PRIVACY POLICY

1- WHO IS THE DATA CONTROLLER OF YOUR PERSONAL DATA?

The data controller and owner of the brand Twist&Shine, the website https://twistnshine.com and of the Twist & Friends app is Akey Laundry SL, a commercial company domiciled at Calle d’Astùries, 85 local 1, 08024 Barcelona and CIF B01917236. The company is registered in the Mercantile Registry of Barcelona, ​​volume 47452, page 163, entry 3082 of Diario 1335, page B-552271 (hereinafter, TWIST & SHINE).

The contact details for TWIST & SHINE, regarding privacy and the protection of your personal data, are:

2- WHAT TYPE OF PERSONAL DATA DO WE PROCESS AND WHY?

1-Types of personal data that we process

We may collect and process the following types of personal data:

a. Name, title, gender. Address for collections and deliveries for our Twist & Delivery service.

b. Your contact details, credit card number, address, telephone number, tax identification number (NIF) and your email address.

c. As TWIST & SHINE has physical “shops” to provide its services, their use by users necessarily requires the collection of information about users’ locations. This information will not be used or disclosed to third parties, and will only be processed for the correct functioning of our service network.

d. To communicate with you.

We record your communications with us made via email and other means. When you make a telephone call, our customer support service may record your questions or complaints in our database.

e. Information collected when you use our website, our app and other digital media, as applicable.

When you use our website or our app, we may record your IP address, browser type, operating system, the source website and your browsing behaviour on the website or app.

f. Information regarding social media.

Depending on your social media settings, we may receive information from your social media provider. For example, when you log in using a social media account to use our services, we may receive your social media profile, including your contact details, interests and contacts. For more information about the personal data that we receive from your social media provider and how to change your settings, please visit your social media provider’s website and read its privacy policy.

g. Information that you choose to share with us.

You can choose to share information with us, by adding a comment on Facebook or Instagram, when completing a customer or other kind of survey for example.

2-Your personal data will only be used for the following purposes:

a) To record you in our database if you register as a member of the Twist & Friends community.

b) To carry out the necessary commercial and administrative steps with users of our website or app and our customers or potential customers.

c) At TWIST & SHINE we process the information that you provide to us in order to reply to requests for information that you send to us, to provide you with information about our services, to manage registration and the use of our services internally and externally via our website or app, and to comply with the legal obligations that arise from said activities.

d) To send advertising and marketing communications via email, social media or any other electronic or physical means, if you have expressly given your consent to receive said marketing communications by email. If you have been recorded in our customer database, we may send you marketing information regarding our services.

e) To communicate with you to reply to your questions and to deal with your complaints.

f) To communicate with you to obtain your opinion about the quality of our services and responses or customer support received.

g) In addition, the data collected during your browsing are processed in order to provide access to the online content of the website and to respond to requests from users on the website, and to keep a statistical record of visits (IP addresses, browser data, country, pages viewed, etc.) so that we can develop better services and products, optimise our range of services and products and provide a more efficient customer support service and improve the design and content of our websites.

h) The data from our customers and suppliers will be processed within the context of the contractual relationship that binds us, in accordance with the administrative, tax, accounting and labour obligations that are required by virtue of current legislation.

i) Objection or revocation. You may object to or revoke your consent to receive marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us at preguntanos@twistnshine.com.

j) If you complete one of the forms that you will find on our web or app, it will be necessary to provide certain personal data, which will be processed for the purposes for which they are requested.

In accordance with the Information Society and Electronic Commerce Services Act, TWIST & SHINE does not use spam techniques, and therefore does not send marketing messages by email if it does not have the right to do so. In any case, you will always have the option of withdrawing your consent to receive our communications.

We do not process your personal data for any purpose other than those described in this policy unless we are legally obliged or ordered to do so.

Your personal data will not be subject to decisions based on automated processing that produce legal effects concerning you.

3- WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA?

The legal basis for the processing of your personal data is your explicit consent for us to carry out the aforementioned processing, which will be requested when you request information or when you check the relevant box when providing your data in any of our forms for the collection of personal data.

If a commercial relationship is established between you, either as a customer or as a supplier, and TWIST & SHINE, the legal basis for the processing of your personal data will be the performance of the established contractual relationship and, if applicable, compliance with the relevant legal obligations.

If you do not provide us with your personal data or if you do not accept our privacy policy, TWIST & SHINE will not carry out the processing of your personal data, although this may also make it impossible for us to send you information or for us to provide you with our services.

Marketing information.

Any information sent will be added to the information systems of TWIST & SHINE.

If you provide us with your personal data and accept this privacy policy, we inform you that TWIST & SHINE may carry out the following activities and/or actions, unless you instruct us otherwise:

– The sending of relevant advertising and/or marketing communications when replying to your request for information by any means. The legal basis for this processing is the explicit consent given by you when you voluntarily make the request.

