Privacy Notice

Privacy Policy

 

This privacy notice tells you what to expect when TwitTwooYou processes your personal data. We may process your personal data if we provide services to you. Personal data includes information such as an individual’s name, address, email address and processing includes collecting, storing, using or disclosing personal data. TwitTwooYou is bound by data protection legislation in each jurisdiction within which it operates and is committed to protecting and respecting your privacy. This Privacy Notice (“Notice”) sets out the basis on which the personal data collected from you, or that you provide will be processed by us.

We use your information strictly in accordance with all applicable laws concerning the protection of personal information and you can be assured that any information provided will only be used in accordance with this Notice. In it we explain:

  • What personal information is collected from you through the website and other third-party integrations, how it is used and with whom it may be shared.

  • The security procedures in place to protect your information.

  • Your rights regarding the information you provide.

Our commitment to you

The EU General Data Protection Regulation (GDPR) is the most significant piece of the European privacy legislation in the last twenty years. It replaces the 1995 EU Data Protection Directive (European Directive 95/46/EC), strengthening the rights that EU individuals have over their data, and creating a uniform data protection law across Europe.

Jersey has implemented its own updated data protection that is broadly equivalent to the GDPR in the form of the Data Protection (Jersey) Law 2018 (the DP Law) and the Data Protection Authority (Jersey) Law 2018 (the Authority Law).

TwitTwooYou promises to comply with applicable data protection legislation. Working in conjunction with our data processors (some of which are listed below), we will keep data protection at the forefront of our activities and ensure we continually respect the legislation whenever we use your data.

How we collect your personal data

We have clients that are individuals and clients that are corporate bodies, including limited liability partnerships. Even where our clients are not themselves individuals, they will be represented by individuals and they may be owned by individuals and invested in by individuals. As a result, we will inevitably process personal data in the course of our relationships with those clients too.

If you are a client, the information we process about you will include personal and/or professional contact details (addresses, telephone numbers, email addresses).

TwitTwooYou makes every effort to maintain the accuracy of personal data, although you must assist with this by promptly contacting TwitTwooYou if there are changes to the personal data you have previously provided or if you become aware that TwitTwooYou holds inaccurate personal data.

We may also obtain personal data about you or another person you have provided us personal data for, under a legal basis from sources other than from you. The sources and categories of personal data, along with whether these are publicly accessible are listed below:

Due diligence screening providers.

  • Names, addresses, age, financial or economic information, social standing, crime or security-related matters. This is publicly available. Internet search engines and public information sources.

  • Names, addresses, age, financial or economic information, social standing, crime or security-related matters. This is publicly available.

  • Those authorised to act on behalf of a client including an advisor or attorney.

  • Name, address, financial information, identifier code, age, gender. This is not publicly available.

Purpose and basis for the collection

If you are a client, TwitTwooYou collects your personal data, or that of other individuals provided by you, in order to provide you with the services you have requested under the Terms of Business you have entered into with TwitTwooYou and also to meet certain legal obligations. We do not collect more information than we need in order to provide you with the services. If you do not provide the information that we ask for, we may not be able to provide you with the services that you require.

If you are a visitor to our website you may give us your information if you fill in a form on the Site or if you send us an email (name, email address, telephone number). We do this so that we can monitor who accesses our Site and also correspond with you.

Use of your personal information

We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give. We will not sell or rent this information to anyone.

We will not share your information with any third party outside of our organisation, other than those noted in this policy, for which we use solely to process your data.

If you consent for us to do so, we may contact you via email in the future to tell you about special offers, products or services, or changes to this privacy policy.

We may use and disclose your personal information only as follows:

(a) To promote our service and our products. You can stop receiving our promotional emails by following the unsubscribe instructions included in the footer of every email we send.

(b) To send you informational and promotional content. For example, you may have opted-in to receive emails from us. If you would like to stop receiving such emails, you can unsubscribe by following the instructions included in the footer of every email we send.

(c) To comply with our Terms of Service and applicable law.

(d) To meet legal requirements, such as complying with court orders, valid discovery requests, valid summons, or other appropriate legal mechanisms.

(e) To provide information to our representatives and advisors, such as lawyers and accountants, to help us comply with legal, accounting, and security requirements.

(f) To prosecute and defend a court, arbitration, or criminal legal proceeding.

(g) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition. In such an event, we will notify you of the change by posting a notice on this website and any acquirer will be subject to our obligations under this Privacy Statement.

Why do we process your information?

a) To send you relevant emails that include our latest news, products and services

b) To invite you to events based on your location and role

c) For the completion of assessments

d) To fulfil our contract for services with you

Security

We take appropriate measures to ensure that any personal data are kept secure and are kept for the duration of your use of our service. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data when transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

To safeguard against unauthorised access to personal information, all electronic personal information held by us is maintained on systems protected by secure network architectures that contain firewalls and intrusion-detection devices. The servers holding personal information are “backed-up” on a regular basis in an effort to avoid any inadvertent erasure or destruction of such personal information and are stored in facilities with appropriate security and fire detection and response systems.

TwitTwooYou stores your data in Jersey, at its physically secure premises in Jersey, Channel Islands. In line with data protection regulation, personal data will not be stored outside the Channel Islands or European Economic Area.

Only people who need the information to perform a specific job are granted access to personal information. The computers/servers in which we store personal information are kept in a secure environment.

Retention of data

Any personal data you provide to TwitTwooYou will be retained by us for as long as we need it for the purposes for which it was collected and subject to any applicable law or other legal obligation that may apply.

Cookies

Cookies are small text files that are placed on your computer by the websites you visit. They are widely used to make websites work, or work more efficiently, to improve the user experience. They also provide certain information to the owners of a site.

The Site currently uses the following cookies:

  • Anonymous analytics cookies

Purpose: Every time a user visits our website, web analytics software provided by a third party generates an anonymous analytics cookie. These cookies can tell us whether or not you have visited the Site before. Your browser will tell us if you have these cookies, and if you don’t, we generate new ones. This allows us to track how many individual unique users we have, and how often they visit the site. These cookies cannot be used to identify individuals; they are used for statistical purposes only.

  • Geo-targeting cookies

Purpose: These cookies are used by software that tries to determine what country you are in from information supplied by your browser when it requests a web page. This cookie is completely anonymous and is only used to help target content and advertising.

  • Third-party advertising cookies

Purpose: On some pages of the Site, third parties may also set their own anonymous cookies, for the purposes of tracking the success of their application, or customising the application for you. Because of how cookies work, TwitTwooYou cannot access these cookies, nor can the third parties access the data in cookies used by the Site.

Most browsers are initially set to accept cookies. If you prefer, you can set your browser to refuse cookies and information concerning cookies and instructions regarding how to manage and delete them is widely available on the internet. If you choose to do so it might affect certain site functionality. We may in the future, without notice, determine to change our use of cookies and if we do, we will update this information.

Your Rights

You have rights as an individual which you can exercise in relation to the personal data we hold about you. Your rights are listed below:

Right of access

You have the right to know what type of personal data we hold about you and details about how we use it. You also have the right to obtain copies of your personal data. To find out what information we hold on you, please contact us.

Right to rectification

You have the right to have any errors or incomplete personal data corrected. To submit your request to rectify any data we hold on you, please contact us.

Right to erasure (to be forgotten)

In certain circumstances, you have the right to request the deletion of all personal data relating to you. To submit your request, please contact us.

Right to the restriction of processing

You have the right to restrict how we use your data e.g. you can request that we do not process your data for a particular purpose. To submit your request to restrict how we use your data, please email TwitTwooYou.

Right to object to processing

You have the right to object to our use of your personal data (including for direct marketing purposes). To exercise your right to object, please email the Data Protection Officer.

Right to withdraw consent

If you have previously given us consent to process your data for a particular purpose, you have the right to withdraw that consent at any time. To submit your request to withdraw your consent to be contacted by TwitTwooYou, please contact us.

Right to data portability

You have the right to be supplied with all of the personal data you have given to us in a structured, commonly used and machine-readable format. You also have the right to have your personal data transferred from one controller to another. To exercise your right to portability, please email TwitTwooYou.

Right to lodge a complaint

You have a right to lodge a complaint with the relevant Data Protection Authority.

How we handle all data requests

When you make a request to exercise one of your rights we will send you an email confirming that we have received your request. We will respond to all data requests within four weeks. If we have difficulties in meeting that deadline, we will contact you to discuss matters.

When you exercise your rights TwitTwooYou will consider any exemptions that may apply. It is possible an exemption may affect how we are able to respond to your request, if this is the case TwitTwooYou will explain this to you in writing.

Changes to this privacy statement

If we make any changes to this privacy statement, we will post them on this website. We reserve the right to modify this privacy statement at any time, so please review it frequently.

Any changes will be effective immediately upon their posting on the website. If we make material changes to this statement, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If you object to changes to our privacy statement, you must refrain from using our services, including the website.

Complaints

If you remain unhappy with the way in which your request or data has been handled, you may email TwitTwooYou. Should we be unable to resolve your complaint, you may contact the Office of the Information Commissioner directly by email at enquiries@oicjersey.org or by calling 00 44 1534 716 530.

Data Protection Authority

TwitTwooYou is registered with the Office of the Information Commissioner in Jersey, Channel Islands.