Privacy Policy

About this policy
TW Financial Ltd (trading as "TW") is committed to protecting and respecting your privacy. This policy describes how we collect, use and otherwise process personal information relating to you, or that you provide to us:

1.1.When you visit or use:
our platform at www.twfin.co.uk (the "Platform");
any of our computer or mobile software applications ("Apps");
our social media pages; and
any of the services accessible through the Platform (the Services); and
1.2.When you contact us (by email or telephone or in person), for example to request our news and updates or to submit a query or comment regarding the Platform or its content; and
1.3.Through offline sales and marketing activities.
Personal information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read this policy carefully to understand our practices regarding personal information.

By visiting the Platform, accessing one of our social media pages and/or using the Services, you are accepting to the practices described in this policy.

For the purposes of this policy, all references to the Platform shall include a reference to the Apps, and references to "TW", "we", "us" or "our" are to TW Financial Ltd, a company registered in England and Wales under company registration number 11311336 with our registered office at 18 Bridge House 6 Waterworks Yard, London, CR0 1UL.

For the purposes of data protection laws, the data controller is TW. In this Policy, the terms "personal data (or information)", "processing", "data controller" and "data processor" shall have the meaning ascribed to them in the General Data Protection Regulation ((EU) 2016/679).

What personal data do we collect?
2.1.Information that we collect from you

The type of information we collect from you will depend upon the type of interaction you have with us.

Broadly speaking, the types of personal data that we collect may include:

you are a customer of TW: your first and last name, email address, postal address, telephone number and the details of the transactions which you conduct using the Services;
if you are a job applicant, employee or contractor: your full name, contact details (including address, phone number and email address), identification details, job title, employment history and education details, names and contact details of referees, next of kin details, national insurance number or other information if required by law;
personal data that you provide by completing forms on the Platform, including if you sign up to receive our newsletter, search for a product, place an order on the Platform, request any information, or enter into any competition or promotion;
if you register or create account with us, your log-in and password details;
information contained in messages when you post on our social media pages;
information contained in communications you send to us, for example when you report a problem or to submit queries, concerns or comments regarding the Platform or its content; and
data from rating and feedback systems and surveys that we may, from time to time, run on the Platform for research purposes, if you choose to respond to, or participate in, them.
You are under no obligation to provide any such data. However, if you choose to withhold requested information, you may not be able to access all of the Platform's contents and services.

Payment processing services are provided by a third party. Any payment card details that you input when placing an order via the Platform are received directly by the payment service provider and will be subject to its terms of use and privacy policy. TW does not store any of your payment card details on its systems. By inputting payment card details, you are accepting that your payment card details may be used by the payment services provider for the purpose of paying for your order. If you have any questions relating to these services please contact the relevant payment service provider.

2.2.Publicly Available Information

We may also collect information relating to you that is available on the Internet, such as from Facebook, LinkedIn, Twitter and Google, or other publicly available information that we acquire from our service providers.

2.3.Website Navigational Information

We also collect personal data automatically when you use the Platform and when you navigate through the Platform. Data collected automatically may include information about your computer and your visits to the Platform, such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed, and other data collected through cookies and other tracking technologies. For more information, please see below:

During the search process, we will send data via cookie in the token,that will include the following information: First Name, Last Name, Company Name, Email Address and Phone Number.
During your use of the platform we will also send data via cookie related to our internal company data related to your account, that will include: User ID, Company ID, Role ID, Currency and Currency Exchange Rate.
During your use of the platform we will also use cookies from the Google Analytics platform in order to gather statistics on the volume of visits on each of the sections of the platform.

2.4.Managing your cookies

You can manage/delete cookies as you wish - for details, see aboutcookies.org.

Removing cookies from your device

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.

Be aware though that you may also lose some saved information (e.g. saved login details, site preferences).

Managing site specific cookies

For more detailed control over site-specific cookies, check the privacy and cookie settings in your preferred browser.

Blocking cookies

You can set most modern browsers to prevent any cookies being placed on your device, but you may then have to manually adjust some preferences every time you visit a site/page. And some services and functionalities may not work properly at all (e.g. profile logging-in).

