Privacy and Cookie Notice for Twofold Spirits Limited
At Twofold Spirits Limited (referred to as “we”, “us”, “our”), we understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone that visits our website.
This privacy notice is intended to give you information about how we collect and process the personal data you supply to us.
Please take time to read this privacy notice and any other notices we may provide to you when we collect or process your personal data. This privacy notice applies to us, so you can be assured that everyone in our group is committed to protecting and respecting your privacy.
This privacy notice will help you understand how we process any and all data collected by us in relation to your use of our website, and what choices you have.
1. Introduction
This website is operated by Twofold Spirits Limited, whose registered address is 23-25 Bore Street, Lichfield, Staffordshire, WS13 4NA
All references to ‘our’, ‘us’, ‘we’, or ‘company’ within this policy and within the opt-in notice are deemed to refer to Twofold Spirits Limited.
We endeavour to protect your personal privacy. We provide this privacy and cookie notice to help you to understand what we may do with any personal information that we obtain from you. By providing your personal information to us, you signify your acceptance of the terms of this privacy and cookie notice and agree that we may collect, use, and disclose your personal information as described in this privacy and cookie notice. If you do not agree to these terms, please do not provide your personal details to us. We will use your information only for the purposes set forth below.
We may need to update this privacy and cookie notice from time to time. We recommend that you check this page regularly to ensure that you have read the most recent version.
2. What is personal information?
Personal information is information about an identifiable individual, as defined by applicable law, including, but not limited to, a first and last name, a home or other physical address and an email address or other contact information.
3. Collecting personal information
It is your choice to provide us with personal information. We will only collect personal information that you choose to provide. This may include your name, username, date of birth, marital status, title and gender or your contact data; including your address, email address, mobile phone number and any other appropriate contact details.
In certain instances, we may provide you with the option to select whether you would like to receive information from us or from trusted third parties (for example, by choosing to opt-in or opt-out of receiving special promotional offers). In some circumstances, you will not have the option to opt-out, such as when we are satisfying the obligations of a contract with you, administering a transaction requested by you, or required by law.
You may choose to provide us with personal information if, for example, you: contact us with an enquiry; register on the site; forward an item to a friend; purchase an item; fill out a survey or other form with your personal information included; ask us to provide you with information; enter a competition.
By providing any such personal information to us, you fully understand and clearly consent to the transfer of such personal information. Any such transfer and processing by us will be in accordance with this privacy and cookie notice.
Payment Data. We may collect data necessary to process your payment if you make purchases. Such information will include your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: Privacy Policy
4. How we process your personal information
The General Data Protection Regulation (GDPR) and Data Protection Act 2018 require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
i. Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
ii. Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our services or at your request prior to entering into a contract with you.
iii. Where it is necessary for the purposes of what we refer to as our “legitimate interests”. In other words, processing personal information about you is necessary for the purposes of our legitimate interests in ensuring we provide to you the services you want to receive from us and your interests and rights do not override those legitimate interests.
iv. Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
4. Cookies
Like many other websites, we use “cookies” to help us gather and store information about visitors to our websites.
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are.
A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.
What types of cookies are used on this site?
Types of cookies which may be used on this website;
(a). Preference Cookie – At your request we may place a cookie to remember your preferences so that you do not need to re-enter your details (country/age and language preferences) on our gateway page. This is not suitable if you share your computer with someone else.
(b). Social Sharing – This is a cookie that identifies you with social networking sites such as Facebook and Twitter and allows interaction between your activity on social networking sites and on our website through your direction, and makes your transition between the sites more seamless.
Cookies – We use session cookies, which are temporary cookies that aid the user journey around the site, and will remember preferences you have selected during the session. These cookies are deleted as soon as you leave the site.
(d). Content Management cookies – These are cookies required by the site for the content management system to work.
(e). Template preference cookies – These cookies are necessary for mobile sites and enable the site to look and feel the way it is intended to.
How do I disable/enable cookies?
You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled.
There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about these functions. For example, in Internet Explorer, you can go to the Tools/Internet options/Security and Privacy Tabs to adapt the browser to your expectations. If you use different computers in different locations you will need to ensure that each browser is adjusted to suit your cookie preferences.
Some modern browsers have a feature that will analyse website privacy policies and allow a user to control their privacy needs. These are known as ‘P3P’ features (Privacy Preferences Platform).
You can easily delete any cookies that have been installed in the cookie folder of your browser. For example, if you are using Microsoft Windows Explorer:
open ‘Windows Explorer’
click on the ‘Search’ button on the toolbar
type “cookie” into the search box for ‘Folders and Files’
select ‘My Computer’ in the ‘Look In’ box
click ‘Search Now’ Double click on the folders that are found
‘Select’ any cookie file
hit the ‘Delete’ button on your keyboard
If you are not using Microsoft Windows Explorer, then you should select ‘cookies’ in the ‘Help’ function for information on where to find your cookie folder.
How will we use the information about you and why?
We will only use your Personal Data to:
5. Use of personal information
We may use personal information collected from you to provide specific services that you request, as well as to provide additional services that may be of interest.
• fulfil our contracts with you and supply you with the goods and services you have asked for, to respond to your queries and requests, maintain your accounts, and manage transactions such as credit card payments for any goods that you order from us or our agents, or for the fulfilment of such transactions (e.g., delivery).
• Manage our relationships with you (for example customer services);
• Provide to you promotional material about our products and services that we think you may be interested in;
• Carry out other business purposes, such as audits, internal communications and/or other administrative purposes;
• Monitor and assess compliance with various laws and our policies and standards;
• Advise you about changes to our terms and conditions, policies or other administrative information;
• For your security and safety whilst you are at any of our locations.
In addition, and as we describe below, in the course of providing our goods and services to you, we may also need to pass your information to various, specific third parties. In these instances, we will only provide the personal information necessary to deliver our services and we require those third parties to keep secure your Personal Data so that they may not use it for their own direct marketing purposes.
The categories of third parties to whom we may need to forward your Personal Data are:
• Any third party contractors/service providers (including their sub-contractors) that provide a service to us or act as our agents, on the understanding they keep the information confidential. These include, but are not limited to, our third party payment platform Stripe and payment portal SumUp as well as any other third parties that process information on our behalf or any logistical services, such as delivery agents we use to deliver our goods to you. [you can add links to Stripe and SumUp policies here]
• Our professional advisers, including our legal advisers and our auditors, all of whom are under a duty to keep confidential any information we provide to them;
• third parties we use for our marketing purposes, in areas such as digital and social media communications, customer care, advertising and market research, all of whom are required to keep your Personal Data secure and not to be used for their own purposes;
• Credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors, on the understanding they keep the information confidential;
• Insurance companies or regulatory authorities so as to comply with any legal and regulatory issues and disclosures;
• Any legal or crime prevention agencies and/or to satisfy any regulatory request if we have a duty to do so or if the law allows us to do so;
• any other organisations if we sell or buy (or negotiate to sell or buy) any business or assets.
We will only use this information subject to your instructions, data protection law and our duty of confidentiality. We will not share your information for marketing purposes with companies outside of our group.
We may also use your personal information in the following ways:
Marketing Communications. We may use your personal information to communicate with you about our products and services, and those of our subsidiaries, affiliates, and parent companies, and any of their related businesses.
Marketing analysis. We may use your personal information for internal marketing analysis, for example, to assess trends amongst our consumers or to measure the amount of traffic to our websites.
If you no longer wish to be contacted for marketing purposes, you can stop us contacting you by sending an email to: info@twofold-spirits.com
Forward to a friend. When you provide us with information regarding another individual, such as when you request that we send someone information from one of our websites, we will send that individual only the information you specifically requested that we send. We will not send them additional communications based on your providing us with their information. You must certify that your friend is of Legal Purchase Age in the jurisdiction where he/she is located in order for us to transmit the requested information
6. Security
We take security seriously and take precautions to keep your personal information secure. We have put in place appropriate physical, electronic, and managerial procedures to safeguard the information we collect. However, we have no control over the privacy of any communications while it is in transit to us. We therefore recommend that you not include confidential, proprietary, or sensitive information in any such communications.
In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If such a notification is appropriate, we will endeavour to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email.
You are reminded that you are responsible for maintaining the strict confidentiality of your account password, and you are responsible for any activity under your account and password. It is your sole responsibility to control the dissemination and use of your password, control access to and use of your account, and notify us when you wish to cancel your account. We will not be responsible or liable for any loss or damage arising from your failure to comply with this obligation.
7. Data storage
Where we retain any personal information, we will ensure it is only kept for as long as necessary to deliver your goods or services, administer your account and therefore fulfil our professional obligations to you, also taking into account our need to meet any legal, statutory and regulatory obligations with which we are bound to comply.
Further, our need to use your personal information will be reassessed on a regular basis and we will dispose securely and safely of any such information which we no longer require.
You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to achieve this.
8. Unsubscribe, access, questions and further information
At your request and where the law requires us to do so, if you contact us using the unsubscribe details provided below, we will confirm what personal information we hold about you, update your information, remove your information, fulfil specific opt-out requests (including requests where you previously opted in with respect to the use of your personal information), and/or correct any inaccuracies in such personal information.
We shall respond promptly to any such request and in any event, within one month from the point of receiving the request and all necessary information from you. In certain (very limited) circumstances, we may make a small charge for this service.
You also have the right to receive your personal information in a structured, commonly used and machine-readable format and have the right to ask us to transmit it to another controller if technically possible.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove without delay any information about you that you think is inaccurate by emailing us at info@twofold-spirits.com or writing to us at the above address.
You have the right to seek a restriction of the processing of your personal information in certain circumstances. Further, you have the right to lodge an objection if you feel that one of the grounds relating to your particular situation apply. When you exercise your right to object, we must stop any processing unless we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
If you would like to unsubscribe from Twofold Spirits communications or wish to obtain any or your personal information, please contact: info@twofold-spirits.com or write to us at 23-25 Bore Street, Lichfield, Staffordshire, WS13 6NA.
If you have any comments, queries, or complaints about our collection or use of personal information please contact us via: info@twofold-spirits.com or you can write to us at 23-25 Bore Street, Lichfield, Staffordshire, WS13 6NA.
9. Complaints
If you feel that your personal information has been processed in a way that does not comply with the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then inform you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office.
10. Interfaces with Third-Party Websites
The site may contain links, references, and content from other websites outside of our control. Please be aware that we have limited or no control over these websites and our privacy and cookie notice does not apply to these sites. We encourage you to read the privacy and cookie notices and terms and conditions of any linked, referenced, or interfacing websites you enter.
This privacy and cookie notice will be supplemented by additional legal requirements in jurisdictions where we conduct business as required. Nothing in this privacy and cookie notice or otherwise will create, or add to, any right or claim (whether legal, equitable, or otherwise) that any individual or person may have at law or otherwise against the company or any third party, or any of their respective directors, officers, employees, agents, or representatives Twofold Spirits nor will the existence of this privacy and cookie notice or its application impose or add to any obligations upon or create any liability Twofold Spirits that it does not already otherwise have under law.