Who We Are
Twisting Spirits Ltd (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
Twisting Spirits Ltd’s registered office is at Unit 1D Oldbury Buildings, Northway Lane, Tewkesbury, Gloucester, GL20 8JG and we are a company registered in England and Wales under company number 09958655. We act as the data controller when processing your data. Our designated Data Protection Officer/Appointed Person is Mary Bateman, who can be contacted at Unit 1D, Oldbury Buildings, Northway Lane, Tewkesbury, Gloucestershire, GL20 8JG or email email@example.com
Information That We Collect
Twisting Spirits Ltd processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from is: –
- Home Address
- Delivery Address
- Personal/Business Email as supplied
- Mobile/Home Telephone Number as supplied
We collect information in the below ways: –
- Order form on our online shop
- Newsletter subscription form on our website
How We Use Your Personal Data (Legal Basis for Processing)
Twisting Spirits Ltd takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below: –
- We collect your personal data in the performance of a contract or to provide a service and to ensure that orders are completed and can be sent out to your preferred address, i.e. orders via our online shop
- We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests
You have the right to access any personal information that Twisting Spirits Ltd processes about you and to request information about: –
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use in the future (we do not use such systems currently)
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Twisting Spirits Ltd uses third-parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
We use Stripe Inc to securely process credit and debit card payments on our behalf for orders placed via our online shop. Credit card details are securely handled by Stripe Inc to process payments made my credit card, Apple Pay and Google Pay.
For more information about Stripe Inc, please see their privacy notice at https://stripe.com/gb/privacy
We offer PayPal checkout services to securely process payments on our behalf for orders placed via our online shop using a PayPal account.
For more information about PayPal, please see their privacy notice at https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev
We use Klaviyo to electronically manage electronic communications to you, such as newsletter and emails. Klaviyo is also used to help us understand customer activity within our shop, such as which products have been viewed or added to basket.
For more information about PayPal, please see their privacy notice at https://www.klaviyo.com/privacy
We use Hotjar to help us understand how customers interact with our website and detect usability issues.
For more information about Hotjar, please see their privacy notice at https://www.hotjar.com/legal/policies/privacy/
We use Royal Mail postage services for the delivery of your order. This involves entering your name and address details into the Royal Mail Click and Drop System to book in and pay for the service.
For more information about Royal Mail, please see their privacy notice at https://www.royalmail.com/privacy-notice
Twisting Spirits Ltd takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. Generally we do not directly store your personal information on our computer systems since these processes are performed by our third party partners. However data associated with your account and orders is securely stored within the shop database. When managing this transient data we work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: –
All our computer systems use hard drive encryption, have valid and up to date Anti-Virus, malware protection and are protected by a firewall. Access to such systems is restricted from unauthorised third parties.
Transfers Outside the EU
Twisting Spirits Ltd utilise some products or services (or parts of them) that may be hosted/stored in USA, which means that we may transfer any information which is submitted by you through the website outside the European Economic Area (“EEA”) for the below purposes: –
- Credit Card Processing
- Newsletter processing and social contact
Therefore, when you use our online shop or sign up to our newsletter, the personal information you submit may be stored on servers which are hosted in USA. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by Twisting Spirits Ltd to protect your data and comply with the relevant data protection laws.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to Twisting Spirits Ltd, however, as this information is required for us to process your order and deliver your products and/or ensure you receive our newsletter, we will not be able to offer some/all our services without it.
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests’ legal basis for processing;
Name, Address, email address and have identified that our interests are to process your order via our online shop and ensure delivery to your chosen address. And/Or,
Name and email address and have identified that our interests are to process your subscription to our newsletter and ensure delivery to your chosen email address
How Long We Keep Your Data
Twisting Spirits Ltd only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Lodging A Complaint
Twisting Spirits Ltd only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Twisting Spirits Ltd
FAO: Mary Bateman
Unit 1D Oldbury Buildings,
Tel 07709 359203,