How do we use personal data?
5.1.For the purposes of our legitimate interests

We use personal data relating to you that we collect, or that you provide to us, for the purposes of our legitimate interests as follows:

to respond to your queries;
to provide you with information, products or services that you request from us;
to provide you with information, products or services that we feel may interest you (including products or services of carefully-selected third parties), where you have expressly consented to be contacted for such purposes (please see paragraph entitled "Your rights" for further information);
to ensure that content from the Platform is presented in the most effective manner for you and for your computer;
to notify you about changes to the Platform and the materials on the Platform; and
as part of our efforts to keep the Platform safe and secure.
We may combine this data with personal data you give to us and personal data we collect that relates to you. We may use this personal data and the combined data for the purposes set out above (depending on the type of data we receive).

You have the right to object to this processing if you wish, and if you wish to do so, please send an email or write to us using the details provided in the Contact Us section. Please bear in mind that if you object this may affect our ability to carry out the tasks above for your benefit.

We will never sell personal data relating to you to any third party.

How do we share personal data with third parties?
We may disclose personal data relating to you to third parties in certain circumstances including (but not limited to) the following:

our suppliers who supply services that you order via the Platform directly or indirectly to you;
other third parties that we engage to help us run our business, such as payment processors and IT services suppliers;
analytics and search engine service providers that assist us in the improvement and optimisation of the Platform;
our professional advisors, including lawyers, accountants, tax advisors and auditors;
law enforcement bodies, Courts of law or as otherwise required or authorised by law; and
regulatory or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies.
We may also disclose personal data to third parties:

in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
if we restructure our business, or if we integrate our business with another group of companies, in which case personal data held by us will be disclosed to the new owner to be used in the same ways set out in this policy;
if we are under a duty to disclose or share personal data relating to you in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions on which we supply services to you Terms & Conditions and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
for any other purposes that you would reasonably expect.
Before TW discloses any personal data to a third party, we take steps to ensure that the third party will protect personal data in accordance with applicable privacy laws and in a manner consistent with this policy. Third parties are required to restrict their use of this information to the purpose for which the information was provided.

External Links
Although the Platform only looks to include quality, safe and relevant external links users should always adopt a policy of caution before clicking any external web links mentioned throughout the Platform.

The Platform may, from time to time, contain links to and from the websites of our distributors, partners, 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.

Social Media Platforms
Communication, engagement and actions taken through external social media platforms that we participate on are subject to the terms and conditions as well as the privacy policies of those social media platforms.

Where do we store personal data?
The personal data that we collect from you may be transferred to, and stored at, locations outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or service providers. These staff may be engaged in, among other things, the fulfilment of your order and the processing of your payment details.

Countries where personal data relating to you may be stored and / or processed, or where recipients of personal data relating to you may be located may have data protection laws which differ to the data protection laws in your country of residence.

By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.

Social Media Platforms
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect personal data relating to you, we cannot guarantee the security of such data transmitted to the Platform; any transmission is at your own risk. Once we have received personal data relating to you, we use strict procedures and security features to try to prevent unauthorised access.

All information you provide to TW is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology. The safety and security of your information and any personal data relating to you also depends on you. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform and/or the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

TW takes steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law to retain the information.

Your rights
You have the right to access personal data held relating to you. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. You will not have to pay a fee to access personal information relating to you (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We also want to make sure that personal data relating to you that we hold is accurate and up to date. You may ask us to correct or remove any information you think is inaccurate.

You also have the right, in certain circumstances, to:

the erasure of personal data relating to you that we hold;
the restriction of processing of personal data relating to you that we hold; and
object to our processing of personal data relating to you that we hold.
Requests in this section should be sent by email or by writing to us using the contact details set out at the end of this policy.

We will only send you marketing material if you consent. When you have consented to marketing material, you have the right at any time to ask us not to process personal data relating to you for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the marketing emails we send to you. You can also exercise the right at any time by sending an email or by writing to us using the contact details set out at the end of this policy.

If you have a concern about the way we are collecting or using your personal information, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner's Office at https://ico.org.uk/concerns.

Changes to this policy
TW reviews and amends its privacy policy from time to time. Any changes we make to this policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check this page occasionally to review any updates or changes to this Policy. This helps you be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed.

11.Contacting Us
If there are any questions regarding this privacy policy, you may contact us using the information below.

TW Technologies Ltd
Bridge House 6 Waterworks Yard
London CR0 1UL.

Email: info@twfin.co.uk

Phone: +44 (0) 020 8287 6575