Privacy Policy

Last Updated: 14th September 2024

 

INTRODUCTION

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Your privacy is important to us. This Privacy Policy explains how Twisted Works Ltd collects, uses, and shares information about you when you interact with our products, services, or website, collectively referred to as “Services.”

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Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By using our Services, you agree to the practices described in this policy.

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OUR POLICY TOWARDS CHILDREN

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We respect children's privacy and are committed to complying with all applicable laws regarding children's privacy. Our Services are not directed to children under 13 years of age, and we do not knowingly collect personal information from children under this age. If you believe we have collected personal data from a child under 13, please contact us immediately at legal@twistedworks.com, and we will delete the information promptly.

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For users aged 13 to 18, we encourage parents or guardians to monitor their children's use of our Services and ensure that they have given proper consent.

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IMPORTANT INFORMATION AND WHO WE ARE

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PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy provides details on how Twisted Works Ltd collects and processes your personal data when you use our Services, including our website, games, newsletters, or when you interact with us directly, such as attending events or contacting customer support.

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This policy supplements any other privacy notices and is not intended to override them. We may update this policy from time to time to reflect changes in how we handle your data or to comply with evolving legal requirements. Any changes will be reflected on this page, and we encourage you to review it regularly.

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CONTROLLER

Twisted Works Ltd is the data controller responsible for your personal data. Throughout this policy, “we,” “us,” or “our” refer to Twisted Works Ltd.

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If you have any questions about this Privacy Policy or wish to exercise your legal rights, don't hesitate to get in touch with us using the details provided below.

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CONTACT DETAILS

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Twisted Works Ltd

Address: 3rd Floor, 86-90 Paul Street, London, United Kingdom, EC2A 4NE

Email: legal@twistedworks.com

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You also have the right to make a complaint at any time to your local data protection authority. However, we would appreciate the opportunity to address your concerns first, so don't hesitate to contact us before escalating any complaints.

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THE DATA WE COLLECT ABOUT YOU

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We may collect, use, store, and transfer different types of personal data about you, including:

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• Identity Data: First name, last name, username, date of birth.

• Contact Data: Email address, phone number, residential address.

• Technical Data: IP address, browser type, time zone setting, and other technical data related to your use of our website and games.

• Profile Data: Game preferences, purchase history, feedback, survey responses.

• Usage Data: Information about your interactions with our games and website.

• Marketing and Communications Data: Preferences regarding marketing from us or third parties.

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We may also collect aggregated data, which is statistical or demographic data used for various purposes but does not directly identify you.

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FINANCIAL DATA

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We do not process or store your payment details directly. Payment transactions are handled by secure third-party providers, and we only receive confirmation of your payment for internal record-keeping.

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We encourage you to review the privacy policies of these third-party payment providers to understand how they process your personal data.

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SPECIAL CATEGORIES OF DATA

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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, or genetic and biometric data). We also do not collect any information about criminal convictions and offences.

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HOW WE COLLECT YOUR DATA

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We collect data in various ways:

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• Direct Interactions: When you sign up for our Services, create an account, purchase a product, request support, or otherwise communicate with us.

• Automated Technologies: As you interact with our website and games, we may collect data automatically through cookies, server logs, pixels, and similar technologies. Please refer to our Cookie Policy for more details.

• Third Parties: We may receive data from third-party analytics providers, payment processors, and social media platforms, based on your interactions with their services in relation to our Services.

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HOW WE USE YOUR DATA

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We will only use your personal data when the law allows us to. The most common uses of your data include:

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• To fulfill our contractual obligations (e.g., providing you with access to our games, managing your account, processing transactions).

• For legitimate business interests, such as improving our games and Services, ensuring website security, and conducting analytics to enhance user experience. We always balance our legitimate interests with your rights and interests.

• To comply with legal obligations (e.g., keeping records for tax purposes or responding to legal claims).

• With your consent, such as when sending marketing communications or using cookies for advertising purposes. You have the right to withdraw your consent at any time by contacting us or using the unsubscribe option in our emails.

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DISCLOSURE OF YOUR DATA

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We may share your personal data with trusted third parties, including:

• Service Providers: Hosting providers, customer service platforms, payment processors, and analytics companies who help us deliver our Services.

• Regulators or Authorities: If required to comply with legal obligations or regulatory inquiries.

• Partners: If you interact with a third-party service (e.g., linking your account to a social media platform), those third parties may receive personal data to the extent necessary to provide the service.

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We require all third parties to respect the security of your personal data and treat it in accordance with the law. We only permit them to process your data for specified purposes and in accordance with our instructions.

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INTERNATIONAL DATA TRANSFERS

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Some of our external third parties may be based outside the UK and the European Economic Area (EEA), meaning their processing of your personal data may involve a transfer of data outside the UK or EEA. In these cases, we ensure your data is adequately protected by:

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• Only transferring personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Secretary of State or the European Commission.

• Implementing appropriate safeguards, such as standard contractual clauses approved by relevant authorities.

• Ensuring any other applicable data privacy safeguards are in place.

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DATA SECURITY

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We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. These may include encrypted data transmission, access controls, and regular security reviews.

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We limit access to your data to employees, contractors, and third parties who have a business need to know. They will only process your data in accordance with our instructions and are subject to a duty of confidentiality.

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DATA RETENTION

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We will retain your personal data only as long as necessary to fulfill the purposes we collected it for, including legal, accounting, or reporting obligations.

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By law, we are required to keep basic information about our customers (such as Contact and Transaction Data) for six years for tax purposes. In some cases, we may anonymize your data so that it can no longer be associated with you, in which case we may use this information indefinitely without further notice.

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YOUR LEGAL RIGHTS

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Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data.

• Request correction of your data.

• Request erasure of your data.

• Object to processing or request restriction of processing.

• Request the transfer of your data to you or a third party.

• Withdraw consent for processing where consent is the basis for processing.

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You can exercise these rights by contacting us at legal@twistedworks.com. We will respond to all legitimate requests within one month, but in complex cases, we may require additional time and will keep you informed.

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CHANGES TO THIS POLICY

We may update this Privacy Policy periodically in response to changes in the law, our services, or the technology we use. Any changes will be posted on this page, and significant updates will be communicated via email or within our Services.