Privacy Policy

TWOLAMARKETING LLC ("TWOLAMARKETING", "we", "us" or "our") is a limited liability company organised under the laws of the State of Wyoming, United States, with its registered address at 30 N Gould St, Ste R, Sheridan, WY 82801, USA. We provide digital marketing services to businesses located primarily in the United States and Canada.

This Privacy Policy explains what personal information we collect through twolamarketing.com, how we use it, who we share it with, and the rights you have over it. It applies to our website and to the marketing services we provide to our clients.

For the purposes of applicable data protection law, TWOLAMARKETING acts as a controller of the personal information described in this policy. Where we manage advertising accounts on behalf of a client, we generally act as a processor on that client's instructions.

Information you give us

• Contact details — name, business name, email address, telephone number and postal address.
• Business information — website URL, industry, years trading, number of locations, service area, competitors and marketing goals.
• Application details — your selected plan, current and planned advertising budgets, platforms you advertise on, and your description of your ideal customer.
• Correspondence — the content of messages you send us through our forms, by email, by telephone or via WhatsApp.
• Electronic signature — where you complete our plan application, the full name you type as your signature, together with the date and time of submission.

Information collected automatically

• Device and usage data — IP address, browser type and version, operating system, referring URL, pages viewed and time spent on them.
• Cookies and similar technologies — as described in our Cookie Policy.
• Advertising identifiers — where you interact with our ads on Meta or Google platforms.

Information we do not collect

We do not collect or store payment card details. All payments are processed by Stripe, Inc., and card information is submitted directly to Stripe. We do not knowingly collect personal information from anyone under 16 years of age.

• To respond to your enquiries and provide the free marketing audit you request.
• To review plan applications and decide whether to offer our services to you.
• To provide, manage and improve the marketing services you have engaged us for.
• To send you a secure Stripe payment link and administer your subscription.
• To send you marketing emails where you have given consent, which you may withdraw at any time.
• To measure the performance of our own advertising and improve our website.
• To comply with our legal, tax and accounting obligations, and to establish or defend legal claims.

Our lawful bases for processing, where applicable, are: performance of a contract with you; our legitimate interests in operating and marketing our business; your consent (which you can withdraw at any time); and compliance with legal obligations.

Meta Pixel

We use the Meta Pixel and, where configured, the Meta Conversions API on our website. These tools allow us to measure the effectiveness of our advertising on Facebook and Instagram and to show relevant ads to people who have visited our site. Data collected may include your IP address, browser information and the actions you take on our website. Meta Platforms, Inc. acts as an independent controller or joint controller in respect of some of this processing. See Meta's own privacy policy for further information.

Google Analytics and Google Ads

We use Google Analytics 4 to understand how visitors use our website, and Google Ads conversion tracking to measure the performance of our search advertising. These services set cookies and may process your IP address in truncated form. You can opt out of Google Analytics using Google's browser add-on.

Your control

Analytics and advertising technologies are only activated after you provide consent through our cookie banner. You can change your choice at any time by clearing your browser storage for this site, which will cause the banner to reappear.

We do not sell your personal information. We share it only with the following categories of recipient:

We may also disclose your information where required by law, court order or governmental authority, or in connection with a merger, acquisition or sale of assets, in which case we will notify you before your information becomes subject to a different privacy policy.

We are based in the United States and our service providers are located primarily in the United States. If you access our website from Canada, the European Economic Area, the United Kingdom or elsewhere, your personal information will be transferred to and processed in the United States, which may not offer the same level of data protection as your home jurisdiction.

Where we transfer personal information from the EEA or UK, we rely on appropriate safeguards including the European Commission's Standard Contractual Clauses. You may request a copy of the relevant safeguards by contacting us.

• Enquiries and audit requests that do not become clients — 24 months from last contact.
• Client records including applications and signed agreements — 7 years after the engagement ends, to satisfy tax and legal requirements.
• Marketing consent records — for as long as you remain subscribed, plus 3 years after unsubscribing, to evidence consent.
• Website analytics data — up to 14 months, in line with our analytics configuration.

Where we no longer need your information, we delete it or irreversibly anonymise it.

We use encryption in transit (TLS) across our website and form submissions, restrict access to personal information to those who need it, and rely on reputable service providers with their own security programmes. Rate limiting and anti-spam controls protect our forms from abuse.

No method of transmission or storage is completely secure. While we take reasonable steps to protect your information, we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and any relevant regulator as required by law.

Subject to your jurisdiction, you may have the right to access, correct, delete, restrict or object to our processing of your personal information, to withdraw consent, and to receive a copy of your information in a portable format. To exercise any right, email us at contact@twolamarketing.com. We will respond within the time limit required by applicable law and may need to verify your identity first. You will not be charged for making a request, and we will not treat you differently for exercising your rights.

California residents (CCPA / CPRA)

If you are a California resident, you have the right to know what categories of personal information we collect, the purposes for which it is used, and the categories of third parties with whom it is shared; to request deletion or correction of your personal information; to opt out of the sale or sharing of personal information; and to limit the use of sensitive personal information.

We do not sell personal information for money. However, the use of advertising cookies may be considered "sharing" for cross-context behavioural advertising under California law. You may opt out by selecting "Essential only" in our cookie banner or by enabling a Global Privacy Control signal in your browser, which we honour. You may also designate an authorised agent to make a request on your behalf.

Canadian residents (PIPEDA)

If you are located in Canada, we handle your personal information in accordance with the Personal Information Protection and Electronic Documents Act. You have the right to access the personal information we hold about you, to challenge its accuracy and completeness, and to withdraw consent subject to legal and contractual restrictions.

Our commercial electronic messages comply with Canada's Anti-Spam Legislation (CASL). We send marketing email only with your express consent or where we have implied consent from an existing business relationship, we identify ourselves clearly in every message, and every message contains a functioning unsubscribe mechanism that we action within 10 business days. If you are dissatisfied with our response to a privacy concern, you may complain to the Office of the Privacy Commissioner of Canada.

European Economic Area and United Kingdom (GDPR)

If you are located in the EEA or the UK, you have the rights of access, rectification, erasure, restriction of processing, data portability, and objection to processing carried out on the basis of legitimate interests or for direct marketing. Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. You also have the right to lodge a complaint with your local supervisory authority.

Our website contains links to third-party websites and services, including social media platforms and scheduling tools. We are not responsible for the privacy practices of those third parties, and we encourage you to read their privacy policies before providing them with personal information.

We may update this Privacy Policy from time to time to reflect changes in our practices or in the law. When we do, we will revise the "last updated" date at the top of this page. Where changes are material, we will provide a more prominent notice, which may include emailing you. We encourage you to review this page periodically.