– The sending of any information, including marketing information about updates, new products, etc. and all information related to our activities or the services contracted by our customers. The legal basis for this processing is our legitimate interest within the commercial relationship established with you.

4- STORAGE TERM How long will we keep your data?

The personal data that you provide to us will be kept for as long as required to obtain the information that you request from us, and to manage your transactions and for the performance of any contract that is established between TWIST & SHINE and third parties. If we have your identification data on our database to send you marketing information, these will be kept for as long as there is a legal basis for their storage and use. You may cancel your data at any time in order not to receive marketing information.

Once the data have fulfilled the purposes for which they were collected, we will definitively delete them. However, we will keep your data for longer if this is required for compliance with legal obligations. In addition, it may be necessary to keep them until the limitation period of any legal liabilities that are established. 

The data that you provide to us to begin an employment selection process will be kept for a maximum period of one year. If after that time you have not joined TWIST & SHINE or are not in a selection process, they will be deleted and we will not keep a copy.

The personal data of our employees will be kept for as long as their employment relationship with TWIST & SHINE lasts and, after this, for the legally provided periods.

5- WHO WILL YOUR DATA BE SENT TO?

At our company, your personal data will be processed by duly authorised staff, and, if it is necessary and practical in order to comply with the aforementioned purposes, they may be processed by third parties. 

The categories of recipients to which your personal data may be disclosed are as follows:

Third parties appointed as data processers, such as IT providers, consultants and advisors and other companies that provide ancillary services, such as courier companies for collections and deliveries.

1. Akey Laundry, S.L., a company that is part of our Group and is responsible for managing the payment gateway, with company tax number (CIF) B01917236 and email address akeylaundry@gmail.com.
2. Third parties appointed as data processers, such as IT providers, consultants and advisors and other companies that provide ancillary services, such as courier companies for collections and deliveries.
3. Other providers to which your personal data might be disclosed, such as financial institutions, etc.
4. Third-party websites. Our websites may be linked to third-party websites. If you follow these links, you will leave our website or mobile apps. This privacy policy is not applicable to third-party websites. TWIST & SHINE does not accept any responsibility for the use of your personal data by third parties. You use these websites under your own responsibility.

Without exception, all of the aforementioned third parties will have previously signed the relevant confidentiality agreement, following our instructions in accordance with current legislation on personal data protection, and will be subject to the duty of personal secrecy or will act in accordance with a legal obligation.

The information that you provide to us via this website and via the app will be stored on TWIST & SHINE servers.

6- WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

If you wish to exercise the rights granted to you by personal data protection legislation, please email us at preguntanos@twistnshine.com  including the right you wish to exercise in the subject line and attaching a copy of your national identity card or passport.

The rights that current legislation recognises and that you may exercise are:

Right of access to data:

You have the right to ask TWIST & SHINE if your personal data are being processed or not, and if processing is confirmed, to facilitate access to them by providing you with the following information:

-The purposes of the processing.

-The personal data categories involved.

-The data storage term or criteria.

Right to rectification of data:

You will have the right to request that TWIST & SHINE rectifies your data when they are inaccurate or incomplete, by making an additional declaration rectifying them.

Right to erasure of data:

The data subject will have the right to request that TWIST & SHINE deletes their data, when:

-The processing is illegal.

-The data subject has withdrawn their consent.

-They are no longer required for the purposes for which they were collected or processed.

-The data subject has exercised their right to objection and other legitimate reasons for the processing do not prevail.

-The data must be deleted to comply with a legal obligation of TWIST & SHINE.

The data subject will not have the right to request that TWIST & SHINE deletes their data when the processing is required:

-To exercise the right to freedom of expression and information.

-To comply with a legal obligation of TWIST & SHINE.

-For the preparation, filing or defence against claims.

-In the public interest, based on current legislation due to reasons of public health or for historical, statistical or scientific research purposes.

Right to data portability:

The data subject has the right to request that TWIST & SHINE transmits their data to another data controller or to the data subject themselves, in a structured, commonly used and machine readable format, when the processing is carried out by automated means and is based on:

-The consent of the data subject for specific purposes.

-The performance of a contract or entering into a contract with the data subject.

The right to data portability will not apply when:

-The transmission is not technically possible.

-It could negatively affect the rights and freedoms of third parties.

-The processing is in the public interest, based on current legislation.

Right to restriction of the processing:

The data subject will have the right to object to the processing of their data carried out by TWIST & SHINE due to reasons related to their particular situation, when the processing is based on or for:

-Direct marketing.

-The preparation of profiles.

-The legitimate interest of the data controller or third parties, provided that the interests or the rights and freedoms of the data subject do not prevail, especially if the data subject is a child.

-Historical, statistical or scientific research, unless the processing is required for reasons of public interest.

