This privacy notice of Twigged It Ltd ensures transparency in how we collect, use, and protect your personal data. For any inquiries, please visit our Contact page.

The purpose of this privacy notice is to inform you as to how we look after your personal data when you
visit our website (regardless of where you visit it from).

We’ll also tell you about your privacy rights and how data protection law protects you.

 

Who we are

 

This privacy notice aims
to give you information on how we collect and process your personal data
through your use of this website, including any data you may provide through
this website when you sign up to our newsletter or book a meeting with us.

 

You must read this
privacy notice together with any other privacy notices we may provide on
specific occasions when we are collecting or processing personal data about you
so that you are fully aware of how and why we are using your data. This privacy
notice supplements the other notices and is not intended to override them.

 

Data Controller

 

Twigged It Ltd is the
controller and responsible for your personal data (collectively referred to as
“Twigged It”, “we”, “us” or “our” in this privacy notice). Our contact details
are for Sarah Twigg at twiggeditltd@gmail.com or
sarahtwigg@hotmail.com.

 

Third-party links outside of our control

 

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.

 

The personal data we collect about you

 

Personal data, or
personal information, means any information about an individual from which that
person can be identified. You can find out more about personal data from
the Information
Commissioners Office. We may collect, use, store and transfer different
kinds of personal data about you which we have grouped together follows:

 

·       
Identity Data includes First name, Last name

·       
Contact Data includes Email address, Telephone numbers

We
also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data
does not directly or indirectly reveal your identity.

For
example, we may aggregate your Usage Data to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect
Aggregated Data with your personal data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in
accordance with this privacy notice.

 

We do not collect any
Special Categories of Personal Data about you (this 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). Nor do we collect any information about
criminal convictions and offences.

 

If you fail to provide personal data

 

Where we need to collect
your personal data by law, or under the terms of a contract we have with you
and you fail to provide that data when requested, we may not be able to perform
the contract we have or are trying to enter into with you (for example, to
provide you with goods or services). In this case, we may have to cancel a
product or service you have with us but we will notify you if this is the case
at the time.

 

How we collect your personal data

 

We use different methods to collect data from and
about you including directly – you may give us your Contact and Financial Data
by filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:

·       
Apply for our services;

·       
Subscribe to our services or publications;

·       
Request marketing to be sent to you.

How we use your personal data

We will only use your
personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:

Performance of
Contract this means processing your data where it is necessary for
the performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.

Legitimate Interest this
means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the most secure experience.
We make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data for our
legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or
are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by emailing
twiggeditltd@gmail.com

Comply with a legal or
regulatory obligation this means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are
subject to.

Generally, we do not
rely on consent as a legal basis for processing your personal data other than
in relation to sending third party direct marketing communications to you via
email or text message. You have the right to withdraw consent to marketing at
any time by contacting us at twiggeditltd@gmail.com

 

Purposes for which we will use your personal data

 

We have set out below,
in a table format, a description of all the ways we plan to use your personal
data, with the legal bases we rely on to do so.

 

Note that we may process your personal data for
more than one lawful ground depending on the specific purpose for which we are
using your data. Please contact us at twiggeditltd@gmail.com if you need
details about the specific legal ground we are relying on to process your
personal data.

·       
Communicating with you – sending you notices regarding our services,
providing you with technical information and responding to any customer service
issue you may have

·       
To communicate with you and to keep you informed about our latest
updates and services

·       
To market our website and services (see more under marketing)

For
statistical and analytical purposes, intended to improve the site in addition
to different uses listed above. We may transfer or disclose personal
information with our trusted third parties, who may be located in different
jurisdictions across the world, for any of the following purposes;

·       
Hosting and operating our site

·       
Providing you with our services, including providing a personal display
of our site;

·       
Storing and processing such information on our behalf

·       
Servicing you with advertisement to assist us in evaluating the success
of advertising campaigns and help us re-target any of our users

·       
Providing you with marketing offers and promotional materials relating
to our site and services

·       
Performing research, technical diagnostics or analytics

We
may also disclose information if we have good reason to believe that disclosure
of such information is helpful or reasonably necessary to: (i) comply with any
applicable law, regulation, legal process or governmental request; (ii) enforce
our policies (including our Agreement), including investigations of potential
violations thereof; (iii) investigate, detect, prevent or take action regarding
illegal activities or other wrongdoing, suspected fraud or security issues;
(iv) to establish or exercise our rights to defend against legal claims; (v)
prevent harm to the rights, property or safety of us, our users, yourself or
any third party; or (vi) for the purpose of collaborating with law enforcement
agencies and/or in case we find it necessary in order to enforce intellectual
property or other legal rights

Marketing

 

We strive to provide you
with choices regarding certain personal data uses, particularly around
marketing and advertising.

 

Promotional offers from
us

 

We may use your
Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you.

You will receive
marketing communications from us if you have requested information from us or
purchased goods or services from us [or if you provided us with your details
when you entered a competition or registered for a promotion] and, in each
case, you have not opted out of receiving that marketing.]

