California Privacy Notice (CCPA/CPRA)

Last Updated: October 29, 2025

This California Privacy Notice (“California Notice”) supplements the TWOR Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). TWOR (“TWOR,” “we,” “us,” or “our”) provides this California Notice to comply with California privacy laws, including the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). Any capitalized term used but not defined here has the meaning given in the CCPA/CPRA or our Privacy Policy. The terms of our Privacy Policy (as applicable) are incorporated by reference.

You can view our general Privacy Policy on tworofficial.com/pages/privacy.

Notice of Collection and Use of Personal Information

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). We may also collect data that does not identify you (e.g., aggregate or de-identified data). If such data is stored with or linked to Personal Information, we treat it as Personal Information; otherwise, it is not subject to this California Notice.

Categories of Personal Information Collected (past 12 months)

• Identifiers (e.g., real name, account name, email address, online identifier, IP address, mobile advertising IDs).
  
• Customer Records (Cal. Civ. Code § 1798.80(e)) (e.g., name, mailing address, phone number).
  
• Commercial Information (e.g., products purchased or considered, purchase histories or tendencies).
  
• Internet/Network Activity (e.g., pages visited; referral/exit sites; actions within the Services; content or ads viewed, forwarded, and/or clicked; Wi-Fi connections; timestamps; logs; diagnostics/crash/performance reports).
  
• Audio/Electronic/Visual (e.g., customer service voicemails or recordings).
  
• Inferences drawn from the above (e.g., preferences, characteristics, shopping behavior).
  
• Sensitive Personal Information — Precise Geolocation (only with your prior consent, where applicable).
  

We will not collect additional categories beyond those listed above without providing a new notice at or before collection.

Sensitive Personal Information (Precise Geolocation)

With your prior consent (for example, via your device/browser/app settings), we may collect precise geolocation. We may use this information:

• As directed by you or to perform Services you request;
  
• With your consent;
  
• To protect legal interests and ensure physical safety; or
  
• To comply with applicable law.
  

We do not sell or share Sensitive Personal Information for cross-context behavioral advertising or for third parties’ own purposes. You may disable sharing of precise location at any time via your device settings.

Purposes for Collecting/Using Personal Information

We collect and process Personal Information for:

• Providing and operating Services (e.g., account creation/maintenance, customer service, order processing/fulfillment, payment processing, verifying customer details).
  
• Communications and support (e.g., responding to requests, product information, service features tied to your submissions).
  
• Marketing (e.g., promotions, special offers, contests, newsletters—according to your preferences and applicable law).
  
• Internal business purposes (e.g., optimizing our Services and campaigns, analytics/statistics, planning, administration, research, security).
  
• Personalization (e.g., improving/customizing content, offerings, or advertisements you see).
  
• Security and fraud prevention (e.g., detecting, investigating, and protecting against malicious, deceptive, fraudulent, or illegal activity).
  
• Debugging (e.g., identifying and repairing errors).
  
• Legal compliance (e.g., complying with laws, law-enforcement requests).
  
• Protection of rights (e.g., protecting the rights, property, and safety of users, TWOR, and others).
  

We will not use Personal Information for materially different, unrelated, or incompatible purposes without notice.

Disclosures for Business Purposes (past 12 months)

Consistent with the purposes above, we may disclose the following categories of Personal Information for business purposes to:

• Identifiers
  
• Commercial Information
  
• Audio/Electronic/Visual
  
• Internet/Network Activity
  
• Inferences
  

Categories of third parties may include:

• Affiliates/related entities
  
• Service providers/contractors (e.g., payment processors, data analytics and advertising partners, fraud prevention, cloud/hosting, IT, delivery partners, marketing and customer support)
  
• Law enforcement or government authorities (as required or permitted by law)
  

We may also disclose Personal Information to comply with legal process; to establish/exercise legal rights; to defend against legal claims; to investigate or take action regarding suspected illegal activities; to enforce our Terms; or in connection with corporate transactions (e.g., merger, sale, or bankruptcy).

Sources of Personal Information

• Directly from you (e.g., account creation, communications, newsletter/SMS opt-ins, waitlists, promotions, orders, reviews, surveys, customer service).
  
• Service providers/contractors (functionality supporting content delivery, email/hosting, software development, data management, ordering/payments, forms/polls, customer service/returns/live chat, marketing, fraud prevention, reviews/promotions).
  
• Operating systems and platforms (e.g., IP address, device identifiers, browser/OS type, device/browser settings).
  
• Data analytics providers (e.g., logs, cookies, pixels, and similar technologies measuring usage, referrers, actions, Wi-Fi connections, timestamps, diagnostics/crash/performance).
  
• Advertising networks (e.g., to serve ads across the Internet using cookies/pixels and similar technologies).
  
• Social networks (e.g., if you connect via a social account, we may receive your name, handle, email).
  

