PRIVACY POLICY

OVERVIEW

United Twirl England values your privacy and is fully committed to adherence to our obligations under UK Data Protection law.

This privacy policy (“policy”) explains how we use any personal information we collect about you when you use this website (https://unitedtwirlengland.org) (“Site“) and our wider services.

This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (as defined below). The Site is operated by United Twirl England (hereinafter referred to as “UTE“, “we“, “us” and “our“). United Twirl England is the Data Controller of personal data collected by, or which you provide through, the Online Facilities, for the purpose of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

WHAT PERSONAL DATA DO WE COLLECT?
Personal Data provided by you

Personal data about you upon registration and form submissions – You will be asked to provide your name, email address and other personal details to either establish an account, purchase something or complete a form.

We will provide you with a separate notice at the time of collection, if the use of that Personal Data differs from the uses disclosed in this Privacy Policy.

Personal Data as you use our Site or Services
We will collect information about you as you use the Site or Service, such as your IP address, browser type and version, operating system, referral source and device information. Through tracking services, we will collect information about you such as length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your usage, operating system, device information, behaviour, visited pages, etc. This anonymous information can not be identified directly with you.

We collect information about purchases you’ve made through our Site or Services, such as product type, subscription type, date of purchase, etc.

Personal Data about you if you visit as a guest
Certain limited Services are available without being required to log in to or establish an Account, also referred to as Guest Usage, such as visiting our public site, accessing a download or upload link and others. We will collect information about you such as length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your service usage, operating system, device information, behavior, visited pages. This anonymous information can not be identified directly with you.

Personal Data about you from third-party sources

Personal Data from payment processors: we will collect information about you from payment providers when you purchase products offered on the Site or Service. Information varies per payment providers but might include: your IP address, country, email, post code, name, last four digits of your card.

Other information we collect related to your use of our Sites or Services
We may collect additional information from or about you when you communicate with us or contact us via one of the website forms.

HOW DO WE PROCESS PERSONAL DATA?

We use information held about you in the following ways:

Information you give to us. We will use this information:

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
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;
to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you based on your previous engagement with UTE (which is based on your registration/purchase/browsing history), or based on the preferences set in your ‘profile’. You can withdraw your consent at any time by changing these preferences.
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site 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;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

DO WE SHARE YOUR PERSONAL DATA?

We do not sell, rent, or otherwise provide personally identifiable information to third-parties without your consent.

In addition, there are some other reasons why we may disclose your personal information to third parties and these are as follows:

to other companies within our group;
to appoint other organisations to carry out some data processing activities on our behalf; For example, mailing services, payment processing, hosting service providers, other relevant partners used to help us deliver the Online Facilities to you and to check your details against the Telephone Preference Service;
If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about customers will be one of the transferred assets;
If we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply any of our other applicable terms and conditions for products, services, content or access provided by us (for example our ground regulations) and other agreements; and/or
to protect the rights, property, or safety of us, our commercial partners, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

HOW DO WE USE COOKIES AND TRACKING TECHNOLOGIES?

We use cookies (a small text file placed on your computer to identify your computer and browser) on the Site. We use cookies to improve the experience of the Site and Services, such as pre-populating your username for easier login and preserving your user session. We do not use cookies to collect Personal Information.

WHAT PRIVACY CHOICES ARE AVAILABLE TO YOU?

United Twirl England want to give you maximum control over your personal data. Learn here how you can manage your information.

WHAT ARE YOUR RIGHTS?

Under the UK GDPR, you have the following rights in relation your data

The right to be informed – this Policy informs you about the data we hold and your rights in relation to that data.

The right of access – If you wish to receive a copy of some or all of the information we hold on you, please write to or email the Data Protection Officer:

Email: info@unitedtwirlengland.org

The right to rectification – If, at any time after registering, you would like to update your data, you can do this via your personal profile page, which is accessible from your account.

The right to erasure – You (and any parent/guardian of a minor) have the right to request that we close your account and/or delete your personal information from our database. We will make all reasonable efforts to comply with this request. However, it may not be possible to delete an entry without some delay and without retaining some residual personal information necessary for our legitimate interests, such as backups and records of deletions (including to ensure we no-longer communicate with you) or because we are required or permitted to retain personal information for other lawful requirements.

The right to restrict processing – In certain circumstances, you have the right to request that we limit the way we use your data. This is an alternative to requesting the erasure of your data.

The right to data portability – This is not really relevant to the data UTE holds for you as the main purpose is to enable consumers to take advantage of applications and services which can use their personal data to help find a better deal (e.g. through price comparison websites), or gain a better understanding of your spending habits (e.g. through banking apps).

The right to object – At any time, you have the right to change your preference and opt-in or opt-out from receiving communications from us or third-parties. You can do this at any time by changing your preferences your personal profile page

Rights in relation to automated decision making and profiling – you have the right not to be subject to a decision when that is based on automated processing which produces a legal effect or a similarly significant effect on you without your consent. We can confirm that do not use your data to make automated decisions that could have this effect on you.

Retaining your personal data – We will keep the personal data you have provided for as long as we have a relationship with you. Once that relationship has ended we will only keep enough information needed to deal with any queries (e.g. to enable us to deal with any future complaints or queries you may have about any products or services you had from us in the past).

Special category (sensitive) information –We do not intend to collect special category (also known as sensitive) personal information through our websites unless we are legally required to do so, or you volunteer this information to us in order for us to help improve your experience with the UTE.

If you have any queries about this Policy, please contact the Data Protection Officer (contact details as above)

If you are dissatisfied with our response to any of your data privacy concerns you have the right to raise this with the Office of the Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (https://ico.org.uk). We may need to change the terms of this Policy from time to time and changes will be posted on this page (and/or where appropriate, otherwise notified to you).

CAN CHILDREN USE OUR SERVICES?

The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.

UPDATES OR CHANGES IN PROCESSING

If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

We keep this Privacy Policy under regular review and we will place any updates on this web page https://unitedtwirlengland.org/privacy-policy.

In other circumstances, if we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will become effective on the revision date, shown in the revised Privacy Policy. Your continued use of our Site or Services constitutes your consent to the revised Privacy Policy.

CONTACT US
You may contact us if you have general questions or concerns about this Privacy Policy and supplemental notices or the way in which we handle your Personal Data. Our Data Protection Officer can be contacted at info@unitedtwirlengland.org

Revised: September 2024