Privacy Policy

 This Agreement is made on 2^nd June, 2025

Between

Twinkle Tag a company engaged in professional opinion sharing on law subjects

And:

Users and visitors who access or use TwinkleTag’s website, or otherwise provide personal information to Twinke Tag (https://twinkletag.com/)

Parties

1. Twinke Tag (https://twinkletag.com/) (“Company,” “we,” “us,” or “our”), a business with its principal place of business at Ghana, which operates https://twinkletag.com/contact-us and collects, processes, and controls personal information in the course of its business operations.
2. Users (“you” or “your”), being any individual who visits, accesses, or uses Company’s website, services, applications, or otherwise provides personal information to Company, including but not limited to customers, prospective customers, subscribers, and website visitors.

Background

1. Company is committed to protecting the privacy and security of personal information collected from Users in connection with the provision of its services and operation of its business.
2. This Privacy Policy describes Company’s practices regarding the collection, use, storage, sharing, and protection of personal information obtained from Users through Company’s website located at https://twinkletag.com/, mobile applications, services, and other online or offline interactions.
3. Company collects and processes personal information in accordance with applicable United States federal and state privacy laws, including but not limited to the California Consumer Privacy Act, Children’s Online Privacy Protection Act, and other relevant data protection regulations.
4. By accessing or using Company’s services, website, or providing personal information to Company, Users acknowledge that they have read, understood, and agree to be bound by the terms of this Privacy Policy.
5. This Privacy Policy is effective as of 2^nd June, 2025 and may be updated from time to time to reflect changes in Company’s practices, legal requirements, or business operations.
6. Company’s collection and processing of personal information is necessary for the legitimate business purposes of providing services, maintaining customer relationships, and operating its business in compliance with applicable laws.

1. Definitions
   1. Personal Information means any information that identifies, relates to, describes, or is capable of being associated with a particular individual, including but not limited to name, postal address, email address, telephone number, social security number, driver’s license number, payment card information, and online identifiers.
   2. Cookies means small data files stored on a User’s device that contain information about the User’s interactions with Company’s website or services.
   3. Processing means any operation performed on Personal Information, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, or destruction.
   4. Services means all websites, mobile applications, software, products, and services provided by Company, including https://twinkletag.com/ and any related platforms.
   5. Third Parties means individuals or entities other than Company and Users, including service providers, business partners, advertisers, and other organizations that may receive Personal Information from Company.
   6. Tracking Technologies means cookies, web beacons, pixels, tags, scripts, and other similar technologies used to collect information about Users’ online activities.
   7. Sensitive Information means Personal Information that reveals racial or ethnic origin, political opinions, religious beliefs, health information, biometric data, or information about sexual orientation.
   8. Children means individuals under the age of thirteen (13) years.
   9. Device Information means information about the computer, mobile device, or other device used to access Services, including IP address, browser type, operating system, and device identifiers.
   10. Usage Data means information about how Users interact with Services, including pages visited, features used, time spent, and navigation patterns.
   11. California Residents means individuals who reside in the State of California as defined under the California Consumer Privacy Act.
2. Information We Collect
   1. Information You Provide to Us. Company collects Personal Information that Users voluntarily provide when creating accounts, making purchases, contacting customer service, subscribing to newsletters, participating in surveys, or otherwise interacting with our Services. This may include name, email address, phone number, mailing address, payment information, account credentials, and any other information Users choose to provide.
   2. Information We Collect Automatically. When Users access or use our Services, Company automatically collects certain information through Cookies, Tracking Technologies, and other means, including:
      1. Device Information such as IP address, browser type and version, operating system, device identifiers, screen resolution, and mobile network information.
      2. Usage Data including pages visited, time spent on pages, links clicked, search terms entered, referring and exit pages, and other interactions with our Services.
      3. Location Information derived from IP addresses or, with consent, precise geolocation data from mobile devices.
   3. Information from Third Parties. Company may receive Personal Information about Users from Third Parties, including business partners, data brokers, social media platforms, marketing companies, and publicly available sources, which we may combine with information we collect directly.
   4. Sensitive Information. Company does not intentionally collect Sensitive Information such as social security numbers, financial account information, health records, or biometric data, except where necessary for specific Services and with appropriate consent or legal basis.
   5. Children’s Information. Company does not knowingly collect Personal Information from Children under 13 years of age without verifiable parental consent in compliance with the Children’s Online Privacy Protection Act.
3. How We Collect Information
   1. Direct Collection from Users. Company collects Personal Information directly from Users when they voluntarily provide such information through various interactions, including account registration, form submissions, purchases, customer service communications, surveys, contests, and other voluntary submissions.
   2. Automatic Collection Through Technology. Company automatically collects certain information when Users access or use the Services through the deployment of Tracking Technologies, including but not limited to web server logs, Cookies, web beacons, pixel tags, and similar automated data collection tools.
      1. Company’s systems automatically record Device Information including IP addresses, browser types, operating systems, device identifiers, and network connection details.
      2. Company collects Usage Data regarding User interactions with the Services, including pages visited, features used, time spent, click-through rates, and navigation patterns.
   3. Third Party Sources. Company may obtain Personal Information from Third Parties, including business partners, service providers, data brokers, social media platforms, publicly available sources, and other lawful commercial sources, subject to applicable legal requirements and the privacy practices of such Third Parties.
   4. Social Media Integration. When Users connect their social media accounts to the Services or interact with Company’s social media presence, Company may collect information made available through such platforms in accordance with the privacy settings and terms of service of the respective social media providers.
   5. Offline Collection. Company may collect Personal Information through offline interactions, including in-person events, telephone communications, physical locations, paper forms, and other non-digital touchpoints.
   6. Mobile Applications. When Users download and use Company’s mobile applications, Company may collect additional information including location data, mobile device identifiers, push notification preferences, and mobile-specific Usage Data, subject to device permissions and User consent where required by law.
4. Use of Information

