PRIVACY AND COOKIE POLICY

The privacy policy below sets out and explains in detail what type of personal information we may collect and process about you when you interact with us. The policy also explains how we keep your data safe as well as how we store and handle it. We hope the information that follows answers any questions you have but if you have any questions, please do not hesitate to get in touch with us.

We take the privacy of your information very seriously and we keep our privacy policy under regular review and we’ll update it from time to time, it was last updated on 22nd May 2018. We’ll notify you by email of any significant changes but you’re welcome to come back and check it at any time. This Privacy Policy applies between you and us, and applies to any and all Personal Information collected by us or provided by you whether that interaction takes place online, by phone, in store or any other means.

Information about us

Twisk Shoes (International) ltd is the controller responsible for your personal information (referred to as “we”, “us” or “our” in this privacy policy). If you have any questions about this privacy policy or our use of your personal information you can contact us, and our data privacy co-ordinator, at this address or via email at info@twiskshoes.com .

What Personal Information we collect

In this privacy policy Personal Information means all information that arises from interactions between you and us, whether that interaction takes place online (including when you make an online purchase and check out as a guest), by phone, in-store. In this privacy policy Personal Information includes but is not limited to:
- Your identity and contact details: your name, gender, date of birth, home/postal/billing/delivery address, email address and telephone number
- Your shopping history with us: Orders placed and dispatched as well as details of your interactions with us online, in-store, by phone, live chat or any other means
- Additional personal details: profession and other demographic data you chose to give us to help us recommend things that may be of interest (e.g. you might tell us your shoe or clothing size to allow us to recommend appropriate items); Copies of documents (e.g. photos of shoes for repair or images for our tattooing service); your comments and product reviews.
- Information we collect when you use our website (“website” means www.Twiskshoes.com or its subdomains). As you interact with our website we automatically collect usage and technical data about your equipment, browsing actions and patterns. We collect this personal information using cookies, server logs and similar technologies.
- Payment Card information;
- Your image may be recorded on CCTV when you visit one of our shops (this is normally only stored for 7 days unless needed for security investigations);
- Your social media username, if you interact with us through those channels to help us respond to you;
- Your interactions with customer service where we will collect notes from our conversations with you, details of any complaints or comments you make and copies of any emails or documents you provide us with;
- Other information we receive from third parties we work with such as delivery services, credit reference agencies and fraud prevention agencies; and/or from publicly available sources (when you have given your consent to share information or where such information is made public as a matter of law);
We may also collect personal information through other marketing activities where you: Request that we send you marketing material (in either physical e.g. a catalogue or electronic e.g. email form) or where you enter a prize draw, competition, fill in a survey, fill in forms we provide to you and when you request to attend and event that we invite you to

Stopping the use of your personal information for direct marketing

If you no longer wish to receive direct marketing from Twisk Shoes there are several ways you can opt out of these communications from us:
- By clicking on the link in the footer of our emails
- By clicking on the unsubscribe from all link within our email preference centre
- If you have an account by logging into your account and changing your preferences
- By contacting customer services at info@twiskshoes.com
Please note that after you have changed your preferences you may continue to receive communications for a short time until our systems have fully updated.
We promise we will never release your details to any outside company for their mailing or marketing purposes.

Your Rights

You have the right to object to our use of your personal information. You also have the right to ask us to delete, remove or stop using it if there is no longer a need for us to keep it. If you think we should not be using your personal information please let us know. Please also be aware that there may be legal, regulatory or other official reasons why we may still need to keep or use your information.
Your rights under data protection laws in relation to your personal information are briefly summarised below. If you wish to exercise these rights you can do so by emailing us at info@twiskshoes.com.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal information, unless we incur costs from third parties in making that data available, in which case the fee will not exceed £50 and we will respond to all requests within 30 days.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with any concerns you may have before you approach the ICO so please contact us in the first instance.
In all instances any data collected will be collected in accordance with this privacy policy.

Explaining the Legal bases we rely on

The law on data protection sets out a number of different reasons for which companies may collect and process your Personal Information, including:
- Contractual Obligations In certain circumstances we need your Personal Information to comply with our contractual obligations. For example: when you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier
- Legal Compliance If the law requires us to, we may need to collect and process your data, for example we can pass on details of people involved in fraud or criminal activity to law enforcement
- Consent In specific situations, we can collect and process your data with your consent. When collecting your Personal Information, we’ll always make clear to you which data is necessary in connection with a particular service
- Legitimate Interest In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available personalised offers and to notify you of products, offers and services that we think might interest you. We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new Products and Services.

