About this notice

Twinky & Hoobie Publishing respects your privacy and is committed to protecting your personal data. This privacy notice describes how we use your personal data when you use our website www.TheLittleCockroach.com. We have provided this notice to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

You can read and print this whole notice or read below to see specific information about:

Who we are and how you can contact us

Our data compliance manager

What personal data we collect about you

What we use your personal data for

Cookies

Consent and other legal grounds for processing your personal data

Personal data you are legally obliged to provide

Your rights to know what personal data we hold and to control how we use it

Automated decision making and profiling

When we will share your personal data with others

How we keep your personal data safe

How we use your personal data for marketing

When we will send your personal data to other countries

How long we keep your personal data

How you can make a complaint

How we keep this notice up to date

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Who we are and how you can contact us

Twinky & Hoobie Publishing (“we”, “us”, “our”) is the data controller and responsible for your personal data.

Our registered office address is at Kenmore House, Navigation Road, Chelmsford, Essex, CM2 6HX.

You can contact us in writing at the above address or by emailing Publishing@Twinky&Hoobie.com.

Please refer to the sections on Our data protection manager, Your rights to know what personal data we hold and to control how we use it and How to make a complaint for further contact information.

Our data compliance manager

We have appointed a data compliance manager who acts as our primary point of contact for any questions or concerns you may have regarding our handling of your personal data.

Our data compliance manager is Susanna Shaw. You can contact our data compliance manager in writing at Kenmore House, Navigation Road, Chelmsford, Essex, CM2 6HX or by email at Publishing@TwinkyandHoobie.com.

What personal data we collect about you

We collect:

• personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you may contact us to request information about our products or services. The personal data that you provide to us may include your name, job title, address, e-mail address and phone number, bank account and payment card details.
• personal data that we receive from third parties. If we work with other businesses or use sub-contractors these parties may collect personal data about you which they will share with us. For example, we may have your name and contact details passed to us by a distributor that sells our products or services, receive feedback from a sub-contractor we have instructed to help us provide you with products or services that you have requested, such as a distributor or courier company.
• personal data about your use of our website. This is technical information and includes details such as your IP address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and any phone number used to call our customer service number.

What we may use your personal data for

We may use your personal data in the following ways:

• personal data that you provide to us may be used to:
  • provide you with the information, products and services that you request from us
  • provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing)
  • manage and administer our business
  • review and improve our products and service
• personal data that we receive from third parties may be combined with the personal data that you provide to us and used for the purposes described above.
• personal data about your use of our website may be used to:
  • administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
  • as part of our efforts to keep our site safe and secure
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
  • to make suggestions and recommendations to you and other users of our site about products or services that may interest you or them

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

Consent and other legal grounds for processing your personal data.

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:

• we are entering into and carrying out our obligations under a contract with you
• we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights
• where we are subject to legal obligations that require us to use your personal data in certain ways (such as disclosing information to HM Revenue & Customs)
• In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
• Please refer to the section on How we use your personal data for marketing to read about our marketing practices.
• To help you understand the legal grounds we rely on for different types of processing, we have set out an overview of the main processing activities we undertake and the relevant legal grounds below:

Categories of personal data used	Purpose	Legal basis
Name and contact details	To respond to your enquiries regarding our products and services	Legitimate interest (in growing our business and developing new customer relationships) and/or contractual necessity
Name and contact details, transaction history	To provide you with the products and services you wish to buy from us and to collect money owed to us	Contractual necessity and/or legitimate interests (to recover monies due to us)
Name and contact details, transaction history	To manage our relationship with you e.g. to keep your details up to date and notify you of any changes to our contractual documents or privacy policies or notices	Contractual necessity and/or legitimate interests (to keep our records updated and understand how our customers use our products and services)
Name and contact details, transaction history, details of your interests and preferences, technical data about your use of our website, your marketing preferences	To send you appropriate marketing communications in accordance with your marketing preferences	Consent and/or legitimate interests (to grow and develop our business)
Name and contact details, transaction history, technical data about your use of our website	To manage and administer our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Legitimate interests (to run our business, provide administration and IT services, ensure network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercises) and legal obligations
Name and contact details, transaction history, details of your interests and preferences, technical data about your use of our website, your marketing preferences	To develop and improve our website, products/services, and our customer relationships and experience	Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, to improve our products and services and to inform our marketing strategy)

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our products or services to you.

Your rights to know what personal data we hold and to control how we use it.

You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right (or any of the other rights described below) by sending us a written request at any time. Please mark your letter “Data Subject Request” and send it to data compliance manager (see the section on Our data compliance manager for contact details).

You also have rights to:

• prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
• have inaccurate personal data corrected, blocked or erased
• object to decisions being made about you by automated means or to your personal data being used for profiling purposes
• restrict our use of your personal data
• require that we delete your personal data (the “right to be forgotten”)
• require that we provide you, or anyone that you nominate, with a copy of personal data you have given us in a structured electronic form such as a CSV file

You can find full details of your personal data rights on the Information Commissioner’s Office website at ww.ico.org.uk.

Automated decision making and profiling

We do not make use of automated decision making or profiling.

When we will share your personal data with others

We share your data with the following people in the day to day running of our business:

the business partners, suppliers and sub-contractors we work with to provide you with products or services that you have requested from us. This includes:

• publishers, couriers, distributors, accountants and persons supporting the delivery of INSETs
• advertisers and advertising networks (see How we use your personal data for marketing for more information
• analytics and search engine providers that assist us in the improvement and optimisation of our site
• our regulator, the Charities Commission

We may also share your personal information with third parties on a one-off basis, for example, if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use or our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

How we keep your personal data safe

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.

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

How we use your personal data for marketing

We will add your details to our marketing database if:

• you make an enquiry about our products or services
• you buy our products or services
• you have told a third party that you would like them to pass us your contact details so that we can send you updates about our products and services
• none of the above apply but we believe that our products or services may interest you and we can lawfully rely on the ground of legitimate interests to process your details

We may send you marketing communications by email, telephone or post.

You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), or you may ask us not to send you any marketing communications at all.

You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.

We never share your personal data with third parties for marketing purposes.

When we will send your personal data to other countries

Your personal data will not be transferred to, and stored at, a destination outside the European Economic Area (EEA) by us or by our sub-contractors except where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies. In such circumstances your personal data may be stored on the servers of these non-UK companies outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How long we keep your personal data

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.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.

If you have any questions about our data retention practices please contact our data compliance manager (see the section on Our data compliance manager for contact details).

How you can make a complaint

If you are unhappy with the way we have used your personal data please contact our data compliance manager to discuss this using the contact details set out in the Our data compliance manager section above.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this notice up to date

We will review and update this privacy notice from time to time. This may be to reflect a change in the products or services we offer or to our internal procedures or it may be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version of this notice on our website (www.tere.org) or you can contact us (see Who we are and how to contact us ) to ask us to send you the latest version of our privacy notice.

Each time we update our privacy notice we will update the notice version number shown at the end of the notice and the date on which that version of the notice came into force.

This privacy notice came into effect on 11 December 2019 and replaces all previous versions.