Privacy Policy

This website (the “Website”), provides information about the products and services (“Services”)
marketed by CyTwist Ltd and its affiliated companies, (“We”, “Our”, “Us”, as appropriate). CyTwist is
committed to protecting and respecting your privacy in accordance with applicable laws. This privacy
policy provides comprehensive information about our processing activities in the Group (the “Privacy
Policy”), though the particular processing activities and privacy practices may vary in different companies
and jurisdictions.

    This Privacy Policy (together with the terms and conditions of any other agreement you may have with
    us) sets out the basis on which any Personal Data (as defined below) we collect from you, or that you
    provide to us, will be processed, stored and shared by us. We process Personal Data in accordance with
    “Applicable Data Protection Laws” (which means the General Data Protection Regulation 269/2016
    (“GDPR”) and any data protection and privacy laws and regulations applicable to us). Please read the
    following carefully to understand our practices regarding your Personal Data, before you access or use
    the Website and/or Services. By browsing this Website and using our Services, you consent to the
    processing of your Personal Data as detailed in this Privacy Policy, (except in specific cases where your
    consent will be collected through a consent form). If you have read this Privacy Policy, and remain opposed
    to our practices, you must immediately leave this Website, and avoid or discontinue all use of the Website
    and/or Services. If you have further questions or concerns regarding this Privacy Policy please contact us
    This Website and our Services is not intended for persons under 18 and we do not knowingly collect data
    relating to minors under 18. Insofar as Personal Data may be collected based on your consent, you must
    be above the age of 18. If these age requirements are not met, you are required to avoid using the Website
    and/or Services.
    “Personal Data” means information that can directly or indirectly identify you. Personal Data may include:
    • “Contact Details” such as your name, address, email address, and telephone number;
    • “Payment Information” such as debit/credit card, Paypal Account and/or bank account;
    • other information such as an IP address; in certain US States, Personal Data may include your
    house-hold data and other items of information, such as inferences drawn from any Personal Data
    to create a profile about a consumer.
    The term Personal Data shall also include and refer to similar terms in Applicable Data Protection Laws.
    3.1. General Overview
    We use different methods to collect data from and about you, including through:

a) Direct interactions: You may give us your Personal Data by speaking to us in person on-site
at our premises or off-site; by filling in forms or by corresponding with us by post, phone,
email or otherwise.
b) Automated technologies or interactions: As you interact with our website, we may
automatically collect data about your equipment, browsing actions and patterns. We collect
this Personal Data by using technologies of third party providers.
c) Third party service providers: We may receive Personal Data such as Contact Details and
Payment Information about you from various third parties including from providers of
technical, payment and delivery services.
d) Where we need to collect Personal Data by law, or under the terms of a contract we have
with you and you fail to provide that data when requested, we may not be able to perform
the contract we have or are trying to enter into with you (for example, to provide you with
goods or services). In this case, we may have to cancel a product or service you have with us
but we will notify you if this is the case at the time.
3.2. For easy reference, we provide below information about the collection of Personal Data,
according to the relationship we have with you.
a) Business Representatives: if you are a member of the personnel of a business (a legal entity)
which is one of our customers or service providers, and you wish to request a quote from us
or to place an order with us, we may collect your Contact Details.
b) Visitors: When visitors come to the premises of a Group company for meetings, inspections,
project work, building and electrical work etc., we may collect some of their Contact Details
and name of workplace.
c) Participants to Trainings and Events:
Attendees. When you book or register for a training course or an event run or hosted by us,
we may collect: your Contact Details, order history, professional registration and qualification
and training history.
Trainers. When you run a training course, we may collect: your Contact Details, professional
details and biography.
In all of the above cases, (subject to your consent if required), we may film you when we
video record the course or event.
3.3. In all of the above relationships mentioned in Section 3.2: i) we may collect information on the
handling of your request and/or the relationship with you and any other Personal Data you
voluntarily provide to us; ii) You represent the Personal Data you provide is accurate, complete
and up to date and that you are legally authorized to provide it.


