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TWF Privacy Notice
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The Wisdom Factory CIC is a company incorporated in England and Wales with registered number 07948302, whose registered office is Suite 407 Jewellery Business Centre, 95 Spencer Street, Birmingham, West Midlands, B18 6DA ('TWF'). TWF is registered with the Information Commissioner’s Office as a data controller (No. ZA135271).

TWF is responsible for,,, and and the GammaGen mobile app (our 'websites').

Please read this notice carefully. This notice is designed to provide further information about how we use your data in relation to TWF’s services, its websites and apps.

This notice describes the type of personal data we collect and how we may use and share that data.

‘Personal data’ is any information that relates to a living, identifiable person. This data can include your name, contact details, and other information we gather as part of our relationship with you.

It can also include ‘special categories’ of data, which is information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation. The collection and use of these types of data is subject to strict controls. Similarly, information about criminal convictions and offences is also limited in the way it can be processed.

We are committed to protecting your personal data, whether it is ‘special categories’ or not, and we only process data if we need to for a specific purpose, as explained below.

We collect your personal data mostly through our contact with you, and the data is usually provided by you, but in some instances we may receive data about you from other people/organisations. We will explain when this might happen in this Notice.

1.        Why do we collect data?

We collect data from you as set out in this Notice. TWF is a community interest company which provides advice, research, training and technology services. Five per cent of our turnover is set aside for a grant fund for community projects in Birmingham each year.

From time to time we want to share information, promote our services and raise awareness of our grant fund.

We collect personal data about registered users of our BIDBase online database service in order to keep them up-to-date with changes to the service and BIDBase software bugs.

We also collect personal data from users of our GammaGen app, as explained below[SC1] .[SC2]

2.        What we collect

We may collect the following information:

You may provide personal data when you book onto/decline/attend our events/training courses, visit our websites, use our apps, respond to research/surveys/competitions, make an application to our grant fund or communicate with us about your use of grant funding. We do not store your data if we have obtained it by the provision of services to one of our clients (e.g. a market research project).

If you communicate with us through any link on our websites or via our apps, we may ask you for your personal data so we can respond to your questions and comments. We may collect personal data from you for research purposes via our GammaGen app, as explained below.

3.        Other data we may collect automatically

When you visit our websites or use our apps, we may automatically collect certain personal data that we then aggregate so that it is not linked to a single, identifiable individual. This information provides us with statistics such as how many users visited our site and which pages were accessed. By collecting this information, we learn how to best tailor our websites. We may collect this information either through 'log files', 'cookie' technology or with 'web beacons', as explained below.

Log Files

Log files are web server files (such as the domain name or IP address, URL, the http response code, the Website from where you visit us or the date and duration of your visit) that are automatically created when an Internet user visits a site. Once you stop using our websites, we process and use this information only to enable further connections, for billing purposes, to detect disruptions to telecommunication equipment and to detect abuse of our telecommunication services.

This information is used to create general aggregated profiles of our websites’ user base and is not used to create personalised user profiles. In case of disruption or misuse, we reserve the right to file a report with law enforcement agencies. We do not use this information for any other purpose(s) and do not share this information with any third parties, except as set out in the section titled How We Share Personal Data below.


Like many businesses, we use 'cookies' or similar objects on our websites. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We use cookies to tell us, for example, whether you have visited our websites before or if you are a new visitor and to help us identify site features in which you may have the greatest interest. Cookies may enhance your online experience, for example, by remembering your passwords and viewing preferences, while you are visiting a particular site.

The majority of browsers are initially set up to accept cookies. The toolbar on most browsers will have a feature to tell you how to stop accepting new cookies, how to receive notifications of new cookies, and how to disable any existing cookies. Please note, however, if you do disable, reject or stop cookies, you may not be able to take full advantage of all our websites’ features and services that we would like to offer you.

Web Beacons

Certain pages on our websites may contain 'web beacons' (also known as Internet tags, pixel tags and clear GIFs). These web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies sent by the third party.

4.        How we use your data

In general terms, we process your data in order to manage our relationship with you. This section identifies more specific purposes for processing your data, and the legal basis for each type of processing.

a.             Goods or services for purchase

From time to time we may offer goods or services for purchase in writing or through our websites and apps. We may ask you to provide personal data which is collected for the purpose of providing you with those goods and services.   Our lawful basis for processing this personal data is contractual.  Whilst we currently request payment by BACS or cheque, we may use third party payment processing services to make payment from time to time. If so, TWF is not liable or responsible for any such service and your use of that service might be subject to terms and conditions imposed by the service provider and other privacy policies.[SC5]

b.             Newsletters and other marketing communications

On our websites, as a TWF client or otherwise following direct communication with us, we may ask you to give explicit consent to receive newsletters and other communications about our services or opportunities of interest e.g. our grant fund. Your personal data is processed by us to send you those communications. Details of how you may withdraw your consent to our processing your personal data in this way and for these purposes are described in section 12 ‘Your Preferences’ below.

c.             Product updates for contracted service subscribers

If you are a subscriber to one of our web-delivered services, such as BIDBase or the GammaGen mobile app, we will process your personal data in order to keep you up-to-date with changes to those services.  The personal data we process will be your name and email address.  It will be stored on our server in the UK.  Our lawful basis under data protection legislation for doing so is ‘legitimate interest’ in the case of BIDBase.   In relation to GammaGen, we will not process your data in this way without your consent, which can be withdrawn at any time (see section 12 below). Further details of the processing of data for the purposes of the GammaGen app are set out below.

