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 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 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.
We collect this information for the purpose of our legitimate interests in maintaining and managing our Website and ensuring its security. If you do not want us to collect this information you can use your web browser’s “do not track” (“DNT”) facility to tell us that you don’t want to be tracked when you visit our Website. Further information about DNT can be found at https://allaboutdnt.com.
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?
Most information we collect about your use of our Website is stored within, and not transferred outside of, facilities located in Hong Kong. However data generated by Google Analytics is transmitted to and stored by Google on servers in the United States. Google is certified under the EU-US Privacy Shield.
If you require further information about these safeguards, please contact us at service.hk@twiningsovo.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
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;
his 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 stored within, and not transferred outside of, facilities located in Hong Kong.
(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.
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.
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 stored within, and not transferred outside of, facilities located in Hong Kong.
(4) INFORMATION YOU GIVE US WHEN YOU SIGN UP FOR OUR NEWSLETTER, ENTER A COMPETITION, PRIZE DRAW, OR PROMOTION, COMPLETE A SURVEY, OR CREATE AN ONLINE ACCOUNT
How do we use this data?
You do not have to supply us directly with your personal data when you use our Website. However, some communications, services and facilities can only be provided if you supply us with relevant details. For example, if you sign up for our newsletter, enter a competition, prize draw or promotion, complete a survey or create an account you will be asked to provide us with your contact details. If we ask you to supply us with information that is not strictly necessary in order for us to provide you with the communication, service or facility you are interested in, we will make this clear. This might be because it’s useful to us in helping us learn more about our customers or enhance our products and services.
If you do sign up for our newsletter, enter a competition, prize draw or promotion, complete a survey, or set up an online account we will use the personal data you provide :
to provide you with newsletters and other promotional information that you request from us;
to provide you with specific information about our products and services where you request this;
to manage your online account;
to improve our understanding of the needs and interests of our customers and contacts; and
to notify you about changes to our service.
When we use your personal data for these purposes, we do so for our legitimate interests in managing and administering online accounts and for our legitimate business interests in developing and promoting our goods and services and communicating with you in accordance with your wishes and expectations. You can object to our use of your data for these purposes at any time. For further information about the way we use your data for direct marketing purposes see our direct marketing section.
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.
you provide us with your information in connection with a competition entry, prize draw or promotion, we will use this to administer our competition, to communicate competition 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 competition rules.
How long do we keep this information for?
Information we hold for the purpose of managing your online account or profile is held by us for as long as your account or profile continues to be active.
Information we hold for market research purposes is not usually held in a form that will identify you for longer than 6 months.
nformation we hold in connection with the management of competitions, prize draws, and promotions is usually held for 6 years.
Information we hold for direct marketing purposes so that we can send you newsletters and other promotional material is held by us for as long as you continue to be interested in receiving our marketing communications. However you can tell us to stop using your details for marketing purposes at any time by using the unsubscribe link in our emails or contacting us a service.hk@twiningsovo.com
Who do we share this information with?
We share this data where necessary with our suppliers, service providers and professional advisers.
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 sign up for our newsletter, enter a competition, prize draw or promotion, complete a survey, or set up an online account is stored within, and not transferred outside of, facilities located in Hong Kong.
(5) 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 service.hk@twiningsovo.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?
nformation we hold for direct marketing purposes is stored within, and not transferred outside of, facilities located in Hong Kong.
