Privacy Policy

1.Who we are

Twist & Burn Ltd is the data controller for the personal data described in this policy. We are registered in England and Wales under company number 17234299, with our registered office at Suite RA01, 195-197 Wood Street, London, E17 3NU, United Kingdom.

We have applied to register with the Information Commissioner's Office (application C2046374). Our registration number will be shown here once it is issued.

If you have any question about this policy or about how we handle your data, write to us at support@twistandburn.com.

We are not required to appoint a Data Protection Officer. Questions go to the address above and are handled by a director.

2.What we collect

We do not ask for your date of birth, your address, or any identity document. We do not knowingly collect data from anyone under 18.

3.A note about what you read

We record which issues you read and which endings you choose so that the service works and so the story continues where you left it.

We treat that carefully. We do not sell it, we do not share it with advertisers, and we do not use it to target you. We use it to run the service and to decide what we publish next. Our marketing is based on whether you are subscribed and how engaged you are, not on which stories you choose.

You can delete your account at any time, and your reading history goes with it.

4.Why we use it, and our legal basis

Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights. You can object to any of it, and we explain how in section 9.

5.Marketing

We send two kinds of email.

Service emails tell you about your account, your payments, and when a new issue is live. These are part of the service and you receive them while you have an account.

Marketing emails and the newsletter go only to people who have asked for them. Every one has an unsubscribe link at the bottom, and unsubscribing takes effect immediately.

We do not sell or rent your email address to anyone.

6.Who we share it with

We do not sell your personal data. We share it only with the companies that provide parts of our service, and only so far as they need it to do their job. Each is bound by contract to protect it and to use it only on our instructions.

We may also share data where we are required to by law, or where it is necessary to establish or defend a legal claim, or if the business is sold, in which case we would tell you first.

7.Transfers outside the UK

Some of the companies above are based outside the UK, mainly in the United States. Our database provider holds your data in Ireland but contracts through a Singapore entity.

Where your data goes outside the UK we rely on the UK International Data Transfer Addendum to the European Commission’s standard contractual clauses, or on UK adequacy regulations where they apply. The EU, including Ireland, is covered by UK adequacy regulations.

If you want to know more about the safeguards for a particular transfer, ask us and we will explain.

8.How long we keep it

When we no longer need personal data we delete it or make it anonymous so that it can no longer identify you.

9.Your rights

Under UK data protection law you have the right to:

• ask for a copy of the personal data we hold about you
• have inaccurate data corrected
• have your data deleted, where we have no continuing reason to keep it
• ask us to restrict how we use it while a question about it is resolved
• object to our use of it where we rely on legitimate interests
• receive the data you gave us in a portable format, or have it sent to another provider
• withdraw consent at any time, where we rely on consent

To exercise any of these, email support@twistandburn.com. We will respond within one month. There is no charge.

You can delete your account yourself at any time from your account settings, which removes your reading history and choices along with it. Two things remain. We keep payment records where the law requires us to, and we keep a one-way hash of your email address so that a deleted account cannot be recreated to claim the founding rate a second time. We cannot recover your email address from that hash.

Complaints. If you are unhappy with how we have handled your data, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk, or by calling 0303 123 1113.

10.Cookies

We use cookies that are necessary for the site to work, and, if you accept them, cookies that help us understand how the site is used and measure our advertising.

You choose when you first visit, and you can change your choice at any time from the cookie settings link in the footer. Our Cookie Policy explains each one.

11.Security

Data is encrypted in transit and at rest. Access to personal data is limited to the people who need it. We never see or store full card details, which are handled entirely by Stripe.

No system is completely secure. If a breach occurs that is likely to put your rights at risk, we will tell you and the Information Commissioner’s Office without undue delay.

12.Children

This service is for adults. We do not knowingly collect data from anyone under 18, and we will delete any account we believe belongs to a child. If you think a child has created an account, tell us at support@twistandburn.com.

13.Changes to this policy

We may update this policy. If a change materially affects how we use your data we will tell you by email before it takes effect. The date at the top shows when it was last changed.