Effective: March 7, 2018.

Purpose of the Privacy Policy

Your privacy is important to us. TWRL. (“Twrl”, “we”, “our” or “us”) provides this Privacy Policy (the “Policy”) to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we may receive from users of the TWRL website ( the “Site”) and users of our application for mobile devices (the “App”). By providing information to us through the Site or the App, you agree to be bound by this Policy. If you do not agree to the terms of this Policy, please do not use the Site, the App or our Service (defined below). This Policy may be updated from time to time and any updates will be posted to our Site or made available through the App. Because of this, when you use the App, our Site or our Service, you should check the date of this Policy and review any changes since the last version.

Why We Collect Information

Our primary reason for collecting information is to provide and improve our Site, App, services, features and content and to administer your membership and allow users to enjoy and easily navigate the Site and App (collectively, the “Service”).

Types of Information We Collect and its Uses

In the course of registering and using our Service through the Site or the App, we may ask you to provide us with, or grant access to, or permission to obtain, certain personally identifiable information. This refers to information about you that can be used to identify you or contact you (“Personal Information”). For example, Personal Information may include information such as your name, phone number, email address and mailing address.

You may register via the App, Site or by logging into your account with certain third party social media or social networking sites such as, but not limited to, Facebook and Twitter (“Third Party Account”). If you register through a Third Party Account we will extract/import the Personal Information from that Third Party Account (for example, full name and email address) and use that information to create your TWRL account. The information extracted/imported from the Third Party Account used will be dependent on the privacy settings you have with that Third Party Account. You consent to our access to and collection of such Personal Information.

We also collect other information that you provide as part of the registration and administration process and by personalization of your profile. For example, this may be information such as age, postal code and geo-location/tracker information (“Non-Identifying Information”). Some of this information is optional.

Certain Non-Identifying Information could be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your postal code with your street address), in a way that allows you to be identified. However, the same pieces of information are considered Non-Identifying Information when taken alone or combined only with other Non-Identifying Information (for example, your viewing preferences). We may use your Personal Information to provide you with a more enjoyable experience, improve the quality and value of our Service and to analyze and understand how our Site, App and Service are used. We may also use the combined information without aggregating it to serve you specifically (for example, to deliver a product to you according to your preferences or restrictions).

We also use your Personal Information to contact you with TWRL marketing and promotional materials and other information that may be of interest to you. This will be done in accordance with your permission and with applicable laws. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of these communications or update your user preferences information.

When you use or visit the Service, whether as a subscriber or a visitor just browsing, our servers automatically record information that your browser sends whenever you visit a website (the “Browser Data”). This Browser Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site or App, access times and dates and other statistical information. From users of our App, we also collect Browser Data such as what platform is being used, App version, mobile device model, access times and dates, time zones and network status. We use this information to monitor and analyze use of the Site and App and for the technical administration of the Site and App in order to enhance the functionality and user-experience of our Service. For example, some of the information is collected so that when you visit the Site or App again, it will recognize you and serve advertisements and other information appropriate to your interests. We also use this information to verify that visitors to the Site meet criteria required to execute their requests.

Use of Cookies

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard drive for record-keeping purposes. Persistent cookies are used to save your login information for future logins to the Service. Session ID cookies are used to enable certain features of our Service, to get a better understanding of how you interact with the Service and to monitor aggregate usage by TWRL users and web traffic routing on the Service. Unlike persistent cookies, session ID cookies are deleted from your computer when you log off from the Site, App or Service and then close your browser. By changing its options, you can instruct your browser to stop accepting cookies or to prompt you before accepting cookies from the website you visit. However, if you do not accept cookies, you may not be able to use all portions of the Site, the App or all functionality of the Service.

Information Sharing and Disclosure

TWRL Subscribers – When you register through our Site or App and submit your Personal Information to create a profile, TWRL users will see your screen name. You can choose what other Personal Information you provide as part of your profile and in some cases you can choose whether to share that information publicly on the Site or App by making selections via the user preferences settings of your account. We will display your Personal Information in your profile page and elsewhere on the Site according to the preferences you set in your account. Because of this, we suggest you guard your anonymity and any sensitive information and think about what information you choose to disclose in your profile pages. You can revise and review your profile information at any time.

Social Networking Sites – The Service gives you the option to share information contained in your account with certain social networking sites. We will not share your account information, which contains your Personal Information, with such sites unless you expressly authorize such sharing.

Aggregate Information and Non-Identifying Information – We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Browser Data with third parties for industry analytics, demographic profiling and other purposes. Any aggregated information shared in this context will not contain your Personal Information.

Service Providers – We may employ third party companies and individuals, in and/or outside of Canada and the US, to facilitate our Service, provide the Service on our behalf and to perform Site and App-related services like maintenance services, web analytics and database management for instance. These third parties have access to your Personal Information only to perform these services on our behalf and are obligated to maintain confidentiality of that information.

Other Third Parties – If you participate in a contest, giveaway or survey via our Service, we may share your email address or other contact information or Personal Information you provide in connection with your entry into such contest, giveaway or survey with any third party partnering with us for such purpose.

Compliance with the Law – TWRL cooperates with the government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your information in response to a legal request (like a court order for instance) if the law requires us to do so. This may include responding to legal requests from outside Canada or the US where we have a good faith belief that the response is required by the laws of that jurisdiction. We may also disclose information when we believe it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others including as part of investigations; and to prevent death or imminent bodily harm.

Business Transfer – We may sell, transfer or share part or all of our assets, including your Personal Information, with another organization in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Changing or Deleting your Personal Information

All subscribers of our Service may review, update, correct or delete the Personal Information provided to us either through our Site or the App. If you completely delete all such Personal Information then your account may become deactivated. If you would like us to delete your account in our system, please contact us at info@twrl.com with a request that we delete your Personal Information from our database. We may retain an archived copy of your records as required by law or for legitimate audit or business purposes.


TWRL takes the security of your information very seriously but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.

We will make any legally required disclosures of any breach of the security, confidentiality or integrity of your unencrypted electronically stored Personal Information to you via email or conspicuous posting on the Site or via the App in the most expedient time possible and without unreasonable delay taking into account the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Third-Party Sites and Services

Our Service may contain links to other websites. We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services. You use the third- party website or service at your own risk.

Children’s Privacy

We do not knowingly collect or solicit any information from children under 13 years of age. If you believe that we might have any personal information from or about a child under 13 years of age, please contact us at info@twrl.com.

Privacy Questions

If you have any questions about this Privacy Policy please contact us at info@twrl.com.