Privacy Statement

Last Updated: July 19, 2023

Definitions

Aggregate Information: information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.

De-identified Information: information that has been stripped of your Registration Information (e.g., your name and contact information) and other identifying data such that you cannot reasonably be identified as an individual, also known as pseudonymized information.

Individual-level Information: information about a single individual’s preferences, decision making, or other traits/characteristics or behaviors, but which is not necessarily tied to Registration Information.

Personal Information: information that can be used to identify you, either alone or in combination with other information. TwoChandys.com, Two Chandys, and/or ASE (collectively “TwoChandys”) collects and stores the following types of Personal Information:

Registration Information: information you provide about yourself when registering for and/or purchasing our Services (e.g. name, email, address, team username, and payment information).
Self-Reported Information: information you provide directly to us, either through the Services or through a third party, including your preferences, behaviors, health-related information, personal traits, ethnicity, family history, and other information that you enter into surveys, forms, or features while employing our Services.
Sensitive Information: information about your health and certain Self-Reported Information, such as racial and ethnic origin, sexual orientation, and political affiliation.
User Content: information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials⸺other than Self-Reported Information⸺generated by users of TwoChandys Services and transmitted, whether publicly or privately, to or through TwoChandys.
Inferences and Derived Data: information, data, assumptions, or conclusions that are derived directly or indirectly from another source of Personal Information. For example, we may use statistical techniques to infer additional behavioral information based on preference information you provide as part of any ASE Competition Experience.
Web-Behavior Information: information on how you use our Services collected through log files, cookies, web beacons, and similar technologies, (e.g., device information (device identifiers), IP address, browser type, domains, page views).

Information We Collect

Information you provide directly to us or through a third party

Registration Information. When you purchase our Services or register for an ASE Competition experience, we collect Personal Information, which may include your name, date of birth, billing and shipping address, payment information (e.g., credit card) and contact information (e.g. email, phone number).

Self-Reported Information. You have the option to provide us with additional information about yourself through surveys, forms, features and applications. For example, you may provide us with information about your personality, ethnicity, health history (e.g., Type 2 Diabetes), other health-related information (e.g., weight, height), and family history information (e.g., information similar to the foregoing about your family members). Before you disclose information about a family member, you should make sure you have permission from the family member to do so.

User Content. Some of our Services will request that you submit or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission (“User Content“). For example, User Content includes any discussions, posts, or messages you send us.

Social media features and widgets. Our Services may include Social Media Features, such as the Facebook “Like” or “Share” button and widgets (“Features”). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. They may also allow third party social media services to provide us information about you, including your name, email address, and other contact information. The information we receive is dependent upon your privacy settings with the third party social media service. Features are either hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the privacy statements of the third party companies providing them. You should always review and, if necessary, adjust your privacy settings on third party websites and services before linking or connecting them to our website or Service.

Third party services (e.g., social media). If you use a third party site, such as Facebook or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person’s name and contact information, we may also collect other information (e.g., your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers) depending on your privacy settings on the third party site. We do not control the third party site’s information practices, so please review the third party’s privacy statement and your settings on the third party’s site carefully.

Sign in. By participating in any ASE competition, and thereby submitting response(s) during approximately three (3) rounds of competition, you are NOT creating an account with TwoChandys or any other related entity. Each time TwoChandys collects any information or content from you during an ASE Competition, you must enter your email and name or nickname for complete submission of your response(s). Responses during any ASE competition are collected and used to determine winners of each of approximately three (3) rounds of any ASE competition in accordance with this Privacy Statement. You are responsible for managing and/or remembering the email, as well as your name or nickname, used during any ASE competition. If you do not enter the same or any name or nickname when submitting response(s) during an ASE competition, you may not be named as a winner of any round of competition.

Referral information and sharing. When you refer a person to TwoChandys or choose to share your TwoChandys results with another person, we may ask for that person’s email address. We will use their email address solely, as applicable, to make the referral or to communicate your sharing request to them, and we will let your contact know that you requested the communication. By participating in a referral program or by choosing to share information with another person, you confirm that the person has given you consent for TwoChandys to communicate (e.g., via email) with him or her. The person you referred may contact us at ase@twochandys.com to request that we remove this information from our database.

