Privacy Policy
TW7Bev Ltd, registered under the Companies Act 2006 having its registered
office address at 114 Ridgeway Road, Isleworth, TW7 5LN, (hereinafter also
referred to as “TW7Bev”, “Company”, “we”, “our” or “us”) operates
www.tw7bev.com (“Website”) and TW7Bev services (collectively “Services”).
Our Privacy Policy (“Policy”) governs your visit to our Website and explains how
we collect, safeguard and disclose information that results from your use of our
Service.
We take your privacy very seriously. In this Policy, we seek to explain to you in
the clearest way possible what information we collect, how we use it and what
rights you have in relation to it. We hope you take some time to read through it
carefully, as it is important. If there are any terms in this Policy that you do not
agree with, please discontinue the use of our Services immediately. We use your
data to provide and improve Service. By using the Service, you agree to the
collection and use of information in accordance with this policy. Unless otherwise
defined in this Policy, the terms used in this Policy have the same meanings as in
our Terms and Conditions. Our Terms and Conditions govern all use of our
Service and together with the Policy constitute your agreement with us.
If this Policy is modified in any way, it will be updated here. Regularly checking
and reviewing this page ensures that you are updated on the information which
may be collected, used and shared with other parties. If we believe that the
modifications are material, we will notify you of the changes by posting a notice
on the Website, or emailing you at the email address provided to us by you, and
as we may deem appropriate. What constitutes a material change will be
determined by us, at our sole and absolute discretion. In this
Policy “you”, “your” or “users” refers to the users of the Website.
WHAT INFORMATION DO WE COLLECT?
The personal information you disclose to us.
We may collect personal information that you voluntarily provide to us on the
Website, express an interest in obtaining information about us or our products
and Services or otherwise when you contact us.
The personal information that we may collect depends on the context of your
interactions with us and the Website, the choices you make and the products and
features you use. The personal information we collect may include the following:
Personal Information provided by you.
We collect first name; last name; email address; age; and other similar
information.
All personal information that you provide to us must be true, complete and
accurate, and you must notify us of any changes to such personal information.
Information automatically collected
When you access our websites, we, our service providers and our partners may
automatically collect information about you, your computer or mobile device, and
your activity on our websites. Typically, this information includes your computer
or mobile device operating system type and version number, manufacturer and
model, device identifier, browser type, screen resolution, IP address, the website
you visited before browsing our website, general location information such as
city, state or geographic area; and information about your use of and actions on
or in our websites, such as pages or screens you accessed, how long you spent
on a page or screen, navigation paths between pages or screens, information
about your activity on a page or screen, access times, and length of access.
Our service providers and business partners may collect this type of information
over time and across third-party websites. This information is collected via
various mechanisms, such as via cookies, web beacons, embedded scripts, and
similar technologies. This type of information may also be collected when you
read our HTML-enabled emails.
The information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic
usage and performance information our servers automatically collect
when you access or use our Website and which we record in log files.
Depending on how you interact with us, this log data may include your
IP address, device information, browser type and settings and
information about your activity on the Website (such as the date/time
stamps associated with your usage, pages and files viewed, searches
and other actions you take such as which features you use), device
event information (such as system activity, error reports (sometimes
called ‘crash dumps’) and hardware settings).
• Device Data. We collect device data such as information about your
computer, phone, tablet or other devices you use to access the Website.
Depending on the device used, this device data may include information
such as your IP address (or proxy server), device application
identification numbers, location, browser type, hardware model Internet
service provider and/or mobile carrier, and operating system
configuration information.
HOW DO WE USE YOUR INFORMATION?
We use personal information collected via our Website for a variety of business
purposes described below. We process your personal information for these
purposes in reliance on our legitimate business interests, in order to enter into or
perform a contract with you, with your consent, and/or for compliance with our
legal obligations. We indicate the specific processing grounds we rely on next to
each purpose listed below.
We use the information we collect or receive:
• To send administrative information to you. We may use your personal
information to send you our service and new feature information and/or
information about changes to our terms, conditions, and policies.
• To protect our Services. We may use your information as part of our
efforts to keep our Website safe and secure (for example, for fraud
monitoring and prevention).
• To enforce our terms, conditions and policies for business purposes, to
comply with legal and regulatory requirements or in connection with our
contract.
