Three Twists

... making accessible media affordable

Privacy Policy

Last Update: 18 May 2021

Scope

This GDPR-compliant privacy policy applies to this website and its subdomains (the “Site”), all of which are owned and operated by Three Twists Ltd. It does not apply to any third-party websites, which have their own policies. Throughout this policy, when we say Three Twists Ltd, we mean our company, including any Three Twists Ltd website, and when we say Services we mean the various products and services, and apps we make available to you through our Site, including our payments, payroll, accounting, invoicing services, and other small business–related services and support.

By “Personal Information”, we mean information about an identifiable individual. That’s what this policy is about – our collection, protection, use, retention, disclosure and other processing of Personal Information and your rights relating to these activities.

We use Personal Information in order to provide you and your business with the Services that we offer.

Our Privacy Policy is based on the following principles:

Accountability and Challenging Compliance

Three Twists Ltd has a Privacy Officer who is responsible for all things privacy at Three Twists Ltd. This includes our policies and procedures that are designed to keep your information safe. If you have any questions about our privacy practices or this policy, you can contact us at:

Email: hello@threetwists.net
Post: 43 Murdock Avenue, Ashton-on-Ribble, Preston, PR2 2BL
Telephone: 01772 34 24 14

If you’re not satisfied with our response, you have the option of contacting the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/

Identifying Purposes

Three Twists Ltd collects, uses, discloses, and otherwise manages Personal Information in a variety of ways related to the Services we provide. We’ve outlined these below. Your use of the Services determines which information we collect and use. For example, payroll information is optional, unless you’d like to use Payroll by Three Twists Ltd to run payrolls, at which point we will need to collect payroll information in order to provide you with this service. Similarly, when you create an invoice, your customer’s email is optional, but if you’d like to us to deliver the invoice by email, this information becomes necessary.

Three Twists Ltd may collect, use, store, or disclose your Personal Information for the purposes described below.

  • In order to provide you with the Services.
  • To promote or offer you products or services, and to determine your eligibility for new services we may offer from time to time.
  • To provide you with educational materials and guides relevant to the Services you use.
  • To contact you for the purposes of Service updates and system and account notifications.
  • To provide you with support in connection with the Services.
  • To comply with any laws, regulation, court orders, warrants, inquiries, subpoenas or other legal processes or investigations, and to protect ourselves, other individuals, or property from harm.
  • In connection with a prospective or completed merger or sale (including insolvency or bankruptcy proceedings) involving all or part of Three Twists Ltd or as part of a corporate reorganization or stock sale or other change in corporate control.

We will never sell your Personal Information to other companies.

Consent

Three Twists Ltd takes a consent-based approach to the collection, use and disclosure of Personal Information.

Submitting the Personal Information of others

When you submit the Personal Information of your customers or employees to us, you are responsible for informing such customers and employees about Three Twists Ltd, and for obtaining any necessary consent or authority from them.

You may also choose to refer someone to our Site. We will send them a single invitation email to the address you provide. Please ensure that you only submit email addresses of individuals or businesses with whom you have a relationship and who would want to receive the message.

Closing your Three Twists Ltd account

At any time and without penalty, Three Twists Ltd users can withdraw their consent to the continued use or disclosure of their Personal Information by closing their Three Twists Ltd account. Please ensure you complete the account closure process which includes a confirmation email. Otherwise, your account may not be closed.

Email and communications consent

At any time, you can opt-out of commercial email communications from us by clicking on the unsubscribe link in such emails, or via the Email Preferences settings in your account. Certain non-commercial communications may still be sent to you that are required to provide you with our Services. For example, system notifications, major product changes, changes to our Terms of Use, or other news that we believe will materially affect how you interact with Three Twists Ltd.

The only way to completely stop all emails from Three Twists Ltd is to close your account as outlined above.

Limiting Collection

Three Twists Ltd only collects the Personal Information necessary to provide the Services to you. The Services you use will determine which information Three Twists Ltd collects. We’ll also provide you the option of sharing additional information to enhance your Three Twists Ltd experience.

Three Twists Ltd may also use third-party services to supplement or enrich our understanding of our customers. This includes cross-referencing information like a name, business name, email address or IP address in third-party databases, and using the information there to improve our understanding of you and your business.

Three Twists Ltd is not intended for children and we do not knowingly or intentionally collect information about individuals under the age of eighteen (18).

Some of the Services allow you to provide access to your Three Twists Ltd account to other authorized users, whom we call “Agents”. Agents have access to information in your Three Twists Ltd account, including Personal Information, and may perform various tasks on your behalf. You take full responsibility for any collection, use or disclosure of your Personal Information by your Agent(s).

