PRIVACY POLICY

This www.twinings.co.uk website (the "Website") is owned and
operated by R. Twining and Company ("Twinings" or "we" or "us")
Twinings are committed to protecting and respecting your privacy
and complying with applicable laws for the protection of personal
data. This policy sets out (1) the type of information we collect
from you when you visit the Website; and (2) the way we treat any
information we collect from you, or that you provide to us through
the Website.
For the purpose of the UK Data Protection Act 1998 (and
equivalent legislation in other EC Member states) the Data
Controller Twinings, a company registered in England and Wales
(Company No. Twinings) whose registered office is at Weston Centre,
10 Grosvenor Street, London, W1K 4QY] .
[This Privacy Policy forms part of the Website Terms &
Conditions and by submitting your personal information to the
Website, you are confirming that you have read and understood this
Privacy Policy and are agreeing to the uses of your personal
information described in it.]
Before you start
Parts of our Website may contain links to third party websites
for your convenience and information. When you access a third
party website through such link please understand that we do not
control the content and are not responsible for the privacy
practices of that site even where they may contain Twinings or
associated company logos. We suggest that you carefully
review the privacy policies of those websites linked from our
site. These sites may send their own cookies to users,
collect data or solicit personal information.
Information collected through our
Website
When you visit our Website, we may collect information on two
different levels about your visit: (1) Statistical Information,
collected as you browse the site, and (2) personal information
which you knowingly give to us.
(1) Statistical
Information
In general this Website automatically gathers certain usage
information such as the number and frequency of visitors to our
Website, very much like the television ratings that tell the
networks how many people tune into the programmes. We may also
invite you to interact with our Website by answering questions and
selecting preferences as you move around the Website. We only use
this data in an aggregated and non-personally identifiable way. The
collected data helps us to determine our visitor's preferences, and
to improve our Website so it is as appealing as we can make it for
as many of you as possible.
Like many companies, we use "cookie" technology on our Website.
These cookies are small text-only strings that store information in
the memory of your browser. There are several reasons we may use
cookies:
Persistent Cookies. These
cookies contain only a unique number, so when you log in they can
tell us whether you've visited us before or if you are a new
visitor. These cookies do not obtain any personal information about
you or provide us with any way to contact you, and they do not
extract any information from your computer. We do use cookies to
help us identify site features in which you have the greatest
interest, so that we can provide more of what you may want.
Session Cookies. These
cookies are used to store information about your current visit to
our site, such as if you have logged in successfully or if you have
entered information into an electronic form. We use these cookies
to personalise information and to help with on-line services. They
can also provide us with a quick and convenient means of keeping
site content fresh and relevant to your interests. Our server uses
cookies to help with back-end interaction as well, which improves
the utility of our site by being able to securely store any
personal data that you have shared with us. These cookies are
deleted the moment you close your browser window.
Most browsers automatically accept cookies, but you can usually
refuse cookies, or selectively accept certain cookies, by adjusting
the preferences in your browser. If you turn off cookies, there may
be some features of our site that will not be available to you and
some Web pages may not display properly.
We do not combine information collected through cookies with any
personal information you tell us about yourself.
(2) Personal
Information
(a) How we collect your personal
information
The only personal information we collect from you is information
you choose to provide us about yourself.
Some services and facilities on our Website we will require you to
provide us with a certain minimum amount of personal information
such as your name, postal address and email address in order that
we can provide those services to you or to fulfill our obligations
to you ("Required Information"). Typical examples where this
arises include entering one of our competitions, prize draws or
promotions, requesting a sample of our product or registering as a
user on our Website.
We may also ask you to provide additional information about
yourself to assist in us contacting you or providing our services
("Voluntary Information"). We will make it clear what information
is Required Information and what is Voluntary Information.
(b) How we use your personal
information
We will use your personal information for the purpose it has
been collected or any other purpose specified at the point of
collection. For example, we will retain and use your personal
information for the purpose of administrating and notifying you of
the results of any competitions or prize draws you have
entered.
(c) Direct
Marketing
If you have agreed to receive direct marketing from Twinings we
may from time to time contact you via phone, post, email or SMS
text message in order to send you news and offers and to help
formulate our marketing and business strategy for example, to ask
your views on how we can improve our products and services, and for
the purpose of analysing and researching our business, customers
and products.
(d) Opting Out and Updating your
personal information
Any time after you register your personal information with us
you may (i) opt out of receiving any communications you have chosen
to receive from us; and (ii) update your personal information by
notifying us of changes to the information previously given to
us.
All requests or notifications should be sent to R. Twining and
Company, South Way, Andover, Hampshire, SP10 5AQ.
(e) Sharing your personal
information
We will sometimes need to share your personal information with
third parties who we contract to help us deliver services to you
and to run and administer the Website and activities run through
the Website such as competitions. The information shared with
them will be limited to that necessary for them to perform the
service. They will not be authorised to make any other use of
that information and will treat it confidentially.
Except as described in the previous paragraph, we do not share
your personal information with any third party which is not a
subsidiary or parent company of Twinings other than: (i) where it
is required by law; (ii) if you specifically authorised us to do
so; or (iii) in the event that substantially all of the assets of
Twinings are acquired by a third party in which case personal data
held by it about its customers in its databases will be one of the
transferred assets.
Age restrictions
In some instances, it may not be possible to register for our
services or products if you are under a certain age determined by
the laws of the country where you are resident. In such
cases we may ask you your age for the purpose of establishing your
eligibility.
We do not intend to collect Personal Information relating to
children through our website. Any person under the age of 16 who
registers on our Website will be asked to provide a parent or
guardian's e mail address where confirmation will be requested
before any communication is made.
Transferring your information to
other countries
If you are resident within the European Economic Area ("EEA")
your Personal Information that we collect from you may be
transferred to, and administered at, a destination outside the EEA
which may have different levels of data protection law to the
country from where you have submitted your personal
information. By submitting your personal information, you
agree to this transfer, storing or processing. We will take all
steps reasonably necessary to ensure that your Personal Information
is treated securely and in accordance with this privacy policy.
OR
Overseas data
transfers
If we transfer personal information to countries, or administer
our services through countries whose data protection laws are not
as extensive as those in the EEA, we will keep control of the
information or require anyone we pass it to to treat it to
appropriate standards.
We will ensure that personal information transferred outside the
EEA is adequately protected.
Security
We take appropriate technical and organisational measures to
prevent accidental or unlawful destruction or unauthorised
disclosure, access or alteration to your personal information under
our control.
We will only store your data for as long as reasonably necessary
in the circumstance, after which your personal information will be
deleted from our systems.
However, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your
personal information, we cannot guarantee the security of your
information transmitted to our site; any transmission is at your
own risk. Once we have received your information, we will use
strict procedures to try to prevent unauthorised access.
Accessing your personal
information
Subject to some exceptions, you have a right upon written
request and payment of a fee of £10, to have a copy of any of your
personal information we hold.
Changes to the privacy
policy
Any changes that we make to this privacy policy will be posted
on this page. Please regularly check the privacy policy for
changes. Any changes that we do make to this privacy policy
will apply to information provided through the Website following
the revised privacy policy being posted. Regardless of any
changes we make to our privacy policy, we will continue to use your
personal information collected before the change in accordance with
the version of the policy in place at the time you provided your
information, unless you give your express consent for us to do
otherwise.
Contact
If you have any questions about this privacy policy or your
privacy, you can contact us at R. Twining and Company, South Way,
Andover, Hampshire, SP10 5AQ.