Data Protection Policy
At Twisted Hygiene & Packaging we are committed to protecting your privacy and your personal information. Our data protection policy gives you detailed information on why we collect your personal information, how we use it and how we store it. This policy applies to information obtained directly by us and not through interactions with third parties.
We collect data from our customers after any point of contact via email, telephone call, visits to our website or through meeting with a member of staff. We do not share any public or private information (other than when we are legally obligated to) without your consent and we do not sell or exchange your information with any information to third parties.
We implement a variety of security measures to maintain the safety of your information. All data is held on a secure server. This data is held on a secure password protected custom built computer software system. Levels of access are restricted for what is required.
As an individual you have the right to access the details we hold on you or to ask us to delete, correct or complete any information we hold. If you would like to know what we hold on file, please fill in the contact form on the ‘contact us’ page and we will be in touch.
The policy applies to the products and services we offer to you as a company or an organisation. It also applies if you are not one of our customers but interact with us by:
- Using one of our products
- Calling our customer services
- Generally enquiring about our products or services.
You can access and update the information we hold about you through our online contact form. Once we have looked at your request, we will be in touch to let you know what to expect from us. We will always try to help you with your request but we can refuse if we believe doing so would have a negative effect on others or if the law prevents us from sharing this information. Although we will complete your request free of charge, we are allowed to reject requests if:
- They are repetitive
- You don’t have the right to access the information
- The request made is excessive
If this is the case then we will explain why the request is unable to be fulfilled.
If you want us to stop using personal information we’ve collected via cookies on our website or apps, you should either change your cookie settings for your app or in your browser settings. In some cases, we might decide to keep information, even if you ask us not to. This could be for legal or regulatory reasons, so that we can keep providing our products and services, or for another legitimate reason. For example, we keep certain billing information to show we have charged you correctly. But we’ll always tell you why we keep the information.
We aim to provide our products and services in a way that protects information and respects your request. Because of this, when you ask us to delete or change your information from our systems, we might not do so straight away from our back-up systems or copies on our active servers. And we may need to keep some information to fulfil your request (for example, keeping your email address to make sure it’s not on our marketing list).
If we’ve asked for your permission to provide a service, you can withdraw that permission at any time. It can take us up to 30 days to do that. And it only applies to how we use your personal information in the future, not what we’ve done in the past (for example, if we’ve run a credit check at the start of your contract).
We have explained the different ways we use your personal information below.
Managing Your Account
We use the following to provide products and to manage your account:
- Name and Surname
- Company Registration Number
- Business Trading Name
- Email address
- Date of Birth
- Contact phone number(s)
- Purchase information
- Interactions with us including emails and phone calls
- Delivery address(s)
- Billing address
- Preferred delivery dates
- Appointments made with sales reps
- We keep records of any settings or communication preferences you choose
This information is used to provide products or services to you. If you don’t give us the correct information or ask us to delete it, we might not be able to provide you with the product or service you ordered from us.
We may use this information to send you direct marketing and to better identify products that interest you. We do that if you’re one of our customers or if you’ve been in touch with us.
This means that we:
- create a profile about you to better understand you as a customer
- tell you about other products that may be of interest
- recommend better ways to manage what you spend with us, like suggesting a more suitable product based on what you use;
- try to identify products that you are interested in; and
- show you more relevant products and work with other well-known brands to make theirs more suitable to you
We may send you information (about the products we provide) by phone, post, email, text message or online advertising. We may use the information we have about you to personalise these messages wherever we can as we believe it is important to make them relevant to you. We do this because we have a legitimate business interest in keeping you up to date with our products and services, making them relevant to you and making sure you manage your spending with us. We also check that you are happy for us to send you marketing messages by text or email before we do so. In each instance, you also have the option to opt out.
Before we provide you with our products or sometimes when you use our products, we use the personal information you have given us together with information we have collected from credit reference agencies (such as Equifax), or fraud prevention agencies. We use this information to manage our credit risk, and prevent and detect fraud and money laundering. We may also use these organisations to confirm your identity. When they get a search from us, a 'footprint' goes on your file which other organisations might see. We might also share the information with other organisations because it’s in our, and the organisations’, legitimate interests to prevent fraud and money laundering, and to check identities, to protect our business and to keep to laws that apply to us.
Details of the personal information that can be used include your name, address, date of birth, contact details, financial information. If you don’t become one of our customers, we may still keep the result of our credits checks about you if we have a legal obligation and it’s in our legitimate interests to help prevent or detect fraud. Fraud prevention agencies can hold your personal information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your information can be held by us and the organisations we share it with for up to six years.
If you give us false or inaccurate information which we identify as fraudulent, we may pass that on to fraud prevention agencies. We might also share it with law enforcement agencies, as may the agencies we have shared the information with.
If you tell us you’re associated with someone else financially (for example, by marriage or civil partnership), we will link your records together. So you must make sure you have their agreement to share information about them. The agencies we share the information with also link your records together and these links will stay on your and their files – unless you or your partner successfully asks the agency to break that link.
If we, a credit reference or fraud prevention agency, decide that you are a credit, fraud or money laundering risk, we may refuse to provide the financing you have asked for, or we may stop providing existing services to you.
The credit reference and fraud prevention agencies will keep a record of any fraud or money laundering risk and this may result in other organisations refusing to provide services, financing or employment to you. If you have any questions about this, please get in touch with us using the contact details on our contact page.
We may send credit reference and fraud prevention agencies information about applications, and they keep that information. We might also give them details of your accounts and bills, including how you manage them. This includes telling them about your account balances, what you pay us and if you miss a payment (going back in the past, too). So if you don't pay your bills on time, credit reference agencies may record that. They, or a fraud prevention agency, might tell others doing similar checks – including organisations trying to trace you or recover money you owe them.
There are different credit reference agencies in the UK (for example, Callcredit, Equifax and Experian). Each one might hold different information about you. If you want to find out what information they have on you, they may charge you a small fee.
Whenever credit reference and fraud prevention agencies transfer your personal information outside of the European Economic Area, they place contractual responsibilities on the organisation receiving it to protect your information to the standard required in the European Economic Area. They may also make the organisation receiving the information subscribe to ‘international frameworks’ aimed at sharing information securely.
If you don’t pay your bills or if you fail to pay within your set time period, we might ask a debt-recovery agency to collect what you owe. We’ll give them information about you (such as your contact details) and your account (the amount of the debt) and may choose to sell the debt to another organisation to allow us to receive the amount due.
With Law Enforcement Agencies
Under investigatory powers legislation, we might have to share personal information about you to government and law-enforcement agencies, such as the police, to help detect and stop crime, prosecute offenders and protect national security.
They might ask for the following details.
- Your contact details. This includes your name, gender, address, phone number, date of birth, email address, passwords and credentials needed to confirm your identity and your communications with us
- Your communications with us, such as calls, emails and texts
- Your payment and financial information
- Details of the products and services you’ve bought and how you use them
The balance between privacy and investigatory powers is challenging. We share your personal information when the law says we have to, but we have strong oversight of what we do and get expert advice to make sure we’re doing the right thing to protect your right to privacy. We’ll also share personal information about you where we have to legally share it with another person. That might be when a law says we have to share that information or because of a court order.
We may ask if you want your details included in our Phone Book. We do not share that information with any third parties or directory services.