TWD Solutions
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PRIVACY POLICY

Effective July 2012
Commonwealth of Virginia, United States of America

TWD & Associates, Inc. ("TWD") has developed this policy statement ("Privacy Policy") to assist end users ("you" or "User") in understanding the personally identifiable information ("PII") collection, use, and dissemination practices for TWD's United States Website(s) (the "the TWD Website"). PII includes information that can be linked to a specific individual, such as a name, address, phone number, or email address. TWD reserves the right to change this Privacy Policy at any time. If TWD makes changes to this Privacy Policy, TWD will post those changes at this location and provide notice of any material changes so that you are aware of what information TWD collects, how TWD uses it, and under what circumstances, if any, TWD disseminates it. Please review this Privacy Policy on a periodic basis.

What Information Does TWD Collect?

The type of PII collected by TWD will vary with your use of the TWD Website. TWD gathers most information during any registration processes TWD may utilize to facilitate subscription or participation or otherwise allow access to or use of certain information, tools, or features. But, TWD may collect PII at other times, including, but not limited to, when you report a problem with the TWD Website, when you complete forms, and when you request to receive a communication(s) from TWD. Below, TWD provides specific examples of the types of PII that TWD may collect through the TWD Website.

Personal Information: TWD may request or require your name, employer, or employment title or industry.

Contact Information: TWD may request or require contact information, such as your phone number and email address.

Technical Information: TWD may collect Internet Protocol (IP) addresses from all Users of the TWD Website as well as the date and time of access and the Web page(s) accessed. TWD may also catalog your log-in information and your computer, browser, or operating system information and may maintain a database of aggregated information about the transactions on the TWD Website (e.g., tool or feature utilization).

How Does TWD Use that Information?

Until you log in, participate in surveys, programs, or events, or register for a subscription, product, or services from TWD, you are able to browse the TWD Website without providing any PII, although your browser may tell us where you are navigating within the TWD Website, what tools or features you are accessing within the TWD Website, what type of computer and operating system you are using as well as other kinds of technical information. Below, TWD sets forth more detail on how TWD uses your PII.

Personal and Contact Information: TWD may use your personal and contact information to facilitate or improve its services or the other capabilities of the TWD Website, advertise its products and services, create a personalized experience for you, provide you with news and information, contact you regarding a survey, get in touch with you when necessary with respect to transactions conducted through the TWD Website, material changes in the TWD Website's policies and agreements, new products, tools, or services TWD may offer, or otherwise. TWD may also share your contact information with TWD's affiliates or business partners, as is necessary to provide TWD's services and information, for advertising purposes, to facilitate transactions through the TWD Website, or for internal business purposes.

Aggregated Information: TWD may share PII or other related data on an aggregated basis, which will not identify any particular User, with TWD's business partners and affiliates and for advertising or other technical or business purposes.

Survey Results: TWD may share survey results collected through the TWD Website with its business partners and affiliates and/or the general public, the news media, and with the U.S. Government and state governments, not only for business or marketing purposes or as may be required by law, but also to participate in government programs and initiatives.

Technical Information: TWD may use technical information to help diagnose problems with TWD's servers, analyze the TWD Website usage trends, track User movements on the TWD Website, and to otherwise manage and monitor the TWD Website.

Business Transactions: In the event that TWD goes through a business transaction, such as a merger or acquisition by another entity involving the sale of all or a portion of its assets, please note that the PII collected and retained by TWD may be among the assets transferred. In the event a transaction of this kind has occurred that results in the transfer of PII, TWD will notify you via email and/or place a prominent notice on the TWD Website for thirty (30) days of any such change in ownership or control and the possible changes to this Privacy Policy.

Legal Action: TWD may disclose PII when legally required to do so in accordance with government requests or regulations or legal proceedings. TWD may also disclose PII to protect against misuse or unauthorized use of the TWD Website or as is otherwise required to limit legal liability, protect or defend TWD's rights, property, or interests, or protect the safety, rights, or property of TWD's Users.

What About the Use of Cookies and other Automated Data Collection Techniques?

TWD may use cookies or similar programming techniques to enhance your experience while using the TWD Website. Cookies are pieces of information, which TWD uses for record-keeping purposes, which the TWD Website transfers to your computer's Web-browser for storage on your computer's hard drive. Cookies enable TWD to customize your experience on the TWD Website. Cookies also make Web-surfing easier by automatically performing certain functions such as saving your personal preferences and by ensuring that you don't see the same advertisement repeatedly. Many consider the use of cookies to be an industry standard. Consequently, your Web browser is likely set to accept cookies. If you would prefer not to receive cookies, however, you can alter the configuration of your browser to refuse or delete cookies. If you choose to have your browser refuse or delete cookies, you should understand that it is possible that some areas of the TWD Website will not function properly when you view them.

What About External or Third Party WebSites?

To the extent hyperlinks or gateways (whether through banner advertisements or otherwise) are utilized to access external or third party sites, you should be aware that these external or third party sites may collect PII and are not controlled by TWD and therefore, are not subject to this Privacy Policy. TWD suggests that you check the privacy policies of these sites to determine how the proprietors of these third party sites will collect or utilize your PII.

What About Security?

As is appropriate for the nature of PII collected and stored by TWD, the TWD Website has industry standard security measures or safeguards in place to protect against the loss, misuse, and alteration of the information under TWD's control. Although TWD has endeavored to create a secure and reliable TWD Website, the confidentiality of any communication or data cannot be guaranteed. Accordingly, you should consider carefully if you want to submit sensitive information to TWD. TWD urges you to take every precaution to protect your PII when on-line.

What About "Opting-Out" of Data Collection and Use?

For certain PII collection, you can decide on your own if you wish to provide your PII to TWD (when requested) or opt-out of doing so. You may opt-out by contacting TWD as set forth below. Thus, to a certain extent, you can control the information you provide or share with TWD. Nevertheless, the collection and use of certain PII is required to provide certain features of the TWD Website and to provide other products or services.

What About Correcting, Deleting, or Updating Information?

TWD will retain your PII for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. At any time, you may contact, as set forth below, TWD to correct, modify, or delete the information you provide to TWD through the TWD Website. TWD may require you to confirm your identity with respect to any request. Please note, however, that the collection and uses of certain PII is necessary to provide certain information and services through the TWD Website and the deletion of such necessary information, e.g., an email address, may render a particular service or TWD's ability to provide it inoperable.

What About Children?

TWD cares about the safety of children on its TWD Website and encourages parents and guardians to monitor their children's use of the Internet. Although the TWD Website is suitable for a general audience, the TWD Website is intended for use only by Users who are over the legal age of majority. Accordingly, TWD does not intentionally solicit PII from children or send them requests for personal information.

What About the Governing Law?

This Privacy Policy shall be governed by and construed in accordance with the laws of the Commonwealth of Virginia, U.S.A. The TWD Website and the servers that host the TWD Website are located in the United States. Any information you provide will be transferred to the United States. By visiting and using the TWD Website and submitting information thereto, you authorize this transfer to the United States. If any part of this Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of this Privacy Policy shall continue in force and effect.

What About Any Other Questions?

If you have any questions about this Privacy Policy or the information collection and dissemination practices of the TWD Website or otherwise wish to make opt-out, update, or deletion requests for TWD, you can contact TWD and its employee(s) responsible for its Privacy Policy and related privacy compliance matters by email at martinr@twd.com, by phone at 703-820-9777, or by mail at TWD & Associates, Inc. (TWD), Attn: Rodney Martin – Privacy {or Opt-Out}, 2800 Shirlington Rd, Suite 400 Arlington, VA 22206.