PRIVACY POLICY
This Privacy Policy describes the policies and procedures of Rainbow beverages limited (Company No: 11680494) . and its subsidiaries (including, without limitation, Twisto) (“we”, “our” or “us”) on the collection, use and disclosure of personal information from those who use or access Twisto.co.uk or Drinktwisto.com, our blog, our branded pages on social media services, or any of the other sites, services, features, content, applications and products we offer in the United Kingdom (“UK”) (collectively, the “Services”). If you are using the Services outside of the UK, a location-specific privacy policy may apply to you instead, so please check the applicable country-specific website. We receive information about you from various sources, including, without limitation: (i) when you visit our websites; (ii) if you register for the Services, through your user account on the Services (your “Account”); (iii) your use of the Services generally, including any purchases that you make on the Services; and (iv) from third party websites and services that interact with our Services.
Where you are based in the UK and use the Services, including when you buy products we offer, Rainbow Beverages LTD, with registered office at Kemp house, 160 city rd, London, EC1V 2NX, is data controller of your information and accordingly is registered with the Information Commissioner's Office.
CONSENT
When you visit www.twisto.co.uk / www.Drinktwisto.com or otherwise use the Services, you are consenting to the collection, storage, disclosure and other uses of your information as permitted by this Privacy Policy. Please see below for more details.
WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services, as well as our treatment of any Personal Information that our partners, service providers and other persons and entities with whom we conduct business (“Business Partners”) share with us, or that we share with our Business Partners where permitted pursuant to the section titled “Information Shared with or by Our Business Partners” below. Please see below for more information on the categories of Business Partners with which we work.
This Privacy Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third party websites, services, products or applications (each a “Third Party Service”) that you elect to access and may interact with during your use of the Services, or to individuals that we do not manage or employ. We take steps to ensure that we only work with Third Party Services that share our respect for your privacy, although we cannot take responsibility for the content, products, services or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.
NOTICE OF WHAT INFORMATION WE COLLECT AND HOW WE USE IT
We collect your Personal Information in connection with your use of the Services and process your information in accordance with this Privacy Policy at all times
WHAT INFORMATION DO WE COLLECT?
In connection with certain aspects of the Services, we may request, collect, display and/or disclose some of your Personal Information. From time to time, we may also supplement information we collect from you with other information we collect or with information we receive from third parties, which may include associating non-personally identifiable information with Personal Information. The information we gather, including the types of information described below, enables us (or, as applicable, our Business Partners, pursuant to the section titled “Information Shared with or by Our Business Partners” below) to personalize, improve and continue to operate the Services or to provide you with information, products and services that we believe may be of interest to you (unless you indicate otherwise). Except as otherwise specified below, such information may be used by us (or, as applicable, our Business Partners, pursuant to the section titled “Information Shared with or by Our Business Partners” below) in connection with such purposes set forth in this Privacy Policy.
ACCOUNT INFORMATION:
When you create an account on the Services (“Account”), you will provide information that could be Personal Information, such as your email address and password. Additionally, if you register for or access the Services using a Third Party Service (such as your social media login credentials, as further described below), we may receive Personal Information that you allow such Third Party Service to share with us. You should consult such Third Party Services’ privacy policies.
We (directly or delivered through our Business Partners pursuant to the section titled “Information Shared with or by Our Business Partners” below) may use such Personal Information and any transaction data relating to your Account or other information relating to your use of the Services for purposes relating to our business or otherwise permitted by this Privacy Policy, including, without limitation, to send you information which we think you might find useful or of interest about our Services where you have indicated you do not object to receiving such information. You may choose not to receive these messages when you register an Account with us by selecting the check box to opt-out or you can unsubscribe from these messages by clicking the “Unsubscribe” link at the bottom of any email message from us or by contacting us directly at Hello@drinktwisto.com. However, when you purchase products from us, request information from us, or when we believe it is necessary with regard to your use of the Services or your Account, we reserve the right to contact you, such as for account recovery purposes or in connection with a purchase you have made on the Services
We (directly or delivered through our Business Partners pursuant to the section titled “Information Shared with or by Our Business Partners” below) may use such Personal Information and any transaction data relating to your Account or other information relating to your use of the Services for purposes relating to our business or otherwise permitted by this Privacy Policy, including, without limitation, to send you information which we think you might find useful or of interest about our Services where you have indicated you do not object to receiving such information. You may choose not to receive these messages when you register an Account with us by selecting the check box to opt-out or you can unsubscribe from these messages by clicking the “Unsubscribe” link at the bottom of any email message from us or by contacting us directly at Hello@drinktwisto.com. However, when you purchase products from us, request information from us, or when we believe it is necessary with regard to your use of the Services or your Account, we reserve the right to contact you, such as for account recovery purposes or in connection with a purchase you have made on the Services
