Twin Star International Privacy Policy

Last updated: December 28, 2023

This privacy policy applies to the Twin-Star International, Inc. (“TSI”, “we”, “our” or “us”) website, as well as mobile sites or apps (collectively, the “Sites”). The purpose of this policy is to fully inform you of how we handle your personal data. By visiting the Sites, you accept the policies set forth in this Privacy Policy and related Cookie Disclosure Policy, which is hereby incorporated.

Collection of Personal Information

Generally, you may browse the Sites without providing any personally identifiable information. However, we may ask you to provide personally identifiable information at various times and places on the Sites. In some cases, if you choose not to provide us with the requested information, you may not be able to access all of the Sites or participate in all their features.

We collect the following information from you:

  • Identifiers such as your name;
  • Contact information such as your email address(es), physical address(es), phone number(s);
  • Financial information such as your credit or debit card number or checking account number;
  • Product preferences and other interests; and
  • Location-based information such as your zip code.

We automatically collect Internet and other electronic network activity information from users to our Sites. This information includes any referral website, the type of web browser and operating system you are currently using, and your network location and IP address.

Subscription Information

  • Subscribers may edit registration information or cancel a subscription at any time. We reserve the right to contact any subscriber at any time regarding subscription renewals or other subscription-related problems or questions, as well as changes to our policies, forms, and agreements.
  • Use of Personal Information

We use your information to:

  • Process your registration on the Portal as a consumer, retailer, or sales representative
  • Provide you with a product or service that you have requested;
  • Process your product registration;
  • Respond to your questions, comments, or concerns;
  • Allow you to track your order(s);
  • Assist with retailer returns;
  • Identify your product and service preferences, so we can notify you of new or additional products, projects, Portal features, special events, services and promotions that may be of interest to you;
  • Notify you of product recalls or provide other information concerning products you have purchased;
  • Conduct surveys to measure your satisfaction with our service;
  • Enforce our rights arising from any contracts entered into between you and us;
  • Protect our rights or property or our safety, our members, or others;
  • Monitor and evaluate our Portal and identify where we should make changes or expand services;
  • Provide advertisers with aggregate – never individual – information about our subscriber base and usage patterns; and/or
  • Give our marketing and development staff information that is useful for developing new features and services that meet subscriber needs.

During registration for your customer account, we collect your personal information to finalize the order process and customize your personal experience.

We use your financial information to process payment for products or services you have requested directly or through our third-party service providers, as described in more detail below.

We use the automatically collected Internet and other electronic network activity information to improve our Site design and product assortments, provide customer service and offer special promotions.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing of Personal Information

We share your information with third-party service providers who help us process your requests. We also share your information with affiliated companies or other entities for the below-mentioned purposes. Affiliated companies refer to Z Capital Group, LLC, its subsidiaries, and affiliated entities, which offer products and services under various brand names. The Z Capital Group brands include Twin-Star Home, TK Classics, Grand Basket, Design Furnishings and Classic Accessories.

We share:

  • Your identifiers and contact information with third-party shipping carriers for purposes of shipping products to you that you ordered. We also share your identifiers, contact information, and financial information with payment service providers and banks who process credit and debit card payments on our behalf for products that you have ordered. We may use third-party service providers or other third-party organizations helping to support our mission that may collect, store, or process your personal information on our behalf, such as to complete your request.  For example, we may work with an outside company to: (a) manage a database of customer information; (b) assist us in distributing emails; (c) assist us with direct marketing and data collection; (d) provide us storage and analysis; (d) provide fraud prevention; and (e) provide other services designed to assist us in maximizing our business potential. We require that these outside companies agree to keep confidential all information we share with them and to use the information only to perform their obligations in our agreements with them.
  • Your identifiers and contact information or aggregate information with our affiliated companies for joint marketing and other purposes.
  • Your identifiers, contact information, and product preferences, and other interests with carefully selected third parties when we believe their products or services may be of interest to you.
  • Your identifiers, contact information, and financial information to comply with any court order legal process or respond to any governmental or regulatory request.
  • Aggregate or De-Identified information with third-party analytics providers to help us analyze visits and traffic to the Sites for purposes of identifying trends and advertisers.
  • Your identifiers, contact information, and financial information with a successor business in the event of a merger, transfer of assets, or other organizational restructuring. We may transfer or share a copy of personal information about you in the event that TSI or one of our properties, affiliates, or subsidiaries goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets. You will be notified via email or prominent notice on our Sites prior to a change of ownership or control of your personal information if your personal information will be used contrary to this policy. However, nothing in this Privacy Policy is intended to interfere with the ability of TSI to transfer all or part of its business and/or assets to an affiliate or independent third party at any time, for any purpose, without any limitation whatsoever. We specifically reserve the right to transfer or share a copy of personally identifiable information collected from our Sites to the buyer of that portion of its business relating to that information.

