Privacy and Cookie Policy

Thwaites Communications (“We”) are committed to protecting and respecting your privacy.

This policy ( and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting you are accepting and consenting to the practices described in this policy.

For the purpose of the UK data protection laws, the data controller is Thwaites Communications Limited at 231 Shoreditch High Street, London, E1 6PJ.

Information we collect from you

We will collect and process the following data about you:

  • Information you give us. This is information about you that you give us by filling in forms on our website www.thwaitescommunications.net (our site), or through use of our mobile application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device or by corresponding with us by telephone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, use our App and any of the services accessible through the App (Services), use our call centre services and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, the telephone number of the mobile telephone or handheld device (Device), username, password and other registration information, financial and credit card information, personal description and photograph.
  • Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
  • technical information, including:
    • the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting, (Device Information);
  • information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content, and check ins (Content Information);
  • details of your use of any of our Apps or your visits to our site including, but not limited to traffic data, and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (Log Information).
  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you 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), methods used to browse away from the page, and any phone number used to call our customer service number.

We may use the information we collect from you for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

Purposes for which we will use the information you give to us Legal basis
To carry out our obligations under any contracts entered into between you and us and to provide you with the information, products and services that you request from us. It will be necessary for the performance of the contract between you and us. Please see any contracts we have with you for further details.
To notify you about changes to our products and services. It will be necessary for our legitimate business interests to ensure you are aware of the latest updates to the products and services we provide, or may provide, to you.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about. We will only do this if you agree, either by ticking the relevant box on the customer registration form or by some other specific, informed and unambiguous method.
To provide you with information about goods or services we feel may interest you by electronic means (email or SMS). We will only do this if you agree, either by ticking the relevant box on the customer registration form or by some other specific, informed and unambiguous method.
To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you by electronic means (email or SMS). We will only do this if you agree by some specific, informed and unambiguous method.
To create you an account in order to provide you with a personalised way to access our services. It will be necessary for the performance of the contract between you and us.
To provide you with information or intelligence about your areas of business, market insights or media monitoring that we feel may interest you by electronic means. We will only do this if you agree by some specific, informed and unambiguous method.

 

It is a contractual requirement for you to provide us with certain information, namely the information that we need to use in order to carry out our obligations under any contracts entered into between you and us. If you do not provide us with that information, we will not be able to carry out our obligations under any contracts entered into between you and us and will be unable to provide you with the information, products and services that you request from us.

All other information you give us is given entirely as your discretion. If you do not provide that information, that we may be unable to notify you about changes to our products and services, or provide you with information about other products and services.

Information we collect about you from other sources

This is information we receive about you (including: name, address and contact details) if you use any of the other websites or apps we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

We may use the information we collect about you for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

Purposes for which we will process the information Legal basis for the processing
To administer our website or application and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

to improve our site or application to ensure that content is presented in the most effective manner for you and for your computer;

to allow you to participate in interactive features of our service, when you choose to do so;

as part of our efforts to keep our site safe and secure;

to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising to you; and

to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website or application.

Disclosure of your information

You agree that we have the right to share your personal information with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
  • Selected third parties including:
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

Our Third Party Suppliers include:

  • IT Guy
  • Xero
  • Google

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Thwaites Communications or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Thwaites Communications, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Email mailing list & marketing messages

We operate an email mailing list programme, used to inform subscribers about news we publish. Users can subscribe through an online automated process and they have to give their explicit permission. Subscriber personal details are collected, processed, managed and stored in accordance with the regulations named above. Subscribers can unsubscribe at any time through an automated online service. The type and content of marketing messages subscribers receive, and if it may contain third party content, is clearly outlined at the point of subscription.

Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data. Our EMS (email marketing service) provider is MailChimp and you can read their privacy policy in the resources section.

Where we store your personal data

We store data on Cloud services such as GoogleDrive who servers are stored outside the UK.

Whenever we transfer your personal data out of the European Union (“EU”), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 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.

How long we will store your personal data

The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:

Legal basis Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us We will use/store your data for as long as it is necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for our legitimate business interests We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data)
Where we use/store your data because you have given us your specific, informed and unambiguous consent We will use/store your data until you ask us to stop

 

Your rights

You may have various legal rights in relation to the information you give us, or which we collect about you, as follows:

  • You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
  • You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
  • You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
  • You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
  • You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
  • Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
  • Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
  • You have the right to object to us using/storing your information for direct marketing purposes.

If you wish to exercise any of your legal rights, please contact us by writing to the address at the top of this policy, or via our contact form on our website and application.

You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.

Our application and website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Automated decision-making

We do not use automated decision-making processes.

External website links & third parties

Although we only look to include safe and relevant external website links on Thwaites Communication’s website and our social media channels, users are advised to approach all external website links with caution before clicking on them.

URL shortening is a technique used on the web to shorten URL’s (Uniform Resource Locators) to something substantially shorter. This technique is often used in social media and looks similar to this (example: http://bit.ly/zyVUBo). Users should be cautious about clicking on shortened URL links and seek to verify their authenticity first.

We cannot guarantee or verify the contents of any externally linked website. Users should therefore note that they click on external links at their own risk. Thwaites cannot be held liable for any damages or implications caused by visiting any external links.

Social media policy & usage

While Thwaites Communications and our staff may have official profiles on social media platforms, users are advised to verify authenticity of such profiles before engaging with, or sharing information with such profiles. We will never ask for user passwords or personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with us on social media. There may be instances where our website features social sharing buttons, which help share web content directly from web pages to the respective social media platforms. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You can find further information about some social media privacy and usage policies in the resources section below.

Cookies

Our website and application uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website/app. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website/app when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website/app. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website/app, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Purpose
Google Analytics cookies Thwaites Communications uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of the site.

Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using the site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

How to reject or delete this cookie: http://www.google.com/intl/en/privacypolicy.html

 

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website/app.

Except for essential cookies, all cookies will expire after a maximum of two years.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Emma Thwaites in writing to the address at the top of this policy, or via our contact form on our website.

Resources & further information

Overview of the GDPR – General Data Protection Regulation

Data Protection Act 1998

Privacy and Electronic Communications Regulations 2003

The Guide to the PECR 2003

Twitter Privacy Policy

Facebook Privacy Policy

Google Privacy Policy

LinkedIn Privacy Policy

MailChimp Privacy Policy