INFORMATION REGARDING YOUR SOCIAL NETWORKS:
As mentioned above, you may be able to register for or access the Services using Third Party Services, such as your social media accounts (e.g., Facebook, Twitter, etc.) (“Social Media Services”). Occasionally, you can also use your Account on our Services to interact with your accounts on Social Media Services. For example, you may be able to access posting and sharing tools on the Services that allow you to post information to your Social Media Services (“Share”) or interact with us through Social Media Services, such as by tagging us or our products on such services. When you use these tools or tag or mention us or our products, or otherwise interact with us through Social Media Services, you acknowledge and agree that some information and content relating to your account on the applicable Social Media Services may be transmitted to us, and that our use of such information is covered by this Privacy Policy, and you hereby allow us to use such information or content in connection with our business, including across our properties and for commercial purposes, or as otherwise permitted by this Privacy Policy. Furthermore, when you use these tools or post to our Services, we may share some of your information and content from our Services with certain Social Media Services, including through our branded pages on such Social Media Services, and such information, including how information is shared with us, and such content would be subject to the privacy policies of such Social Media Services and your privacy settings with such Social Media Services. Additionally, if a tool, such as the Share tool, is operated by a Third Party Service, the Third Party Service that operates the tool may collect information about your browser or online activity, which is subject to such Third Party Service’s privacy policy. Therefore, we encourage you to read the privacy policies, and other policies, of any Third Party Services, and review your privacy settings on such Third Party Services, including any applicable Social Media Services, that you use in connection with the Services.
We may also collect and receive your Social Media Services login credentials in connection with providing you with the Services, but only if you expressly provide us with such information. We will only use such login information as permitted by this Privacy Policy or as otherwise expressly authorized by you and your settings with such Social Media Services. Please review your applicable Social Media Services’ respective privacy settings and their associated privacy policies to understand more about disclosures of information from your Social Media Services.
USER CONTENT:
Some features of the Services may now or in the future allow you to provide content, such as written comments or reviews, to the Services, including through Social Media Services as described above. We may use or continue to disclose such content to Business Partners pursuant to the section titled “Information Shared with or by Our Business Partners” below, including, but not limited to, after you have finished using the Services as permitted by this Privacy Policy.
SHIPPING AND BILLING INFORMATION:
If you place an order through the Services, we will ask you for your shipping address, telephone number and credit card information and/or certain other Personal Information about you. We use this information for purposes such as processing and fulfilling your orders, notifying you of your order status and otherwise communicating with you in connection with the Services. We also retain this information as part of your Account for your convenience in making future purchases.
All credit card information and shipping information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to our third party payment processing company (the “Payment Processor”), which is currently Stripe. Please note that your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information) is used and stored by our Payment Processor, and use and storage of that information by the Payment Processor is governed by the Payment Processor’s applicable terms of service and privacy policy (for Square, available
at:https://squareup.com/gb/en/legal/general/privacy or any of its successor sites). We may from time to time request and receive information about you and the products you have bought or ordered from our Payment Processor or from you directly for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.
at:https://squareup.com/gb/en/legal/general/privacy or any of its successor sites). We may from time to time request and receive information about you and the products you have bought or ordered from our Payment Processor or from you directly for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.
COMMUNICATIONS WITH US:
We may collect Personal Information when you communicate with us. For example, if you choose to send us Personal Information by sending us an email, completing a survey or contacting our customer service department, we will keep a record of that communication and may collect and use Personal Information that you provide to us in accordance with this Privacy Policy. If we communicate with you via email, SMS, MMS or other text message (“Text Message”) or push notifications (to the extent you permit us to do so), we may collect information regarding such communications, such as confirmation when you open an email, read a Text Message or receive a push notification. We use this information for purposes such as to operate and improve our Services, including our customer service, or as otherwise permitted by this Privacy Policy.
COOKIES AND OTHER SIMILAR TECHNOLOGIES:
We may collect Personal Information when you communicate with us. For example, if you choose to send us Personal Information by sending us an email, completing a survey or contacting our customer service department, we will keep a record of that communication and may collect and use Personal Information that you provide to us in accordance with this Privacy Policy. If we communicate with you via email, SMS, MMS or other text message (“Text Message”) or push notifications (to the extent you permit us to do so), we may collect information regarding such communications, such as confirmation when you open an email, read a Text Message or receive a push notification. We use this information for purposes such as to operate and improve our Services, including our customer service, or as otherwise permitted by this Privacy Policy.