To provide access to your account to an Agent, you must provide the Agent’s name and email address. We will send them a single email inviting them to the Site. Three Twists Ltd only uses this information to invite your Agent. Please ensure that you only submit email addresses of individuals or businesses that you have a relationship with and who would want to receive the message. The Agent may contact us at hello@threetwists.net to request that we remove their name and email address from our database.

Limiting Use, Disclosure and Retention

We will use your Personal Information as described in this policy.

We will share your Personal Information with third parties only as described in this policy.

We will retain your information for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required by law or regulation. To be clear, that means we’ll retain your Personal Information while you have an active account, and afterward if we need to do so to meet our legal obligations. If you choose to close your Three Twists Ltd account, we will destroy your Personal Information within 60 days unless we are otherwise obliged to keep it longer.

Accuracy

Three Twists Ltd relies on you to provide us with information that is accurate and complete. We provide you the mechanisms and rely on you to keep your information up to date. You can request updates or corrections of any inaccuracies in your Personal Information at any time by contacting us at the contact information listed in the policy. We will respond to your request within a reasonable timeframe.

Safeguards

Three Twists Ltd uses a combination of reasonable and appropriate safeguards designed to protect your information. These safeguards are administrative controls (things like policies, procedures, and training), technical controls (things like encryption, firewalls, and secure coding frameworks), and physical controls (secured hosting environments).

We ensure that any third party acting on our behalf maintains reasonable and appropriate safeguards in respect of your Personal Information. Additional information about our third parties’ privacy practices is available upon request.

If you have questions about security on our Site, you can contact us at hello@threetwists.net.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or your password for the Services to third parties. Our team will never request your password or PIN, and we ask that you never post account or credit card numbers to our support channels.

Openness

This policy outlines our privacy practices. If you have questions about it, please contact our Privacy Officer.

Individual Access

You may access, update and correct inaccuracies in the Personal Information in our custody or control at any time, subject to limited exceptions prescribed law. You can download or export data you input into the Site at any time, or to correct inaccuracies, simply log in to your account and make the necessary changes.

You can also request access, corrections or updates to all your Personal Information, including information not available through your account, by contacting us as set out in the Challenging Compliance section of this document. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Additional Details

Order Information

When you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (the payment processor chosen), email address, and phone number. We refer to this information as “Order Information.”

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

  • Communicate with you;
  • Screen our orders for potential risk or fraud; and
  • When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

Testimonials

If you provide us with a testimonial, with your consent we may post it on our Site or in other materials and media, along with your name. If you want your testimonial removed, please contact us at hello@threetwists.net.

Social Media

You may engage with us through social media sites. When you engage with us on these sites, we may have access to certain information about your account (e.g., name, username). These sites may collect your IP address, how you’re engaging with us, and may use cookies to enable the site to function properly. We may use this information to personalize your experience and to provide you with other products or services you may request.

Service Providers

We may transfer (or otherwise make available) your personal information to third parties who provide services on our behalf. For example, we may use service providers to host our website and to process payments. Your Personal Information may be maintained and processed by these third parties in other jurisdictions, like the U.S. – when your information is in another jurisdiction, it will be subject to their laws. We only share the information these service providers need to do their job and we don’t authorize them for any other use or disclosure of personal information.

Visiting the Site

In general, you can visit the Site without telling us who you are or submitting any Personal Information. However, we and/or our service providers (such as Google Analytics) collect IP (Internet protocol) addresses from all visitors to the Site and other related information such as page requests, browser type, operating system and average time spent on our Site. We also use Google Analytics to help us understand how our customers use the Site – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Cookies, Tags, and Web Beacons

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

Technologies such as cookies, web beacons, tags and scripts are used by Three Twists Ltd, our advertising and analytics service providers (such as Google analytics), and affiliates to analyse usage trends, administer the Site, and to gather demographic information about our user base as a whole.

A cookie is small piece of data that our Site can send to your browser, which may then be stored on your device so we can recognize you when you return. We use cookies for session tracking to make it possible to navigate the secure environment inside our Site. These cookies (1) may let us know who you are, (2) are necessary to access your account, and (3) will give us information that we can use to personalize our Site according to your preferences.

You can control the use of cookies in your browser. If you disable cookies, you will not be able to access your account or take advantage of all of the features of the Site.

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

Notification of Privacy Policy Changes

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our website prior to the change becoming effective. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices.