Who are we?
This website twinings.co.uk (the “Website”) is owned and operated by R. Twining and Company Limited (registered in England and Wales under company number 5525071 and with its registered office at Weston Centre, 10 Grosvenor Street, London W1K 4QY) (called in this notice “Twinings”, “we”, “our” or “us”).
Purpose of this notice
This privacy notice tells you about the information we collect about you when you visit our Website or otherwise provide us with information.
It also tells you how you can exercise Your Rights (including the right to object to some of the data handling we carry out). More information about your rights and how you can exercise them is set out in the “Your Rights” section below.
What personal data do we collect?
1. Site traffic data and information about your computer
How do we use this data?
When you browse our Website, we use cookies to collect:
Information about your use of our Website – we collect standard internet log information and details of visitor behaviour patterns.
• We use this information to record visitor numbers, their use of different areas of the Website and any useful features or links. We do not use this information in any way that would identify you personally.
• We use a third parties, Google Analytics, HotJar and Nosto to collect this information but it is only processed in a way which does not identify anyone. We do not make, and do not allow Google or any other third parties to make, any attempt to find out the identities of those visiting our website;
Information about your computer; this includes your IP address, device type, operating system, browser type, events, viewed products, cart content, liked products, disliked products, external campaign attributions, clicked recommendations and country code.
• We use this information to help maintain the security of our Website and to identify trends so that we can improve its performance.
• We use information collected by Nosto to present you with tailored content, including information about products and promotions that, based on your browsing history, we think will be of interest to you.
• We also use this information to customise the Website according to your interests and to ensure the Website’s content is presented as effectively as possible for you and to enable you to participate in interactive features of the Website, when you choose to do so.
• We do not use this information in any way that would identify you personally.
Information about your preferences for online advertising purposes – where you have consented to marketing or advertising cookies or similar technologies using our cookies tool, we use this information to record your preferences and to personalise our advertisements to you directly and through our advertising partners, including AWIN [affiliate marketing networks], Facebook, Instagram [the social media platforms that we use] as well as Nosto and Klaviyo [our Ad Partners].
• The personalisation of ads may be based on information we have collected as set out in this section, [that you agree to provide to us (under our Direct Marketing section below)] or based on other information attributed to you by our Ad Partners – such as your interests, age, gender or similar demographics inferred from your internet browsing.
• We refer to this information as ‘Event Data’. Where we use Facebook or Instagram marketing, this type of personal data is jointly controlled by us and our Ad Partner (Facebook Ireland Limited) as we use this information jointly to provide you with tailored advertising. For the purposes of exercising your data subject rights in relation to Event Data, our Ad Partner will be your primary contact. For contact details and further information about how our Ad Partners use your data, please see Facebook's Terms of Service and ensure you are happy with how your information is used by those sites. If you are a logged-in user you can adjust your privacy controls with the Ad Partner directly.]
Data we collect using non-essential cookies (e.g. for the tailored content and targeted advertising mentioned above) is used on the basis of your consent. You can withdraw your consent at any time by using our Cookies Tool. Any other information that we collect about your use of our Website is used on the basis that this is necessary for the purposes of our legitimate interests in maintaining and managing our Website and ensuring its security.
For more information about how we use cookies on our Website, see our Cookies Policy
How long do we keep this information for?
We will only keep information about your visit to our Website for as long as is necessary for the purposes we’ve mentioned. Typically we delete browsing data every 14 months.
Who do we share this information with?
We share information about visitors to our Website with service providers who help us administer and manage the Website. We also share information about your use of our Website with advertising networks, although you cannot be personally identified from this information.
Where do we transfer this information to?
Information we collect about your use of our Website is held by our service provider(s) on secure servers located outside the UK.
We protect your privacy by using service providers located within the European Economic Area (EEA) whose data protection laws are deemed to provide adequate protection and we protect your privacy by entering into approved contractual clauses with service providers operating outside the UK.
If you require further information about these safeguards, please contact us at twinings.direct@twinings.com
2. Information you send us
How do we use this data?
You do not have to supply us directly with any information when you use our Website. If you choose to use our ‘contact us’ feature or otherwise get in touch with us, we will use the information you send us for the purpose of responding to your enquiry. When we use your personal data for this purpose, we do so for our legitimate business interest in communicating with you in accordance with your wishes and expectations. We will also use this data for the purpose of our legitimate interests in accessing appropriate professional advice and in order to ensure we comply with legal obligations to which our business is subject.
General enquiries about our recruitment procedures are welcome but we are not able to consider CVs or job applications sent to us via this Website. If you do use this Website to send us this type of information, it will be securely deleted on receipt. For recruitment please visit our careers page..
How long do we keep this information for?
We will only keep your information for as long as is necessary in order to manage your query. We usually keep records of routine queries for 6 months but in some cases (for example where the query relates to a contract between us, or where we need to obtain legal advice in order to respond to a complaint) we may need to retain a record of our communications for up to 6 years.
Who do we share this information with?
We will share your data with our service providers and our professional advisers if this is necessary in order to resolve a query or complaint.
Otherwise we will not share your information with any third party unless:
• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
• this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).
Where do we transfer this information to?
Information you send us via our Website is held by our service provider(s) on secure servers located outside the UK. We protect your privacy by using service providers within the European Economic Area (EEA) whose data protection laws are deemed to provide adequate protection and we protect your privacy by entering into approved contractual clauses with service providers operating outside the UK.
If you require further information about these safeguards, please contact us at twinings.direct@twinings.com
3. Information about your on-line transactions
How do we use this data?
If you use our Website to place an order with us, we will ask you to supply us with the information we need in order to process your order. We collect this information because it is necessary for the performance of our contract with you.
