Privacy Policy

This Privacy Policy explains how Twily LTD ("Twily", "we", "us") collects, uses and protects your personal information when you visit twily.store, buy our digital eBooks, contact us or subscribe to our newsletter. We are committed to handling your information responsibly and in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who we are

Twily LTD is the data controller for the personal information described in this policy. If you have any questions about this policy or how we use your information, please contact us:

2. Information we collect

We only collect the information we need to run our store and support you:

Order information: your name, email address, billing address and country, the eBooks you bought, the order total and the payment method used. We need this to take payment, deliver your eBooks and keep tax and accounting records.
Download records: when your eBook files were downloaded and the IP address used, so we can deliver your purchase, help if a download fails and prevent misuse of download links.
Checkout confirmations: a record that you agreed to immediate access to your eBook and acknowledged the effect on your right to cancel (see our Refund Policy).
Messages you send us: your name, email address, subject, order number (if you give it) and message when you use our contact form, email or phone us. Contact form messages are sent to us by email; they are not published on the website.
Newsletter: your email address and a record of your consent: the wording you agreed to, when you signed up and when you confirmed your subscription.
Technical information: standard server logs (such as IP address, browser type and pages requested) and the cookies described in our Cookie Policy.

We do not ask for, and you do not need to share, any information about your health in order to buy or use our eBooks. Please don't send us personal medical information.

3. Payments

Payments are handled by the secure payment provider you choose at checkout. You enter your card or account details directly with that provider. Twily never sees or stores your full card number. The payment provider processes your information under its own privacy policy, which is linked from its payment screen.

4. How we use your information and our lawful bases

To process your order and deliver your eBooks, including sending order confirmation and download emails. Lawful basis: performance of a contract with you.
To reply to your messages and give customer support. Lawful basis: our legitimate interests in helping our customers, or performance of a contract where your message is about an order.
To send our newsletter, only if you have subscribed and confirmed by email. Lawful basis: your consent, which you can withdraw at any time using the unsubscribe link in every email.
To keep accounting and tax records. Lawful basis: legal obligation.
To keep our website secure and prevent fraud, spam and misuse of downloads. Lawful basis: our legitimate interests in protecting our business and customers.
To understand how our website is used, only if analytics is enabled and you choose "Accept analytics". Lawful basis: your consent.

We do not use your information for automated decision-making that has legal or similarly significant effects on you, and we do not sell your personal information.

5. Who we share information with

We share personal information only when it is needed to run our store, with:

our website hosting provider, which stores the website and its data;
payment providers, to process your payment and prevent fraud;
email delivery services, to send order emails, newsletter confirmations and replies to your messages;
an analytics provider (Google Analytics), only if analytics is enabled and you have accepted it;
professional advisers such as accountants, and authorities such as HMRC, where we are legally required to.

These providers may only use your information to provide their services to us.

6. International transfers

Some of our service providers may store or process information outside the UK, for example in the European Economic Area or the United States. When this happens, we make sure appropriate safeguards are in place as required by UK data protection law, such as UK adequacy regulations or the UK International Data Transfer Agreement or Addendum.

7. How long we keep information

Orders, invoices and download records: 6 years from the end of the financial year of the order, to meet UK accounting and tax requirements.
Messages and support emails: up to 2 years after our last contact, unless they relate to an order, in which case we keep them with the order records.
Newsletter records: until you unsubscribe, when your details are deleted. Sign-ups that are never confirmed are not sent any newsletters and are deleted periodically.
Analytics data: for the retention period set in Google Analytics (no longer than 14 months).

8. How we protect your information

Our website uses an encrypted (HTTPS) connection. eBook files are delivered through protected download links rather than public web addresses, and access to our systems is limited to people who need it. No method of transmission or storage is completely secure, but we take reasonable steps to protect your information.

9. Your rights

Under UK data protection law, you have the right to:

ask for a copy of the personal information we hold about you;
ask us to correct information that is wrong or incomplete;
ask us to delete your information, where we no longer have a reason to keep it;
ask us to restrict how we use your information, or object to us using it based on our legitimate interests;
receive your information in a portable format, where this applies;
withdraw your consent at any time, for example by unsubscribing from our newsletter.

To make a request, email us at contact@twily.store. We will reply within one month. We may need to confirm your identity before we act on a request.

If you are unhappy with how we have handled your information, please contact us first so we can try to put it right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113.

10. Children

Our store is intended for adults. You must be 18 or over to make a purchase, and we do not knowingly collect personal information from children.

11. Cookies

We use essential cookies to run the store, cart and checkout, and optional analytics cookies only with your permission. See our Cookie Policy for details.

12. Changes to this policy

We may update this policy from time to time, for example if we start using a new service. The "Last updated" date at the top of this page shows when it was last changed. If we make significant changes, we will make this clear on the website.