We collect and use your Personal Data for the following purposes and under the following legal
4.1. In order to enter into and/or perform a contract with you, we may: provide you with the
information that you request from us; maintain your order history and Contact Details in our
customer relations database; book you onto a course or an event, ensure that you have the
necessary qualifications and experience to join the course, take payment if required and keep a
record of attendees so we can issue a certificate of completion.
4.2. To fulfill our legal and regulatory obligations, we may: take action to prevent, investigate and
detect crime, fraud or anti-social behavior and prosecute offenders, (including working with law
enforcement agencies or the regulators).
4.3. To exercise tasks under our legitimate interests such as to:
d) enforce our terms and conditions, notably conditions of returns, refunds and payments;
e) handling customer contacts, queries and complaints or disputes;
f) to protect our operations;
g) to know who is on-site for security purposes and to check timings and attendance in relation
to project works to protect our rights, privacy, safety of property, and that of our group
companies, you or others;
h) to allow us to pursue available remedies or limit our damages;
i) ensure the security and integrity of our services and ensuring our websites operate
j) to administer our website and for internal operations, including troubleshooting, data
analysis, testing, research, statistical and survey purposes.
k) to improve our website to ensure that content is presented in the most effective manner for
you and for your computer;
l) where we assist you in obtaining your own finance for the purchase of our products and/or
services we may pass your Personal Data to credit reference agencies and they may keep a
record of any search that they do. This includes exchanging information with other
companies and organizations for the purposes of fraud protection and credit risk reduction.
m) to improve our training courses.
4.4. Where you have provided your consent we may: deliver relevant online and/or off-line
advertising to you; make suggestions and recommendations to you and other users of our
website about goods or services that may interest you or them; if you are a leader of a course
we may provide your professional information to delegates, and in our marketing materials. We
may use event/course video recordings and/or before/after photos that may include information
about you for education and marketing purposes on the product and how treatments are


5.1. In addition to the categories of Personal Data described above, we will also process “Non-
Personal Information”, (meaning information that does not personally and specifically identifies a

natural person, such as anonymized information) which may be collected through the App in the
following ways:
a) Information that your browser sends (“Log Data”). This Log Data may include, but is not
limited to, non-identifying information regarding the User’s device, operating system,
internet browser type, screen resolution, language and keyboard settings, internet service
provider, referring/exit pages, date/time stamps, the web page you were visiting, information
your search, etc.
b) We may collect further Non-Personal Information through the use of automated devices and
applications to evaluate usage of our Service and through cookies. We use these tools to help
us improve our Website, performance, and user experience. We may also engage third parties
to track and analyze data or provide other services on our behalf. Such third parties may
combine the Non-Personal Information that we provide about you with other information
that they have collected from other sources. This Policy does not cover such third-parties use
of the data and such use is governed by such third parties privacy policies.
c) Other Apps and applications may also place or read cookies on your computer’s browser. For
more information about our use of cookies, please see our Cookie Policy [add link].

    6.1. We retain Personal Data as long as we are required to keep the information by applicable laws,
    or in accordance with our contractual obligations or legitimate interests. The information may
    be located in the EU, the USA and/or other jurisdictions.
    We may share Personal Data that we receive from you including information used to order our products
    and/or services with the following third parties:
    7.1. Our service providers – such as accountants, auditors, experts, lawyers, credit reference
    agencies, IT systems providers, manufacturers, support and hosting service providers; printing,
    advertising, marketing and market research and analysis service providers; document and
    records management providers; technical engineers; data storage and cloud providers and
    similar third-party vendors and outsourced service providers that assist us in carrying out
    business activities.
    7.2. Government or other public authorities – including, but not limited to, government health
    organizations, law enforcement or other agencies to which we are required to disclose Personal
    Data by law, or by a warrant, subpoena or court order.
    7.3. Other third parties – In the event that we sell or buy any business or assets, we may disclose your
    Personal Data to the prospective seller or buyer of such business or assets. If the Group or a company which is part of the Group or substantially all of its assets are acquired by a third party,
  3. Personal Data held by it its customers will be one of the transferred assets.
  4. 7.4. We do not sell, share or rent any information collected to third parties except for those detailed
  5. in this privacy policy.
    8.1. If you opt-in (on-line or off-line) to receive on-line marketing and offers we will add your name

and email address to our marketing database. In some jurisdictions, we may also send you on-
line marketing messages if you have previously placed an order with us or where you have

provided your information for the purpose of contact (for example a badge scan at a tradeshow
or industry event). You can change your marketing preferences at any time and will always be
offered the opportunity to unsubscribe.
8.2. We will still contact you regarding your account or orders even if you have opted out of receiving
marketing from us.

    9.1. We have put in place appropriate security measures to prevent your Personal Data from being
    accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we
    limit access to your Personal Data to those employees, agents, contractors and other third parties
    who have a business need to know. They will only process your Personal Data on our instructions
    and they are subject to a duty of confidentiality.
    9.2. We have put in place procedures to deal with any suspected “Personal Data Breach” (as this and
    similar terms are defined in the Applicable Data Protection Laws) and will notify you and any
    applicable regulator of a Breach where we are legally required.
    9.3. Unfortunately, the transmission of information via the internet is not completely secure.
    Although we will do our best to protect your Personal Data, we cannot guarantee the security of
    your data transmitted to our website; any transmission is at your own risk. Once we have
    received your information, we will use strict procedures and security features to try to prevent
    unauthorized access.
    10.1. When you use our company page on a social media platform, and/or when you use social sharing
    buttons on our Website, or click on any links contained in our Website to the websites of our
    partner networks, our social media pages, advertisers and affiliates; you do so at your own
    discretion and subject to the terms and conditions as well as the privacy policies of each social
    media platform respectively. Please note that we do not accept any responsibility or liability for
    these policies and that these social media platforms or websites may track your activity.

