privacy policy
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data, including through your use of our site twistconsultants.co.uk.
By providing us with your data, you warrant to us that you are over 13 years of age.
Twist Consultants is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact Details
Our full details are:
Full name of legal entity: Twist Consultants (UK) Ltd
Email address: jo@twistconsultants.co.uk
Registered address: 1 Billing Road, Northampton, NN1 5AL
Telephone number: 07834 378070
Registered in the UK, number: 05952970
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at jo@twistconsultants.co.uk
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
Much of the personal data we process is provided to us directly by you for a range of reasons such as you have made an enquiry, you have made an information request, you want to or have attended an event, workshop, programme or consultancy or you subscribe to the Twist Consultants newsletter. You have provided us with your business card and are connected with us on social media channels such as LinkedIn whereby we may contact you to ask for your consent to future marketing such as to join our email newsletter list.
We process your personal data when it is necessary to comply with a legal obligation, to carry out a contract, for legitimate interests and where consent is given.
We may collect and process the following categories of personal data about you:
• Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us such as via our third-party parties, including the likes of EventBrite, Zoom, Google and Mailchimp. This data collected may include name, email address, address, phone number, business name and address, personal information you provide to us such as feedback forms, Google forms, surveys. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
• Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract, informing you about updates or services, for financial/legal reasons such debt recovery and record keeping.
• Prospect Data that includes data you have supplied in requesting information about our products and services and/or to access resources such as free downloads and guides. We will process this data to reply to you and for recordkeeping purposes, for example. Our lawful ground for processing is legitimate interest.
• User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
• Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
• Mailing List Data to send email newsletters and details of our services and offers. We hate spam and only send our email newsletters to those people that have opted-in to receive them. You can unsubscribe at any time by clicking the unsubscribe link at the bottom of our emails or by emailing jo@twistconsultants.co.uk.
• Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in promotions such as free give-aways, to deliver relevant website content to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
• We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content to you and to measure or understand the effectiveness of the materials we serve to you. Our lawful ground for this processing is legitimate interests to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
• Other data supplied by you such as for testimonials and case studies. Our lawful ground of processing is legitimate interests and we also ask for consent in advance for testimonials and case studies. For legal and compliance reasons.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at jo@twistconsultants.co.uk. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site, by sending us emails or providing us with your contact details such as business cards). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.
We may receive data from third parties such as analytics providers such as Google based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU. We may also collect data from social media channels such as Twitter.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since, including to receive a freebie or download, for example, where there will be follow-up emails. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at jo@twistconsultants.co.uk
5. DISCLOSURES OF YOUR PERSONAL DATA
Please also see Section 2 for more details on data sharing. We may have to share your personal data with the parties set out below:
• Service providers who provide IT and administration services
• Professional advisers including lawyers, bankers, auditors and insurers
• Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. DATA SECURITY
We allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances, we may anonymise your personal data for research or statistical purposes in which case, we may use this information indefinitely without further notice to you.
9. REQUESTING PERSONAL DATA
Individuals with whom we have had contact have the right to request a copy of the personal data that we hold about them. In such cases, they will be required first to prove their identity in order to protect the true individuals regarding whom such requests are made. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Changes
We reserve the right to make changes to this Privacy Notice. It was last reviewed and updated in line with GDPR on 3 December 2018 and will be reviewed on an ongoing basis.