Privacy policy

Effective October 6, 2026

This policy explains what Twynela LLC, doing business as Twynela ("Twynela", "we", "us"), collects when you use twynela.com, buy from us, take the quiz, join The Next Turn or write to us; what we do with it; who sees it; and the choices you have. We wrote it to be read. If anything is unclear, email hello@twynela.com.

The short version

  • We collect what we need to take your order, ship it, answer you, and, if you say yes, send you email.
  • Card details go to our payment processors. We never see your full card number.
  • We do not sell your personal information for money. We do use advertising cookies and pixels, which some state laws treat as "selling" or "sharing". You can turn those off with one click: Your choices.
  • You can ask to see, correct or delete your data at any time, wherever you live. We honor the Global Privacy Control signal.

1. What we collect

What you give us. Your name, email address, shipping and billing addresses, phone number if you give one, what you order, what you say to us in messages and reviews, your quiz answers, and anything you submit to The Next Turn (scent memories, votes, name ideas, tester feedback). If you create an account, your login details.

What your device gives us. When you visit the site, we and our providers record your IP address, approximate location derived from it, browser and device type, the pages you view, how you got here, what you add to your cart, and cookie and pixel identifiers. This is standard for any online store; see Cookies and pixels.

What we get from others. Our payment processors tell us whether a payment succeeded and give us the last four digits and card type for your records, never the full number. Carriers give us tracking events. Our email and advertising providers give us delivery and engagement data. Fraud-prevention services may give us a risk assessment of an order.

What we do not collect. We do not ask for and do not want government identification numbers, financial account numbers, precise geolocation, health information, or any data about children. If you report a reaction to a product, we keep only what the law requires us to record (see section 3).

2. How we use it

  • To take, process, ship and support your order, and to send you the order, shipping and delivery messages that go with it.
  • To answer your questions and resolve problems.
  • To show you quiz results and, if you choose, to remember them.
  • To run The Next Turn: count votes, publish submissions you agree to publish, and manage the tester circle.
  • To send marketing email if you signed up or bought from us. Every one has an unsubscribe link.
  • To understand how the site is used and improve it, using analytics.
  • To show you our ads on other sites and apps, and to measure whether they worked, if you have not opted out.
  • To prevent fraud, enforce our terms and protect the site.
  • To meet legal obligations, including tax records and cosmetic-safety recordkeeping.

We do not use your data to make decisions that have legal or similarly significant effects on you, and we do not sell it for money.

3. Product reactions

If you tell us a product caused a reaction, federal cosmetic law requires us to keep a record of the report, including your contact details and what happened, for at least three years, and to report serious adverse events to the US Food and Drug Administration. We use that information for no other purpose.

4. Cookies and pixels

The site uses three kinds:

  • Necessary. Cart, checkout, login, security and your cookie preferences. The store cannot work without them.
  • Analytics. Shopify's own analytics and Google Analytics, which tell us which pages are visited and where people drop off. We configure them not to store full IP addresses.
  • Advertising. Pixels from Meta (Facebook and Instagram), Google Ads, TikTok and Pinterest, which let us show ads to people who visited the site and measure the results. These share your activity on our site with those companies, who may combine it with what they know about you. This is the part some laws call "selling" or "sharing" personal information or "targeted advertising".

You control analytics and advertising cookies in the banner that appears on your first visit and at any time through the Cookie settings link in the footer. If your browser sends a Global Privacy Control signal, we treat it as an opt-out of advertising cookies and of the sale or sharing of your data without you needing to do anything else. We do not respond to older "Do Not Track" signals, which have no agreed meaning.

5. Who we share it with

  • Shopify Inc. hosts the store, processes orders and provides checkout, customer accounts, Shop Pay, email, analytics and fraud screening. Shopify processes your data under its own privacy policy and keeps data in the United States and other countries where it operates.
  • Payment processors: Shopify Payments (operated with Stripe), PayPal, and any other processor shown at checkout. They receive what they need to charge you and screen for fraud.
  • Carriers and shipping software: the United States Postal Service and the label provider we use, who receive your name, address and phone number to deliver your package.
  • Email, text and reviews providers, which send our messages and host product reviews on our behalf.
  • Analytics and advertising partners described in section 4.
  • Professional advisers such as our accountant, and authorities when the law requires it or to protect anyone's safety or rights.
  • A buyer of the business if Twynela is sold or merged, under the same promises in this policy.

