Privacy Policy

Last Updated: March 2024

This Privacy Policy applies to the way in which Two Barrels LLC and our affiliates (“we” and “us”) might interact with you—from telephone calls to email exchanges to the use of twobarrels.com. In this Privacy Policy we go over the exact types of user and client data that we collect, what we do with it, and how we collect it. By using our website, you accept the terms of this Privacy Policy.

If you have any difficulty reading or using this Privacy Policy because of a disability, we’re happy to provide any assistance you may need. Simply reach out to us at help@twobarrels.com or 1-888-704-7214.

Our Privacy Policy

Except as explained in this Privacy Policy, we do not disclose personal information to any companies not part of Two Barrels LLC or its parent, subsidiaries or related entities. We may provide some personal information to certain service providers and other third parties, but in no event will we sell your personal information as part of a customer list or similar transaction for unrelated parties to independently market to you.

1. Children Under Thirteen Years

Our website is not intended for use by children under the age of 13 and we do not knowingly collect personal information from children under 13.

2. Governing Law

This site is intended for use in the United States of America. We attempt to protect the personal information of all users of our site and we attempt to comply with local data protection laws to the extent they apply to our services and website, but our site is targeted to United States citizens and our policies are directed at compliance with those laws.

3. The Different Ways We Collect Your Information

At Two Barrels LLC, it is sometimes important for us to collect user and client information. Below you will find a list of how (and from whom) we collect our clients’ and user’s information.

• From You: The majority of information that we collect will come directly from you. We may also collect information indirectly about you when you interact with our website, through the use of cookies and other tracking technologies as described below.
• From Related Entities: We may collect information about you from another party.
• From Service Providers: We may collect information about you from our service providers. Service providers are entities that we have contracted with to provide us with services to help fulfill our business needs.
• From Business Partners and Affiliates: We may collect information about you from our business partners and affiliates. For example, we may receive information that you are interested in a service that we offer.
• From Publicly Available Information: We may collect information related to you from publicly available sources of information, including government records.

4. The Different Ways We Use Your Information

We strive to personalize your user experience at twobarrels.com, and this involves collecting some information. We may also use this information in the following ways:

• To provide services to you: We may collect information to send you email or postal mail, perform tasks required to complete a purchase transaction, provide customer support, or provide other types of customer relationship management and fulfillment. We may also use your information to optimize or improve our services and operations, for example training and quality assurance.
• To fulfill legal and compliance obligations: We collect information in order to fulfill our legal obligations. We may also collect information for the purpose of detecting fraud or other suspicious activity.
• Analytics: We collect information for use in performing various types of analytics. For example, we use information to analyze how visitors interact with our website, where visitors to our website arrive from and exit to, pages visited, links clicked, text entered and mouse movements to understand site usage, to detect fraud and potential threats and improve our services.

5. What About Cookies & Similar Technologies?

In order to personalize your online experience, our website employs the use of “cookies.” A cookie is a text file that is placed on your device by a web server. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. If you register an account with us, a cookie allows us to recall your specific information on subsequent visits. This facilitates the process of recalling your personal information so that when you return to our website, the information you previously provided can be easily retrieved. Most web browsers automatically accept cookies, but you can typically modify your browser settings to decline cookies if you want to.

We also employ a technology called web beacons or “clear gifs” that help us track referrals from our partners and affiliates and better manage content on our website. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track online movements of web users.

Our partners and affiliates may use cookies and web beacons to collect information about your activities on our site. The use of tracing technologies by our service providers, technology providers or other third parties is not covered by our Privacy Policy.

6. How (and With Whom) We Share Your Information

Except as disclosed in this Privacy Policy, we do not disclose personal information to any companies not part of Two Barrels LLC or its parent, subsidiaries or related entities. Although, as discussed below, we may provide some personal information to certain service providers and other third parties, in no event will we sell your personal information as part of a customer list or similar transaction for unrelated parties to independently market to you.

• Service Providers: We may share personal information with agents, affiliates, partners or other third parties that perform functions on our behalf, such as analytics, credit card processing, etc. These entities have access to the personal information needed to perform their functions and are obligated to maintain the confidentiality and security of that personal information. Service providers are not authorized to use the information we share with them for any purpose other than providing services to us or to you.
• As Required by Law: We may disclose information as required by law, such as in response to a subpoena, a lawful request by a public authority, including to meet national security or law enforcement requirements, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.

7. Types of Information We Collect

We collect various categories of information. These may include:

• Internet Information: This category includes information such as your internet browser, browsing history on our website, search history on our website, information about the device you are using to access our website, and information regarding your interaction with our website or advertisements. We may also collect information about visitors to our website such as browser settings, operating systems, referring/exit pages and clickstream data.