Sale or Sharing of Personal Information (Cross-Context Behavioral Advertising)

TWOR does not sell Personal Information in the traditional sense (for money). However, we may “sell” or “share” (as defined by the CCPA/CPRA) certain Personal Information with third parties for cross-context behavioral advertising (e.g., targeted ads/remarketing). In the preceding 12 months, we may have sold or shared:

• Identifiers and Internet/Network Activity with analytics, marketing, advertising, and remarketing partners for analytical and targeted advertising purposes (including displaying ads for our products on other sites).
  

Your right to opt out:

You may opt out of the sale or sharing of your Personal Information:

• By using the “Data Sharing Opt Out” link here: https://tworofficial.com/pages/data-sharing-opt-out
  
• By enabling a browser Opt-Out Preference Signal such as Global Privacy Control (GPC). Learn more at globalprivacycontrol.org. (You’ll need to enable the signal per browser/extension.)
  

We do not knowingly sell or share the Personal Information of minors under 16 without affirmative authorization.

Do Not Track / Opt-Out Preference Signals

We participate in analytics and advertising that process Personal Information about your online activities over time and across third-party websites. Where required by applicable law, we process/browser Opt-Out Preference Signals (e.g., GPC). You can also consult our Privacy Policy for instructions on managing cookies/trackers and opting out of online behavioral advertising.

Retention of Personal Information

We retain Personal Information no longer than necessary for the purposes for which it was collected, consistent with:

1. the length of our relationship and Services provided;
   
2. applicable legal obligations; and
   
3. considerations such as statutes of limitations, litigation, or regulatory investigations.
   

Your California Privacy Rights

• Right to Know/Access (last 12 months): categories of Personal Information collected; sources; business/commercial purposes; categories of third parties; and specific pieces of Personal Information.
  
• Right to Correct inaccurate Personal Information (we will use commercially reasonable efforts to correct it).
  
• Right to Data Portability (receive a copy in a portable, readily usable format, to the extent technically feasible).
  
• Right to Delete Personal Information we collected from you (subject to legal exceptions).
  
• Right to Opt-In to Financial Incentives and Right to Opt-Out at any time (see Notice of Financial Incentives below).
  
• Right to Opt-Out/In of Sale or Sharing of Personal Information (see the Do Not Sell or Share link and GPC).
  
• Right to Non-Discrimination for exercising your rights (we will not discriminate against you for doing so).
  

We do not use Personal Information to profile you in furtherance of decisions producing legal or similarly significant effects, as defined by law. You may also submit a complaint to the California Privacy Protection Agency at https://cppa.ca.gov/webapplications/complaint.

Submitting a Verified Consumer Request

To exercise your rights, submit a verifiable consumer request with enough detail to allow us to reasonably verify your identity (and, if applicable, your authority as an agent) and to understand your request:

• Email: help@tworofficial.com
  
• Web Form: Use any “Data Request” or Privacy form provided on tworofficial.com (if available).
  

We may request additional information to verify your identity (e.g., at least two data points such as name and email). We may deny a request we cannot verify or that appears fraudulent.

Authorized Agents

If an authorized agent makes a request for you, we may require:

• Proof of authorization (e.g., California Secretary of State paperwork, written permission, or power of attorney);
  
• Information to verify the agent’s identity; and
  
• Information to verify your identity (as above).
  

Our Response Timing and Format

• We will acknowledge receipt within 10 business days.
  
• We will respond within 45 days. If we need more time (up to 90 days), we will inform you of the reason and extension in writing.
  
• We will deliver responses electronically (or by mail upon request).
  
• Disclosures cover the 12-month period preceding receipt of your verifiable request.
  
• For data portability, we will provide information in a portable, and where technically feasible, readily usable format.
  
• We do not charge a fee unless a request is excessive, repetitive, or manifestly unfounded. If a fee applies, we will provide a cost estimate before proceeding.
  

Notice of Financial Incentives

From time to time, TWOR may offer financial incentives and/or price or service differences related to the collection and use of Personal Information (e.g., discounts, coupons, free shipping, expedited returns processing, VIP service) for joining our marketing lists or a loyalty program.

• Categories of Personal Information involved may include Identifiers (e.g., name, email) and Commercial Information (e.g., purchase history).
  
• Opt-In/Opt-Out: Participation is voluntary. You can opt in by following the sign-up instructions and may opt out at any time by emailing help@tworofficial.com(or via any mechanism provided in program terms).
  
• Value of Incentive: The value of your Personal Information is reasonably related to the value of the offer or discount presented (e.g., estimated by the expense related to the program, anticipated revenue, or the value of insights generated).
  
• Additional terms may apply and will be presented at sign-up where relevant.
  

Modifications and Updates

This California Notice replaces prior disclosures about our information practices for California residents. We may modify or update this California Notice at any time. Changes are effective upon posting. If we make material changes, we will provide reasonable notice (e.g., posting on the Services or emailing you). Your continued use of the Services after posting constitutes acknowledgment of the updated California Notice.

Additional Information and Assistance

If you have questions or concerns about this California Notice and/or how we process Personal Information, please contact:

TWOR — Attn: Privacy

Email: help@tworofficial.com

We are happy to assist California consumers in exercising their privacy rights.