Twinklers Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
Definitions and Interpretations
1. In this Policy, the following terms shall have the following meanings:
- “Account” – means an account required to access and/or use certain areas and features of Our Site;
- “Cookie” – means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section “Our Use of Cookies”, below;
- “Cookie Law” – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”);
- “personal data” –means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
- “We/Us/Our” – means Twinklers Ltd.
Information About Us
Our Site is owned and operated by Twinklers Ltd.
What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
Your Rights
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section “How Can You Access Your Data“)
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact us by emailing sales@twinklers.com)
- The right to be forgotten – i.e. the right to ask us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section “How Do We Use Your Data?” but if you would like us to delete it sooner, please contact us by emailing sales@twinklers.com
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes.
- Rights with respect to automated decision making and profiling.
What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section “Our Use of Cookies” on Our use of Cookies and similar technologies.
- name;
- date of birth;
- gender;
- business/company name;
- job title;
- profession;
- contact information such as email addresses and telephone numbers;
- demographic information such as postcode, preferences, and interests;
- financial information such as credit / debit card numbers;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section “How and Where Do We Store Your Data?“, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Contacting you in the event of a non-completed or pending transaction to ascertain if this was due to any malfunction in Our process and, if so, to complete the transaction with you;
- Supplying Our products to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring Our products for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by informing Us;
- Market research;
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and or post with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
4. Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section “Our Use of Cookies“. Please refer to section “Our Use of Cookies” for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
5. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
How And Where Do We Store Your Data?
1. We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
2. Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
3. Data security is very important to us, and to protect your data. We have taken suitable measures to safeguard and secure data collected through Our Site.
Do We Share Your Data?
1. We may share your data with other companies in Our group. This includes Our holding company and its subsidiaries.
2. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
3. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
4. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
5. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
6. In order to be able to offer you Clearpay’s payment options, we will pass to Clearpay certain of your personal information, such as contact and order details, in order for Clearpay to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Clearpay you can find here. www.clearpay.co.uk . Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Clearpay’s privacy statement
What Happens If Our Business Changes Hands?
1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
2. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
How Can You Control Your Data?
1. In addition to your rights under the GDPR, set out in section “Your Rights“, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right To Withhold Information
1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
2. You may restrict Our use of Cookies. For more information, see section “Our Use of Cookies“.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more by emailing hello@myperfectcosmeticscompany.com.au. Alternatively, please refer to Our Data Protection Policy.
Our Use Of Cookies
1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
2. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for advertising, tracking and analytics. For more details, please refer to section “How Do We Use Your Data?“, above, and to sub section 7 of “Our Use of Cookies” below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
3. All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
- Strictly Necessary Cookies – A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions
- Analytics Cookies – It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
- Functionality Cookies -Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
- Targeting Cookies – It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests. Some information gathered by targeting Cookies may also be shared with third parties.
- Third Party Cookies – Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us (these Cookies will work in the same way as analytics Cookies described above).
- Persistent Cookies – Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
- Session Cookies – Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
4. Cookies on Our Site are not permanent and will expire.
5. Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
6. Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in sub section 7 of “Our Use of Cookies“. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in sub section 10 of “Our Use of Cookies“, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
7. The following first party Cookies may be placed on your computer or device:
| Name of Cookie | Purpose | Strictly Necessary |
| _ga | This cookie enables the function of Google Analytics. This software helps us take and analyse anonymised visitor information such as browser usage, new visitor numbers, response to marketing activity and browsing times. That information helps us to improve the website and your experience, and to make our marketing campaigns relevant. These cookies can be turned off via your web browser, and will not affect the user’s experience. | Yes |
| _gid | Used to distinguish users. | Yes |
| _uetsid | Microsoft Bing Ads Universal Event Tracking (UET) tracking cookie | Yes |
| __lc.visitor_id.9006680 | LiveChat Inc, which allows us to talk to visitors on site | Yes |
| catAccCookies | Consent plugin to record that you accept the fact that the site uses cookies. | Yes |
| lc_sso9006680 | Unclassified | Yes |
| lc_ssoundefined | Unclassified | Yes |
| lc_window_state | Unclassified | Yes |
| pps_show_102 | Unclassified | Yes |
and the following third party Cookies may be placed on your computer or device:
| Name of Cookie | Provider | Purpose |
| __lc_vv | Live Chat Inc. | Unclassified |
| __livechat | Live Chat Inc. | Used to hide the user’s personal customisation of LiveChat. |
| __livechat_lastvisit | Live Chat Inc. | Stores when the user last used LiveChat. |
| 3rdparty | Live Chat Inc. | Used to hide the user’s personal customisation of LiveChat. |
| Wd, xs, sb, presence, pl, datr, Dpr,fr, c_user, act | To track users, interactation and retarget them on Facebook. | |
| sess, usersync, uuid2, anj, icu | AppNexus | provides data and analytics helping businesses buy and sell online advertising |
| Machine, JSESSIONID | Worldpay.com | To collect the session ID and complete payment from our website to Worldpay and authentication the purchase |
| MUID | Bing | Bing Ads uses the Microsoft User Identifier (MUID) to help count valid clicks |
8. The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
9. In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
10. The links below provide instructions on how to control Cookies in all mainstream browsers:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB;
- Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835;
- Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist);
- Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB;
- Safari (iOS): https://support.apple.com/en-gb/HT201265;
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences;
- Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers).
11. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. In addition, Our Site uses analytics services, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site.