10.2. We may collect Personal Data from your public profile, including, name, photo, and other
information you make available to us when you like, post or otherwise interact with our social
media pages such as Facebook, Twitter, and Instagram.

    11.1. Different privacy rights may apply in various jurisdictions. In some jurisdictions, you may have a
    right to receive information about the processing of your Personal Data by us, the right to rectify
    your Personal Data and/or to request deletion of your Personal Data.
    11.2. General conditions for complying with Personal Data inquiries: When you contact us about your
    Personal Data, we may need to ask you to provide us certain credentials to make sure that you
    are who you claim you are, to avoid disclosure to you of Personal Data related to others and to
    ask you questions to better understand the nature and scope of data that you request to access.
    We may redact from the data which we will make available to you, any Personal Data related to
    others. In addition, we may delete your Personal Data if required by Applicable Data Protection
    11.3. At any time, you may contact us at: _____ in order to inquire about your Personal
    Data rights. We will make good-faith efforts to assist you as we are required under the Applicable
    Data Protection Laws.
    11.4. If you think that the processing of Personal Data by us violates the Applicable Data Protection
    Laws, you can lodge a complaint with the regulator at your jurisdiction. We may provide the
    details of the regulator upon request.
    12.1. Data Location and International Data Transfers:
    a) Your Personal Data may be stored on our servers outside the EEA and may be processed by our
    Group companies and service providers outside the EEA. We transfer and process your Personal
    Data outside the EEA, and we do so in a manner commensurate with Applicable Data Protection
    12.2. Your EU Privacy Rights
    a) If you are a European resident, in addition to the rights mentioned above, under the GDPR and
    subject to its conditions, you have the following additional rights:
    • Erasure of Personal Data;
    • Objection to the processing of Personal Data;
    • Restriction of processing of Personal Data; and
    • Portability of Personal Data – to receive the Personal Data you have provided to us in a
    structured, commonly used and machine-readable form and transmit it to another data

b) In some instances, our legal obligations may override your rights under data protection laws. We
are also legally required to identify you before we process your request.
c) Normally, you will not have to pay a fee to access your Personal Data (or to exercise any of your
rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive
, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
d) We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.

    13.1. Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA). We
    do not support Do Not Track. Do Not Track is a preference you can set in your web browser to
    inform websites that you do not want to be tracked. You can enable or disable Do Not Track by
    visiting the Preferences or Settings page of your web browser.
    13.2. California Civil Code permits customers of the Group who are California residents to request
    certain information regarding its disclosure of Personal Information to third parties for their
    direct marketing purposes. To make such a request, please send an email to _.
    Please note that we are only required to respond to one request per customer each year.
    13.3. If you are a California resident under the age of 18 and a registered user, California Business and
    Professions Code permits you to remove content or Personal Data you have publicly posted on
    our Website. If you wish to remove such content or Personal Data and you specify which content
    or Personal Data you wish to be removed, we will do so in accordance with applicable law.
    Please be aware that after removal you will not be able to restore removed content. In addition,
    such removal does not ensure complete or comprehensive removal of the content or Personal
    Data you have posted and that there may be circumstances in which the law does not require
    us to enable removal of content.
    13.4. Under the California Consumer Privacy Act 2018 (you may have the following rights, subject to
    submission of a verifiable request made to us:
    a) The right to know whether your Personal Data is collected and processed by us;
    b) The right to know what specific categories of Personal Data we collect about you, the
    sources from which it was obtained and the business or commercial purposes for which it
    is collected or sold;
    c) The categories of third parties with whom we share Personal Data;
    d) If we sell information or disclose information for a business purpose, the categories of third
    parties to whom your Personal Data was sold or disclosed and which Personal Data was
    sold or disclosed;
    e) request us to rectify and/or delete your Personal Data; please note that such removal does
    not ensure complete or comprehensive removal of the content or Personal Data you have
    posted and that there may be circumstances in which the law does not require us to enable
    removal of content.

f) Personal Data portability;
g) The right to request us not to sell your Personal Data.
13.5. To exercise your rights, please send an email to

    Any changes we may make to our Privacy Policy in the future will be posted on this page and, where
    appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our
    Privacy Policy.
    15.1. Questions, comments and requests regarding this Privacy Policy are welcomed and should be
    addressed to:
    15.2. Note to EU residents: for the purpose of the GDPR, the data controller, may be one of the
    companies in the Group. If you have an inquiry and you are not sure which Group entity is the
    controller of your Personal Data, please contact us at the email mentioned above and we will
    try to connect you to the relevant controller.
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