Privacy & Security

TWINB2B.COM

PRIVACY POLICY

Twin Liquors, LP

Effective Date: August 16, 2026

 

1. Overview 

Twin Liquors, LP ("Twin Liquors," "we," "us," or "our") operates TwinB2B.com (the "Portal"), a proprietary wholesale ordering platform made available exclusively to TABC licensed on-premise businesses operating within Twin Liquors' service territory in the State of Texas. 

This Business-to-Business Privacy Policy (“Privacy Policy”) describes how Twin Liquors collects, uses, stores, discloses, shares, and protects information obtained by Twin Liquors through the Portal. It applies to all Account Holders, authorized users, and individuals who access or interact with TwinB2B.com in any capacity. 

By accessing the Portal or creating an account, you acknowledge that you have read and understood this Privacy Policy and consent to the practices described herein on behalf of yourself and the business entity you represent. If you do not agree, do not use the Portal. 

This Privacy Policy is incorporated by reference into the TwinB2B.com Terms and Conditions. Capitalized terms not defined here have the meanings ascribed to them in the Terms and Conditions. The terms “include,” “including,” “includes” and similar terms mean “including, but not limited to.”

 

2. Texas Privacy Law 

TwinB2B.com is a business-to-business platform serving licensed commercial entities, not individual consumers. For Twin Liquors consumer privacy practices, refer to the Twin Liquors Consumer Privacy Policy found at twinliquors.com. 

The Texas Data Privacy and Security Act (TDPSA) governs the processing of personal data of Texas residents. The TDPSA's definition of "consumer" generally excludes individuals acting in a commercial or employment context - meaning most business contact information (e.g., the name, work email, job title, and business phone number of a business customer's employee acting on behalf of that business) falls outside the TDPSA's core consumer-rights framework. Notwithstanding that exclusion, other Texas and federal laws apply and Twin Liquors adheres to those requirements.

3. Information We Collect 

3.1 Business Account Information 

When registering for or maintaining a Portal account, Twin Liquors collects information about the Account Holder's business, including: 

  • Legal business name and any trade name (DBA) 

  • Physical address of licensed premises as registered with the Texas Alcoholic Beverage Commission (TABC) 

  • TABC license or permit number and permit type 

  • Federal Employer Identification Number (EIN) or other business tax identification, where required 

  • Business phone number and primary contact information 

  • Billing and remittance address 

  • Bank account or payment information where ACH or electronic payment methods are used 

 3.2 Authorized User Information 

Twin Liquors collects the following personal information about individuals authorized to access the Portal on behalf of an Account Holder: 

  • Full name 

  • Business email address 

  • Business phone number 

  • Job title or role 

  • Login credentials (passwords are stored in hashed form and are not accessible to Twin Liquors personnel) 

3.3 Order and Transaction Data 

Each time an order is placed through the Portal, Twin Liquors records: 

  • Products ordered, quantities, and SKUs 

  • Order date, time, and confirmation number 

  • Requested delivery date and delivery address 

  • Invoice amounts, payment terms, and payment history 

  • Order modifications, cancellations, and associated communications 

  • Delivery confirmation and receipt acknowledgments 

 3.4 Usage and Technical Data 

Twin Liquors automatically collects certain technical data when you access the Portal, including: 

  • IP address and device identifiers 

  • Browser type and version 

  • Operating system 

  • Pages visited within the Portal and time spent on each page 

  • Referring URLs and navigation paths 

  • Session timestamps and login/logout activity 

  • Errors, crashes, and performance metrics 

This data is collected using standard web server logs, cookies, and similar tracking technologies. See Section 8 for details on cookies. 

 3.5 Communications Data 

Twin Liquors retains records of communications between Account Holders and Twin Liquors personnel, including emails, messages sent through the Portal, and notes from sales representative interactions. These records are used for account management, dispute resolution, and service improvement. 