If you have consented to marketing or advertising cookies using our website Cookies Tool, we also use the information about your on-line transaction to recommend additional or other products to you while you are browsing our website.
How long do we keep this information for?
We keep information regarding your on-line transactions for 6 years.
Who do we share this information with?
We share information about your on-line transactions with our suppliers and service providers where this is necessary to manage on-line payments, or to fulfil and deliver on-line orders. We also use suppliers to assist us in recommending other products.
Otherwise we will not share your information with any third party unless:
• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
• this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).
Where do we transfer this information to?
Information we hold about your on-line transactions is held by our service provider(s) on secure servers located outside the UK. We protect your privacy by using service providers abased within the European Economic Area (EEA) whose data protection laws are deemed to provide adequate protection and / or we protection your privacy by entering into approved contractual clauses with service providers operating outside the UK.
If you require further information about these safeguards, please contact us twinings.direct@twinings.com
5. Information you give us when you enter a competition, prize draw or promotion
How do we use this data?When you enter a competition, prize draw or promotion, we collect personal data from you as part of your entry. We use this to administer our competition, to communicate results where relevant and to deliver prizes. When we use your personal data for these purposes, we do so because it is necessary for us to collect and use this information for the performance of our contract with you in accordance with our promotion rules.
If you are lucky enough to win a competition, prize draw or promotion we use your data in additional ways. Unless you ask us not to, we will make your surname and county of residence available: (a) on request to anyone who sends us a self-addressed envelope within 10 weeks of the closing date of the competition; and (b) to the Advertising Standards Authority (ASA) if they ask us. We do this because it is necessary for the purpose of our legitimate interests in complying with the Code.
You have the right to object to our publication of this data. Please contact us as soon as possible, and within a week of receiving your winner’s notification if you want to object.
If we haven’t heard from you within a week, and we are asked to publish the information, we will do so. If you object later, we may have already published the information.
Where we are asked to disclose information to the ASA, and you object before we have disclosed the information, we will take into account your reasons for objecting although we may still be required to disclose this information, if for example, we are required to demonstrate that a valid award took place.
We will also write to winners to request agreement to reasonable publicity and the use of winners’ initial, surname, county of residence and any images provided as part of that publicity (e.g. photos) to publicise your win and our brand on our website and any of our social media accounts, including Facebook, Instagram, Twitter or Youtube. We will also write to request agreement to the creation of further materials based on competition entries which will be hosted on www.twinings.co.uk. We use your information in this way on the basis of your consent (which we will ask for). You can withdraw your consent at any time after you’ve agreed but please bear in mind that, due to the nature of social media, this information will have been public and potentially copied or otherwise further distributed beyond our control.
How long do we keep this information for?Information we hold in connection with the management of competitions, prize draws, and promotions is usually held for 6 years although any publicity information mentioned above may be held for longer if still published on our website.
Who do we share this information with?We share this data where necessary with our suppliers, service providers and professional advisers and as required by the Code.
Otherwise we will not share your information with any third party unless:
• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).
Where do we transfer this information to?Information we collect when you enter a competition, prize draw or promotion, is held by our service provider(s) on secure servers located outside the UK. We protect your privacy by using service providers based in the European Economic Area (EEA) whose data protection laws are deemed to provide adequate protection and we protect your privacy by entering into approved contractual clauses with service providers operating outside the UK.
If you require further information about these safeguards, please contact us at;twinings.direct@twinings.com
6. Direct Marketing
How do we use this data?We will use contact details you give us to deliver promotional information that you request or that we feel may interest you. We will also use this information to gain insights into the needs and interests of our customer base and to evaluate the effectiveness of our marketing activities.
We will only contact you for marketing purposes by email if you have consented to this.
When we use your data for our direct marketing purposes we do so for our legitimate interests in promoting our business and the goods we offer.
How long do we keep this information for?We keep information for direct marketing purposes for as long as you continue to be interested in receiving our marketing communications. We use tracking technology to help us monitor the effectiveness of our e-marketing and delete contacts from our e-marketing database after 2 years of recipient inactivity.
You can tell us to stop using your details for marketing purposes by contacting us twinings.direct@twinings.com and can opt out of email marketing at any time by using our unsubscribe feature.
Who do we share this information with?Where necessary we share this data with our suppliers and service providers.
Otherwise we will not share your information with any third party unless:
• we have your permission;
• we are required to do so by law;
• this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
• this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).
Where do we transfer this information to?Information we hold for direct marketing purposes is held by our service provider(s) on secure servers located outside the UK. We protect your privacy by using service providers based within the European Economic Area (EEA) whose data protection laws are deemed to provide adequate protection and we protect your privacy by entering into approved contractual clauses with service providers operating outside the UK.
If you require further information about these safeguards, please contact us attwinings.direct@twinings.com
7. Your Rights
You can ask us at any time to provide you with a copy of your personal data. In relation to personal data you have supplied to us, and which is held by us for the purpose of entering into a contract between us or on the basis of your consent, you are entitled to ask us for a copy of this information in a structured, commonly used and machine readable format so that you can reuse it or share it with other organisations.
If you think the personal data we hold about you is inaccurate or incomplete, you can ask us to correct it or complete it.
In some circumstances you also have the right to object to our processing of your data and can ask us to restrict our use of your data and to delete it.
There are some exceptions to these rights, however. For example, it will not be possible for us to delete your data if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your data may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information.
If you wish to exercise any of these rights you should contact us at twinings.direct@twinings.com
8. Contacting us and your rights of complaint
Questions, comments or requests concerning this privacy notice are welcomed and should be addressed to the eCommerce Manager at twinings.direct@twinings.com.
If you have a concern about the way we handle your personal data you have the right to complain to the Information Commissioner (ICO). You can find details of how to do this on the ICO website at ttps://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
This privacy notice was last updated on 22 April 2021.