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Privacy Policy

 

Welcome to Twinings

Twinings is committed to ensuring that your privacy is protected and that we comply with all applicable data protection rules (including applicable marketing and cookies laws, together with associated guidance) (the "Data Protection Laws").

This policy explains how we collect, use, store and disclose the personal information we collect about you, how you can exercise your rights in respect of that personal information and the procedures that we have in place to safeguard your privacy. This policy supplements any other fair processing or privacy notice that may be provided to you from time to time. Please contact us by email at [consumer.service@twiningsusa.com] if you have any questions, comments or concerns about this policy or how we handle your personal information, or if such information changes at any time.

This website (the "Website") is run by Twinings North America, Inc., 301 NJ-17, Suite 705, Rutherford, NJ 07070 ("Twinings", "we" and "us"). By using our Website, or any service or product (including any mobile application or other digital platform) that links to this policy, you consent to the collection, use and disclosure of your personal information in accordance with this policy.

When we refer to "processing" in this policy, we mean any activity concerning your personal information, including collecting, using, disclosing, deleting and anonymising.

Please note: this policy does not cover third party websites that we may link to from our Website, unless specifically mentioned in this policy. We are not responsible for the privacy policies and practices (including use of cookies) of such third parties even if you accessed the third party website using links from our Website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.

Any changes to this policy in the future will be posted on this page and, where appropriate, notified to you by email. We will also post a notice on the Website landing page and on appropriate pages on the Website. Please check back frequently to see any updates or changes to this policy.

The personal information we collect and how we use it
Under the Data Protection Laws, we are required to explain what personal information we collect from you and how and why we use your personal information (the "processing activity"). This is summarised in the table below.

How do we use your information?

What information is collected?

Where is the information collected from?

How long do we keep the information for?

To enter into and administer our contract with you when you purchase our products, including to collect payments due to us.

Name, email address, billing and delivery address, user account details, payment details.

 

 

Directly from you via our Website or when you otherwise correspond with us.

We keep information regarding your orders for up to 6 years (or longer, if required by applicable laws) following the date of your purchase.

 

To register you as a customer and create your account if you decide to open an account.

 

Name, email address, postal address, gender and user account details.

Directly from you via our Website or when you otherwise correspond with us.

We keep information relating to the management of your account for as long as your account or profile continues to be active.

 

To notify you about changes to our terms or this policy.

Name, email address and user account details.

Directly from you via our Website or when you otherwise correspond with us.

We keep information relating to the management of your account for as long as your account or profile continues to be active.

 

To ask you to leave a review or take a survey.

Name, email address, postal address and user account details.

Directly from you via our Website or when you otherwise correspond with us.

Any information collected for market research purposes is not held in a form that will identify you for longer than 6 months following collection.

To send you newsletters, marketing emails, and messages via SMS, WhatsApp and social media platforms.

 

Name, phone number, email address, gender, age, transaction history, and any information we collect about your use of our Website or social media accounts.

Unique personal identifiers (device identifiers; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)

Please see Marketing and Promotional Materials below for further information.

Directly from you via our Website, where you otherwise contact us, or via third party social media platforms.

 

We keep information for direct marketing purposes for as long as you continue to be interested in receiving our marketing communications, i.e., until you opt-out.

Please refer to our Cookies Policy for further information regarding the use and duration of the cookies used.

To deliver relevant website content and advertisements to you, and measure the effectiveness of the advertising we serve to you.

Name, phone number, email address, gender, age, transaction history, social media account name, and any information we collect about your use of our Website or social media accounts.

Unique personal identifiers (device identifiers; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)

Please see Marketing and Promotional Materials below for further information.

 

Directly from you via our Website, where you otherwise contact us, or via third party social media platforms.

 

We keep information for direct marketing purposes for as long as you continue to be interested in receiving our marketing communications, i.e., until you opt-out.

Please refer to our Cookies Policy for further information regarding the use and duration of the cookies used.

To use data analytics to improve our Website, products, marketing, customer relationships and experiences.

 

 

Information about your use of our Website, including:  duration, frequency and time; pages you have visited, search terms, and use of our check-out process.

Technical data, including: internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website.

Unique personal identifiers (device identifiers; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)

Directly from you when you visit our Website.