 3.6 Information We Do Not Collect 

TwinB2B.com is a business-to-business wholesale platform. Twin Liquors does not collect: 

  • Consumer personal information (the Portal is not accessible to the general public) 

  • Sensitive personal information such as Social Security numbers, driver's license numbers, or personal financial data of individuals 

  • Health information or biometric data 

  • Information from minors under the age of 21 

 

4. How We Use Information 

4.1 Portal Operations and Order Fulfillment 

The primary purpose for which Twin Liquors collects and uses information is to operate the Portal and fulfill wholesale orders. This includes: 

  • Verifying Account Holder eligibility and maintaining account records 

  • Processing, confirming, and fulfilling product orders 

  • Scheduling and executing deliveries to licensed premises 

  • Generating and collecting invoices 

  • Managing credits, returns, and shortage claims 

  • Communicating with Account Holders regarding order status, delivery scheduling, and account matters 

 4.2 Regulatory Compliance 

Twin Liquors uses Account Holder and transaction data as required to comply with applicable laws and regulations, including: 

  • Verifying and monitoring TABC license status of Account Holders 

  • Maintaining transaction records required by the Texas Alcoholic Beverage Code and TABC regulations 

  • Responding to TABC audits, investigations, or requests for records 

  • Reporting as required by applicable state law, including mandatory reporting of license violations or suspicious purchasing patterns 

  • Complying with applicable federal and state tax reporting obligations 

 4.3 Account Management and Customer Service 

Twin Liquors uses account and contact information to manage the business relationship with Account Holders, including onboarding new accounts, communicating policy updates, resolving disputes, processing payment issues, and responding to account inquiries. 

 

 

4.4 Business Analytics and Service Improvement 

Twin Liquors uses order and usage data to analyze purchasing trends, optimize product offerings and inventory, evaluate Portal performance and user experience, plan logistics and route optimization, and improve the overall wholesale service including developing new products. 

4.5 Sales and Marketing Communications 

Twin Liquors may use Account Holder contact information to communicate information about product promotions, new offerings, pricing updates, trade education events, and other business-relevant communications. These communications are directed to Account Holders in their capacity as wholesale customers and are distinct from consumer marketing. Account Holders may opt out of non-essential marketing communications at any time by contacting wholesale@twinliquors.com. See Section 9 for details on non-essential marketing and promotional communications.

4.6 Security and Fraud Prevention 

Usage and technical data are used to monitor unauthorized access, detect fraudulent or abusive activity, investigate security incidents, and protect the integrity of the Portal and Twin Liquors' business systems. 

 

5. How We Share Information  

5.1 Service Providers

Twin Liquors shares information with third-party service providers that support Portal operations and business functions, including: 

  • Cloud hosting, data storage, and cybersecurity providers 

  • Payment processors and banking institutions for invoice collection and ACH transactions 

  • Logistics and route management software providers 

  • Customer relationship management (CRM) platform providers 

  • Email and communications service providers 

  • IT support and managed services vendors 

All service providers are contractually required to use Account Holder information only on a confidential basis and in accordance with applicable law. Twin Liquors does not authorize service providers to use or disclose information for their own independent purposes. 

5.2 Supplier and Distributor Partners 

Twin Liquors may share aggregated, non-identifying purchasing data with supplier and brand partners for purposes of inventory planning, product allocation, and market analysis. Individual Account Holder identities and specific order details are not shared with supplier or distributor partners without the Account Holder's consent, except as required by law. 

5.3 Commercial Data Collection and Industry Analytics Disclosure

To optimize supply chains, manage inventory levels, and evaluate market competitiveness, Twin Liquors regularly tracks wholesale information including shipment volumes, product stock-keeping units (SKUs), order dates, and venue-level delivery data (collectively, "Commercial Operational Data"). You acknowledge and agree that Twin Liquors shares your compiled Commercial Operational Data with third-party market research firms, alcohol industry analytics platforms, and business intelligence aggregators, who in turn may further disclose such Commercial Operational Data to suppliers and distributors. This data sharing is conducted for the legitimate business purposes of measuring product depletions, assessing brand performance, and generating industry market share benchmarks. The Commercial Operational Data shared relates strictly to business-to-business transactions, and no personal data belonging to individual consumers, retail patrons, or private individuals (such as credit card details, guest receipts, or consumer identities) is collected, stored, or transmitted under this data sharing practice. Data is shared in a manner consistent with applicable commercial data regulations, including the TDPSA, which expressly excludes data processed in a commercial context.

