Twoth understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://twoth.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site.
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Oral Care Hygiene Limited, a limited company registered in England under company number 10247911, whose registered address is The Pavilion, Rosslyn Crescent, Harrow, Middlesex, United Kingdom, HA1 2RZ .
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies and Our Cookie Policy https://twoth.com/privacy-policy/#cookies-policy/):
5.1 name;
5.2 contact information such as email addresses and telephone numbers;
5.3 demographic information such as post code, preferences and interests;
5.4 financial information such as credit / debit card numbers;
5.5 IP address;
5.6 web browser type and version;
5.7 operating system;
5.8 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
5.9 electronic reviews or correspondence submitted via our website.
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your access to Our Site;
6.2.2 Supplying Our services to you (please note that We require your personal data in order to book an appointment with you);
6.2.3 Replying to emails from you;
6.2.4 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing us at hello@twoth.com or by unsubscribing at the foot of emails;
6.2.5 Market research;
6.2.6 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 For a period no longer than 24 months after the last interaction with you related to the provision of Our services and/or products.
6.5.2 Or for up to six years related to business transactions in order to meet our obligations to HMRC.
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
7.2.1 Ensuring that our partners are GDPR compliant.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Data collected will be encrypted using SSL certificate.
7.4.2 Data stored on our website is protected by a firewall and premium security software.
7.4.3 Back ups of our website are stored securely in a GDPR compliant way.
8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9.1 We 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 Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being 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 that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10.1 When you submit personal data via Our Site, you will be given options to restrict Our use of your data. In particular, We will give you controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
11.1 You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
11.2 You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy https://twoth.com/cookies-policy/.
You have the right to ask for a copy of any of your personal data held by Us (where such data is held Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at hello@twoth.com, or using the contact details below in section 14.
13.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products. In addition, Our Site uses analytics services provided by Google Analytics, and advertising services provided by Google Adwords and Facebook, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. For more details, please refer to Our Cookie Policy.
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@twoth.com. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, as you use that website, or when you revisit that website, it can present the correct and/or tailored options based on the information stored about your visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this can be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. For more information on how to control cookies on your browser see Cookie Control Settings below.
We use cookies to make our website work and to track your use of our website. These are called first party cookies. Cookies also enable us to understand how you use the site and track any patterns with regards to how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.
By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for:
Cookies are either:
– Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
– Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.
Cookies can also be categorised as follows:
– Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
– Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
– Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
The links below provide instructions on how to control Cookies in all mainstream browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB
Safari (iOS): https://support.apple.com/en-gb/HT201265
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)
We may alter this Cookie Policy at any time.
