twisted loop Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
Twistedloop Ltd, registered in England and Wales with company number 15534050
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
Names and contact details
Occupation
Payment details (including card or bank information for transfers and direct debits)
Financial data (including income and expenditure)
Transaction data (including details about payments to and from you and details of products and services you have purchased)
Usage data (including information about how you interact with and use our website, products and services)
Information relating to compliments or complaints
Website user information
We collect or use the following personal information for the operation of client or customer accounts:
Names and contact details
Addresses
Purchase or service history
Account information, including registration details
Information used for security purposes
Marketing preferences
Technical data, including information about browser and operating systems
We collect or use the following personal information for information updates or marketing purposes:
Names and contact details
Addresses
Profile information
Marketing preferences
Purchase or account history
Website and app user journey information
IP addresses
We collect or use the following personal information to comply with legal requirements:
Contact information
Client account information
Any other personal information required to comply with legal obligations
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Address
Account information
Purchase or service history
Customer or client accounts and records
Financial transaction information
Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
The legitimate interest clause is relevant here as we are collecting personal information for direct marketing purposes, for instance through our newsletter and social media channels. Any person can unsubscribe from our newsletter or unfollow our social media channels at any time, and if they are choosing to receive our marketing communications then they are showing that they are legitimately interested in the subject matter.
Our lawful bases for collecting or using personal information to comply with legal requirements:
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Where we get personal information from
Directly from you
Publicly available sources
Previous employment
Suppliers and service providers
How long we keep information
We keep personal information as long as we need to for contractual purposes, to abide by legal requirements and where there is legitimate interest unless a person opts out from our marketing communications in which case they will be removed from our marketing lists.
Who we share information with
Professional or legal advisors
Organisations we’re legally obliged to share personal information with
Publicly on our website, social media or other marketing and information media
Suppliers and service providers
Professional consultants
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Last updated
November 2024