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TWIGGED LTD PRIVACY STATEMENT

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1 CONTENTS
2 Introduction
3 Data that we hold
3.1 Professional Services
3.1.1 Why do we process data?
3.1.2 What data is processed?
3.1.3 How long do we hold data for?
3.2 Respondent personal data
3.2.1 Research panel
3.2.2 Survey and focus group participation
3.3 Business Contacts
3.3.1 Why do we process data?
3.3.2 What data do we hold?
3.3.3 How long do we hold data for?
3.4 Suppliers
3.4.1 Why do we process data?
3.4.2 What data do we hold?
3.4.3 How long do we hold data for?
4 People who visit our offices
5 People who use our website
5.1 Why do we process data?
5.2 What data do we hold?
5.3 How long do we hold data for?
6 Sharing personal data
7 Locations of processing
8 Individual’s Rights
9 Complaints
10 Contact information
11 Changes to our privacy statement

12 Cookies Policy

 

2 INTRODUCTION

Twigged Innovation (Twigged Ltd) respect your privacy and do not sell, rent or loan any identifiable information collected on this site. Any information that you give will be treated in a careful and secure manner. It will not be used in ways to which you have not consented. This statement explains how we may collect and use information about you through our website. If you have any questions about our GDPR privacy policies, want to exercise your right to see a copy of the information that we hold about you, or think that information we hold about you may need to be corrected, please send an email to enquiries@twiggedinnovation.com

We do not seek to identify individual visitors.  We do on our site invite you to send us emails which may, of course, identify you.  The purpose for which you are invited to give us information is clear.

We will only use your details to send you information from Twigged Ltd that you have specifically requested to receive. If you no longer wish to receive such information, our emails contain a link that will allow you to change or terminate your subscription to our email alerting service.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.


We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

Our full privacy policy can be found below.

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3 DATA THAT WE HOLD


3.1 Professional services

We provide services to businesses, non-profits, and other organisations. The exact data held will depend on the services to be provided.
Where we engage with clients for professional services, we may collect and process personal data in order to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.

3.1.1 Why do we process data?

Where data is collected for professional services, it is used for a number of purposes, as follows;
• Providing services to clients. Data is processed in accordance with our agreed project scope between clients and us.  We provide a range of professional services to our clients, which includes;
• Client management. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services are provided to our clients are appropriate.
• Administration. In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client facing applications, and maintaining internal operating processes.
• Regulatory. In order to undertake professional services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of identity of individuals.

3.1.2 What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

• Services to businesses, non-profits, and other organisations. We process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, lists of shareholders, customers and suppliers and any other specifically relevant data.
• Services to individuals. Personal data may include contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.

3.1.3 How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 7 years). We may keep data for longer in order to establish, exercise, or defend our legal rights and the legal rights of our clients.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

3.2 Respondent personal data

Twigged Ltd is an Insight and Innovation Consultancy. We collect data from consumers and/ or respondents and deliver the information necessary to our clients.

3.2.1 Research panel

If you are filling in a survey through a research panel, we will not receive your personal data, because contact details are shared in such a way that we cannot link them to a natural person. Thus, the data is not considered personal data under GDPR.

3.2.2 Survey and focus group participation

Sometimes Twigged does receive personal data from you or third parties. When you participate in our surveys, research communities or focus groups, you do agree to the following:
• You consent to the collection, use, disclosure and processing of your personal data in the manner described in this privacy policy, including our procedures relating to cookies, IP addresses and log files. You consent to the transfer and processing of your personal data in the European Union (EU), as well as territories outside of the EU, which do not have data protection laws that provide the same level of protection that exists in countries in the EU. Your consent is voluntary, and you may revoke your consent by opting out at any time. You consent to us sharing your personal data with relevant persons working for service providers who assist us to provide our services. At any time you will be allowed to unsubscribe from email lists. The information is voluntarily provided and you have the option to decline to answer any question. All responses given by the respondents will become the sole property of Twigged.
• When you agree to participate in any online research activity with us you unequivocally agree to us using your personal information for market research. As a respondent you will conduct yourself as can reasonably be expected, i.e. you will refrain from abusive language, keep keys or passwords to yourself, and will report misuse of data immediately to us. Respondents will hold Twigged harmless against all damages, direct or consequential.
• Twigged does not sell your personal data to third parties and we do not use any contact details collected in our customers’ surveys to contact survey respondents.
3.3 Business Contacts

Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held in our system.  This information is entered into the system after contact is made between a staff member of Twigged and a business contact individual.

3.3.1 Why do we process data?

Where personal data on business contacts is held, it is used for a number of purposes, as follows;
• Promote and develop our offerings.
• Communication of updates.
• Hosting and facilitating of events.
• Relationship management.
• Administration and management.

3.3.2 What data do we hold?

Personal data that may be stored includes, but is not limited to, name, email address, physical address, job title, and details of the initial meeting.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

3.3.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected.

3.4 Suppliers

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.

3.4.1 Why do we process data?

• Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
• Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
• Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:
– managing our relationship with suppliers;
– developing our businesses and services (such as identifying client needs and improvements in service delivery);
– maintaining and using IT systems;
– hosting or facilitating the hosting of events; and
– administering and managing our website and systems and applications.
• Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.
• Promoting our services. We may use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
• Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.

3.4.2 What data do we hold?

We will hold supplier’s names, contacts names, and contact details of suppliers.

3.4.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.

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4 PEOPLE WHO VISIT OUR OFFICES

We have security in place at our offices. The only visitors in our offices have a need to be there. Our offices have a front-door with a lock and key system.
 

5 PEOPLE WHO USE OUR WEBSITE

When people visit our website, personal data is collected both through automated tracking and interacting with the website. Personal data may be collected when individuals correspond with us by phone, e-mail or otherwise. This includes information provided when an individual makes an enquiry, comment on publications, enter a promotion or survey, and report any problem with our website.
When individuals visit our websites, certain personal data may be automatically collected. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers).
Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

5.1 Why do we process data?

There are a number of reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;
• Administration. To administer our site and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimised appropriately.
• Functionality. In order to allow individuals to use some functionality of our website, certain personal data must be entered in order for features to work as intended.
• Security. In order to keep our site safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.
• Promote and develop our offerings. Some personal data may be used in order to measure or understand the effectiveness of advertising we serve to individuals, and to ensure that only relevant advertising appears.

5.2 What data do we hold?

The data that we hold depends on what data was entered and for what purpose.
Where data was entered in order to engage with functionality of our website, that personal data may include their name, address, e-mail address and phone number.
Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

5.3 How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 7 years).
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

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6 SHARING PERSONAL DATA

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:
Third party organisations that provide applications/functionality, data processing or IT services to us
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

Third party organisations that otherwise assist us in providing goods, services or information
Auditors and other professional advisers
Law enforcement or regulatory agencies or those required by law or regulations
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

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7 LOCATIONS OF PROCESSING

Where possible, personal data resides within the UK but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by people operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.
We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

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8 INDIVIDUAL’S RIGHTS

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:
• Individuals may request access to their personal data held by us as a data controller.
• Individuals may request us to rectify personal data submitted to us.
• Individuals may request that we erase their personal data
• Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
• Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
• Individuals may request information about, or human intervention into, any automated data processing that we may undertake.
If you wish to exercise any of these rights, please send an email to dataprivacy@twiggedinnovation.com

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9 COMPLAINTS

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to dataprivacy@twiggedinnovation.com. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the UK data protection regulator. For the UK this is the Information Commissioner’s Office (“ICO”).  For further information on your rights and how to complain, please refer to the ICO website https://ico.org.uk/concerns
 

10 CONTACT INFORMATION

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
 

ADDRESS: Kemp House, 160 City Road, London EC1V 2NX

EMAIL: dataprivacy@twiggedinnovation.com

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11 CHANGES TO OUR PRIVACY STATEMENT

Updates to this privacy statement will appear on this website. This privacy statement was last updated on September 17th, 2018.

 

12 COOKIES POLICY

Last updated: 17.09.18

Twigged Ltd uses cookies on the Twigged website www.twiggedinnovation.com. By using the website, you consent to the use of cookies.
Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

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What are cookies?

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies.

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How Twigged Ltd uses cookies

When you use and access the Service, we may place a number of cookies files in your web browser.
We use cookies for the following purposes: to enable certain functions of the Service, to provide analytics, to store your preferences, to enable advertisements delivery.

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We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:

svSession               (Persistent)                                                                                   Identifies unique visitors and tracks a visitor’s sessions on a site

hs                           (Session)                                                                                                                              Security

XSRF-TOKEN         (Persistent)                                                                                                                           Security

smSession              (Persistent (Two weeks))                                                                                                     Identifies logged in site members

TSxxxxxxxx             (where x is replaced with a random series of numbers and letters)        (Persistent)         Security

TSxxxxxxxx_d         (where x is replaced with a random series of numbers and letters)     (Persistent)            Security

 

Third-party cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

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What are your choices regarding cookies?

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Cookies Policy
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