Despite the data subject objecting to the processing of their data, TWIST & SHINE may continue processing them provided that its legitimate interest prevails over the interests or rights and freedoms of the data subject in legal proceedings that justify it.

TWIST & SHINE must inform the data subject of their right to object to the processing of their data explicitly, clearly, and separately from any other information at the time of the first communication with the data subject.

Right to object:

This is the right to request that your data not be processed or that the processing cease when your consent is not required for the processing, due to the existence of a legitimate reason regarding your specific personal situation, or to request that the processing be justified, provided that the law does not provide otherwise. 

Right not to be subject to the preparation of profiles:

The data subject will have the right not to be subject to the preparation of profiles when their purpose is to take individual decisions based on the automated processing of data, and that are used to evaluate, analyse or predict the following personal aspects:

-Performance at work.

-Financial situation.

-Health.

-Preferences or personal interests.

-Reliability.

-Behaviour.

-The location or movements of a person.

When the preparation of profiles is based solely on automated processing:

-The data subject will have the right to be informed whether the decision that might be taken could have legal effects that significantly affect them.

-The data subject will have the right to obtain human intervention by TWIST & SHINE, to express their point of view and to challenge the decision, if the processing has been authorised through:

-The explicit consent of the data subject.

-A contract between TWIST & SHINE and the data subject.

The right to not be subject to the preparation of profiles will not be applicable when the decision that might be taken as a consequence of it is authorised through:

-The explicit consent of the data subject.

-A contract between TWIST & SHINE and the data subject.

-Processing that is justified by current legislation.

7-COMPLAINTS TO THE SUPERVISORY AUTHORITY:

If you consider that TWIST & SHINE has violated one of your rights protected by personal data protection legislation or that it has violated any obligation regarding the protection of personal data, you have the right to  submit a complaint to the competent supervisory authority, which in Spain is the Spanish Data Protection Agency located at Calle Jorge Juan, 6. 28001 – Madrid.

Tel. 901 100 099 – 912 663 517

You can also submit an electronic complaint via the electronic office available on its website https://www.aepd.es  

8-LEGISLATION AND JURISDICTION

This privacy policy is governed in all its points by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

It is also governed by Organic Law 3/2018 of 5th December 2018 on Personal Data Protection and the Guarantee of Digital Rights. In addition, our website is governed by the 34/2002 Act of 11th July on Information Society and Electronic Commerce Services.

Users of this website are subject to Spanish legislation and jurisdiction, to which they expressly submit, with the courts of BARCELONA being competent to resolve all disputes arising from or related to its use.

9-ADDITIONAL INFORMATION

-SOCIAL MEDIA (PRIVACY POLICY)

We inform you that TWIST & SHINE may have a presence on social media. The data processing carried out of people who become followers on social media (and/or that establish any link or carry out any connecting action via social media) of official TWIST & SHINE websites will be governed by this section and by the terms and conditions of use, privacy policies and rules of access of the relevant social media platform in each case that have been previously accepted by the user.

TWIST & SHINE will process your data in order to correctly manage its presence on social media, informing you about activities, products or the provision of services, and for any other purpose permitted by social media rules.

The publication of the following contents is prohibited:

– That are allegedly illegal according to national, European or international legislation, or contents that allegedly conduct illegal activities or contravene the principles of good faith.

– That violate the fundamental rights of people, break online etiquette, disturb or could generate negative opinions in our users or third parties, and in general any contents that TWIST & SHINE considers inappropriate.

– And in general, contents that contravene the principles of legality, honour, responsibility, the protection of human dignity, the protection of minors, public order, privacy, consumers and intellectual and industrial property rights.

TWIST & SHINE also reserves the right to remove without notice any contents that it considers inappropriate from the company’s website or social network.

Communications sent via social media will be added to a file owned by TWIST & SHINE, and the company may send you information of interest.

You can find more information and see the companies that comprise our group in this privacy policy.

Without exception, if you send personal information via the social network, TWIST & SHINE will be exempt from all liability regarding the security measures used on this platform, and if users wish to find out about them they must consult the individual relevant  terms and conditions of the network in question.

SECURITY MEASURES:

The data you provide us with will be processed confidentially. TWIST & SHINE has adopted all the technical and organisational measures and all the protection levels required to guarantee security in the data processing and to avoid their alteration, loss, theft, unauthorised processing or access, in accordance with the state of the technology and the nature of the stored data. It also guarantees that the processing and storage in files, programmes, systems or equipment, premises and centres comply with the requirements and conditions concerning integrity and security as established in current legislation.

LANGUAGE

This privacy policy has been drafted in Spanish. Therefore, if there is any contradiction in any of the versions provided in other languages, the Spanish version will prevail. 

10-REVISION

This privacy policy was last revised in February 2021 but may be revised at any time. We recommend that you read it every time you log into our website in case it has been amended.