Who we are

Our website address is: https://twistmarketing.co.uk.

This privacy policy is for the website www.twistmarketing.co.uk and governs the privacy of its users who choose to use it.

The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy. We comply with all UK national laws and requirements for user privacy.  

Use of Cookies
Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website,, through its server, to provide users with a tailored experience.. Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive, they should take necessary steps within their web browser’s security settings to block all cookies from this website.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information [ http://www.google.com/privacy.html ].

Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

Contact & Communication
Users contacting this website and/or its owners, The Twist Group Ltd, do so at their own discretion and provide any such personal details requested at their own choice. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998 and in compliance with the General Data Protection Regulation (GDPR). Every effort has been made to ensure a safe and secure process through which our website visitors submit their details but we advise users that they do so at their own risk.

We use any information submitted for legitimate business reasons, to provide you with further information about the business services we offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program that the website operates but only if this was made clear to you and your express permission was granted when submitting any form to email process.  This is by no means an entire list of your user rights in regard to receiving email marketing material. Your details are NEVER passed on to any third parties.

Email Newsletter
We operate an email newsletter program, used to inform subscribers about our work, and services. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user. Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998 and in compliance with the General Data Protection Regulation (GDPR). No personal details are passed on to third parties nor shared with companies / people outside of the company that operates this website. Under the Data Protection Act 1998 you may request a copy of personal information held about you by this website’s email newsletter program. A small fee will be payable. If you would like a copy of the information held on you please write to the business address at the bottom of this policy.

Our email marketing campaigns may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list].

This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.

In compliance with the General Data Protection Regulation (GDPR) UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.

External Links
Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites).

We cannot guarantee or verify the contents of any externally linked website despite our very best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Platforms
Communication, engagement and actions taken through external social media platforms that we participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. We will never ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact us through primary communication channels such as by telephone or email.

We use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Shortened Links in Social Media
Through our social media platform accounts we may share web links to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses] (this is an example: http://bit.ly/zyVUBo). 

Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by The Twist Group Ltd. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore The Twist Marketing Group and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

What personal data we collect and why we collect it

Comments

When visitors leave comments on this website we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service we use to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture may be visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included, as this opens up to visitors to the website the chance to download and extract any location data from images on the website.

Cookies

If you leave a comment on our website you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

Embedded content from other websites

Articles on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this website, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

This section refers to the recording of activities of the site’s registered users. The retention duration of activity data will depend on activity type.

Cookies

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for one year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Activity Log

Data Used: To deliver this functionality and record activities around site management, the following information is captured: user email address, user role, user login, user display name, WordPress.com and local user IDs, the activity to be recorded, the WordPress.com-connected site ID of the site on which the activity takes place, the site’s Jetpack version, and the timestamp of the activity. Some activities may also include the user’s IP address (login attempts, for example) and user agent. Login attempts/actions, post and page update and publish actions, comment/pingback submission and management actions, plugin and theme management actions, widget updates, user management actions, and the modification of other various site settings and options. Retention duration of activity data depends on the website’s plan and activity type. 

Data Synced: Successful and failed login attempts, which will include the actor’s IP address and user agent.

Comment Likes

Data Used: In order to process a comment like, the following information is used: WordPress.com user ID/username, the local site-specific user ID (if the user is signed in to the site on which the like occurred), and a true/false data point that tells us if the user liked a specific comment.

Contact Form

Data Used: Where Akismet is enabled on the website, the contact form submission data — IP address, user agent, name, email address, website, and message — is submitted to the Akismet service (also owned by Automattic) for the sole purpose of spam checking. The actual submission data is stored in the database of the site on which it was submitted and is emailed directly to the owner of the form (i.e. the site author who published the page on which the contact form resides). This email will include the submitter’s IP address, timestamp, name, email address, website, and message.

Data Synced: Post and post meta data associated with a user’s contact form submission. Where Akismet is enabled on the site, the IP address and user agent originally submitted with the comment are synced, as well, as they are stored in post meta.

Google Analytics

Activity Tracked: This feature sends page view events over to Google Analytics for consumption. 

Gravatar Hovercards

Data Used: This feature will send a hash of the user’s email address (if logged in to the site or WordPress.com — or if they submitted a comment on the site using their email address that is attached to an active Gravatar profile) to the Gravatar service (also owned by Automattic) in order to retrieve their profile image.

Infinite Scroll

Data Used: In order to record page views via WordPress.com Stats (which has been enabled for page view tracking) with additional loads, the following information is used: IP address, WordPress.com user ID (if logged in), WordPress.com username (if logged in), user agent, visiting URL, referring URL, timestamp of event, browser language, country code.

Activity Tracked: Page views will be tracked with each additional load (i.e. when you scroll down to the bottom of the page and a new set of posts loads automatically). 