• To respond to legal requests and prevent harm. If we receive a
subpoena or other legal request, we may need to inspect the data we
hold to determine how to respond.
• To respond to user inquiries/offer support to users. We may use your
information to respond to your inquiries and solve any potential issues
you might have with the use of our Services.
• To send you marketing and promotional communications. We and/or
our third-party marketing partners may use the personal information you
send to us for our marketing purposes if this is in accordance with your
marketing preferences. For example, when expressing an interest in
obtaining information about us or our Website, subscribing to marketing
or otherwise contacting us, we will collect personal information from you.
You can opt-out of our marketing emails at any time.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We may process or share the data that we hold based on the following legal
basis:
• Consent: We may process your data if you have given us specific consent
to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably
necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with
you, we may process your personal information to fulfil the terms of our
contract.
• Legal Obligations: We may disclose your information where we are
legally required to do so in order to comply with applicable law,
governmental requests, a judicial proceeding, court order, or legal
processes, such as in response to a court order or a subpoena
(including in response to public authorities to meet national security or
law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding potential
violations of our policies, suspected fraud, situations involving potential
threats to the safety of any person and illegal activities, or as evidence
in litigation in which we are involved.
More specifically, we may need to process your data or share your personal
information in the following situations:
• Business Transfers. We may share or transfer your information in
connection with, or during negotiations of, any merger, sale of company
assets, financing, or acquisition of all or a portion of our business to
another company.
• Third-Party Advertisers: We may use third-party advertising companies
to serve ads when you visit or use the Website. These companies may
use information about your visits to our Website(s) and other websites
that are contained in web cookies and other tracking technologies in
order to provide advertisements about goods and services of interest to
you.
• Affiliates: We may share your information with our affiliates, in which case
we will require those affiliates to honour this Policy. Affiliates include our
parent company and any subsidiaries, joint venture partners or other
companies that we control or that are under common control with us.
• Business Partners: We may share your information with our business
partners to offer you certain products, services or promotions.
USE OF COOKIES, WEB BEACONS AND OTHER TRACKERS
We use temporary and permanent cookies, tags, scripts, and other similar
technologies to identify users of our services and enhance user experience and
identify visitors, track website navigation, gather demographic information about
visitors and users, understand email campaign effectiveness and for targeted
visitor and user engagement by tracking your activities on our websites.
You can set your browser to refuse all cookies or to indicate when a cookie is
being sent to your computer. However, this may prevent our site or services from
working properly. You can also set your browser to delete cookies every time you
finish browsing. For more information please refer to our Cookies Policy.
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
The Website may contain third parties links and which may link to other websites
like Instagram, Twitter etc. We cannot guarantee the safety and privacy of the
data you provide to any third parties. Any data collected by third parties is not
covered by this Policy. We are not responsible for the content or privacy and
security practices and policies of any third parties, including other websites,
services or applications that may be linked to or from the Website. We strongly
advise you to review the Privacy Policy of every site you visit. We have no
control over and assume no responsibility for the content, privacy policies or
practices of any third-party sites or services.
WE HEREBY DISCLAIM LIABILITY FOR, ANY INFORMATION, MATERIALS,
PRODUCTS, OR SERVICES POSTED OR OFFERED AT ANY OF THE THIRD-
PARTY SITES LINKED TO THIS WEBSITE. BY CREATING A LINK TO A
THIRD-PARTY WEBSITE, WE DO NOT ENDORSE OR RECOMMEND ANY
PRODUCTS OR SERVICES OFFERED OR INFORMATION CONTAINED ON
THAT WEBSITE, NOR ARE WE LIABLE FOR ANY FAILURE OF PRODUCTS
OR SERVICES OFFERED OR ADVERTISED AT THOSE SITES. SUCH A
THIRD PARTY MAY HAVE A PRIVACY POLICY DIFFERENT FROM THAT OF
OURS AND THE THIRD-PARTY WEBSITE MAY PROVIDE LESS SECURITY
THAN THIS SITE.
HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the
purposes set out in this Policy, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements). No
purpose in this Policy will require us keeping your personal information for longer
than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this is not
possible (for example, because your personal information has been stored in
backup archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational security
measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your information,
no electronic transmission over the Internet or information storage technology
can be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties will not be able to
defeat our security, and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information,
transmission of personal information to and from our Website is at your own risk.
You should only access the Website within a secure environment.
YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION
REGULATION (GDPR) AND UK DATA PROTECTION ACT (DPA).
If you are a resident of the United Kingdom (UK), European Union (EU) and
European Economic Area (EEA), you have certain data protection rights, covered
by GDPR and DPA. We aim to take reasonable steps to allow you to correct,
amend, delete, or limit the use of your Personal Data. If you wish to be informed
of what Personal Data we hold about you and if you want it to be removed from
our systems, please contact us.
Under certain circumstances, individuals in Europe have rights under data
protection laws in relation to their personal data. If you are located in Europe,
you may ask us to take the following actions regarding personal data that we
hold:
- Access. You are entitled to ask us if we are processing your personal
data and, if so, for a copy of the personal data we hold about you, as
well as obtain certain other information about our processing activities. - Correction. If any personal data we hold about you is incomplete or
inaccurate, you can require us to correct it, though we may need to
verify the accuracy of the new data you provide to us. - Erasure. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your personal data where
you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or
where we are required to erase your personal data to comply with local
law. - Object. Where our reason for processing your personal data is a
legitimate interest you may object to the processing as you feel it
impacts your fundamental rights and freedoms. You also have the right
to object where we are processing your personal data for direct
marketing purposes. - Restriction. You may ask us to suspend our use of your personal data
in the following scenarios: if you want us to establish the data’s
accuracy; where our use of your personal data is unlawful but you do not
want us to erase it; where you need us to hold your data for a longer
period than we usually would, because you need it to establish, exercise
or defend legal claims; or you have objected to our use of your data but
we need to verify whether we have overriding legitimate grounds to use
it. - Transfer. Where it is possible, we will provide to you, or a third party
you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to personal
data provided by you which you initially provided consent for us to use
or where we used the information to perform a contract with you. - Withdraw consent. Where our reason for processing is based on your
consent, you may withdraw that consent at any time. If you withdraw
your consent, we may not be able to provide certain services to you. We
will advise you if this is the case at the time you withdraw your consent. - You have the right not to be subject to
automated decision-making (e.g., profiling) that significantly affects you.
The exercise of this right is not available to you in the following cases:
a. The automated decision is required to enter into, or perform, a
contract with you.
b. We have your explicit consent to make such a decision.
c. The automated decision is authorised by the local law of an EU
member state.
However, in the first two cases set out above, you still have the right to obtain
human intervention in respect of the decision, to express your point of view and
to contest the decision.
There may be legal or other reasons why we cannot, or are not obliged to, fulfil a
request to exercise your rights. We will use available lawful exemptions to your
individual rights to the extent appropriate. If we decline your request, we will tell
you why, subject to legal restrictions.
You will not have to pay a fee to exercise any of your rights relating to your
personal data. However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply
with your request in these circumstances.
Please note that we may ask you to verify your identity before responding to
such requests. Please note, we may not be able to provide Service without some
necessary data.
You also have the right to file a complaint with the supervisory authority in the
EEA, and in the UK you can file a complaint with the Information Commissioner’s
Office.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do- Not-Track (“DNT”) feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities
monitored and collected. At this stage, no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do
not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard
for online tracking is adopted that we must follow in the future, we will inform
you about that practice in a revised version of this privacy notice.
HOW DO WE PROTECT CHILDREN’S PRIVACY?
In compliance with the requirements of COPPA (Children’s Online Privacy
Protection Act), we do not knowingly collect personally identifiable information
from Children below the age of 13 (“Child” or “Children”) without the consent
of the parents or legal guardian. If you become aware that a Child has provided
us with Personal Data without the parent’s or legal guardian’s consent, please
contact us. If we become aware that we have collected Personal Data from
Children, we take steps to remove that information from our servers.
DO WE MAKE UPDATES TO THIS NOTICE?
We may update this privacy notice from time to time. The updated version will be
indicated by an updated “Last updated” date and the updated version will be
effective as soon as it is accessible. If we make material changes to this privacy
notice, we may notify you either by prominently posting a notice of such changes
or by directly sending you a notification. We encourage you to review this privacy
notice frequently to be informed of how we are protecting your information.
CONTACT US
After reviewing this policy, if you have any additional questions, concerning this
Privacy Policy, please contact us by sending an email to info@tw7bev.com by
adding the word “Privacy” in the subject line.
Effective Date: March 1, 2024 Last Updated: March 1, 2024