Specific Commercial Operation Data shared include:

·       SKU or Product ID

·       Account Holder name and TABC Permit Number

·       Venue-level delivery data (i.e. name and physical address of licensed premises)

·       Products, brands and quantity purchased (including description of the product and size of the product)

·       Company the products are purchased from

·       Order dates

Individual retail consumer personal information (e.g. credit card receipts, patron names) is never included in these wholesale data feeds).

5.4 Regulatory and Law Enforcement Disclosure 

Twin Liquors will disclose Account Holder and transaction information to the TABC, other regulatory authorities, or law enforcement agencies: 

  • As required by the Alcoholic Beverage Code of Texas or TABC regulations 

  • In response to a valid subpoena, court order, or regulatory request 

  • When Twin Liquors believes in good faith that disclosure is necessary to prevent fraud, protect public safety, or comply with applicable law 

  • In connection with a TABC audit, investigation, or compliance review 

5.5 Business Transfers 

In the event of a merger, acquisition, sale of assets, or other corporate transaction involving Twin Liquors, Account Holder information may be transferred to the successor entity as part of the transaction. 

5.6 With Account Holder Consent 

Twin Liquors may share information in other circumstances with the Account Holder's prior written consent. 

 

6. Data Retention 

6.1 Retention Periods 

Twin Liquors retains Account Holder and transaction information for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with applicable legal and regulatory obligations. Specific retention guidelines include: 

  • Active account records: retained for the duration of the business relationship plus a minimum of seven (7) years following account closure, in accordance with Texas record-keeping requirements applicable to licensed alcoholic beverage distributors. 

  • Transaction and invoice records: retained for a minimum of four (4) years from the date of the transaction, as required by TABC regulations, and up to seven (7) years for tax and audit purposes. 

  • Payment and financial records: retained in accordance with applicable federal and state tax and financial regulations, generally seven (7) years. 

  • Usage and technical log data: retained for up to twenty-four (24) months for security and analytical purposes, then deleted or anonymized. 

  • Communications records: retained for a minimum of three (3) years from the date of the communication. 

6.2 Post-Termination Retention 

Following termination of a Portal account, Twin Liquors will retain records necessary for legal compliance, dispute resolution, and regulatory obligations. Records not required for these purposes will be deleted or anonymized within ninety (90) days of account closure, subject to applicable mandatory retention periods. 

 

7. Data Security 

7.1 Security Measures 

Twin Liquors implements reasonable and appropriate technical, administrative, and physical security measures to protect Account Holder information against unauthorized access, loss, alteration, or disclosure. These measures include: 

  • Encryption of data in transit using TLS/SSL protocols 

  • Encryption of sensitive data at rest, including payment information 

  • Role-based access controls limiting employee access to Account Holder data to those with a business need 

  • Multi-factor authentication requirements for Portal administrative access 

  • Regular security assessments and vulnerability monitoring 

  • Employee training on data handling and security practices 

 7.2 Password Security 

Account Holder passwords are stored using industry-standard hashing algorithms and are not accessible in plain text by Twin Liquors personnel. 

7.3 Breach Notification 

In the event of a security incident that results in unauthorized access to, disclosure, loss, or alteration of Account Holder information, Twin Liquors will notify affected Account Holders in accordance with applicable Texas and federal law, including the Texas Identity Theft Enforcement and Protection Act (Tex. Bus. & Com. Code, Chapter 521), where applicable. Notification will be provided without unreasonable delay. 

7.4 Limitation of Security Guarantee 

No data transmission over the internet or electronic storage system can be guaranteed to be completely secure. Twin Liquors cannot and does not warrant absolute security of Account Holder information and is not liable for unauthorized access, loss, alteration, or disclosure of Account Holder information. 

