T W Chambers & Co (TWC) is a trading name of Shandwick Supply Co Ltd, a company limited by shares. The company registration number is SC153702 and the registered office is Unit 12B Evanton Industrial Estate, Dingwall, Ross-shire, IV16 9XJ.
Maintaining the security of your data is a priority at TWC, and we are committed to respecting your privacy rights. We undertake to handle your data appropriately and legally at all times. We will also be clear about what data we collect about you and how we use it.
This policy applies to all customers, regardless of how you engage with us, and provides you with information about:
- how we use your data.
- what personal data we collect.
- how we ensure your privacy is maintained; and
- your legal rights relating to your personal data.
For clarity, TWC may be both data controller and data processor for your personal data under certain circumstances.
We must advise that this policy is subject to change, so please check our website on a regular basis for any further changes.
This policy is based on the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).
How the law protects you
Data protection laws state that we are only able to process personal data if we have valid reasons to do so. The reasons we process your personal data include, but are not limited to, your consent, performance of a contract, billing and to contact you.
How do we collect personal data from you?
We receive information about you when you use our website, if you contact us by phone, email, live-chat or otherwise in respect of any of our products and services or during the purchasing of any product or service. Additionally, we also collect information from you when you sign up, enter a competition, promotion or survey or when you inform us of any other matter.
How we use your data
TWC (and partners acting on our behalf) use your personal data:
- to provide goods and services to you.
- to manage any registered account that you hold with us.
- to verify your identity.
- for crime and fraud prevention, detection and related purposes.
- with your agreement, to contact you about promotional offers and products and services which we think may interest you, and this may be by electronic or other means.
- for customer insight and market research purposes - to better understand your needs.
- to enable TWC to manage customer service interactions (including refunds) with you; and
- where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a law enforcement agency, HMRC, or in a legal dispute).
TWC may use your personal data (with your consent) to send you promotional messages by email or other electronic communication channels and may send you postal mail to update you on the latest TWC offers.
You have the right to opt out of receiving promotional communications at any time, by:
1. changing marketing preferences via your TWC account.
2. making use of the simple “unsubscribe” link in emails.
3. contacting us through the means set out in this Policy.
Sharing data with third parties
In order to make goods and services available to you, we may need to share your personal data with some of our service partners. These include payment processing, IT, delivery and marketing service providers and fraud prevention and identification partners.
TWC only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. Data shared in such circumstances can only be used to provide goods and services to TWC and to you, and for no other purposes.
Other third parties
Aside from our service providers, TWC will not disclose your personal data to any third party, except as set out below. We will never sell or rent your data to other organisations for marketing purposes.
We may share your data with:
- credit reference agencies, banks and payment card issuers.
- payment processing service providers.
- Third party marketing partners used to deliver emails.
- governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so to comply with our legal obligations, to exercise our legal rights (for example in court cases); for the prevention, detection, investigation of crime or prosecution of offenders; and to safeguard and protect our employees, customers or other individuals.
Mergers and Takeovers
In the event that a separate business acquires all or part of our business or its assets, for example in the context of a merger or takeover, we may need to disclose your personal data to that company, so they can continue to provide services to you. In this situation, your data will only be used by the other business for the purposes set out in this Policy.
In certain circumstances, it is possible that your personal data could be transferred to a company with whom we’re discussing selling or transferring all or part of the TWC business, but only where strictly necessary for the evaluation of the transaction. If this happens, the data will be kept secure and confidential and will be deleted if the business sale does not go ahead.
How long do we keep your data?
We will not retain your data for longer than necessary for the purposes set out in this Policy. The longest we will normally hold any personal data is 7 years from last transaction.
Please note if you close your account, we may keep your data for up to 7 years after you have cancelled your services with us. We may not be able to delete your data before this time due to our legal and/or accountancy obligations.
What personal data do we collect?
TWC may collect the following information about you:
- your name and verification you are over 18.
- your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address.
- purchases and orders made by you.
- your on-line browsing activities on TWC website.