TWF may also store your data in order to keep track of important direct communications that we have had with you. We may do this by storing emails or via an appropriately sourced customer relationship management system.  We will retain your data only in accordance with paragraph 8 below.

d.             Events or training courses

When you book onto and/or attend one of our events or training courses we may collect your personal data and record your interest in and attendance at that event/course. We may also record your evaluation responses for the purposes of continuous improvement. [SC8] Our lawful basis for processing this personal data is our legitimate interest in improving our products and services to better meet the needs of our customers.  You can request we stop processing your personal data in this way at any time by contacting us.

e.             Use of images

TWF may use photos and videos to promote our work via our social media accounts, our websites, our newsletters and other communications. Where possible, we will try to gain your consent in advance. However, if we are using an image of you, and you would like us to stop, please contact us.

f.              Special Categories of Data

Some of our services involve the collection and processing of personal data which is within a special category of data as described above.

g.             GammaGen app

Our GammaGen mobile app collects health information about users and sends that information to a database at  The information specifically is whether or not the user has been diagnosed with Alzheimer’s Disease and if they have, what year they received the diagnosis.  This health data is processed for the purposes of gathering relevant data for research in relation to potential treatment for Alzheimer’s Disease and related neurological disorders. The legal basis for processing this data is as follows:

1.             the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, those interests being the performance of the app and the research which is being undertaken as a result of participation and the provision of health data for use by the app, and these interests are not overridden by the interests or fundamental rights and freedoms of the data subjects which require protection of personal data, in particular where the data subject is a child;

2.             the data subject has given explicit consent to the processing of their personal data for the purposes specified in 1. above.  

Accordingly, we will ask for your explicit consent to this processing before you use the app. You may withdraw your consent at any time in accordance with section 12.

At times, we may further process data which we have already collected. We will only do this if the new purpose for processing it further is compatible with the original purpose that the data was collected for. We will tell you about any further processing before carrying it out.

5.        How we don’t use your data

We don’t use your personal data for personal marketing profiling or automated decision-making using algorithms.

6.        How we share personal data

We never sell or otherwise disclose your personal data, subject to some specific exceptions:

This is a list of the information we may share with external recipients, and for what purpose:

Recipients of your data

Purpose for sharing

Researchers working in neurological fields to find a cure for Alzheimer’s Disease.


To further advance the investigation of induced gamma brain waves in treating Alzheimer’s Disease.


Harris Accountancy CIC

External payroll providers (TWF employees only)


To circulate emails on GDPR compliant distribution lists

7.        How we store your personal data

Your personal data is held in both hard copy and electronic formats.

Electronic data, including emails, is stored on our servers, which are located in the UK on our software suppliers’ servers.

Your personal data will be processed in the United Kingdom and/or other states of the European Union (EU).

8.        How long we keep your data.

Information about how long we process your data for can be found below:



Personal and special category data collected by the GammaGen app


Two years after the user last used the app or sooner by request

Employee data

As required by HMRC

BIDBase user personal data

Two years after the person ceases to be a BIDBase user or sooner by request

Personal data relating to goods and services purchased

As required by HMRC

Personal data relating to events/courses

Two years after the event or course is complete


Some retention periods are based on legal requirements while others take into account practical needs to keep the data.

Once the applicable retention period expires, unless we are legally required to keep the data longer, or there are important and justifiable reasons why we should keep it, we will securely delete the data.

9.        Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

10.        How we protect your personal data

We maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorised access, disclosure, alteration or destruction of the personal data you provide to us.

11.        Right to be Informed, Right of Access, Right to Data Portability and Right of Rectification

As a data subject, you have the following rights in relation to your personal data processed by us:


·           To be informed about how your data is handled;

·           To gain access to your personal data;

·           To have errors or inaccuracies in your data changed;

·           To have your personal data erased, in limited circumstances;

·           To object to the processing of your personal data for marketing purposes or when the processing is based on the public interest or other legitimate interests;

·           To restrict the processing of your personal data, in limited circumstances;

·           To obtain a copy of some of your data in a commonly used electronic form, in limited circumstances;

·           Rights around how you are affected by any profiling or automated decisions.


If you would like a copy of the personal data relating to you that we hold, please contact us.

If you wish to obtain a copy of any of your data in portable format, we can supply your data in a common format, e.g. Excel file or CSV file.  This applies only to personal data you have provided to us.

If you believe that any information we are holding on you is incorrect or incomplete, please contact us as soon as possible and we will promptly correct any information found to be incorrect.

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact Mike Mounfield, our Data Protection Officer .

12.         Your Preferences

If you would like to update your contact details and preferences (e.g. you are interested in hearing about our grant fund but not our services) or tell us you no longer consent to our processing of your personal data, please contact us.

13.        Updates to our Privacy Notice

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

14.        Right to Object, Right to Erasure, Right to Restriction of Processing and other complaints

If you would like to object to our processing your personal (subject to the appropriate lawful basis) or are otherwise unhappy with the way that we have processed your data, or with aspects of our data protection policy, we would encourage you to contact us in the first instance.

If you would like us to restrict processing your personal data or erase it from our systems (subject to the appropriate lawful basis) please contact us.

If you are dissatisfied with the way that we have handled your complaint (or if you would prefer to exercise your right to do so), you may contact the Information Commissioner directly. Information on how to do this can be found on their website.

15.        How to contact us

If you have any questions, comments or requests please contact Mike Mounfield, our registered Data Protection Officer. You can do this by sending an email.

Last updated: June 2018