Owner and Data Controller:
Twirel Studio, 180 Granville Street, Birmingham, B1 1SF
Contact email: firstname.lastname@example.org
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
1. What data we collect:
1.1 The information we collect about individuals is business related information – such as:
1.1.1 Full Name and Title
1.1.2 Contact information including email address
1.1.3 Role within the company
1.1.4 Website usage data
1.1.5 Other information relevant to client enquiries
1.1.6 Other information pertaining to special offers and surveys
1.1.7 This data is only collected when a form is submitted on the website. The website is unable to collect this data without this action.
2. Why we collect this data:
In accordance with data protection laws, we will only process your personal data where we have a lawful basis for doing so.
2.1 Information we process because we have a contractual obligation with you
2.1.1 When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
2.1.2 In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information. We may use it in order to:
126.96.36.199 Verify your identity for security purposes
188.8.131.52 Sell products to you
184.108.40.206 Provide you with our services
220.127.116.11 Provide you with suggestions and advice on products, services and how to obtain the most from using our website
18.104.22.168 We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
22.214.171.124 Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
2.1.3 We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2.2 Information we process with your consent
2.2.1 Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities, our products and services, you provide your consent to us to process information that may be personal information.
2.2.3 Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
2.2.4 Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
2.2.5 If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
2.2.6 We will continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
2.2.7 You may withdraw your consent at any time by instructing us at www.twirel.com. However, if you do so, you may not be able to use our website or our services further.
2.3 Information we process for the purposes of legitimate interests
2.3.1 We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
2.3.2 Where we process your information on this basis, we do after having given careful consideration to:
126.96.36.199 Whether the same objective could be achieved through other means;
188.8.131.52 Whether processing (or not processing) might cause you harm;
184.108.40.206 Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.
2.3.3 We may gather data for the following purposes:
220.127.116.11 For record-keeping and for the proper and necessary administration of our business
18.104.22.168 To contact business contacts about our services
22.214.171.124 To obtain information from data providers publicly available and online sources
126.96.36.199 To enrich the details we have on business contacts with other information
188.8.131.52 To obtain information from data providers and publicly available sources about businesses which may be interested in our services
184.108.40.206 To respond to enquiries and requests made to us about our services
220.127.116.11 To conduct market research in respect of our services for our customers, so we can better understand your business needs
18.104.22.168 To improve our website and services based on your use or and your feedback, so that it is as effective and easy to use as possible
22.214.171.124 To send you promotional emails or to call you about products, services, offers and other things we think might be relevant to you
3. How we collect the data:
3.1.1 Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
3.1.2 Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.
3.1.3 Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
126.96.36.199 To record whether you have seen specific messages we display on our website
188.8.131.52 To record your answers to surveys and questionnaires on our site while you complete them
184.108.40.206 To record the conversation thread during a live chat with our support team
220.127.116.11 Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website structure, design, content and functions.
18.104.22.168 Identify whether you are signed in to our website. A cookie allows us to check whether you are signed in to the site.
22.214.171.124 Test content on our website. For example, 50% of our users might see one piece of content, the other 50% a different piece of content.
126.96.36.199 Store information about your preferences. The website can then present you with information you will find more relevant and interesting.
188.8.131.52 To recognise when you return to our website. We may show your relevant content, or provide functionality you used previously.
3.1.7 Information about controlling cookies:
184.108.40.206 Chrome cookies settings
220.127.116.11 Firefox cookies settings
18.104.22.168 Safari cookies settings
22.214.171.124 Opera cookies settings
3.2 Google Analytics
3.2.1 This cookie allows us to see information on user website activities including, but not limited to page views, source and time spent on the website. The information is depersonalised and is displayed as numbers, meaning it cannot be traced back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our website, and strive to give you more of the things you enjoy reading and watching.
3.2.2 Learn more at https://policies.google.com/privacy?hl=en-US
3.3 Google Search Console
3.3.1 Our website uses Google Search Console. The search analysis generated through this shows how often our website appears in Google search results. We can use this to filter and group the data, e.g. in categories such as search request, date or device. The results are used by us in this way only to optimise the search performance of our website.