1. Service Provision and Operations. Company uses Personal Information to provide, operate, maintain, and improve the Services, including to:
   1. Process transactions and fulfill orders or requests;
   2. Create and manage user accounts and profiles;
   3. Provide customer support and respond to inquiries;
   4. Deliver requested products, services, or information;
   5. Process payments and manage billing activities.
2. Communications. Company uses Personal Information to communicate with Users, including to:
   1. Send transactional messages, service announcements, and administrative communications;
   2. Respond to comments, questions, and customer service requests;
   3. Send newsletters, marketing materials, and promotional communications where consent has been obtained;
   4. Notify Users of changes to the Services or this Privacy Policy.
3. Business Operations and Analytics. Company uses Personal Information for legitimate business purposes, including to:
   1. Analyze Usage Data and website traffic to improve Services and user experience;
   2. Conduct market research, surveys, and data analysis;
   3. Develop new products, services, and features;
   4. Monitor and analyze trends, usage patterns, and effectiveness of marketing campaigns.
4. Security and Fraud Prevention. Company uses Personal Information to:
   1. Protect the security and integrity of the Services and Company’s systems;
   2. Detect, investigate, and prevent fraudulent, unauthorized, or illegal activities;
   3. Verify user identity and authenticate access to accounts;
   4. Monitor compliance with Company’s terms of service and policies.
5. Legal Compliance. Company uses Personal Information to:
   1. Comply with applicable laws, regulations, and legal processes;
   2. Respond to lawful requests from government authorities and law enforcement;
   3. Establish, exercise, or defend legal claims;
   4. Protect the rights, property, and safety of Company, Users, and Third Parties.
6. Employment and Business Relationships. When applicable, Company uses Personal Information to:
   1. Evaluate job applications and manage employment relationships;
   2. Conduct background checks and verify credentials;
   3. Manage vendor, partner, and contractor relationships;
   4. Facilitate business transactions and due diligence activities.
7. Personalization. Company may use Personal Information and Cookies to:
   1. Customize content, advertisements, and Services based on user preferences;
   2. Remember user settings and preferences;
   3. Provide personalized recommendations and targeted marketing.
8. Aggregated and De-identified Data. Company may aggregate or de-identify Personal Information for research, analytics, and other business purposes, provided such data cannot reasonably be used to identify individual Users.