 

We delete browsing data every 14 months.

Please refer to our Cookies Policy for further information regarding the use and duration of the cookies used.

To help maintain the security of our Website, including troubleshooting, data analysis, testing, system maintenance, and support.

Technical data, including: internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website.

Directly from you when you visit our Website.

 

We delete browsing data every 14 months.

To respond to your queries or comments via the "contact us" form on our Website or when you otherwise correspond with us.

Name, email address, and any other information you supply to us when contacting with us.

Directly from you via our Website or when you otherwise contact us.

We maintain a record of routine queries for 6 months. However, we may need to keep your information for up to 6 years (or longer, if required by applicable laws) where your query relates to a contract between us, or where we need to obtain legal advice.

To administer our competitions, prize draws, or promotions which you may enter.

Name, email address, postal address.

 

 

Directly from you when you enter a competition, prize draw or promotion.

Personal data we hold in connection with the management of competitions, prize draws, and promotions is held for 6 years (or longer, if required by applicable laws).

Any information we use for publicity may be held and used for longer (for example where published on our Website).

Please see Competitions, Prize-draws, and Promotions below for further information.

Cookies

Some of the information identified in the table above, is collected by us through the use of cookies or similar technology when you visit our Website, or other websites or social media sites where we have included a cookie. In some cases, we will need your consent in order to place such cookies on your device. More information on the specific types of cookies we collect, our lawful basis and how to manage them can be found in our Cookies Policy.

Marketing and Promotional Materials

We may use your information to provide you with marketing and promotional materials (as stated above). In such instances, we will use your information to deliver promotional information that you have requested, or that we feel may interest you (unless you have previously told us that you do not wish to receive marketing communications from us).

The personalisation of advertisements displayed on social media platforms may be based on information you have provided directly to us (for example when browsing our Website or purchasing our products) or based on other information attributed to you via cookies, including cookies set by third parties.

You may opt-out of receiving marketing and promotional materials from us at any time by emailing us at [consumer.service@twiningsusa.com], using the 'unsubscribe' link in the marketing or promotional email. You may also update your preferences to receive marketing or promotional materials by visiting our Website.

Please see below, Sharing your Personal Information, for further information regarding the third parties we share your information with for marketing and advertising purposes.

Competition, Prize-draws and Promotions

We may use and disclose your personal information in connection with competitions, prize draws and promotions (as stated above) you may enter from time to time. Please refer to the relevant terms and conditions of such competition, prize draw or promotion for further information.

Unless you ask us not to, we may (subject to the laws applicable in your country of residence) 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 any relevant regulator if they ask us. We do this because it is necessary for the purpose of our legitimate interests in complying with the laws, regulatory codes and guidelines in force from time to time.

You have the right to object to our publication of your information. To do so, please contact us as soon as possible, and within a week of receiving your winner’s notification should wish you wish to object.

If we haven’t heard from you within a week, and we are asked to publish your information, we will do so. If you object later, we may have already published your information.

Where we are asked to disclose your information to a relevant regulator, and you object before we have done so, we will consider your reasons for objecting and aim to comply with your request (where we are able to do so). However, please note that we may still be required by law or regulation to disclose your information, if for example, we are required to demonstrate that a valid award took place.

Should you win one, we may also write to you to request your agreement to reasonable publicity and the use of your initial, surname, county of residence and any photograph provided by you as part of that publicity on our Website and any of our social media accounts. We may also write to request your agreement to the creation of further materials based on competition entries which will be hosted on our Website. We use your information in this way on the basis of your consent. 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, once your information has been made publicly available for promotional purposes, it will be public and potentially copied or otherwise further distributed beyond our control.

Security

We have in place appropriate policies, rules and technical and organisational measures to protect your personal information from unauthorised or unlawful processing, and against accidental loss, destruction or damage.

We also have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.

However, the internet and email are not secure. Your communications may route through a number of countries before being delivered, may be intercepted by third parties and may not always reach the intended recipient – this is the nature of the World Wide Web/Internet. We cannot accept responsibility for any such unauthorised access or loss of personal information that is beyond our control.

You are responsible for protecting your username and password and must not share it with, or disclose it, to anyone.

