Data Privacy Notice
Your data and privacy are important and we will handle them securely, fairly and legally at all times. Apply To Model is a trading as name for Twisted Logistics Limited, of which complies fully with the General Data Protection Regulation (GDPR) and below we tell you about what data we collect and how we store and use it.
What Information Do We Collect?
We keep all the data that you give us. This information is kept online and at our offices and it can be updated by you at any time. These are things like your name, address, email, telephone number, proof of age etc.
Websites that we own and operate that allows card payments to be made do not collect or store credit card details, this kind of information could be collected and stored by those we have contracted as payment processors. They do NOT keep or even see your CVV security number.
If you call us we will record the call so that we have a record of what has been said. Similarly, we keep a record of all contact with you via email and chat platforms such as Skype, iMessage, WhatsApp etc.
What Information Do We Not Collect?
We don’t see and therefore do not store or use your credit/debit card security number (CVV).
We regularly delete stored voicemails, faxes and text messages.
Where We Keep Your Data – Security
The security of your personal data is a very major concern for us. We have legal obligations to keep it safe and handle it with care and the penalties for not doing so are very high.
We store your personal data securely and it’s backed up in two geographically separated locations so that it cannot be lost in the event of a catastrophic failure in our data centres or systems.
How Do We Use Your Information?
The GDPR says that we are allowed to use and share your personal data only where we have a proper reason for doing so.
The permitted Legal Bases for processing are set out in article 6 of the GDPR. At least one of these must apply whenever we process your personal data:
- Consent: you have given clear consent for us to process your personal data for a specific purpose (for example, marketing).
- Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
- Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
- Vital interests: this process is necessary to protect someone’s life.
- Public task: this process is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
- Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data that overrides those legitimate interests.
Here is a list of the ways that we may use your personal information, and which of the Legal Bases outlined above we rely on to do so.
Business Function Why we use your Personal Information Our Reasons (Legal Basis)
Sub-contractors – Sub-contractors are required to provide proof of age and we maintain and store physical and electronic copies in two geographically separate locations. We are also required to share this information with some of our suppliers – Legal Requirement – Legitimate Interest
Customers – We collect and store customers names, postal addresses (as given) and account information which includes purchase history – Legitimate Interest – Service
Customer Services – To provide you with customer services and support via phone and email – Legitimate Interest – Service Notifications
Notification – Informing You Of New Products & Services
Informing You of Regulatory Changes – Service Changes, Marketing, Informing you of new products, services which include third-party marketing, goods & services. – Consent – Website Analytics – To Obtain Statistics on The Usage Of Our Website(s) – Legitimate Interest
Who We Share Your Information With And Why
Twisted Logistics Limited works with a number of trusted suppliers to provide the high-quality services you expect from us. In all cases, our suppliers have been carefully vetted and only the minimum personal data is shared in order to fulfil our legal responsibilities and your orders or provide the services you have requested.
Your data may be shared with the following categories of third parties:
- Affiliate Management Suppliers – to enable our affiliate managers to comply with their own legal obligations.
- Delivery Companies – if you order good from us.
- Payment processors – to enable you to make online payments for our products and services.
- Emergency services – Contact details must be provided to the Emergency Services should an incident arise.
- Website analytics – We use Google Analytics to supply statistics on the usage of our website.
We also have a legal obligation to share data in response to properly made requests from
- Law enforcement agencies – for the prevention and detection of a crime, for the purpose of safeguarding national security, for the purpose of safeguarding life or when the law requires us to, such as in response to a court order or other lawful demand or powers contained in the legislation.
How Long Do We Keep Your Personal Data?
We keep your data while you have an account with us, and sometimes for a longer period, depending on whether there are legal or regulatory reasons for doing so. We are legally required to keep Sub-contractor information in perpetuity.
Contact details, account details and payment history must be retained for seven years.
Transfers To Third Countries
At Twisted Logistics Limited your data is stored in our offices in Manchester (UK) as at our data centre which is located in the United Kingdom. Your information may be transferred to a third country (defined under the GDPR as a country outside of the European Economic Area). The third country is Canada, home to our affiliate managers.
Keeping In Touch With You
We want to keep you updated about our new products, services and any special offers that may become available. We promise to never share your personal information with any third party marketing company.
Customers can opt-in or opt-out of receiving these messages at any time by using the ‘unsubscribe’ link contained in our marketing emails.
What Are Your Rights?
You have the following rights under the GDPR:
- The right to be informed. Individuals have the right to be informed about the collection and use of their personal data. This privacy notice fulfils that requirement.
- The right of access. All of the information we have about you can be requested.
- The right to rectification. If you find an error in your data that you cannot rectify yourself, please contact our central office 0161 850 2503
- The right to erasure. In certain circumstances, you have the right to request that we delete personal data held on you. This does not apply if we have a legal reason for retaining it.
- The right to restrict processing. In certain circumstances, you have the right to ask us to ‘restrict the processing of data’. This means we would need to secure your data but not otherwise use it. In practice, this would involve suspending your account or the relationship that we have with you and therefore your access to our services.
- The right to object. You have the right to opt-out of any marketing communications that we may wish to send you. You can do this by using the ‘unsubscribe’ link contained in our marketing emails.
- Rights related to automated decision-making including profiling. Twisted Logistics Limited does not apply any automated decision-making or profiling to any of your personal data.
If you have any questions about how Twisted Logistics Limited uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Customer Services team on 0333 3442 151.
You have the right to lodge a complaint with the Information Commissioners’ Office. Further information, including contact details, is available at https://ico.org.uk
Ryan James Christian
Twisted Logistics Limited
Empress Business Centre
380 Chester Road
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Changes To This Privacy Notice
We recognise that transparency is an ongoing commitment, so we will keep this privacy notice under regular review.
This privacy notice was last updated on 1st December 2020