5. Information Sharing and Disclosure
   1. Service Providers and Business Partners. Company may share Personal Information with Third Parties who provide services on Company’s behalf, including but not limited to payment processing, data analytics, customer service, marketing assistance, website hosting, and technical support. Such Third Parties are contractually obligated to protect Personal Information and use it solely for the purposes specified by Company.
   2. Legal Compliance and Protection. Company may disclose Personal Information when required by law, legal process, or government request, or when Company believes in good faith that disclosure is necessary to: 5.2.1 comply with applicable laws, regulations, or legal obligations; 5.2.2 protect and defend Company’s rights, property, or safety; 5.2.3 protect the rights, property, or safety of Users or Third Parties; or 5.2.4 investigate, prevent, or respond to fraud, security breaches, or illegal activities.
   3. Business Transactions. In the event of a merger, acquisition, reorganization, sale of assets, bankruptcy, or other business transaction, Personal Information may be transferred to the acquiring entity or Third Parties involved in such transaction, subject to continued protection under this Privacy Policy or a substantially similar privacy policy.
   4. Consent-Based Sharing. Company may share Personal Information with Third Parties when Users have provided specific consent for such sharing, including through opt-in mechanisms or explicit authorization.
   5. Aggregate and De-Identified Information. Company may share aggregate, de-identified, or anonymized information that cannot reasonably be used to identify individual Users with Third Parties for business purposes, analytics, research, or marketing activities.
   6. Children’s Information. Personal Information of Children will not be shared with Third Parties except: 5.6.1 with parental consent; 5.6.2 as necessary to protect the safety of the child; or 5.6.3 as required by law.
   7. California Residents. California Residents have specific rights regarding the sharing of their Personal Information, including the right to know about and opt-out of certain sales or sharing of Personal Information as defined under California privacy laws.
   8. Restrictions on Third Parties. Company requires Third Parties who receive Personal Information to maintain appropriate security measures and use such information only for authorized purposes consistent with this Privacy Policy and applicable law.
6. Data Retention
   1. Company retains Personal Information for as long as necessary to fulfill the purposes for which it was collected, provide Services to Users, comply with legal obligations, resolve disputes, and enforce Company’s agreements.
   2. Company applies the following general retention periods: 6.2.1 Account information and profile data are retained for the duration of the User’s active account plus seven (7) years after account closure or termination; 6.2.2 Transaction and payment records are retained for seven (7) years from the date of the transaction to comply with financial recordkeeping requirements; 6.2.3 Marketing communications and preferences are retained until the User unsubscribes or opts out, plus three (3) years thereafter; 6.2.4 Usage Data and Device Information are typically retained for twenty-four (24) months from collection; 6.2.5 Customer service communications are retained for three (3) years from the date of the last interaction.
   3. Company may retain Personal Information for longer periods when required by applicable law, including tax laws, employment laws, securities regulations, or litigation hold requirements.
   4. Personal Information of Children is deleted within a reasonable time after Company becomes aware that such information is no longer necessary for the purpose for which it was collected, unless parental consent has been obtained for continued retention.
   5. Company may retain anonymized or aggregated data indefinitely for analytics, research, and business intelligence purposes, provided such data cannot reasonably be used to identify individual Users.
   6. Upon expiration of applicable retention periods, Company will securely delete or anonymize Personal Information using industry-standard methods, unless retention is required by law or legitimate business interests.
   7. California Residents may request information about Company’s data retention practices and deletion procedures by contacting Company using the methods specified in this Privacy Policy.
7. Cookies and Tracking Technologies
   1. Company uses Cookies and other Tracking Technologies on its website, mobile applications, and Services to enhance user experience, analyze usage patterns, and deliver personalized content and advertisements.
   2. Cookies are small data files stored on Users’ devices that contain information about their interactions with Company’s Services. Tracking Technologies include web beacons, pixels, tags, and similar technologies that collect information about Users’ online activities.
   3. Company uses the following types of Cookies:
      1. Essential Cookies that are necessary for the basic functionality of the Services and cannot be disabled;
      2. Functional Cookies that remember Users’ preferences and settings to improve their experience;
      3. Analytics Cookies that collect information about how Users interact with the Services to help Company improve performance and functionality;
      4. Advertising Cookies that track Users’ browsing behavior to deliver targeted advertisements and measure advertising effectiveness.
   4. Company may allow Third Parties, including advertising partners, analytics providers, and social media platforms, to place Cookies and Tracking Technologies on Users’ devices through Company’s Services.
