Privacy Policy

The TWiCe Campaign is committed to protecting the privacy and security of your personal information.  This privacy policy describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).


This privacy policy applies between you, the User of this Website and the TWiCE Campaign, the owner and provider of this website. TWiCE Campaign takes the privacy of your information very seriously.  This privacy policy applies to our use of any and all data collected by us or provided by you in relation to the use of the Website.


Please read this privacy policy carefully:


Definitions and interpretation:-

1.      In this privacy policy, the following definitions are used:

Collectively, all information that you submit to the TWiCE Campaign via the website.  This definition incorporates, where applicable, the definitions provided in the Date Protection Laws.



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.  Details of the cookies used by this Website are set out in the clause below (Cookies).



Any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Date Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK.

Data Protection Laws:


The General Data Protection Regulation (EU) 2016/679



TWiCE Campaign whose registered office as at Surrey Research Park, 40 Occam Way, Guildford, Surrey GU2 7YG

TWiCE Campaign, we, Our, us:


The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.

UK and EU Cookie Law:


Any third party that accesses the Website and is not either (i) employed by TWiCE Campaign and acting in the course of their employment; or (ii) engaged as a consultant or otherwise, providing services to TWiCE Campaign and accessing the Website in connection with the provision of such service.

User or you:


The website that you are currently using,, and any sub-domains of this site unless expressly excluded by their own terms and conditions.



2.      In this privacy policy, unless the context requires a different interpretation:-

a.     The singular includes the plural and vice-versa;

b.     References to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

c.     A reference to a person includes firms, companies, government entities, trust and partnerships.

d.     “including” is understood to mean “including without limitation”.

e.     Reference to any statutory provision includes a medication or amendment of it.

f.      The headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3.      This privacy policy applies only to the actions of TWICE Campaign and Users with respect to this Website.  It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4.      For purposes of the application Data Protection Laws, TWiCE Campaign is the “Data controller”.  This means that we are responsible for determining the purposes for which, and the manner in which your Data is processed. We are required under data protection legislation to notify you of the information contained in this privacy policy.

Data collection

5.     We may collect, store and use the following categories of Data, which includes personal Data from you:-

a.     Personal contact details such as name, title, address, telephone number and email address.

b.     Date of birth.

c.     Gender.

d.     Job title.

e.     Profession.

How we collect Data

6.      We collect Data in the following ways:-

a.      Data given to us by you;

b.     Data received from other sources; and

c.     Data is collected automatically.

Data that is given to us by you

7.      TWiCE Campaign will collect your Data in a number of ways in accordance with this privacy policy, for example:

a.      When you contact us through the Website, by telephone, post or email or through any other means.

b.     When you register with us and set up an account to receive our products/services;

c.     When you enter a competition or promotion through a social media channel.

d.     When you make payments to us, through this Website or otherwise.

e.     When you elect to receive marketing communications from us.

f.      When you use our services.

Data that is received from third parties

8.      TWiCE Campaign will receive Data about you from the following third parties:


b.     Local Council

Data that is collected automatically

9.      To the extend that you access the Website, we will collect your Data automatically, for example:-

a.      We automatically collect some information about your visit to our Website.  This information helps us to make improvements to the Website content and navigation and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

b.      We will collect your data automatically via cookies, in line with the cookie settings on your browser.  For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Our use of data

10.      Any or all of the above Data may be required by us from time to time, in order to provide you with the best possible service and experience when using our Website, specifically data may be used for the following reasons in accordance with this privacy policy:-

a.     Internal record keeping.

b.     Improvement of our products/services.

c.     Transmission by email of marketing materials that may be of interest to you.

d.     Contact for market research purposes which may be done using email, telephone, fax or mail.  Such information may be used to customise or update the Website.

e.     Distribution of our fortnightly hints and tips.

11.   We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests.  If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

12.  For the delivery of direct marketing to you via email, we will need your consent, whether via an opt-in or soft opt-in:-

a.      Soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service or element of the campaign, and we are marketing similar products/services).  Under “soft opt-in” consent, we will take your consent as given unless you opt-out.

b.     For other types of marketing, we are required to obtain your explicit consent; that is, you need to make positive and affirmative action when consenting by, for example, checking a tick box that we will provide.

c.     If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time.  To find out how to withdraw your consent, see the section headed “Your rights” below.

13.  When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contact between you and us and/or taking steps, at your request, to enter into such a contract.

Keeping data secure

14.   We will use technical and organisational measures to safeguard your Data, for example:-

a.      We store your Data on secure servers.

b.     Payment details are encrypted using SSL technology (typically) you will see a lock icon or green address car (or both) in your browser when we use this technology.

15.   Technical and organisational measures include measures to deal with any suspected data breach.  If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address:

16.  If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identify theft, viruses and may other online problems, please visit  Get Safe Online is support by HM Government and leading businesses.

Data retention

17.   Unless a longer retention period is required or permitted by law, we will only hold your Data on our system for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

18.   Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

19.   You have the following rights in relation to your Data:-

a.     Right to access:  the right to request

i.               Copies of information we hold about you at any time; or

ii.              That we modify, update or delete such information.  If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”.  Where we are legally permitted to do so, we may refuse your request.  If we refuse your request, we will tell you the reason why.

b.     Right to correct:  the right to have your Data rectified if it is inaccurate or incomplete.

c.     Right to erase:  the right to request that we delete or remove your Data from our systems.

d.     Right to restrict our use of your Data:  the right to “block” us from using your Data or limit the way in which we can use it.

e.     Right to data portability:  the right to request that we move, copy or transfer your Data.

f.      Right to object:  the right to object to our use of your Data including where we use it for our legitimate interests.

20.   To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address:

21.   If you are not satisfied with the way a complaint you make in relation to how your Data is handled by us, you may be able to refer your complain to the relevant data protection authority.  This is the Information Commissioner’s Office (ICO).  The ICO’s contact details can be found on their website                  

22.  It is important that the Data we hold about you is accurate and current.  Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

23.   The 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 on 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.

Changes of business, ownership or control 

24.  TWiCE Campaign 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 the TWiCE Campaign.  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.

25.  We may also disclose Data to a prospective purchaser of our business or any part of it.

26.  In the above instances, we will take steps with the aim of ensuring your privacy is protected.


27.   This Website may place and access certain Cookies on your computer.  TWiCE Campaign uses Cookies to improve your experience of using the Website and to improve our range of products and services.  TWiCE Campaign has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

28.   All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

29.  Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to those Cookies.

30.  This Website may place the following Cookies:-


Type of Cookie

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.

Analytical/performance cookies

Used to analyse how users use our website and ascertain our most popular products/services.



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).

Functionality cookies

Used to analyse traffic patterns.


31.      You can choose to enable or disable Cookies in your internet browser.  By default, most internet browsers accept Cookies but this can be changed.  Further details can be found from the help section in your internet browser.

32.     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.

33.     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.

34.     For more information generally on cookies, including how to disable them, please refer to about  You will also find details on how to delete cookies from your computer.


35.     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.

36.     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.

37.     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.

38.     This Agreement will be covered 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.

Changes to this privacy policy

39.      We reserve the right to change this privacy policy as we deem necessary, from time to time or as may be required by law.  Any changes will immediately be 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.  You may contact TWiCE Campaign by email at