How we use your Personal Information

We want to provide you with the best possible customer experience with us. To achieve this we use your personal information in a variety of ways, including to:
- Process any orders online or in-store. If we are not able to collect your personal information during checkout we won’t be able to process your order and comply with our legal obligations.
- Process payments and prevent fraud. We do this on the basis of our legitimate business interest.
- Process your booking/appointment (for example with a delivery service). We do so to fulfil our commitment to you. Without sharing your personal information, we wouldn’t be able to fulfil your request.
- Update you on the status of your order: we or our delivery partners will contact you by email or phone (if you have provided your phone number) to inform you about when your product or service will be delivered.
- Provide an after sales service including cancelations and returns. We need to keep your details for a reasonable period in order to fulfil our contractual obligations to provide these. We may also keep a record of the information you have provided to us which will inform future communications with you and demonstrate how we communicated with you throughout the process. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service.
- Manage your account with us, where you have registered.
- Protect our business and your account from fraud and illegal activities. We will use your personal information to safeguard your account as part of our legitimate business interest, we will also monitor your browsing activity to identify and resolve problems.
- Administer, analyse, develop, test and improve our website, store performance and overall operational performance improve the systems, services and products we offer to you. We do this on the basis of our legitimate business interest.
- Send you survey and feedback requests to help improve our services. These messages will not include promotional material. We have a legitimate interest to do this as it helps improve our products and services and make them more relevant to you.
- Comply with our contractual or legal obligations to provide data to law enforcement. This includes processing personal information for purposes of preventing, detecting and identifying unlawful acts.
- Protect our premises, customers and staff we operate CCTV systems in our stores and record images for security we do this on the basis of our legitimate business interests.
- Send you communications required by law or which are necessary to inform you about changes to the services we provide you. For example, updates to our privacy policy or product recall notices. These messages will not include promotional material. We need to use your personal information to send these messages to comply with our legal obligations.
- Administer prize draws or competitions based on your consent at the time of entering. With your consent to receive direct marketing communications from us we may use the information you have given us to:
- Keep you informed about forthcoming events, products, services, special offers, events, competitions and other information about us (by email or by post);
- Measure and understand the effectiveness of any advertising we serve to you and others;
- Make suggestions and recommendations to you about goods and services that may be of interest to you.
You can of course change how we use your data and amend your marketing preferences at any time by logging into your account online or contacting our Customer Services team.
We sometimes share your personal information with trusted third parties for example:
- Service providers acting as processors based in the UK, EU, US, Africa and Asia who provide IT, system administration, operational, delivery and fulfilment services;
- Service providers (including payment acquiring service providers) acting as processors based in the UK, EU and US and India who provide sales order processing services;
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, EU and US who provide consultancy, banking, legal, insurance and accounting services.
- Tax authorities, regulators and other authorities acting as processors or joint controllers based in the UK, EU and US who require reporting of processing activities in certain circumstances;
- Credit reference and fraud prevention agencies acting as processors based in the UK, EU and US for credit checking and identify verification;
- Customer service call, email, display advertising, product review service providers and website behavioural service providers, acting as processors, based in the UK, EU, US and India;
- Direct marketing agents based in the UK, EU and US sending you marketing information on Twisk Shoe’s behalf;
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent, your acceptance of cookies in this Privacy Policy, our legitimate business interest, contractual obligations or legal compliance;
- Analytics and search engine providers as processors based in the UK, EU and US who assist us in the improvement and optimisation of our website.
Any Data used by our trusted third-parties is used only to the extent required by them to perform the services that we request of them. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the General Data Protection Regulation 2016.
When we share data with trusted third parties:
- We provide only the information they need to perform their specific services
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Data security is important to us and we know how much it matters to our customers as well. With this in mind we treat your data with the utmost care and attention and take all appropriate steps to protect it. We secure all transactional areas of our Website using Https technology. Access to your personal information is password-protected, and we do not store payment card information on our systems. All personal information is stored securely in accordance with the principles of the General Data Protection Regulation 2016. For more details on security see the clause below (Security).

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

How Long we keep your Personal Information

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about you (including contact data, name, address, email address, transaction history) for a minimum of six years after you buy something from us for tax purposes. We keep this basic information for seven and a half years following your most recent active interaction with us, to enable us to deal efficiently with any after-sales queries that you may have. We also keep basic information for warranty and/or recall purposes for a period of seven and a half years. We keep customer profile information that you have indicated you are happy for us to have in order to keep you up to date regarding our products, services and events and will keep this information until such time as you indicate you no longer wish us to keep this data.
Whenever we collect or process your Personal Information we’ll only keep it for as long as necessary for purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. In the event that we anonymise your Personal Information we may use this information indefinitely without further notice to you.

Security

Data security is of great importance to Twisk Shoes (International) ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
Password access is required for accessing your information within the My Account section of the Website, you are responsible for keeping your password confidential.
We endeavour to do our best to protect your personal information. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

Cookies

This Website may place and access certain cookies on your computer. A cookie is a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website
We use Cookies to improve your experience of using the Website and to improve our range of products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
All Cookies used by this Website are used in accordance with current UK and EU Cookie Law (the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011).
Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
This Website may place the following Cookies:
- Strictly necessary cookies: These are cookies that are required for the operation of our website. 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 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. 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, 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 choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings and items in your basket.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

Transfers outside the European Economic Area

Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which may be located outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA.
If we transfer Data outside the EEA in this way, we will take steps to ensure that the same level of protection is afforded to it by either:
1. the location where the data is being received has been approved by the EC as having appropriate protections in place;
2. our contract with the recipient holds the recipient to data protection obligations equivalent to those set out in the GDPR; or
3. if the recipient is in the US, they are part of the data “Privacy Shield”.

General

To use all features and functions available on the Website, you may be required to submit certain Data (Eg to place an order we will need to take your name, address and payment details).
You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Twisk Shoes (International) ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Twisk Shoes (International) ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us. We may also disclose Data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Changes to this privacy policy

We reserve the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

If you have any questions or require any more information please contact us at info@twiskshoes.com.

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