   5. Users may control Cookies through their browser settings by accepting, rejecting, or deleting Cookies. Users may also opt out of certain Tracking Technologies through industry preference centers and third-party opt-out mechanisms.
   6. Disabling Cookies may limit Users’ ability to access certain features or functionality of the Services, and Company cannot guarantee full functionality if essential Cookies are disabled.
   7. Company’s Cookies and Tracking Technologies may collect Device Information and Usage Data as described in other sections of this Privacy Policy.
8. Third-Party Links and Services
   1. Company’s Services may contain links to websites, applications, or services operated by Third Parties that are not owned or controlled by Company, including social media platforms, payment processors, analytics providers, and other service providers.
   2. Company is not responsible for the privacy practices, content, or policies of any Third Parties, and this Privacy Policy does not apply to information collected by Third Parties through their websites, applications, or services.
   3. Third Parties may have their own privacy policies and terms of service that govern their collection, use, and disclosure of personal information, and Users are solely responsible for reviewing and understanding such policies before providing any personal information to Third Parties.
   4. Company may integrate Third Party services or technologies into its Services, including but not limited to social media widgets, analytics tools, advertising networks, and customer support platforms, which may collect information about Users independently of Company.
   5. The inclusion of links to Third Party websites or the integration of Third Party services does not constitute an endorsement by Company of such Third Parties or their privacy practices, and Company disclaims any liability for the actions or policies of such Third Parties.
   6. Users acknowledge and agree that Company has no control over Third Party privacy practices and that any interactions with Third Parties are at Users’ own risk and subject to the applicable Third Party’s terms and privacy policies.
9. Children’s Privacy
   1. Company does not knowingly collect, use, or disclose Personal Information from Children under the age of thirteen (13) years without verifiable parental consent, in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws.
   2. Company’s Services are not directed to Children, and Company does not knowingly solicit or collect Personal Information from Children through its website, mobile applications, or other platforms.
   3. If Company becomes aware that it has inadvertently collected Personal Information from a Child without verifiable parental consent, Company will take immediate steps to delete such information from its systems and databases.
   4. Parents or legal guardians who believe that Company may have collected Personal Information from their Child may contact Company using the contact information provided in this Privacy Policy to request review and deletion of such information.
   5. Upon receiving a verified request from a parent or legal guardian, Company will promptly investigate the matter and, if confirmed, will delete the Child’s Personal Information within thirty (30) days of verification.
   6. Company reserves the right to request additional verification of parental identity before processing requests related to Children’s Personal Information to ensure the security and protection of such information.
   7. If Company determines that certain Services require collection of Personal Information from Children, Company will first obtain verifiable parental consent in compliance with COPPA requirements before collecting, using, or disclosing such information.
10. Data Security
    1. Company implements administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, disclosure, alteration, or destruction. 10.2 Technical security measures include but are not limited to encryption of data in transit and at rest, secure socket layer (SSL) technology for data transmission, firewalls, intrusion detection systems, and access controls that limit access to Personal Information to authorized personnel only. 10.3 Administrative safeguards include employee training on data protection practices, background checks for personnel with access to Personal Information, confidentiality agreements, and regular security policy reviews and updates. 10.4 Physical security measures include secured facilities, restricted access to data centers and servers, environmental controls, and secure disposal of physical media containing Personal Information. 10.5 Company requires Third Parties that Process Personal Information on its behalf to implement appropriate security measures and contractual protections consistent with this Privacy Policy and applicable law. 10.6 Users are responsible for maintaining the confidentiality of their account credentials and for all activities that occur under their accounts, and must notify Company immediately of any unauthorized use of their accounts. 10.7 Despite these security measures, Company cannot guarantee absolute security of Personal Information, as no method of transmission over the internet or electronic storage is completely secure, and Users acknowledge the inherent risks of data transmission and storage. 10.8 In the event of a data breach that affects Personal Information, Company will notify affected Users and relevant authorities as required by applicable law, including within the timeframes specified by federal and state breach notification requirements. 10.9 Company regularly monitors its systems for potential vulnerabilities and security incidents, conducts periodic security assessments, and updates its security measures as necessary to address evolving threats and technological changes.
11. Your Rights and Choices