If you want you to learn more about how to protect your data and your devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by the UK's HM Government and leading businesses.

Sharing your personal information  


We will only disclose your personal information to:

  • companies within the Twinings group for internal business purposes such as management, accounting and marketing;
  • e-commerce platform providers (see below regarding Shopify), payment gateway and payment service providers and suppliers of cookie-consent management solutions;
  • other third-party suppliers, including business partners and sub-contractors for business administration, support, processing, services, or IT purposes;
  • our third-party logistics and delivery providers who deliver products to you on our behalf;
  • analytics or search engines, that enable us to optimise and improve your experience of our Website;
  • third-party suppliers for marketing and advertising purposes (including (but not limited to) those as set out below), and agents who (on our behalf) tailor our marketing communications and offer you products we believe you would be interested in;
  • our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters;
  • our professional advisors (including without limitation tax, legal, insurance, or other corporate advisors who provide professional services to us); and
  • HMRC or other tax bodies or agencies to comply with our legal and regulatory obligations.

To the extent authorised by applicable laws, we will disclose your personal information to third parties:

  • in the event that we consider selling or buying any business or assets, merging with another business, financing our business, granting a charge over our assets or leasing or licensing our assets, we may disclose your personal information to any prospective sellers or buyers of such business or assets;
  • in the event we are the subject of any insolvency situation (e.g., the administration or liquidation);
  • if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;
  • in order to enforce or apply our terms and conditions;
  • to protect our rights, property, or safety, or that of our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation HMRC, the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

We share your name, phone number, email address, gender, age, transaction history, social media account name, and any information we collect about your use of our Website or social media accounts with the parties set out below for the purpose of providing you with marketing and promotional materials:

(together our Ad Partners).

Once we have shared your personal information with our Ad Partners, they are responsible for ensuring your personal information is used and disclosed only in accordance with Data Protection Laws. Please ensure you review their privacy policies (as set out above) carefully for further information. We will, however, take reasonable steps in the circumstances to ensure our Ad Partners afford a similar degree of protection to your personal information.

Shopify.

We use the Shopify platform to power our e-commerce business, provide you with an enjoyable customer experience and better enable you to browse our Website and purchase our products. To do this, Shopify collects your personal information on our behalf, and shares this with us – for example, your name, email address, and delivery address. Shopify shall handle your personal information in accordance with Shopify's Privacy Policy. Further information regarding how we use Shopify's cookies can be found within our Cookies Policy.

The parties to which we may disclose your personal information (as summarised in this section) may be located in countries outside of Canada, including the United Kingdom and countries within the European Economic Area.  

International transfers of your personal information


We may transfer personal information to countries other than the country in which the data was originally collected (for example, outside Canada) in order to provide you with our products. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection. Your personal information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction.

If we transfer personal information to countries outside of your usual place of residence, we will ensure (in accordance with applicable laws) an adequate degree of protection is afforded to your personal information in accordance with applicable data protection laws.

Personal data collected via cookies set by our Ad Partners may be transferred by those Ad Partners outside of your usual country of residence Please refer to the relevant third-party privacy policy for further information.

Your rights

Depending on the jurisdiction in which you reside, you may have certain privacy rights regarding the personal information we hold about you, including:

 

Right

 

Description

 

Of access

A right to access the personal information we hold about you and obtain a copy of this in a portable and, to the extent technically feasible, readily usable format.

To rectification

A right to require us to rectify any inaccurate personal information we hold about you.

To withdraw

A right to withdraw your consent, where we are relying on it to use your personal information (for example, to provide you with brochures and newsletters).

We welcome your views about our Website and this policy. If you would like to contact us with any queries or comments, request further information or exercise any of your available rights set out above, please email us at: [consumer.service@twiningsusa.com] or write to us at: Twinings North America, Inc., 3700 Steeles Ave W., Suite 901, Woodbridge, ON L4L 8K8.

If you would like this notice in another format (for example audio, large print, braille) please contact us using the details above.

We encourage you to contact us if you have any queries, comments, complaints or concerns about the way we handle your personal information. We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.  We request that you cooperate with us during this process and provide us with any relevant information that we may need.

Last updated: [January 2024]

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