Twofold (withtwofold.com)
This Privacy Policy explains how Haystack Group LLC ("Haystack," "we," "us," "our") collects, uses, shares, retains, and protects information about you when you use withtwofold.com and related services (the "Service").
The Service collects detailed psychometric and cognitive performance information. We use identifiable assessment information to operate the Service, provide results, support users, preserve assessment integrity, and improve the product. We do not sell or license your identifiable Assessment Data to third parties for their own commercial purposes. You have rights and choices that vary by jurisdiction; we describe them below.
To the maximum extent permitted by law, we may receive information about you from third parties (e.g., data providers, advertising partners, analytics providers, or public sources) and combine it with information we collect.
Assessment Data is sensitive in context because it can reveal intimate aspects of personality and cognitive performance. Depending on the questions asked and your responses, Assessment Data may also reveal or allow inferences about "special category" data (EEA/UK/Switzerland) or "sensitive personal information" (certain U.S. state laws).
We use information for the following purposes:
We do not sell or license identifiable Assessment Data, derived scores, or assessment inferences to third parties for their own independent commercial purposes. We share information only as described in Section 6, including with service providers, for user-directed sharing features, for legal/safety reasons, and in aggregated or de-identified form.
If you are in the EEA/UK/Switzerland, we rely on one or more of the following legal bases, as applicable:
to provide the Service you request (e.g., administering/scoring assessments; responding to requests)
security, fraud prevention, service improvement, integrity controls, internal analytics (balanced against your rights)
compliance with applicable laws and lawful requests
We disclose information to vendors who process data on our behalf for hosting, infrastructure, security, analytics, email delivery, and support under contractual restrictions.
We do not sell or license identifiable Assessment Data, derived outputs, or inferences to third parties for their own commercial use. We may share information with third parties in the limited categories below:
Assessment Data is shared in identifiable form only where needed to provide the Service, support a feature you requested, meet a legal or safety need, or complete a business transfer described below.
We may disclose information in connection with an actual or contemplated merger, acquisition, financing, reorganization, or sale of assets.
We may disclose information where required by law or necessary to protect rights, prevent fraud, or protect users and the public.
The Service provides access to individual results and, where you choose to share, comparison results through the user interface. Authorized Haystack personnel may access identifiable Assessment Data (including responses, outputs, and registration information) to operate the Service, provide support, and respond to requests. Access is restricted and governed by internal controls.
We use automated processing to score assessments, generate psychometric outputs, and create inferences and profiles. Where required by law, we will provide additional disclosures and rights relating to profiling and automated decision-making.
We may use cookies, SDKs, pixels, and similar technologies for:
Where required by law (including in the EU/EEA/UK), we request consent for non-essential cookies before they are placed.
We are based in the United States. Your information may be processed in the United States and other countries where we or our vendors and partners operate. Where required, we use appropriate safeguards for cross-border transfers (e.g., Standard Contractual Clauses and supplementary measures).
We retain personal information for as long as reasonably necessary for the purposes described in this Policy. Because our purposes include maintaining assessment records, supporting results access, validating psychometric methods, and improving the Service, retention may be long-term while those purposes continue, subject to legal requirements and periodic review.
We may irreversibly de-identify/anonymize or aggregate information. De-identified/anonymized or aggregated information may be retained indefinitely and used for any lawful purpose.
We may retain limited information as needed for security, fraud prevention, compliance, and to establish, exercise, or defend legal claims, including maintaining suppression lists to honor opt-outs/withdrawals.
Rights vary by location and law.
Subject to conditions and exceptions, you may have the right to:
You also have the right to lodge a complaint with your supervisory authority.
Effect of withdrawal: If you withdraw consent, we will stop the processing covered by that consent going forward, subject to legal exceptions. Withdrawal does not affect processing already performed.
Depending on your state of residence and applicable law, you may have rights to:
California "Do Not Sell or Share" / "Limit the Use of Sensitive Personal Information": If we engage in "sale" or "sharing" as defined by California law, we provide an opt-out method via a "Do Not Sell or Share My Personal Information" link (or a combined link) and honor applicable opt-out preference signals (such as Global Privacy Control) where required.
If we use or disclose "sensitive personal information" for purposes beyond those permitted without limitation, we provide a "Limit the Use of My Sensitive Personal Information" option (or a combined option).
Email [email protected] with subject "Privacy Rights Request." We may verify your identity before fulfilling requests, as permitted by law. Authorized agents may be required to provide proof of authorization.
If we offer a price or service difference in exchange for collection, retention, or sale/sharing of personal information, we will provide a Notice of Financial Incentive describing the material terms, how to opt in, and how to withdraw/opt out, as required by law. Participation is optional where required by law.
We use reasonable administrative, technical, and organizational safeguards designed to protect information. No method of transmission or storage is 100% secure.
The Service is intended for adults (18+). We do not knowingly collect personal information from anyone under 18.
We may update this Policy from time to time. The "Last Updated" date indicates the most recent revision. Material changes will be posted on the Service.
Haystack Group LLC
501 Union St Ste 545 PMB 60566
Nashville, TN