1. Access Rights. Users have the right to request access to the Personal Information that Company has collected about them, including the categories of Personal Information, sources of collection, business purposes for collection, and categories of Third Parties with whom such information has been shared.
2. Correction Rights. Users may request that Company correct or update inaccurate or incomplete Personal Information maintained about them.
3. Deletion Rights. Users have the right to request deletion of their Personal Information, subject to certain exceptions including legal compliance requirements, fraud prevention, security purposes, and legitimate business operations.
4. Marketing Communications Opt-Out. Users may opt out of receiving promotional or marketing communications from Company by following the unsubscribe instructions in such communications or by contacting Company directly.
5. Cookie Choices. Users may manage their cookie preferences through their browser settings or through Company’s cookie management tools where available.
   1. Disabling Cookies may affect the functionality of Company’s Services.
   2. Certain essential Cookies cannot be disabled while using Company’s Services.
6. Tracking Technologies Opt-Out. Users may opt out of certain Tracking Technologies through industry opt-out mechanisms or browser settings, though this may limit Service functionality.
7. California Residents Rights. California Residents have additional rights under the California Consumer Privacy Act, including the right to know, delete, opt-out of sale, and non-discrimination.
   1. California Residents may designate an authorized agent to exercise these rights on their behalf.
   2. Company does not sell Personal Information as defined under California law.
8. Exercise of Rights. Users may exercise their rights by contacting Company through the methods specified in the Contact Information section of this Privacy Policy.
   1. Company may require verification of identity before responding to rights requests.
   2. Company will respond to verified requests within the timeframes required by applicable law.
9. Non-Discrimination. Company will not discriminate against Users for exercising their privacy rights, including by denying Services, charging different prices, or providing different levels of service quality.
10. Limitations. Certain rights may be limited by applicable law, including requirements to retain information for legal compliance, fraud prevention, or security purposes.