Pseudonymised, De-identified and Aggregated Data

TSI may process pseudonymized or de-identified data. Pseudonymized data is personal information that can no longer be attributed to a specific individual without the use of additional information. The additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to a specific individual. Pseudonymized data is subject to certain exemptions related to consumer privacy rights under certain state privacy laws.

De-identified data means the information cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual or a device linked to such an individual. To the extent we process de-identified data, we will only use the data in a de-identified manner and will not attempt to re-identify the data. To the extent we share the de-identified data with affiliated companies or other entities, such entities will be contractually obligated to comply with the same requirements. De-identified data is not considered personal information under most state data privacy laws.

TSI may develop, maintain, collect, use, or share aggregate data. Aggregate data means information related to a group or category of individuals from which individual identities have been removed. The aggregate data is not linked or reasonably linkable to any individual or household, including via a device. Aggregated data is not considered personal information under certain state privacy laws. However, if we re-combine or re-connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal information, which will be used in accordance with this Policy. 

Market Research

We may contract with a market-research firm to conduct occasional online surveys. When you are within the customer services website portal, you may see a pop-up window offering you the optional opportunity of participating in a survey. If you do not wish to participate, simply click the “No, Thank You” link and you will not see this window again. If you choose to participate, you will be prompted to answer a series of online questions. You will be prompted to enter your e-mail address for validation purposes but no other personal information (name, address, etc.) will be collected as part of the survey. In some cases, however, you may be offered a free gift for your participation. We will need your name and address, which will be used exclusively to fulfill your gift request.

Cookie Technology

TSI collaborates with advertising companies to place our advertising on publisher websites on the Internet. These advertising companies collect anonymous information about your visits to our Sites. This technology involves the use of third-party cookies, which allow them to develop personalized advertising so that it directly relates to offers that may be of interest to you. We may also use our own cookies to provide similar enhanced online marketing to you based on your interests and preferences.

We also employ cookie technology to help subscribers move faster through our Sites and streamline your experience. When you use one of our Sites, we pass several cookies to your computer. A cookie is a string of information sent by a website and stored on your hard drive or temporarily in your computer’s memory. This avoids the potentially time-consuming task of checking our registration database each time a page is requested. The cookie is deleted when a user chooses the log-out feature to terminate their session. We also employ cookie technology to store subscribers’ User Names and Passwords. Read our Cookie Disclosure Statement and view a cookie-by-cookie breakdown.

We use tools such as Google Analytics to help analyze how users use the Site. Google Analytics uses cookies to collect information such as how often users visit the Site, what pages they visit and what other sites they used prior to coming to the Site. We use this information to improve our Sites and services. You may prevent the use of Google Analytics on your browser by downloading and installing the Google Analytics opt-out browser add-on.

Third-Party Web Sites

We use third-party advertising companies to serve advertisements when you visit our Sites. These companies may use information (not including your name, address, email address, or telephone number) about your visits to our Sites and other websites to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

Our Sites may contain links to other websites provided by third parties. Please be aware that we do not control these third-party websites or any of the content contained on those websites. Once you have left our Sites, we cannot be responsible for the privacy practices of such other websites. We encourage you to exercise caution and to read the privacy policy for the websites you visit. Including hyperlinks to third-party websites on our Sites in no way constitutes an endorsement by us of such websites’ content, actions, or policies.  We do not make any representations or warranties about any website you may access through our Sites. They are independent from us, and we have no control over, or responsibility for, their information or activities.

Promotional Offers

  1. If you have opted in to receive certain emails from us but no longer wish to have your email address and contact information used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to us as part of a product purchase, warranty registration, product service experience, or other transactions.

Processing in the United States

We store and process your data in the United States. If you are located in a foreign jurisdiction, the privacy laws in the United States may be different from the privacy laws in your home jurisdiction and may not offer the same level of protection. If you do not want to transfer your data to the United States for processing, please do not use our services or purchase our products. 

Children

The Sites are not directed toward children under 18 years of age, nor do we knowingly collect information from children under 18. If you are under 18, please do not use the Sites or submit any personally identifiable information to us.