8. How We Keep Your Information Secure

In general, personal information collected by the site is stored in operating environments that are not available to the public, and our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. In certain telephone and in person transactions, we may ask for certain client identifiers or other information to verify your identity before conducting the transactions you have requested.

Please understand that while we try our best to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. We periodically review our security procedures to consider appropriate technology and methods to secure information.

9. How Long We Retain Your Information

At a minimum, we will retain your information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may maintain some or all of this information in our archives even after it has been removed from the site.

10. Information for California, Texas, and European Residents

Your Data Protection Rights

The State of California passed the California Consumer Protection Act of 2018 (CCPA) followed by the California Privacy Rights Act of 2020 (CPRA).

The State of Texas passed the Texas Data Privacy and Security Act (TDPSA) in 2023.

The CCPA. CPRA and TDPSA grant consumers rights concerning digital privacy and personal data, including the right to review any personal information collected by businesses, opt out of personal data sales, and request that a business delete personal information. Additionally, consumers have the right to receive equal treatment and pricing when exercising these rights. Certain exemptions may apply which will decrease or eliminate our obligations under the CCPA, CPRA and TDPSA.

Likewise, the General Data Protection Regulation (“GDPR”) allows individual residents of the European Union (“EU”) to submit a verifiable request for us to provide them with certain information including: i) specific pieces and categories of personal information that we have collected about them; ii) the categories of sources for that information; iii) the legitimate interest for collecting their information; and iv) the categories of third parties with which their information is shared.

European residents also have the right to object to the collection or processing of their information or to submit a request for deletion of their information under certain circumstances. These rights, however, are not absolute, and we may decline to stop collection/processing or decline to delete information when retention is allowed by law, for example, when we have an on-going business relationship with the person, we have a continued need to use the information, or we need to retain the information in order to comply with a legal obligation.

We do not, and will not, sell or share your information to third-parties (as defined in the CPRA and TDPSA).

WE DO NOT share your personal information that is intended to or result in targeted advertising.

We already limit the use of any Sensitive Personal Information we gather from you to that which is necessary to perform the services and/or goods you hired us to perform but you have the right to request us to “Limit the use of Sensitive Personal Information.” Sensitive personal information includes: a social security number, account log in information, financial information, geo-location, racial or ethnic origin, religious beliefs, sexual orientation, health information, bio-metrics, and the contents of communications to us, unless we were the intended recipient of the communication. This is not an absolute right, and we may decline to limit the use of Sensitive Personal Information under a qualifying exemption.

You have the right to request copies of your personal data.

You have the right to request that any information you believe is incomplete or inaccurate to be corrected.

Non-Discrimination

If you exercise your rights under the California Consumer Privacy Act of 2018 (CCPA), California Privacy Rights Act of 2020 (CPRA), Texas Data Privacy and Security Act (TDPSA) or the General Data Protection Regulation (GDPR), we will not provide discriminatory treatment to you.

In Texas, you have the right to appeal our denial of a request. If we reject your appeal, you may contact the Attorney General at Consumer Protection | Office of the Attorney General.

If you would like to submit a request about your data, obtain additional information, or appeal our denial of a request, you may do so by emailing help@twobarrels.com or by calling our toll free number at 1-888-704-7214.

After you submit the request, you will be asked to verify your email address and you may also be asked to provide additional information in order to verify your identity. We will attempt to verify your identity by asking for information that matches the information that we have previously collected about you. Where this is not possible, we may request that you submit additional documentation for verification. Please note that, in accordance with the CCPA, CPRA and or TDPSA we will not be able to satisfy your request until we have verified your identity.

You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request, you must provide us with your written permission for the agent to make the request on your behalf, or provide us with a signed power of attorney. We will also need to verify valid government issued identification for both you and the agent.

11. Notice to Non U.S. Users

If you are located outside of the United States of America, you should be aware that your personal information will be transferred to the United States of America, the laws of which may differ from the laws of your country. If you are located in a country outside of the United States of America and voluntarily submit personal information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage or processing of that information in, the United States of America and you understand that your information may be available to government authorities under lawful orders and laws applicable there. By using this website, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

Individuals within the EU have a right to object to our information collection and processing, however it should be noted that the right to object is not absolute. In order to render Services to you and your business as your service provider, we have statutory obligations to maintain updated and accurate information about you and your business.

How to Contact Us

Our experienced, knowledgeable, and dedicated staff are here to answer any questions you might have regarding this Privacy Policy. Please contact us using one of the options listed below:

The Two Barrels Privacy Team
help@twobarrels.com
1-888-704-7214