 

Third-party marketing

 

We will get your express
opt-in consent before we share your personal data with any company outside the
Twigged It group of companies for marketing purposes.

 

Opting out

 

You can ask us or third
parties 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
twiggeditltd@gmail.com at any time.

 

Where you opt out of
receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, warranty
registration, product OR service experience or other transactions.

 

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.

 

If you leave a comment
on our site you may opt-in to saving your name, email address and website in
cookies. These are for your convenience so that you do not have to fill in your
details again when you leave another comment. These cookies will last for one
year.

 

If you visit our login
page, we will set a temporary cookie to determine if your browser accepts
cookies. This cookie contains no personal data and is discarded when you close
your browser.

When you log in, we will
also set up several cookies to save your login information and your screen
display choices. Login cookies last for two days, and screen options cookies
last for a year. 

 

If you select “Remember
Me”, your login will persist for two weeks. If you log out of your account, the
login cookies will be removed.

 

If you edit or publish
an article, an additional cookie will be saved in your browser. This cookie
includes no personal data and simply indicates the post ID of the article you
just edited. It expires after 1 day.

 

Change of purpose

 

We will only use your
personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to
how the processing for the new purpose is compatible with the original purpose,
please twiggeditltd@gmail.com.

 

If we need to use your
personal data for an unrelated purpose, we will notify you and we will explain
the legal basis which allows us to do so.

Please note that we may
process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.

 

Embedded content from
other websites

 

Articles on this site
may include embedded content (e.g. videos, images, articles, etc.). Embedded
content from other websites behaves in the exact same way as if the visitor has
visited the other website.

 

These websites may
collect data about you, use cookies, embed additional third-party tracking, and
monitor your interaction with that embedded content, including tracking your
interaction with the embedded content if you have an account and are logged in
to that website.

 

Who we share your data with

 

We may have to share your data with external third
parties for the purposes below:

·       
Providers acting as processors based in the UK who provide IT and system
administration services.

·       
Professional advisors acting as processors including lawyers,
accountants, bankers, auditors and insurers based in the UK who provide
consultancy, accounting, banking, legal and insurance services.

·       
Third parties to whom we may choose to sell, transfer, or merge parts of
our business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business, then the
new owners may use your personal data in the same way as set out in this
privacy notice.

We
require all third parties to respect the security of your personal data and to
treat it in accordance with the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.

We do not transfer your
data outside of the UK.

 

Data Security

 

We have put in place
appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality.

 

We have put in place
procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do
so.

 

How long we retain your data

 

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.

To determine the
appropriate retention period for personal data, we consider the amount, nature,
and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other means, and the applicable legal requirements.

 

By law we have to keep
basic information about our customers (including Contact, Identity, Financial
and Transaction Data) for 6 years after they cease being customers for tax
purposes.

In some circumstances
you can ask us to delete your data: see Your legal rights below for
further information. In some circumstances we may anonymise your personal data
(so that it can no longer be associated with you) for research or statistical
purposes in which case we may use this information indefinitely without further
notice to you

 

Your legal rights

 

Unless subject to an exemption under the data
protection laws, you have the following rights with respect to your personal
data:

·       
The right to request a copy of the personal data which we hold about
you;

·       
The right to request that we correct any personal data if it is found to
be inaccurate or out of date;

·       
The right to request your personal data is erased where it is no longer
necessary to retain such data;

·       
The right to withdraw your consent to the processing at any time, where
consent was the lawful basis for processing your data;

·       
The right to request that we provide you with your personal data and
where possible, to transmit that data directly to another data controller,
(known as the right to data portability), where applicable 9i.e. where our
processing is based on consent or is necessary for the performance of our
contract with you or where we process your data by automated means);

·       
The right, where there is a dispute in relation to the accuracy or
processing of your personal data, to request a restriction is placed on further
processing;

·       
The right to object to our processing of personal data, where applicable
i.e. where processing is based on our legitimate interests (or in performance
of a task in the public interest/exercise of official authority); direct
marketing or processing for the purposes of scientific/historical research and
statistics).

If you wish to exercise
any of the rights set out above, please email twiggeditltd@gmail.com.

 

No fee required – with
some exceptions:

 

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 admin fee if your request is clearly
unfounded, repetitive, or excessive. Alternatively, we may refuse to comply
with your request in these circumstances.

 

What we may need from you

 

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.

 

Time limit to respond

 

We try to respond to all
legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.

 

Changes to this notice and your duty to inform us of changes

 

This version was last
updates on 28/03/2024 and historic versions can be obtained by contacting us at
twiggeditltd@gmail.com

 

Queries, requests or concerns

 

To exercise all relevant
rights, queries or complaints in relation to this policy or any other data
protection matter between you and us, please in the first instance contact our
Data Protection Officer at twiggeditltd@gmail.com

 

If this does not resolve
your complaint to your satisfaction, you have the right to lodge a complaint
with the Information
Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or
at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF, England, UK.