Privacy Policy

Twin Lakes Consulting Privacy Policy – Last Updated: June 1, 2018

1. Introduction

Twin Lakes Consulting Corporation (Twin Lakes) provides client services as a business consultancy (“Services”).  Twin Lakes licenses access to cloud business applications (“Applications”).  Twin Lakes maintains business-oriented web sites (“Web Sites”).  Our Privacy Policy applies to customer and visitor use of our Services, Applications, Web Sites and related communications.

2. Confidentiality – Consulting Clients

2.1  Twin Lakes understands that a sound relationship between a client and a trusted advisor entails maintaining the confidentiality of our clients and our clients’ information.

2.2  We may use applications and research tools to collect your information, from internal and / or external sources, to determine which of our products and services might work well for you.

2.3  We may use information pertaining to your account, and information from third parties, to verify information about your account.

3. Confidentiality – Application Users

3.1  Data We Collect

3.1.1  We log your visits and build usage data when you use our Services.

3.1.2  We collect data through cookies and similar technologies.

3.1.3  We may build metrics based on application data stored in our databases.

3.2  How We Use Your Data

3.2.1  We use log-ins, cookies, device information, and internet protocol (“IP”) addresses to identify you and log your use.

3.2.2  We use your data to assist you with issues and correct problems.

3.2.3  We use log and metric data to gain insights about ways our applications are being used.

3.2.4  We use your data if we think it’s necessary for security purposes or to investigate possible theft of services or fraud, violations of this Privacy Policy or any applicable service agreements, and/or attempts to harm our assets or our clients.

4. Confidentiality – General

4.1  Twin Lakes does not sell, trade or rent personal information provided by you for any purpose, except as provided in this privacy policy, or with your permission.

4.2  We use third-party service providers to assist us in making our Services , Applications, and Web Sites available to authorized customers, users, and visitors.  We may share data with third parties who provide services to us, such as credit card processing, analytics, data storage, and data security services.

4.3  Twin Lakes does not knowingly engage in business transactions with those that will use your information for purposes other than those intended by Twin Lakes.

4.4  We may recast, mask, or otherwise mutate your information, so that it is not personally identifiable, and use and share such modified information for training, quality assurance, and service and product enhancement purposes.

5. Safeguarding Your Information

5.1  Twin Lakes believes no system is perfectly secure.  The root cause of data breaches is “hackers”.  Until hackers are eliminated, the threat of data breach will remain with providers and users of data processing services and applications.  Using Twin Lakes Services, Applications, and Web Sites creates a relationship of risk shared between Twin Lakes and its customers and visitors.

5.2  Twin Lakes uses security measures designed to protect against the loss, misuse and alteration of the information under our control.

5.3  Application data that we store is maintained on hardened servers located in highly secured data centers.  Access to this data is protected by access control mechanisms including firewalls, client-based access controls, user authentication, and activity monitoring.  Data is backed up, and secured archives are stored off-site, in highly secured locations.  We also apply encryption techniques and data mutation or obfuscation as deemed appropriate.

5.4  Client billing data, including credit card information, resides in encrypted data volumes on devices other than our production cloud application servers.  Backups of such are maintained in encrypted form.

6. Data Retention

6.1  We maintain your personal data while your account is in existence or as needed to provide services to you.

6.2  We may retain your personal data after you have closed your account if reasonably necessary to comply with legal requirements, complete unfinished business, or enforce agreements.

6.3  We may retain de-personalized data after your account is closed.

7. Data Disclosure

We may disclose information we collect about you under the following circumstances:

7.1  When you, or any authorized person, gives us permission to do so,

7.2  To process a legitimate business transaction,

7.3  To support a third party who performs functions on behalf of Twin Lakes,

7.4  To comply with a legal process (such as a court order, subpoena, or search warrant) or other legal requirement of any governmental authority,

7.5  If we reasonably believe it is necessary to report, investigate, or prevent unauthorized transactions or other illegal activities,

7.6  If we reasonably believe it is necessary or appropriate to protect the rights or property of any person or entity,

7.7  If we reasonably believe it’s required by law or appropriate to help protect the safety of any person,

7.8  If we reasonably believe it’s required to investigate or defend ourselves against any third-party claims or allegations,

8. Rights to Access and Control Your Personal Data

8.1  Data Changes or Deletion:  You may be able to edit some of your personal data through your Application account.  You may ask us to change, update or delete your personal data.

8.2  Data Objections or Restrictions: You may ask us to stop using all or some of your personal data.

8.3  Data Access: You may ask us for a copy, or description, of your personal data.

9. Your Choices & Obligations

9.1  If you elect to engage in any communication or data exchange with Twin Lakes or a customer that uses our Services, Applications, or Web Sites, it is up to you to decide what, if any, information to provide.  If you do not wish to provide certain information, you should not do so.

9.2  Pay attention to your billing cycles and follow up with us if billing seems incorrect.

9.3  Twin Lakes does not believe unencrypted email communication is private or secure.  Contact Twin Lakes to determine best means for sharing confidential information.

9.4  Communication of a proprietary, secret, sensitive, or business-confidential nature (and the like) must not be sent to anyone at Twin Lakes until a related contractual relationship has been established with Twin Lakes.

10. Privacy Policy Changes

10.1  This Privacy Policy is subject to change.

10.2  Changes to this Privacy Policy apply to your use of our Services, Applications, Web Sites, and related communication as of the ”Last Updated” date.

10.3  You acknowledge that your continued use of our Services, Applications, and Web Sites after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

10.4  We recommend that you review this Privacy Policy periodically.  Your use of our Services, Applications, and Web Sites, as applicable, constitutes your consent to the updated Privacy Policy to the fullest extent permitted by law.

11. How to Contact Us

Should you have any questions or concerns about our privacy policies, please contact us directly at 724-330-7030 or at privacy@twinlakesconsulting.com.