Security

Personal information provided on the website and online credit card transactions are transmitted through a secure server using Secure Socket Layering (SSL) encryption technology. When the letters “http” in the URL change to “https,” the “s” indicates you are in a secure area employing SSL. Also, your browser may give you a pop-up message that you are about to enter a secure area.

We are committed to handling your personal information with high standards of information security and maintaining your confidence and trust. However, no transmission or electronic information storage is guaranteed to be secure. We therefore urge you to always use caution when transmitting information over the Internet. We take appropriate physical, electronic, and administrative steps to maintain the security and accuracy of personally identifiable information we collect, including limiting the number of people who have physical access to our database servers and employing electronic security systems and password protections that guard against unauthorized access. Our website uses encryption technology, such as Secure Sockets Layer (SSL), to protect your personal information during data transport. SSL encrypts ordering information such as your name, address, and credit card number.

If you use a public computer, we strongly encourage you to LOG OUT after your session. Your information will still be stored with us, but it will not be accessible to anyone else from that computer.

We also take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes we process it unless we are required by law to keep it for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and/or services requested by or provided to you, mandatory retention periods provided by applicable law, and the statute of limitations.

Category of Personal InformationExamples of Personal Information Collected or Used
IdentifiersName, physical address, email address, phone number, online identifier, IP address
Internet or other electronic network activity informationAny referral website, the type of web browser and operating system you are currently using, and your network location and IP address.
Geolocation DataZip code Approximate geolocation
InferencesInferences drawn from any of the information identified here to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Sensitive Personal InformationFinancial information such as your credit or debit card number or checking account number
Business or Commercial Purpose(s) for Collection, Use or DisclosureCategories of Third Parties to Which Personal Information is Disclosed
To provide you with our products and services; for advertising and marketing services; for short-term transient use; and to communicate with you.Affiliated companies Service providers Banks and payment processors Other merchants Third-party advertisers Analytics providers
To provide you with our products and services; and to protect the safety, security, and integrity of our websites.Analytics providers
To provide you with our products and services; for advertising and marketing services; and to protect the safety, security, and integrity of our websites.Service providers Banks and payment processors Other merchants Analytics providers
To provide you with our products and services; and for marketing and advertising.Affiliated companies Third-party advertisers Analytics providers
To provide you with our products and services.Service providers Banks and payment processors

California Privacy Rights

If you are a California resident, you have the following rights.

Right to Know. You have the right to receive notice at or before the point of collection about our collection and retention practices.

In particular, our Sites have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

  • Publicly available information.
  • De-identified data, if certain conditions are met.
  • Aggregated consumer information.
  • Information excluded from the scope of the law, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Right of Access. You have the right to access your personal information maintained by us. Upon receipt of a verifiable request to access personal information, we will disclose and deliver the personal information requested free of charge. For example, you may request the following:

  • The categories of personal information we collected about you.
  • The categories of sources from which the personal information is collected.
  • Our business or commercial purpose for collecting, selling, or sharing that personal information.
  • The categories of third parties to whom we disclose that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Please note that we are not required to provide personal information to you more than twice in 12 months.

Right of Deletion. You have the right to request that we delete any personal information about you that we have collected from you. Upon receipt of a verifiable request for deletion, we will delete your personal information from our records and direct any service providers to delete your personal information from our records within 45 days.

We will comply with your request to delete personal information unless it is necessary for us to maintain your personal information in order to:

  • Complete a transaction, provide requested-for goods/services, and/or perform a contract between you and us;
  • Detect security incidents;
  • Comply with a legal obligation;
  • Enable our internal uses that are aligned with your expectations and your relationship with us and are compatible with the context in which you provided the information.

Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you. You can review and change your personal information by logging into the Site and visiting your account profile page.

Requests should be submitted to [email protected].

Only you, or someone legally authorized to act on your behalf, may make a request to access, delete, or correct related to your personal information. To use an authorized agent, you must (i) provide written instruction to your agent and verify your identity to us or (ii) provide a power of attorney.

After you submit a request, we will promptly take steps to determine whether your request is a verifiable request. We will verify that you are who you say you are by asking you to confirm certain unique pieces of information relating to your relationship and/or transactions with us. You may only submit a request to access twice within a 12-month period.

Your request to access, delete, or correct must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will confirm receipt of your request within ten (10) business days. We will comply your request free of charge within 45 days of receiving your verifiable request. If necessary, we will extend the time period to provide the required information once by an additional 45 days and will provide you with notice of the extension within the first 45-day period. The disclosure shall cover the 12-month period preceding our receipt of the verifiable request.

