Welcome to TTT’s (as defined herein) website (“Site(s)”). This Site is offered as a service to our customers. Twin Towers Trading, Ltd. and its affiliates, including, without limitation, Twin Towers Trading Site Management, LLC, and Twin Towers Trading Distribution Company, LLC, (collectively, “TTT”) are committed to the protection of consumer privacy.
- Personal Information Collection
TTT may collect personal information such as name, telephone number, email address, social security number, and home or mailing address when you access certain areas of the Site that require registration for certain services. If you decide to purchase any products or services, or marketing related materials offered by TTT, we will need to collect certain additional information, like your credit card number, credit card expiration date, shipping and billing address.
At other times, TTT may collect information that cannot be used to identify you. For example, we may aggregate non-personal information about you and other customers who visit our Site. Aggregated information will not contain any information that can be linked directly back to you.
- How TTT Collects Personal Information
TTT may also collect additional information from your web browser each time you visit our Site. We may collect information on the pages that you visit, the advertisements that you click, and other actions that you take while using our Site. This information may include your Internet Protocol (“IP”) address, the type of browser, the time that your browser was used to access our Site, and the referring website address.
We may also use other standard web-based technologies to analyse your movements while accessing our Site. The technologies include web “beacons,” “pixel tags,” and “clear gifs.” These technologies help us ascertain the effectiveness of our advertising campaigns and marketing programs, allow us to customise the services offered on or through our Site, and help determine the best use for Site content and programming. Some of this information, including the IP address that we obtain from your browser, may be stored on our server logs, and may be available for extended periods of time.
- Our Use and Disclosure of Your Personal Information
TTT uses the personally identifiable information that you provide about yourself or your business when placing an order only to complete that order. We do not share personally identifiable information with outside parties without your consent, except to the extent necessary to complete your order or to provide the services offered on this Site. For example, we may provide your personal information to our service providers that may handle our credit card processing or shipping services.
TTT may use your personal information to contact you via mail, email, or telephone in order to give you updates about TTT products, order status or changes, and other promotional events that may be of interest to you. We use return e-mail addresses to answer the e-mail we receive; they are not used for any other purpose or shared with outside parties for marketing purposes. We may also use your IP address to help protect TTT and our partners from fraud.
Additional uses of your personal information will allow us to tailor products and services specific to your needs, to help organise and manage your customer relationship and our business, to conduct business, to provide you with customer support, to perform functions that are described to you at the time of collection, and to enforce our Terms and Conditions of Use.
We use non-personal cumulative information to improve our Site. We may, for example, report to an affiliate that there were a particular number of visitors to a certain area of our Site, or that X number of men and Y number of women completed our registration form, but we would not offer any information that could be used to identify those individuals. Such information may also be used to analyse the effectiveness of our business and advertising models.
If you are seeking an independent contractor relationship with TTT, or seeking to fulfil other TTT business needs as may be posted from time to time, we will use that information solely in connection with your application for current or future TTT business needs, and we may also share your application information with our business partners or affiliates that have business needs that you may be qualified for.
TTT may also disclose your personal information as is necessary to: (a) comply with a subpoena or court order; (b) cooperate with law enforcement or other government agency; (c) establish or exercise our legal rights; (d) protect the property or safety of our company and employees, contractors, vendors and suppliers; (e) defend against legal claims; (f) help with internal and external investigations; or (g) as otherwise required by law or permitted by law. We may disclose your information in connection with the sale or merger of TTT or any transaction that involves the sale or assignment of some or all of our assets.
Notwithstanding the foregoing, to the extent TTT collects any of your personal information that is subject to the laws of any jurisdiction outside of the United Kingdom including but not limited to the EU Data Protection Directive, then TTT shall use that personal information solely in compliance with such laws.
- Data Storage and Security
TTT has implemented physical, electronic, and procedural security measures to assist with safeguarding your personal information, and to help protect against unauthorised access and disclosure. Only our authorised personnel and service providers who are performing legitimate business functions for TTT are permitted to access your personal information. We also use secure sockets layer (“SSL”) and other forms of encryption to protect any sensitive personal information that is transmitted or authorised to be transmitted by TTT, and we also use electronic firewalls to help prevent unauthorised individuals from gaining access to your personal data.
Notwithstanding our efforts, the Internet has inherent security risks. TTT cannot promise, and you should not expect, that your personal information, personal searches, and other communications will always remain secure. You should take care with regard to how you handle and disclose your personal information.
- Children and Data Collection
TTT Sites are general audience Sites. But TTT content is neither directed toward minors nor children who are under the age of 13. We do not knowingly collect personal information from children under the age of 13 without parental consent. If TTT becomes aware that a child under the age of 13 has provided us with personal information without the parental consent, that information will be deleted from our databases. Parents who have questions about personal information that may have been submitted by a child under the age of 13 should email us at firstname.lastname@example.org.
- Your Privacy Rights
TTT will not share any personal information about you with our third-party affiliates for our direct marketing purposes to the extent prohibited by law, unless you agree otherwise as authorised by your prior written consent.
UK residents have the right to request information from TTT regarding the manner that we may share personal information with affiliated companies and other third parties for their direct marketing purposes. To find out what and how we share such information, you may send us an email request at email@example.com and receive the following information:
- The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- The names and addresses of the third parties who received information for their direct marketing purposes; and
- Examples of the products and services subject to the third-parties’ direct marketing programs, if the nature of the third parties’ business cannot be determined from their names.
- How You May Access and Change the Information that TTT Collects
The first time that you provide us with registration information through our Site, you may be offered the opportunity to subscribe to receive additional information regarding TTT’s products and services. After your first use, you can change your initial choices by contacting the customer service email at firstname.lastname@example.org. Each commercial email that we send to you, will offer you the opportunity to opt-out of continuing to receive such messages. We may take up to 10 business days to process your opt-out requests. In some instances, we may have already shared your information with one of our authorised third parties before you changed your information preferences. In those cases, you may have to directly contact those third parties to opt-out of receiving their communications.
FTC email compliance guidance allows us to send you transactional and relationship email without offering you the opportunity to opt-out of receiving those types of email.
- General Contact Information Privacy Support
If you require additional information about TTT’s privacy commitment, please contact us at email@example.com