Gifts. If you provide us with Personal Information about others, if others give us your information, or if you authorize another individual to share or send your Personal Information to our third party service provider(s) for the purpose of ordering the Service or other personalized gift(s), we will only use that information for the purpose for which it was provided to us. These purposes may include, for example, where you provide us with a friend’s email address when placing an order. Once a gift recipient registers for our Services and agrees to our Privacy Statement and Terms & Conditions, his or her Personal Information will be used in manners consistent with this Privacy Statement, and will not be shared with the purchaser, unless he or she independently chooses to share his or her own Personal Information through the Services with the purchaser. Information shared directly with our third party service provider(s) for personalized gifts are subject to such third party’s terms of service and privacy policies.

Customer service. When you contact our Support Center or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Privacy Statement, Terms & Conditions, or applicable laws or regulations; and analyze and improve our Services.

Information related to our Services

To use our Services, you must purchase, or receive as a gift, a TwoChandys service and subsequently register for the related competition experience. During registration you are asked to review a consent document for collecting data directly related to the competition experience. If you provide consent, your data will be added to the Aggregate Information for that service and archived accordingly at the expiration of the competition experience.

Web-Behavior Information collected through tracking technology (e.g. from cookies and similar technologies)

We and our third party service providers use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to

help us recognize you when you use our Services;
customize and improve your experience;
provide security;
analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Service);
gather demographic information about our user base;
offer our Services to you;
monitor the success of marketing programs; and
serve targeted advertising on our site and on other sites around the Internet.

If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We may receive reports based on the use of these technologies from third party service providers as de-identified, Individual-level Information or as Aggregate Information.

Google Analytics. Google Analytics is used to perform many of the tasks listed above. We may use the User-ID feature of Google Analytics to combine behavioral information across devices and sessions (including authenticated and unauthenticated sessions). We may enable the following Google Analytics Advertising features: Remarketing, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and DoubleClick Campaign Manager integration. We do not merge information collected through any Google advertising product with individual-level information collected elsewhere by our Service.

Other Types of Information

We continuously work to enhance our Services with new products, applications and features that may result in the collection of new and different types of information. We will update our Privacy Statement and/or obtain your prior consent to new processing, as needed.

How We Use Your Information

TwoChandys will use and share your Personal Information with third parties only in the ways that are described in this Privacy Statement.

To provide you with Services and to analyze and improve our Services

We use the information described above to operate, provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with this Privacy Statement to:

open your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., referrals);
enable and enhance your use of our website and mobile application(s), including authenticating your visits, providing personalized content and information, and tracking your usage of our Services;
contact you about your account, and any relevant information about our Services (e.g. policy changes, security updates or issues, etc.);
enforce our Terms of Service and other agreements; monitor, detect, investigate and prevent prohibited or illegal behaviors on our Services, to combat spam and other security risks; and
perform research & development activities, which may include, for example, conducting data analysis in order to develop new or improve existing products and services, and performing quality control activities.

To process, analyze and deliver our Services

As described above, to use our Services, you must purchase, or receive as a gift, a TwoChandys Service and subsequently register for the related competition experience. After registration your data is added to the Aggregate Information for that specific experience and, depending on the results and the Service(s) purchased, analyzed and reported back as statistical results to all users registered for the same Experience. TwoChandys continuously works to improve our Services based on our research, product development, and the associated empirical literature. If you are eligible to receive additional reports or updates in the future, you may be notified of or may directly access these updates.

For individuals located in the Designated Countries: Our legal basis for processing your Sensitive Information for the purpose described above is based on your consent. You may withdraw your consent at any time, however, the withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

To allow you to share your Personal Information for TwoChandys Research purposes

You have the choice to participate in TwoChandys Research by providing your consent. “TwoChandys Research” refers to research aimed at publication in peer-reviewed journals conducted by TwoChandys .

TwoChandys Research may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations or academic institutions. TwoChandys Research may study a specific group or population, identify potential areas or targets for research and development, work with public, private and/or non-profit entities on research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve outcomes. TwoChandys Research uses Aggregate and/or Individual-level Self-Reported Information as specified in the appropriate Consent Document(s), as explained in greater detail below.