Making a verifiable consumer request does not required you to create an account with us. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide a cost estimate before completing your request.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Right to Opt-Out of Sale or Sharing. Certain data collection on our Sites by third parties for purposes of interest-based advertising and social media tools may be a “sale” or “sharing” under California privacy law. As defined by California law, we “sold” or “shared” certain data elements within the following categories of personal information: identifiers, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the information identified here. We “sold” or “shared” each category to or with affiliated companies, third parties, and service providers who provide advertising, marketing, or audience measurement; and with social networks at your direction. The business or commercial purposes of “selling” or “sharing” the information is to assist us with advertising, marketing, audience measurement, and other functionality on our Sites.  You may exercise your right to opt-out of the sale or sharing of personal information by selecting the Do Not Sell or Share My Personal Information link. In addition, we respond to and abide by opt-out preference signals sent by online tools, such as the Global Privacy Control.

Right to Limit Use or Disclosure of Sensitive Personal Information. To the extent we collect or process sensitive personal information, such processing is restricted to the following business purposes:

  • Perform services or provide goods that an average consumer requesting those goods or services would reasonably expect.
  • Help ensure security and integrity if that use is reasonably necessary and proportionate.
  • Perform short-term, transient uses, including but not limited to non-personalized advertising shown as part of a consumer’s current interaction with the business, if the business does not:
    • disclose the sensitive personal information to another third party; or
    • use it to build a profile about the consumer or otherwise alter the consumer’s experience outside their current interaction with the business.
  • Perform services for the business, including:
    • maintaining or servicing accounts;
    • providing customer service;
    • processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services for the business.
  • Verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by the business.
  • Improve, upgrade, or enhance the service or device owned, manufactured, manufactured for, or controlled by the business.

Children. As noted above, we do not knowingly collect information from or about children, including children aged 16 and under. We do not sell or share information of minors under 16 years of age.

No Discrimination. We will not discriminate against a California resident because the California resident exercised any of the rights described here. Specifically, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  • Discriminate in making employment decisions.

Financial Incentives. We may offer you certain financial incentives permitted by California law that can result in different prices, rates, or quality levels. Any legally permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time by emailing [email protected].

California Shine the Light

California’s “Shine The Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for their direct marketing purposes in the preceding calendar year.  If you are a California resident and would to request this information, please submit a written request to the following address: [email protected]. Please allow 30 days for a response.

Additional U.S. State Privacy Rights

Residents of other states may be entitled to certain privacy rights and protections under state law.

Specifically, U.S. residents may have the following privacy rights.

Right to Access. You have the right to know and see what personal information we have collected about you in a usable format.

Right to Delete. You have the right to request that we delete the personal information we have collected about you, subject to certain exceptions.

Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.

Right to Opt-Out of Targeted Advertising and Sale of Personal Information. You have the right to “opt-out” of “targeted advertising” and the “sale” of your personal information (as defined under applicable state law).

Requests to access, delete, or correct should be submitted to [email protected].

You may exercise your right to opt-out of targeted advertising by selecting the Do Not Sell or Share My Personal Information link. In addition, we respond to and abide by opt-out preference signals sent by online tools, such as the Global Privacy Control.

Only you, or someone legally authorized to act on your behalf, may make a request to access, delete, or correct related to your personal information. To use an authorized agent, you must (i) provide written instruction to your agent and verify your identity to us or (ii) provide a power of attorney.

After you submit a request, we will promptly take steps to determine whether your request is a verifiable request. We will verify that you are who you say you are by asking you to confirm certain unique pieces of information relating to your relationship and/or transactions with us.

You may have the right to appeal a decision we make regarding the exercise of your privacy rights. To appeal our decision regarding a request related to your privacy rights, please email [email protected].

Changes and Updates

We may revise this Privacy Policy from time to time. We will post any changes on this page and update the date at the top, so be sure to check back periodically to stay aware of any modifications. Your continued use of the Sites after changes have been posted will constitute your acceptance of this Privacy Policy and any changes.

Contact Us

If you have any questions, concerns, or suggestions regarding this Privacy Policy or to update any information you have provided us, please contact us at [email protected] or

Twin-Star International, Inc.

750 Park of Commerce Blvd

Suite 400

Boca Raton, FL 33487

Accessibility

We are committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone and applying the relevant accessibility standards.

If you have difficulty accessing any material on this site, please contact us, and we will work with you to make the information available.