12. California Privacy Rights
    1. Applicability. This section applies exclusively to California Residents and supplements the other provisions of this Privacy Policy. In the event of any conflict between this section and other provisions, this section shall control with respect to California Residents.
    2. Right to Know. California Residents have the right to request that Company disclose the categories and specific pieces of Personal Information collected about them, the categories of sources from which such information was collected, the business or commercial purposes for collecting such information, and the categories of Third Parties with whom such information is shared.
    3. Right to Delete. California Residents have the right to request deletion of Personal Information collected from them, subject to certain exceptions under applicable law including but not limited to legal compliance obligations, fraud prevention, and completion of transactions.
    4. Right to Correct. California Residents have the right to request correction of inaccurate Personal Information maintained by Company.
    5. Right to Opt-Out. California Residents have the right to opt-out of the sale or sharing of their Personal Information for cross-context behavioral advertising purposes.
    6. Right to Limit Use of Sensitive Information. California Residents have the right to limit Company’s use and disclosure of Sensitive Information to purposes necessary to perform Services or provide goods requested by the consumer.
    7. Right to Non-Discrimination. Company will not discriminate against California Residents for exercising their privacy rights, including by denying Services, charging different prices, or providing different levels of service quality.
    8. Exercising Rights. California Residents may exercise their rights by contacting Company through the methods specified in the Contact Information section of this Privacy Policy or through any designated consumer request portal.
    9. Verification Process. Company will verify the identity of individuals making requests through reasonable methods, which may include requesting additional information or documentation to confirm identity and protect against fraudulent requests.
    10. Response Timeframes. Company will respond to verified requests within forty-five (45) days, with the possibility of one forty-five (45) day extension if reasonably necessary.
    11. Authorized Agents. California Residents may designate an authorized agent to make requests on their behalf, provided that Company receives adequate proof of authorization and verifies the consumer’s identity.
13. International Data Transfers
    1. Company may transfer Personal Information to countries outside the United States in connection with the provision of Services, business operations, or when working with Third Parties located in foreign jurisdictions.
    2. International transfers of Personal Information may occur when Company:
       1. Utilizes cloud storage services or data centers located outside the United States;
       2. Engages service providers, vendors, or business partners operating from international locations;
       3. Processes transactions or communications involving users located in foreign countries;
       4. Complies with legal obligations or responds to lawful requests from foreign authorities.
    3. When transferring Personal Information internationally, Company implements appropriate safeguards to protect such information, including:
       1. Contractual protections requiring recipients to maintain adequate data protection standards;
       2. Standard contractual clauses or similar legal mechanisms;
       3. Verification that recipient countries provide adequate levels of data protection;
       4. Technical and organizational security measures appropriate to the sensitivity of the transferred data.
    4. Company will not transfer Personal Information to countries or organizations that Company reasonably believes do not provide adequate protection for Personal Information unless appropriate safeguards are in place or the transfer is otherwise permitted by applicable law.
    5. For California Residents, Company provides notice of international transfers as required by the California Consumer Privacy Act and will honor any applicable rights regarding such transfers.
    6. Users may contact Company using the information provided in this Privacy Policy to request additional information about international transfers of their Personal Information or to exercise any available rights regarding such transfers.
14. Updates to Privacy Policy
    1. Company reserves the right to modify, update, or revise this Privacy Policy at any time in its sole discretion to reflect changes in Company’s practices, legal requirements, or business operations.
    2. Company will provide notice of material changes to this Privacy Policy by posting the updated Privacy Policy on Company’s website with a revised effective date and may provide additional notice through email, in-app notifications, or other reasonable means.
    3. Non-material changes, including administrative updates, clarifications, or changes required by law, may be made without prior notice and will become effective immediately upon posting.
    4. Material changes to this Privacy Policy will become effective thirty (30) days after the updated Privacy Policy is posted on Company’s website, unless a longer notice period is required by applicable law.
    5. Users are responsible for periodically reviewing this Privacy Policy to stay informed of any changes, and continued use of Company’s Services after the effective date of any modifications constitutes acceptance of the updated Privacy Policy.
    6. If Users disagree with any modifications to this Privacy Policy, their sole remedy is to discontinue use of Company’s Services and, where applicable, request deletion of their Personal Information in accordance with this Privacy Policy.
    7. Company will maintain prior versions of this Privacy Policy for a reasonable period and may make them available upon request for Users’ reference.
15. Contact Information
    1. Users may contact Company regarding privacy-related questions, concerns, or requests by emailing hello@twinketag.com.
    2. For formal privacy requests, including requests to exercise rights under applicable privacy laws, Users may submit written requests to Company’s Privacy Officer at the following address: Twinke Tag (https://twinkletag.com/), Attention: Privacy Officer, [MAILING ADDRESS].
    3. Users may contact Company regarding the following privacy matters:
       1. Questions about this Privacy Policy or Company’s privacy practices;
       2. Requests to access, correct, update, or delete Personal Information;
       3. Requests to opt-out of certain data processing activities;
       4. Privacy complaints or concerns; and
       5. Requests for information about data sharing with Third Parties.