Your De-identified Genetic and Self-Reported Information may be used for TwoChandys Research only if you have consented to this use by completing a Consent Document. If you have completed the main Research Consent Document:

Your Self-Reported Information will be used for research purposes, but it will be de-identified and will not be linked to your Registration Information.
TwoChandys may use individual-level Self-Reported Information internally at TwoChandys for research purposes.
TwoChandys may share summary statistics, which do not identify any particular individual or contain individual-level information, with our qualified research collaborators.

Withdrawing your Consent. You may withdraw your consent to participate in TwoChandys Research at any time by emailing ase@twochandys.com to change your consent status. TwoChandys will not include your Self-Reported Information in studies that start more than 30 days after you withdraw (it may take up to 30 days to withdraw your information after you withdraw your consent). Any research involving your data that has already been performed or published prior to your withdrawal from TwoChandys Research will not be reversed, undone, or withdrawn. You may also discontinue your participation in TwoChandys Research by emailing ase@twochandys.com to remove yourself.

To recruit you for external research

Research is an important aspect of our Services and we want to ensure interested participants are aware of additional opportunities to contribute to interesting, novel scientific research conducted by academic institutions and other groups. If you have chosen to participate in TwoChandys Research, from time to time we may inform you of third party research opportunities for which you may be eligible. For example, if a university tells us about a new cancer research project, we may send an email to TwoChandys research participants who potentially fit the relevant eligibility criteria to make them aware of the research project and provide a link to participate with the research organization conducting the study. We will not share Self-Reported Information with any third party without your explicit consent. If you do not wish to receive these notifications, email ase@twochandys.com to change your consent status.

To provide customer support

When you contact Customer Care, we may use or request Personal Information, including Sensitive Information, as necessary to answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints. In some instances, we may be required to process one customer’s Personal Information to resolve another customer’s dispute or request. For example, if a customer reports behavior that violates our Terms of Service, we will separately process both customers’ Personal Information and respond separately to each individual as appropriate. We will not share your Personal Information with another customer without your consent.

For individuals located in the Designated Countries: Our legal basis for processing your Personal Information for the purpose described above depends on the nature of the customer support request. Our legal basis can be to satisfy our contractual or legal obligations and/or our legitimate interest to improve our Services.

To conduct surveys or polls, and obtain testimonials

We value your feedback and may send you surveys, polls, or requests for testimonials to improve and optimize our Services. You are in control of the information you would like to share with us. If you do not wish to receive these requests, email ase@twochandys.com.

For individuals located in the Designated Countries: Our legal basis for processing your Personal Information for the purpose described above is based on our legitimate interest. We think it is important to continue improving our Services to ensure your continued enjoyment.

To provide you with marketing communications

By using TwoChandys Services, you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You may also opt-in to receiving similar notifications on the website or mobile application(s). You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe” link. To opt-out of receiving website and mobile notifications, you may do so within your browser or device settings. Please note, the opt-out process differs between web browsers and mobile devices. You may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.

Information We Share with Third Parties

General service providers

We share the information described above with our third party service providers, as necessary for them to provide their services to us and help us perform our contract with you. Service providers are third parties (other companies or individuals) that help us to provide, analyze and improve our Services. While TwoChandys directly conducts the majority of data processing activities required to provide our Services to you, we engage some third party service providers to assist in supporting our Services, including in the following areas:

Order fulfillment. Our payment processor processes certain Registration Information, such as your billing address and credit card information, as necessary to enable you to purchase the TwoChandys experience.
Service distribution. To use our Services, you must purchase, or receive as a gift, a TwoChandys Service and subsequently register for the related ASE Competition experience via survey or form. Information obtained as part of registration is added to the Aggregate Information for that specific experience and, depending on the results and the Service(s) purchased, analyzed and reported back as statistical results to all users registered for the same Experience. Receiving personnel associated with our response capturing software may, in some cases, be exposed to “sender information” (e.g., name, address); however, receiving personnel do not perform any statistical analysis or otherwise engage with the data. During registration, you are asked to review our Consent Document. If you agree, after registration your data is added to the Aggregate Information for that specific experience and, depending on the results and the Service(s) purchased, analyzed and reported back as statistical results to all users registered for the same Experience and thereafter archived accordingly.
Customer Care support. Our Customer Care team uses a number of tools to help organize and manage the requests we receive. These tools help to ensure we provide timely, high quality support.
Cloud storage, IT, and Security. Our cloud storage providers provide secure storage for information in TwoChandys databases, ensure that our infrastructure can support continued use of our Services by TwoChandys customers, and protect data in the event of a natural disaster or other disruption to our Service. Our IT and security service providers assist with intrusion detection and prevention measures to stop any potential attacks against our networks. We have these third party experts perform regular penetration tests and periodically audit TwoChandys’s security controls.
Marketing and analytics. When you use our Services, including our website or mobile app(s), our third party service providers may collect Web-Behavior Information about your visit, such as the links you clicked on, the duration of your visit, and the URLs you visited. This information can help us improve site navigability and assess our Marketing campaigns. NOTE: Our service providers act on TwoChandys’s behalf. We implement procedures and maintain contractual terms with each service provider to protect the confidentiality and security of your information. However, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically. For individuals located in the European Economic Area (“EEA”), United Kingdom, or Switzerland (collectively the “Designated Countries”): Where Personal Information are transferred to a third country or to an international organization, TwoChandys implements appropriate safeguards, such as contractual obligations, relating to the transfer.

“Targeted advertising” service providers

We permit third party advertising networks and providers to collect Web-Behavior Information regarding the use of our Services to help us to deliver targeted online advertisements (“ads”) to you. They use cookies and similar technologies, to gather information about your browser’s or device’s visits and usage patterns on our Services and on other websites over time, which helps to better personalize ads to match your interests, and to measure the effectiveness of ad campaigns. We and our third party service providers will not use your Sensitive Information, such as Self-Reported Information, for targeted marketing without asking for and receiving your explicit consent.

Aggregate information

We may share Aggregate Information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties. This Information is different from “Individual-level” information and is not Personal Information because it does not identify any particular individual or disclose any particular individual’s data. For example, Aggregate Information may include a statement that “30% of our female users share a particular preference,” without providing any data or testing results specific to any individual user. In contrast, Self-Reported Information consists of data about a single individual’s traits/characteristics information and could reveal whether a specific user has a particular trait. TwoChandys will ask for your consent to share Individual-level Self-Reported Information with any third party, other than our service providers as necessary for us to provide the Services to you.

Information we share with commonly owned entities

We may share some or all of your Personal Information with other companies under common ownership or control of TwoChandys , which may include our subsidiaries, our corporate parent, or any other subsidiaries owned by our corporate parent in order to provide you better service and improve user experience. Generally, sharing such information is necessary for us to perform on our contract with you. We may provide additional notice and ask for your prior consent if we wish to share your Personal Information with our commonly owned entities in a materially different way than discussed in this Privacy Statement.

As required by law

Under certain circumstances your Personal Information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. For example, we may be required to disclose Personal Information in coordination with regulatory authorities in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. TwoChandys will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that TwoChandys may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the TwoChandys Terms of Service and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of TwoChandys , its employees, its users, its clients, and the public.

Business transactions

In the event that TwoChandys goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.

Your Choices

Marketing communications

As noted in above, you may be asked to opt-in to receive product and promotional emails or notifications when using our Services. You may opt out at the browser or device level, or by contacting our Privacy Administrator at ase@twochandys.com. You can also click the “unsubscribe” button at the bottom of promotional email communications, as applicable.

Sharing outside of the TwoChandys Services

You may decide to share your Personal Information with friends and/or family members and/or other individuals outside of our Services, including through third party services such as social networks and third party apps that connect to our website and mobile apps through our application programming interface (“API”). These third parties may use your Personal Information differently than we do under this Privacy Statement. Please make such choices carefully and review the privacy statements of all other third parties involved in the transaction. TwoChandys does not endorse or sponsor any API applications, and does not affirm the accuracy or validity of any interpretations made by third party API applications.

In general, it can be difficult to contain or retrieve Personal Information once it has been shared or disclosed. TwoChandys will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with others. Likewise, if you are reading this because you have access to the Personal Information of an TwoChandys customer through a multi-profile account, we urge you to recognize your responsibility to protect the privacy of each person within that account. Users with multi-profile accounts (i.e., where multiple family members register together) should use caution in setting profile-level privacy settings.