When you access the Services, we and our third party service providers and Business Partners collect information as described above from cookies, pixels and other similar technology. Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. Some cookies last only for the duration of your web session and expire when you exit the browser, while other cookies may remember you when you return to our Services, as you continue your web session and after you exit the browser. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit and otherwise use the Services through the Internet, to analyze trends, and to learn about our customers and user base, including by helping us to understand how effective our marketing initiatives are. We may combine non-personally identifiable information collected through cookies with other Personal Information that we have about you, for example, to tell us who you are or whether you have an Account. We may also supplement the information we collect from you with information received from third parties in order to enhance our Services, or to offer you information that we believe may be of interest to you. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide whether to accept each new cookie in a variety of ways. Most browsers allow you to block and delete cookies. However, if you do that, some of the Services may not work properly. You can learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information about cookies and how to block cookies using different types of browsers. We use different types of cookies on our Services:
Type of Cookies
Description and Further Information
Essential Cookies
Essential cookies are cookies that enable you to navigate and use all of the features provided through our Services. Without these, you would not be able to navigate between pages or use certain features.
Functionality Cookies
Functionality cookies enable us to remember whether you have previously visited our site, including any preferences you may have previously selected, to help us give you a tailored experience and to deliver certain services to you.
For example:
Performance and Analytical Cookies
Performance and analytical cookies are used to help ensure that our Services can support the number of visitors we get and to help correct any errors on the Services. They also help us understand if you have interacted with these Services before or if you are a unique visitor. We can also see which parts of the Services are the most popular. We use third parties, such as Google Analytics, to analyse statistical information from users of our Services. Please see below for more information. For example: h_eph_sess: a short-lived unique identifier that we use to see if you arrive to the Site and whether this could be linked to any offline advertising like TV or radio advertisements; ga: Google Analytics identifier, a third party cookie served by Google. Please see below for further detail.
Retargeting and Advertising Cookies
Retargeting and Advertising Cookies Retargeting and advertising cookies collect information about the pages on our Site that you visit and other information about other websites you visit, in order to place you in a "market segment". This information is collected by reference to the cookie or other unique identifier. This may result in your seeing advertisements for our products you may be interested when visiting other websites or apps. We use a number of third parties as described below to help deliver these Services, such as Google (AdWords, Google Display Network, DoubleClick (including Noble Media)), BizoID and Optimizely. Please see below for further detail.
COOKIES ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS AND THE USE OF WEB BEACONS:
We use third party companies such as ad servers, ad agencies, ad technology vendors and research firms (“adtech companies”) to serve advertisements on our behalf, to measure the effectiveness of our advertising and to identify people who are most likely to respond to our advertisements. Our advertisements may be targeted to users who fit a certain general profile category and may be based on (i) anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age); (ii) usage patterns with respect to the Services; or (iii) user activity on Third Party Services.
To increase the effectiveness of ad delivery, we may also deliver a file (known as a “web beacon”) from an adtech company to you. Web beacons allow adtech companies to provide anonymized, aggregated auditing, research and reporting for us and for other advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from an ad network’s servers, these adtech companies can view, edit or set their own cookies, just as if you had requested a web page from their site.
We may use one or more Third Party Services to provide audience measurement and analytics services to us, to serve ads across the Internet on our behalf, to track and report on the performance of those advertisements, and/or to collect information via the Services for marketing and advertising purposes. To do so, these Third Party Services may use information about your visits to the Services and other Third Party Service websites, your interaction with our products and the Services, and they may also use cookies, web beacons, pixel tags, SDKs, and other technologies to identify your device when you visit or use our Services, as well as when you visit other online sites and services, including your IP address, web browser, pages viewed, time spent on different pages, websites and apps, across various devices, links clicked and conversion information. As a result of some of these services, targeted or interest-based advertisements or recommendations may appear on other sites that you visit.
If you would like more information about this practice and how to opt out of having your web browsing information used for behavioural advertising purposes, please visit http://www.youronlinechoices.com/ At present, some of the third party cookies include: • Atlas Universal Tags: These services allow us to measure the performance of our advertising network against purchases or other interactions customers have with our Services. You can opt out of the Atlas Universal Tags by visiting http://www.youronlinechoices.com/uk/.
If you would like more information about this practice and how to opt out of having your web browsing information used for behavioural advertising purposes, please visit http://www.youronlinechoices.com/ At present, some of the third party cookies include: • Atlas Universal Tags: These services allow us to measure the performance of our advertising network against purchases or other interactions customers have with our Services. You can opt out of the Atlas Universal Tags by visiting http://www.youronlinechoices.com/uk/.
WHAT IF I HAVE QUESTIONS, CONCERNS, OR COMPLAINTS?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to hello@drinktwisto.com We will make every effort to resolve your concerns.