Your privacy is important to us. To better protect your privacy the following notice explains the information we collect, how it is used, how it is safeguarded, and how to contact us if you have any concerns.
The policy applies to any personal data we collect from you, including when you create an account or contact us for any other reason. It also applies to your use of our website tweesecake.app and TweeseCake application (the “Service”).
Please read this policy carefully before giving us any of your personal data.
WHO WE ARE
We are TweeseCake ("Josh Stirland").
THE DATA WE COLLECT
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where any identifying markers have been removed.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We may collect the following kinds of personal data from you:
Our application uses a phone home type system to check license validity; data transmitted includes:
- Machine ID (is encrypted before transmission; we cannot decrypt this); and
- IP address and other technical information (webserver logs)
FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to create an account, you will need to provide us with your name/username, email and other information).
HOW WE COLLECT YOUR DATA
A lot of the data we collect about you will be provided by you directly to us when you create an account or contact us for any other reason. We will collect technical data from your browser when you use our Service.
HOW WE USE YOUR PERSONAL DATA
Generally, we do not rely on consent as a legal basis for processing your personal data. We will only use your personal data when the law allows us to. Most commonly, we will use it in the following circumstances:
- We need to provide the service (e.g. provide your license and take payment for it);
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- Where we need to comply with a legal obligation.
Where we rely on our own legitimate interests to process your data, those interests are:
- To administer and protect our service;
- To use data analytics as a way of improving the user experience on our Service.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR DATA
We will never sell your personal data.
However, we may share it with subcontractors or suppliers who provide services to our business. Our subcontractors will typically fall within the following categories:
- Professional Advisers (e.g. accountants, marketing specialists and lawyers);
- IT services providers;
Where we share your data with suppliers or subcontractors, they will be subject to a contract which imposes strict obligations of confidentiality and compliance with UK data protection laws on them.
All of our external third-party suppliers and subcontractors are either based within the UK, or are subject to suitable legal restrictions about where they may store your personal data.
DATA SECURITY AND RETENTION
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection law in relation to your personal data. You have the right to:
- Request access to the personal data we hold about you;
- Request corrections to any of the personal data we hold, if it is inaccurate;
- Ask us to erase your personal data;
- Object to the way in which we process your personal data; or
- Request transfer of your personal data in a commonly-used file format.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
YOUR RIGHT TO COMPLAIN
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK regulator for data protection issues. Details of how to do this can be found on their website. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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