Service termination

If you no longer wish to participate in our Services, email us at ase@twochandys.com. Once we confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. When you terminate our Services, all associated Personal Information is deleted subject to the following limitations:

Information previously included in TwoChandys Research. As stated in any applicable Consent Document, Self-Reported Information that you have previously provided, and for which you have given consent to use in TwoChandys Research, cannot be removed from completed studies that use that information. Your data will not be included in studies that start more than 30 days after you terminate our services (it may take up to 30 days to withdraw your information after you terminate our services).
Legal Retention Requirements. TwoChandys will retain limited information, including but not limited to, your email address, account deletion request identifier, communications related to inquiries or complaints and legal agreements for a limited period of time as required by law, contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes.

Security Measures

TwoChandys takes seriously the trust you place in us. TwoChandys implements physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information. Our team regularly reviews and improves our security practices to help ensure the integrity of our systems and your information. These practices include, but are not limited to, limiting access to Sensitive Information to authorized personnel, based on job function and role. Your Responsibility. Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your information you use to access our Services. Your information collected through the Service may be stored and processed in the United States or any other country in which TwoChandys or its subsidiaries, affiliates or service providers maintain facilities and, therefore, your information may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.

Children’s Privacy

TwoChandys is committed to protecting the privacy of children as well as adults. Neither TwoChandys nor any of its Services are designed for, intended to attract, or directed toward children under the age of 18. A parent or guardian, however, may purchase Services for his or her child who is under the age of 18. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to TwoChandys about his or her child is kept secure and that the information submitted is accurate.

Linked Websites

TwoChandys provides links to third party websites operated by organizations not affiliated with TwoChandys. TwoChandys does not disclose your information to organizations operating such linked third party websites. TwoChandys does not review or endorse, and is not responsible for the privacy practices of these organizations. We encourage you to read the privacy statements of each and every website that you visit. This Privacy Statement applies solely to information collected by TwoChandys and our service providers on our behalf.

Information for Customers in Designated Countries

This Section only applies to individuals located in the European Economic Area (“EEA”), United Kingdom, or Switzerland (the “Designated Countries”).

Our relationship with you

We are the “controller” with respect to your Personal Information because we determine the means and purposes of processing your information when using our Services.

Legal bases for processing Personal Information from the EU

We describe how we process your Personal Information above in this Privacy Statement. In short, we may process your Personal Information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of TwoChandys, our customers or others.

Direct Marketing

We will obtain your consent where required to send you marketing communications using electronic means. You may withdraw your consent at any time by emailing ase@twochandys.com. We will only contact you by electronic means (email, push notification, SMS, etc.) with information about our Services that are similar to those which were the subject of a previous sale or negotiation of a sale to you.

We will only share your Personal Information with third parties for marketing purposes with your explicit consent. If you do not want us to use your Personal Information in this way, please review contact us at ase@twochandys.com. You may raise such objection with regard to initial or further processing for purposes of direct marketing at any time and free of charge. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

Other marketing activities will happen based on the legitimate interests of TwoChandys (e.g., where we tailor marketing communications or send targeted marketing messages via email or third party platforms, and in providing existing customers with information⸺via email or other channels⸺about similar products and services).

Privacy Rights

You can exercise your privacy rights by contacting us at ase@twochandys.com. We will handle your request under applicable law. When you make a request, we may verify your identity to protect your privacy and security.