Every provider is bound by contract to use your data only to provide its service to us. We do not give customer lists to other brands.

6. How long we keep it

Order records: seven years, for tax and consumer-protection law. Account data: until you delete the account or ask us to. Marketing data: until you unsubscribe, then only a record of the unsubscribe so we honor it. Quiz answers and Next Turn submissions: as long as the program runs or until you ask us to delete them, except published content you agreed to make public. Product reaction records: at least three years as the law requires. Analytics and advertising data: as set by those providers, typically 2 to 26 months.

7. Security

The store runs on Shopify's PCI DSS Level 1 certified infrastructure over encrypted connections, with access to customer data limited to the people who need it to fill orders and answer you. No system is perfectly secure. If we ever discover a breach that affects you, we will tell you and the authorities as Texas law and other applicable laws require.

8. Children

The site is for adults. We do not knowingly collect information from anyone under 13, and anyone under 18 should not place an order. If you believe a child has given us information, email hello@twynela.com and we will delete it.

9. Your choices

  • Marketing email: click unsubscribe in any message, or email us.
  • Text messages: reply STOP to any text.
  • Advertising and analytics cookies: use the Cookie settings link in the footer, the Do not sell or share my personal information link, or turn on Global Privacy Control in your browser.
  • Your account: log in to update your details, or ask us to delete the account.

10. Your rights under state privacy laws

Depending on where you live (including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia), you may have the right to know what personal information we hold about you, to get a copy of it, to correct it, to delete it, to opt out of targeted advertising and of any sale or sharing of it, to opt out of profiling, and not to be treated differently for exercising these rights. Several of these laws apply only to businesses above a size threshold that Twynela may not yet meet. We give these rights to everyone anyway.

To exercise a right, email hello@twynela.com with the subject "Privacy request", or use the request form linked in the footer. Tell us what you want and the email address you used with us. We will confirm your identity by matching the details to our records and, for deletion or access requests, by sending a verification email. We answer within 45 days and will tell you if we need more time. If we refuse a request, we will say why, and you can appeal by replying to our decision; we answer appeals within 45 days, and you may then contact your state attorney general. An authorized agent may make a request for you with your written permission, and we may ask you to confirm it directly.

California residents. In the last 12 months we have collected the categories of personal information listed in section 1 (identifiers, customer records, commercial information, internet activity, approximate geolocation from IP address, and inferences such as quiz results), from the sources listed there, for the purposes in section 2, and disclosed them for business purposes to the providers in section 5. We "sell" or "share" (as the California Privacy Rights Act defines those words) internet activity and identifiers with advertising partners through cookies and pixels; we do not knowingly sell or share the personal information of anyone under 16. We do not use or disclose sensitive personal information to infer characteristics. Financial incentive notice: when we offer a discount for joining our email list, the discount is given in exchange for your email address and consent to marketing. We value that information at roughly the discount amount, based on the cost of acquiring a customer by advertising. You can withdraw at any time by unsubscribing. Under California's "Shine the Light" law you may ask what personal information we have shared with third parties for their own direct marketing; we do not share it for that purpose.

Texas residents. We do not sell sensitive personal data, and we will not process it without your consent. NOTICE: We may sell your personal data in the limited sense that advertising cookies share it with advertising partners; you can opt out as described above.

11. Where your data lives

We serve customers in the United States and our providers store data primarily in the United States, with some processing in Canada and the European Union by Shopify and its subprocessors under appropriate safeguards.

12. Changes

If we change this policy in a way that matters, we will post the new version here with a new effective date and, for significant changes, email customers who have an account or a subscription.

13. Contact

Twynela LLC, doing business as Twynela
5900 Balcones Drive, Suite 100, Austin, TX 78731
hello@twynela.com