3.3.2 Learn more at https://policies.google.com/privacy?hl=en-US
3.4.1 If you have opted in to receive our newsletters, then this may include tracking codes that help us understand who, as well as how many people have opened or clicked on each email. This data helps us to create better emails in the future and provide you with a better service. This data is stored on the servers of our email partners and covered under their security measures.
3.4.2 Learn more at https://www.sendinblue.com/legal/privacypolicy/
3.5 AdWords & Facebook Re-marketing Tags
3.5.1 Both Google and Facebook re-marketing is a way of reconnecting with users who have previously visited our website. They collate depersonalised data on our website visitors. These platforms can enable us to position targeted adverts to a defined audience when they are browsing other websites. Re-marketing also encompasses the use of emails to reconnect with previous users.
3.5.2 Learn more at https://policies.google.com/privacy / https://www.facebook.com/policy.php
3.6 Automated systems data collection
3.6.1 Requests by your web browser to our servers for web pages and other content on our website are recorded.
3.6.2 We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the web pages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
4. How we process the data:
4.1 The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
4.2 The Data processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
4.3 The Data is processed at (Twirel Offices) the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller- Contact email@example.com for more information.
5.1 Apart from our 3rd party service providers listed above we do not share any other information unless we are obliged to disclose personal data by law, or the disclosure is necessary for purposes of legal proceedings, national security, taxation, or criminal investigation; or where we have your consent; or in relation to a takeover, merger or asset sale of our business.
5.2 The bases on which we process information about you:
5.2.1 The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
5.2.2 If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
5.2.3 If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
6. Controlling your personal information
6.1 When you fill in a form or provide your details on our website, you will see one or more tick boxes allowing you to:
6.1.1 Opt-in to receive marketing communications from us by email, telephone, text message or post.
6.2 If you have agreed that we can use your information for marketing purposes, you can change your mind easily, via one of these methods:
6.2.1 Unsubscribe from all Twirel communication emails using one of the unsubscribe links we provide in all marketing emails.
6.2.2 Send an email to firstname.lastname@example.org
6.2.3 Write to us at: Twirel Studio, 180 Granville Street, Birmingham, B1 1SF
6.3 Under certain circumstances, by law, you have the right to:
6.3.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
6.3.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
6.3.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
6.3.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground and where we do not have compelling legitimate interests to override such objection. You also have the right to object where we are processing your personal information for direct marketing purposes.
6.3.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
6.3.6 You will not have to pay a fee to access your personal information (or to exercise any of the other rights).
6.3.7 Please be aware that the rights above are not absolute and there may be circumstances where we are unable to comply with your request. In such cases we will explain why we cannot comply with the request.
6.3.8 If you would like to exercise any of your rights please contact us at email@example.com. Please note that we may need to verify your identify before being able to give effect to any request by you to exercise your rights.
7. Data Retention
7.1 We currently hold your data for 44 months to ensure that all of our information on contacts are up to date.
7.2 If you opt-out of any marketing we will retain a record of your data to ensure that you do not receive any future marketing.
7.3 If you have made a deletion request we will still store all of your Personal Data but will be held this as a suppression record to ensure you are not contacted again.
8. Data Security
8.1 To prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards. We also follow stringent procedures to ensure we work with all personal data in line with the Data Protection Act 1998.
8.2 The Twirel website is secured by HTTPS to ensure all data transferred to and from our server to your device(s) is encrypted during transit. The security policy we have in place will force this secure connection (HSTS).
8.3 We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
8.3.1 Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
8.4 You will always have the right to opt-out of receiving marketing from us and we will always ensure that we screen any databases against the Corporate Telephone Preference Service prior to contacting businesses.
9. Job Application and Employment Data
9.1 If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
9.2 If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
10.1 When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
10.2 If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
10.3 We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
11.1 We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.