 

8. Cookies and Tracking Technologies 

8.1 Use of Cookies 

TwinB2B.com uses cookies and similar tracking technologies to support Portal functionality and collect usage data. Cookies are small text files placed on your device when you access the Portal. 

8.2 Types of Cookies Used 

Essential Cookies: Required for Portal functionality, including maintaining login sessions, preserving cart contents, and enabling navigation. 

Analytics Cookies: Used to collect aggregated data on how users navigate and interact with the Portal, including page views, session duration, and error rates. This data is used to improve Portal performance and user experience. 

Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and abusive behavior on the Portal. 

 8.3 Cookie Management 

Account Holders may manage cookie preferences through their browser settings. Disabling essential cookies will impair or prevent Portal access. Disabling analytics cookies will not prevent Portal functionality but will limit Twin Liquors' ability to monitor and improve the service. Security cookies cannot be disabled.

TwinB2B.com does not use third-party advertising cookies or behavioral tracking technologies for marketing purposes. The Portal is a business-to-business platform and does not serve sponsored advertising. 

 

 

9. Account Holder Rights and Choices 

9.1 Access and Correction 

Account Holders may request access to the business and account information Twin Liquors holds about them by contacting wholesale@twinliquors.com. Account Holders may also request correction of inaccurate or outdated information. Twin Liquors will respond to access and correction requests within thirty (30) days. 

9.2 Deletion Requests 

Account Holders may request deletion of their account and associated information by submitting a written request to wholesale@twinliquors.com. Twin Liquors will honor deletion requests to the extent permitted by applicable law. Information that Twin Liquors is required to retain for regulatory, tax, or legal compliance purposes will not be deleted until the applicable mandatory retention period has elapsed. 

9.3 Marketing Opt-Out 

Account Holders may opt out of receiving non-essential marketing and promotional communications from Twin Liquors at any time by contacting wholesale@twinliquors.com or following the unsubscribe instructions included in any marketing email. Opting out of marketing communications does not affect the receipt of transactional and account-related communications, which are necessary for Portal operation. 

9.4 Authorized User Requests 

Requests from authorized users to access or delete their personal information (name, email address, login history) associated with a Portal account should be submitted through the Account Holder. Twin Liquors may require verification of identity and authorization before processing any individual request. Further, any such access or deletion will be subject to applicable federal and state laws including with respect to legal compliance, dispute resolution, and regulatory obligations.

  

10. Third-Party Links and Integrations 

TwinB2B.com may contain links to third-party websites, platforms, applications or services (e.g., TABC license verification tools, supplier portals or social media platforms) that are not owned or controlled by Twin Liquors. This Privacy Policy does not apply to those third-party sites. Twin Liquors is not responsible for the privacy practices, content or security of any third-party site. Account Holders should review the privacy policies of any third-party service you access through or in connection with the Portal. Inclusion of a link does not imply our endorsement or affiliation with the linked site or its operator.

 

11. Changes to This Privacy Policy 

Twin Liquors reserves the right to update or modify this Privacy Policy at any time. When material changes are made, Twin Liquors will notify Account Holders by posting the updated policy on TwinB2B.com and, where appropriate, by sending notice to the primary contact email address on file for each account. 

The Effective Date at the top of this document will be updated to reflect the date of the most recent revision. Continued use of the Portal following notice of any update constitutes acceptance of the revised Privacy Policy. 

Account Holders are encouraged to review this Privacy Policy periodically. 

 

12. Contact and Privacy Inquiries 

For questions, concerns, or requests related to this Privacy Policy or Twin Liquors' data practices, contact: 

Twin Liquors, LP 

Attn: Wholesale Operations / Privacy Inquiries 

Email: wholesale@twinliquors.com 

Mailing Address: 5639 Airport Blvd, Austin, TX 78751 

 

Twin Liquors will respond to written privacy inquiries within thirty (30) days of receipt. For urgent account security concerns, contact your Twin Liquors sales representative directly.