Privacy Policy & Data Protection Practices
Last updated: 2025-09-24
This Privacy Policy explains how Twilight Commercial Cleaning LLC ("Twilight Commercial Cleaning", "we", "our", or "us") collects, uses, discloses, and protects information in the course of operating our website and delivering commercial cleaning and related facility services within the United States.
1. Scope
This Policy applies to information collected through our website, embedded HubSpot forms, optional newsletter sign‑ups, career / application submissions, and limited operational systems (HubSpot, Jira, Jobber) used to manage customer relationships and project coordination. We do not target or provide services in the EU, UK, or California and do not knowingly collect data from children.
2. Company Identity & Contact
Legal Entity: Twilight Commercial Cleaning LLC
Mailing Address: PO Box 10945, Fargo, ND 58106
Privacy Contact Email: gninaelc.thgiliwt@ofni
Data Protection Officer: Not appointed; inquiries handled by general contact.
3. Information We Collect
The categories of information we may collect include:
- Identity & Contact: Name, company, email, phone, mobile phone.
- Professional & Application: Resume content, employment history (careers form submissions).
- Communications: Message body, inquiry details, support/project notes.
- Technical / Usage: IP address, referrer, region, user agent, page interactions, aggregated analytics (Google Analytics, Netlify Analytics), Facebook Pixel events.
- System & Error Logs: Diagnostic error traces, request metadata.
- CRM Enrichment: Records manually added to HubSpot (e.g., business leads).
- Payment / Service Operations: Limited customer identity and service history data in Jobber (invoice / scheduling context). We do not process full payment card data on our site; that is handled via third-party systems.
Not Collected Intentionally
We do not intentionally collect sensitive categories (e.g., government IDs, health data) nor children’s personal information.
4. How We Collect Information
- Direct Submission: Contact / quote / support forms, newsletter sign‑ups, careers submissions, optional chat/bot interactions (when present).
- Automated Means: Analytics scripts, cookies (see Cookie Policy), server & application logs, Facebook Pixel.
- Manual Entry: Lead information added directly into HubSpot by our team.
5. Purposes of Use
- Responding to inquiries and providing proposals or quotes.
- Delivering and coordinating services and related project activities (Jira for internal task tracking).
- Customer relationship management and follow‑up (HubSpot CRM).
- Marketing communications (with consent where required) and remarketing (Facebook Pixel).
- Website performance measurement, usage analytics, and service optimization.
- Security, fraud prevention, diagnostics, and legal compliance.
- Recruiting and evaluating job applicants.
6. Legal Bases (Informational)
We operate solely within the United States and do not target EU/UK data subjects. If international data were incidentally received, typical legal bases (for informational transparency) would align with: (a) performance of a contract or pre‑contractual steps (quotes), (b) legitimate interests (analytics, security, basic B2B outreach), (c) consent (newsletter sign‑ups / non-essential cookies), and (d) legal obligations (record keeping). This section is provided for clarity only.
7. Cookies & Tracking Technologies
We use necessary cookies for site functionality and performance / analytics cookies (Google Analytics, Netlify Analytics) plus Facebook Pixel for remarketing. Users may opt out of non-essential categories via our cookie banner or by adjusting browser settings. For more detail, see our Cookie Policy.
You may also use industry opt‑out resources such as: Google Analytics Opt-Out and Facebook Ad Preferences.
8. Data Retention
- Form & CRM Records: Retained for the active business relationship plus 24 months, unless earlier deletion is requested.
- Applicant Data: Up to 24 months after position closure unless legal requirements dictate longer or deletion is requested.
- Server / System Logs: Typically retained up to 90 days for security and diagnostics.
- Analytics Data: Google Analytics retained per GA4 standard (currently 14 months) unless adjusted; aggregated Netlify Analytics per provider defaults.
- Jira Project Data: Maintained for life of active project + 12 months for reference and quality assurance, then archived or deleted.
- Jobber Operational Records: Retained as needed for service history, invoicing, or legal accounting requirements.
We may retain minimal suppression records to honor unsubscribe or deletion requests.
9. Third-Party Service Providers
- HubSpot: Forms, CRM, marketing automation, tracking cookies.
- Jira: Internal project coordination (limited customer identifiers).
- Google Analytics (GA4): Site usage analytics (aggregated reporting).
- Facebook (Meta) Pixel: Remarketing and ad performance measurement.
- Netlify: Hosting, deployment, edge delivery, basic analytics.
- Cloudinary: Media asset optimization and delivery (no intentional personal data).
- Jobber: Service scheduling, invoicing, limited customer account data.
- Email Delivery (HubSpot): Transactional / marketing email sending.
We do not sell personal information. Disclosures occur only to operate services, comply with law, or protect rights and security.
10. Data Sharing & Disclosures
We share information with the providers above strictly for operational purposes. We may disclose information if required by valid legal request (e.g., subpoena, court order) or to protect our legal rights or the safety of others.
11. Cross-Border Considerations
We operate in and serve customers within the United States. International transfer frameworks (e.g., SCCs) are typically not implicated given our service geography.
12. Security Measures
We employ reasonable administrative, technical, and organizational safeguards including enforced HTTPS/TLS, role‑based access, least‑privilege principles for CRM and project tools, regular patching, vendor due diligence, and encryption in transit. No system is completely secure; we encourage users not to transmit unnecessary sensitive data via open text fields.
13. Your Choices & Requests
- Access / Deletion / Update: Email gninaelc.thgiliwt@ofni.
- Marketing Opt-Out: Use the unsubscribe link in marketing emails or email us.
- Cookie Preferences: Adjust settings via the site cookie banner or browser controls.
- Analytics / Remarketing: Use published opt-out tools (Google Analytics Opt-Out, Facebook Ad Preferences).
We will respond to verified requests within a reasonable timeframe (generally within 30 days).
14. Children’s Privacy
We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us to request deletion.
15. Automated Decision-Making
We do not engage in automated decision-making or profiling that produces legal or similarly significant effects. Basic marketing automation (e.g., follow‑up sequences) may occur within HubSpot.
16. Changes to This Policy
We may update this Policy periodically. The “Last updated” date reflects the most recent revision. Material changes may be highlighted on the site. Continued use after changes indicates acceptance.
17. Data Breach Notification
In the unlikely event of a data incident impacting personal information, we will investigate promptly and notify affected parties and/or authorities when legally required.
18. Contact
Questions or requests: gninaelc.thgiliwt@ofni
This Policy is provided for transparency and does not create contractual rights. For specific contractual commitments, refer to executed service agreements.