This privacy policy (“Policy”) describes the types of personal data you provide and/or TWIL Group Pension Fund collect via your use of our website and interaction with our business services, what we may do with that personal data and your rights.
TWIL Group Pension Fund are Data Controllers of personal data collected by, or which you provide through, our website or interaction with our business services, for the purpose of the Data Protection Act 1998 (“Data Protection Law”).
References to “we”, “us” and “our” in this policy are all references to TWIL Group Pension Fund.
‘Personal data’ is defined in the Data Protection Law and is essentially information from which an individual person can be identified. By submitting information and/or continuing to use our website, you signify your consent to us using your personal data in accordance with the below.
We may need to change the terms of this Policy from time to time and changes will be posted on this page (and/or where appropriate, otherwise notified to you). Your continued use of our website and/or business services will be deemed to be acceptance of amendments we make. This Policy was last updated on 2 May 2018.
Use of our business services or website may require you to provide specific types of information.
We may also supplement the information that you provide with other information that we obtain from our dealings with you or which we receive from other organisations.
In addition, we reserve the right to perform statistical analysis of user behaviour and characteristics to measure interest in and use of the various areas of our website and to ascertain the number of users that have visited particular web pages. We also keep track of what you do with our newsletters when you receive them for trends and statistics and to evaluate the efficiency of our newsletter and information service. For example, whether you open, delete, or access links contained in the newsletter.
We do not sell, rent, or otherwise provide personally identifiable information to third-parties without your consent, except only as set out in the ‘Disclosing (Sharing) Your Information’ section below.
From time to time TWIL Group Pension Fund would like to contact you to tell you more about the offers, services and products available to you from TWIL Group Pension Fund.
TWIL Group Pension Fund will only contact you if you have consented to this.
If, at any time after registering, you would like to change your preference and opt-in or opt-out from receiving communications from us or third-parties you can do this at any time by changing your preferences from the links contained in all of our emails.
We are not responsible or liable for the content, privacy policies or services offered by websites or apps other than our website, including those which are linked to from any of the our website. We encourage you to read and familiarise yourself with the privacy policies, terms and conditions and/or other notices on other websites you visit.
We are committed to protecting the security of your personal data, which is held in secure data centres in the European Union in accordance with current legislative requirements, industry standards and technology. We will keep the personal data you have provided for as long as we have a relationship with you. Once that relationship has ended we will retain it in accordance with this Policy only for as long as we reasonably require and it will then be deleted and destroyed.
Some of the organisations to which we may disclose your personal information (including, but not limited to, our technical partners used in delivery of our website) may be situated outside of the European Economic Area, in countries which may not have laws that protect privacy rights in the same manner as in the United Kingdom. We will however take reasonable steps to ensure that your information is still properly protected.
Once it is received we store your personal data as set out in this Policy.
We cannot guarantee the complete security of our databases, nor that information you supply may not be intercepted while being transmitted to us over the internet.
We have already described in the ‘Marketing Information’ section of this Policy under what circumstances your personal information may be shared with our commercial and official partners, if you have agreed.
In addition, there are some other reasons why we may disclose your personal information to third parties and these are as follows:
Where we share your personal information with third parties we will take reasonable steps to ensure that it is properly protected and processed in accordance with this Policy.
TWIL Group Pension Fund use the below 3rd party data processors to enable us to provide our business services, marketing activity and run our website. Please read and familiarise yourself with the privacy policies of our 3rd party data processors.
Mailchimp
Marketing emails for the website are processed by the MailChimp service by The Rocket Science Group.
Privacy Policy:
Statistics on visitors activity and website usage are gathered using Google Analytics. Google comply with the Eu-US Privacy Shield Framework.
Privacy Policy:
Upon occasion we may use 3rd party mailing houses for the purposes of postal services. These mailing houses are always UK based.
You have the right to see a copy of the information that we hold about you. We may charge a small fee towards the cost of administering any request you make which is manifestly unfounded, excessive or repetitive. The current fee is £10.00.
You have the right to ask that the information we hold about you is corrected by contacting us as above. We encourage you to update your personal information promptly if it changes.
You have the right to ask that we, TWIL Group Pension Fund companies and/or commercial partners stop contacting you by clicking the relevant boxes on the screen upon which you provide information or by contacting us.
You have the right to ask that we, TWIL Group Pension Fund companies and/or commercial partners stop contacting you by clicking the relevant boxes on the screen upon which you provide information or by contacting us.
You (and any parent/guardian of a minor) have the right to request that we delete your personal information from our databases. We will make all reasonable efforts to comply with this request. However, it may not be possible to delete an entry without some delay and without retaining some residual personal information necessary for our legitimate interests, such as backups and records of deletions (including to ensure we no-longer communicate with you) or because we are required or permitted to retain personal information for other lawful requirements.If you are dissatisfied with our response to any of your data privacy concerns you have the right to raise this with the Office of the Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (ico.org.uk).
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Google Analytics uses cookies to gain information about the use that is made of pages on the applicable Online Facilities. We use the information from these cookies to generate reports on the usage of the applicable Online Facilities which are used for evaluation and analysis. The purpose is to improve the Online Facilities by tailoring them to the needs of users.
In such cases, no data which is itself specific to any identifiable user is retained.
In addition to standard analytics parameters, we receive data via Google Analytics Advertising Features including information about 'Demographics and Interest Reporting' which gives us greater insight into the types of visitors we receive.
As a user you can opt out of this process of collecting traffic log data. To do so please visit the following site which provides a browser add-on that enables a user to opt out.
tools.google.com/dlpage/gaoptout
All modern browsers allow you to change your cookie settings. These settings will typically be found in the 'options' or 'preferences' menu of your browser. To understand these settings, the following links may be helpful, otherwise you should use the 'Help' option in your browser for more details.
We do not recommend turning cookies off when using the Online Facilities, as this will prevent you from using many of the services on the relevant Online Facility to which the cookies apply.
For further information about cookies and how to control their use, please visit the following third party educational resources: www.allaboutcookies.org and www.youronlinechoices.eu
The Fund is in surplus for the first time in many years and we have a formal Guarantee from the company
Jonathan Storer, Chairman of Trustees