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Twilight Wheel
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GDPR Compliance

Last updated: May 6, 2026

Our Commitment to GDPR

Twilight Wheel is fully committed to compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We take our responsibility to protect your personal data seriously.

Data Controller

Twilight Wheel is the data controller for personal information collected through our website and services.

Contact Details:
Email: [email protected]
Address: 47 Rodney Street, Liverpool, L1 9EW, United Kingdom

Lawful Basis for Processing

We process personal data under the following lawful bases:

1. Consent

When you submit enquiry forms, you provide explicit consent for us to process your information to respond to your enquiry and provide our services.

2. Contract

Processing is necessary to fulfill our contractual obligations when you book and attend our educational programmes.

3. Legitimate Interests

We process data for legitimate business interests, such as improving our services and website functionality, provided these do not override your rights and freedoms.

Your GDPR Rights

Under UK GDPR, you have the following rights regarding your personal data:

Right to Access (Article 15)

You have the right to request a copy of the personal data we hold about you.

Right to Rectification (Article 16)

You can request correction of inaccurate or incomplete personal data.

Right to Erasure (Article 17)

You can request deletion of your personal data in certain circumstances, such as when it's no longer necessary for the purposes for which it was collected.

Right to Restrict Processing (Article 18)

You can request that we limit the processing of your personal data in specific situations.

Right to Data Portability (Article 20)

You can request a copy of your data in a structured, commonly used, and machine-readable format.

Right to Object (Article 21)

You can object to processing based on legitimate interests or for direct marketing purposes.

Rights Related to Automated Decision-Making (Article 22)

We do not use automated decision-making or profiling that produces legal effects or similarly significant impacts.

How to Exercise Your Rights

To exercise any of your GDPR rights, please contact us at:

Email: [email protected]

We will respond to your request within one month, as required by UK GDPR. In complex cases, we may extend this period by two additional months and will inform you accordingly.

Data Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of personal data in transit and at rest
  • Regular security assessments and updates
  • Access controls and authentication measures
  • Staff training on data protection

Data Retention

We only retain personal data for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations:

  • Active client records: Duration of service plus 7 years
  • Enquiries (unconverted): 2 years from last contact
  • Financial records: 7 years (legal requirement)
  • Marketing consent: Until withdrawn

Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours and inform affected individuals without undue delay.

International Data Transfers

Your personal data is processed and stored within the United Kingdom. We do not transfer data outside the UK unless adequate safeguards are in place.

Children's Data

Where we process data relating to children under 13, we ensure parental or guardian consent is obtained. We implement additional safeguards for children's data in accordance with UK GDPR.

Complaints

If you believe we have not handled your personal data in accordance with UK GDPR, you have the right to lodge a complaint with the supervisory authority:

Information Commissioner's Office (ICO)
Website: ico.org.uk
Telephone: 0303 123 1113

Updates to This Policy

We may update this GDPR policy to reflect changes in our practices or legal requirements. The "Last updated" date at the top of this page indicates when the most recent changes were made.

Contact Us

For any questions about our GDPR compliance or to exercise your rights, please contact us:

Email: [email protected]
Address: 47 Rodney Street, Liverpool, L1 9EW, United Kingdom

Twilight Wheel

Financial education for every stage of life, based in Liverpool.

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