Jetpack Comments

Data Used: Commenter’s name, email address, and site URL (if provided via the comment form), timestamp, and IP address. Additionally, a jetpack.wordpress.com IFrame receives the following data: WordPress.com blog ID attached to the site, ID of the post on which the comment is being submitted, commenter’s local user ID (if available), commenter’s local username (if available), commenter’s site URL (if available), MD5 hash of the commenter’s email address (if available), and the comment content. Where Akismet (also owned by Automattic) is enabled on the site, the following information is sent to the service for the sole purpose of spam checking: commenter’s name, email address, site URL, IP address, and user agent.

Activity Tracked: The comment author’s name, email address, and site URL (if provided during the comment submission) are stored in cookies. Learn more about these cookies.

Data Synced: All data and metadata (see above) associated with comments. This includes the status of the comment and, if Akismet is enabled on the site, whether or not it was classified as spam by Akismet.

Likes

Data Used: In order to process a post like action, the following information is used: IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID (on which the post was liked), post ID (of the post that was liked), user agent, timestamp of event, browser language, country code.

Activity Tracked: Post likes.

Mobile Theme

Data Used: A visitor’s preference on viewing the mobile version of a site.

Activity Tracked: A cookie (akm_mobile) is stored for 3.5 days to remember whether or not a visitor of the site wishes to view its mobile version. Learn more about this cookie.

Notifications

Data Used: IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code. Some visitor-related information or activity may be sent to the site owner via this feature. This may include: email address, WordPress.com username, site URL, email address, comment content and follow actions.

Activity Tracked: Sending notifications (i.e. when we send a notification to a particular user), opening notifications (i.e. when a user opens a notification that they receive), performing an action from within the notification panel (e.g. liking a comment or marking a comment as spam), and clicking on any link from within the notification panel/interface.

Data Used: In order to check login activity and potentially block fraudulent attempts, the following information is used: attempting user’s IP address, attempting user’s email address/username (i.e. according to the value they were attempting to use during the login process), and all IP-related HTTP headers attached to the attempting user.

Activity Tracked: Failed login attempts (these include IP address and user agent). We also set a cookie (jpp_math_pass) for 1 day to remember if/when a user has successfully completed a math captcha to prove that they’re a real human. 

Data Synced: Failed login attempts, which contain the user’s IP address, attempted username or email address, and user agent information.

Data Used: Any of the visitor-chosen search filters and query data in order to process a search request on the WordPress.com servers.

Data Used: When sharing content via email (given Akismet is active on the site), the following information is used: sharing party’s name and email address (if the user is logged in, this information will be pulled directly from their account), IP address (for spam checking), user agent (for spam checking), and email body/content. This content will be sent to Akismet (also owned by Automattic) so that a spam check can be performed. Additionally, where reCAPTCHA (by Google) is enabled by the site owner, the sharing party’s IP address will be shared with that service. You can find Google’s privacy policy here.

WordPress.com Secure Sign On

Data Used: User ID (local site and WordPress.com), role (e.g. administrator), email address, username and display name. Additionally, for activity tracking (see below): IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code.

Activity Tracked: The following usage events are recorded: starting the login process, completing the login process, failing the login process, successfully being redirected after login, and failing to be redirected after login. Several functionality cookies are also set, and these are detailed explicitly in our Cookie documentation.

Data Synced: The user ID and role of any user who successfully signed in via this feature.

WordPress.com Stats

Data Used: IP address, WordPress.com user ID (if logged in), WordPress.com username (if logged in), user agent, visiting URL, referring URL, timestamp of event, browser language, country code. Important: The site owner does not have access to any of this information via this feature. For example, the site owner can see that a specific post has 285 views, but cannot see which specific users/accounts viewed that post. Stats logs — containing visitor IP addresses and WordPress.com usernames (if available) — are retained by Automattic for 28 days and are used for the sole purpose of powering this feature.

Activity Tracked: Post and page views, outbound link clicks, referring URLs and search engine terms, and country. When this module is enabled, Jetpack also tracks performance on each page load that includes the Javascript file used for tracking stats. This is exclusively for aggregate performance tracking across Jetpack sites in order to make sure that the plugin and code is not causing performance issues. This includes the tracking of page load times and resource loading duration (image files, Javascript files, CSS files, etc.). The site owner has the ability to force this feature to honor DNT settings of visitors. By default, DNT is currently not honored.

WordPress.com Toolbar

Data Used: Gravatar image URL of the logged-in user in order to display it in the toolbar and the WordPress.com user ID of the logged-in user. Additionally, for activity tracking (detailed below): IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code.

Activity Tracked: Click actions within the toolbar.

Resources & Further Information
GDPR
Data Protection Act 1998
Privacy and Electronic Communications Regulations 2003
Privacy and Electronic Communications Regulations 2003 – The Guide
Twitter Privacy Policy
Facebook Privacy Policy
Google Privacy Policy
Linkedin Privacy Policy
Mailchimp Privacy Policy

The Twist Group Ltd, 71 Grey Street, Newcastle Upon Tyne, NE1 6EF Tel: +44 0191 341 0045