Accuracy. Personal information will be maintained by Twirling Umbrellas Ltd. in an accurate, complete and up-to-date format as is necessary for the purpose(s) for which the personal information was collected.
Safeguards. We will protect personal information with security safeguards appropriate to the sensitivity of such information.
Openness. We will make our policies and practices relating to the collection and management of personal information readily available upon request, including our brochures or other information that explains our policies, standards, or codes.
Customer access. We will inform customers of the existence, use, and disclosure of their personal information and will provide access to it, subject to any legal restrictions. We may require written requests for access to personal information and, in most cases, will respond within 30 days of receipt of such requests. Customers may verify the accuracy and completeness of their personal information and may request the personal information be corrected or updated if appropriate.
Our email interactions with our customers are compliant with Canadian Anti-Spam Legislation. The Company does not send unsolicited emails to persons with whom we have no relationship. We will not sell personal information, such as email addresses, to unrelated third parties. On occasion, your personal information may be provided to our third-party partners to administer the products and services you request from us.
When you leave our website by linking to another website, you are subject to the privacy and security policies of the new website. We encourage you to read the privacy policies of all websites you visit, especially if you share any personal information with them.
Enquiries, Reports and Escalation
If we fail to resolve your concern to your satisfaction, you may also contact the Office of the Privacy Commissioner of Canada:
30, Victoria Street
Gatineau, Quebec K1A 1H3
Toll Free: 1.800.282.1376
For any questions or concerns regarding your privacy, you may contact us using the following details: