This policy tells you what to expect when we collect personal information.

Twyn Limited is the "data controller" of the personal information we hold for the purposes of the UK General Data Protection Regulation (the UK GDPR) and the Data Protection Act 2018 (the Data Protection Act). If you would like to ask for information about our policy, you can email us at: contactus@mytwyn.com.

Personal data is defined in the UK GDPR as any information relating to an identified or identifiable natural person. It can include obvious data like your name but also identification numbers, online identifiers and/or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Special category data includes data revealing race or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data, data concerning health or data concerning a person’s sex life or sexual orientation.

As a business, we collect the following data from you, some of which may fall within the definition of personal or special category data:

We do not request or require special category date, but if volunteered by you, we may process it with extreme caution and confidentiality.

We will not generally rely on consent as a basis for processing data. In the limited circumstances where we may rely upon consent, we will specifically obtain this.

This policy applies to information we collect about you:

We generally process data on the basis it is necessary for the performance of a task carried out by Twyn Limited or its group, to improve the level of our service and/or in the exercise of our statutory functions. Where we use your data for a business use, we do it to help inform us how to improve the way we work since both we and those we deal with have an interest in us doing so.

More particularly but not exclusively, we collect, use and share data in the exercise of the following functions:

Personal information that we collect may be used to inform our business of its market. We undertake research to gain more insight into our emerging business and to inform development, achieve regulatory objectives, comply with equality duties and inform decision making. We also prepare and publish statistics obtained from data we collect from you but not in a form that identifies anyone. This is to assist us with understanding the arrangements that we have to put in place to ensure that the application can operate appropriately and effectively. It may also inform our thematic work, for example, the data used collectively identifies trends about risks that either exist or are emerging in the market.

In many cases processing this data is necessary to provide a service you have requested (i.e. usage of the Twyn app).

When we receive complaints, we create a complaint file. Usually the file will contain the identity of the complainant and other people involved in the complaint. We usually have to disclose a complainant's identify to the person or entity involved. If a person making a complaint does not want to be identified we will try to respect that. Where we take action as a result of a complaint, where possible, we try to keep those making the complaint informed of progress.

When enquiries are sent to us we usually only use the information to handle the request or to deal with any later issues. We may also use information to help, check and improve our level of service. Where we do this, we do it to help inform us how to improve the way we work since both we and those we deal with have an interest in us doing so.

We keep personal information for as long as necessary to ensure we can fulfil our requirements as a business and at law.

We apply best practice in terms of information security and adopt a privacy by design approach in developing new systems and processes involving personal data, considering the rights of individuals and the risks involved to make sure we build in suitable controls. We are also alert to cyber security threats.

Depending on the information we hold about you, and the reason for us holding it, you have certain rights which are set out below. In some cases, exemptions disapply your rights.

If you have any concerns about the matters in this statement or the way we process your data, then you can you can email us.

We use:

Our partners operate internationally, and consequently your data may be transferred outside of the the U.K.. When this happens, we will endeavour to ensure that your privacy rights are adequately safeguarded.
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We also might share data with organisations who perform audit and assurance roles for us and those who provide professional advisory services.

We might work with third parties to carry out research. For example, if we need to collect certain data including special category data to monitor the diversity of our customer base or to identify trends.

In appropriate cases, personal information will be disclosed to regulators where required by Law.

International transfer of data occurs where we need to send information to our international contractual counterparts in connection with our processes. In such circumstances, the relevant individuals will not generally be informed that their data has been transferred.

Twyn is primarily delivered as a native mobile application which does not use cookies and other similar technologies.Cookies are used on our marketing and support websites for the purposes described above.

We keep this notice under regular review.