Right to withdraw consent. To the extent TwoChandys requests and you provide your consent to the processing of your Personal Information, you can withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
Right to rectification of your Personal Information. If you would like to access or rectify any information, email ase@twochandys.com and we will do our best to assist you without undue delay. We may reject part or all of your request if responding to your request could adversely affect the rights and freedoms of others.
Right to erasure (or, “Right to be Forgotten”). You can request erasure of Personal Information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing to which you previously consented, but later withdrew such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. If we have made your Personal Information public and we are required to erase such Personal Information, we will take reasonable steps, including technical measures, to inform controllers that are processing any links to or copies or replications of your Personal Information of your erasure request. Our assistance with your request for erasure is subject to limitations by relevant data protection laws, available technology and the cost of implementation.
Right to data portability. If we process your Personal Information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request your Personal Information in a structured, commonly used and machine-readable format. You may also request the transfer of your Personal Information directly to another controller, where technically feasible, unless choosing to exercise this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which alone or jointly with others, determines the purposes and means of the processing of your Personal Information.
Right to restriction of our processing. You can restrict our processing of your Personal Information where one of the following applies: (a) you dispute the accuracy of Personal Information processed by TwoChandys (for a period enabling us to verify its accuracy); (b) the processing is unlawful and you oppose the erasure of the Personal Information and request the restriction of its use instead; (c) TwoChandys no longer needs the Personal Information for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; and (d) you have objected to certain processing relying on legitimate interest, pending the verification whether TwoChandys’s legitimate grounds override your rights. Restricted Personal Information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will notify you if the restriction is lifted.
Notification of erasure, rectification and restriction. We will provide notice to each recipient that we disclosed your Personal Information to regarding any rectification or erasure of Personal Information or restriction of processing, unless you initiated the disclosure or providing notice proves impossible or involves disproportionate effort. Upon your request, we will share the list of recipients with you.
Right to object to processing. Where the processing of your Personal Information is based on consent, contract, or legitimate interests described under the Legal Bases for Processing heading above, you may restrict or object, at any time, to the processing of your Personal Information as permitted by applicable law. We may continue to process your Personal Information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, except as allowed under applicable data protection laws.
Retention of your Personal Information. Unless you ask us to delete your Personal Information (i.e., User Content, etc.), we will store it. If you request that we delete your account, we will take the delete all your Personal Information unless a longer retention period is required or permitted by law.

The rights described above may be limited by local laws. Further, your right of access and deletion is not absolute and may not be available if fulfillment of such right would, among other things:

cause interference with execution and enforcement of the law and legal private rights (such as in the case of the investigation or detection of legal claims or the right to a fair trial);
breach or prejudice the rights of confidentiality and security of others;
prejudice security or grievance investigations, corporate re-organizations, future and ongoing negotiations with third parties, the compliance with regulatory requirements relating to economic and financial management; or
otherwise violate the interests of others or where the burden or cost of providing access would be disproportionate.

Complaints

If you believe that we have infringed your rights, we encourage you to contact us so that we can try to address your concerns or dispute informally. Our contact information is: TwoChandys, P.O. Box 2036, DeLeon Springs, FL 32130 ase@twochandys.com

California Residents

Pursuant to the California Consumer Privacy Act of 2018, California residents are afforded certain additional rights regarding our use of your personal information. To learn more about your California privacy rights, email ase@twochandys.com.

Nevada Residents

Pursuant to Nevada law, you may direct a business that operates an internet website not to sell certain Personal Information a business has collected or will collect about you. TwoChandys does not sell your Personal Information pursuant to Nevada law. For more information about how we handle and share your Personal Information or your rights under Nevada law, contact us ase@twochandys.com.

Do Not Track Statement

Some browsers have a ”do not track” feature that allows you to tell websites that you do not want to have your online activities tracked. At this time, due to a lack of industry standards, we do not respond to browser ”do not track” signals.

Changes to this Privacy Statement

TwoChandys modifies this Privacy Statement from time to time. We recommend revisiting this page periodically to stay aware of any changes to this Privacy Statement. If we modify this Privacy Statement, we’ll make it available through our website. Whenever material changes to this Privacy Statement are made, we will provide you with notice before the modifications are effective, such as by posting a notice on our website or sending a message to your email address.

By continuing to access or use the Services after changes to this Privacy Statement becomes effective, you agree to be bound by the revised Privacy Statement. If any changes are unacceptable to you, you may stop using our Services at any time.

We also may provide additional “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. Such notices may supplement or clarify our privacy practices or may provide you with additional choices about how TwoChandys processes your Personal Information.

Contact Information

If you have questions about this Privacy Statement, or wish to submit a complaint, request or inquiry, please email TwoChandys’s Privacy Administrator at ase@twochandys.com or send a letter to: TwoChandys, P.O. Box 2036, DeLeon Springs, FL 32130.