- your password.
- CCTV images if you visit our premises.
- your IP address, device-specific information, server logs, device event information.
- when you make a purchase or place an order with us, your payment card details (indirectly as these details are held by our payment processing partner – TWC do not hold your card details)
- your communication and marketing preferences.
- your interests, preferences, feedback and survey responses.
- your location.
- your correspondence and communications with TWC.
Our website is not intended for children, and we do not knowingly collect data relating to children.
You must certify that you are 18 years of age or older to use the TWC website.
This list is not exhaustive, and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our website or send an email to our team. Other personal data is collected indirectly, for example you’re browsing or shopping activity.
Personal data we receive from third parties
Payment service providers, banks, credit card companies, credit reference agencies.
How we protect your data
TWC is committed to keeping your personal data safe and secure.
Our security measures include: -
- encryption of data.
- all our service providers who may handle your personal data undertake regular cyber security assessments
- security controls which protect the entire TWC IT infrastructure from external attack and unauthorised access; and
- internal policies setting out our data security approach and training for employees.
What you can do to help protect your data
TWC will never ask you for any bank account or credit card details via email. If you receive an email claiming to be from us asking you to do so, please ignore it and do not respond.
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety both in relation to TWC and more generally:
- keep your account passwords private. Remember, anybody who knows your password may access your account.
- when creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. You can change your password at any time by accessing your account, clicking ‘your account’, clicking ‘your data’ and selecting ‘change password’.
- avoid using the same password for multiple online accounts.
You have the following rights:
- to ask for a copy of personal data that we hold about you (the right of access).
- to request that we delete personal data held on you; where we no longer have any legal reason to retain it (the right of erasure or to be forgotten).
- to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification).
- to opt out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so (the right to object).
- to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances. (the right to data portability).
If you wish to exercise any of the above rights, please contact us using the contact details set out below.
- phone: 01349 832974
- e-mail: email@example.com
- mail: T W Chambers & Co, Unit 12B Evanton Ind Est, Dingwall, Ross-shire, IV16 9XJ.
Legal basis for TWC processing customer personal data
TWC collects and uses customers’ personal data because it is necessary for the legitimate interests of operating the company, complying with our duties and exercising our rights under a contract for the sale of goods or services to a customer; or complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers by any means.
Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The legal basis for processing customer data includes: -
selling and supplying goods and services to our customers.
protecting customers, employees and other individuals and maintaining their safety, health and welfare.
promoting, marketing and advertising our products and services.
sending promotional communications.
understanding our customers’ behaviour, activities, preferences, and needs.
improving existing products and services and developing new products and services.
complying with our legal and regulatory obligations.
preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
handling customer contacts, queries, complaints or disputes (including managing refunds).
protecting TWC, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to TWC.
effectively handling any legal claims or regulatory enforcement actions taken against TWC.
fulfilling our duties to our customers, colleagues, shareholders and other stakeholders; and
managing corporate transactions, including selling or transferring any parts of our business to third parties, acquiring new businesses or entering into mergers.
What are cookies?
How are cookies managed?
The cookies stored on your computer or other device when you access our websites are designed by:
TWC, or on behalf of TWC, and are necessary to enable you to a make purchase on our website.
third parties who assist us in detecting and preventing fraud.
third parties who participate with us in marketing programmes.
What are cookies used for?
The main purposes for which cookies are used are: -
For technical purposes essential to effective operation of our website, particularly in relation to on-line transactions and site navigation.
For TWC to market to you, particularly web advertisements and targeted updates.
To help TWC detect and prevent fraud through web and social media advertising.
To enable TWC to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, and find out if promotional communications have been opened.
How do I disable cookies?
Note - if you have already consented to cookies on our website, you can change your preferences at any time by clearing cookies from your browser and re-entering our site. This will cause the pop-up banner to re-display, and you can choose to use the site without consenting to cookies.
If you want to disable cookies, you can also change your website browser settings to reject cookies. How you can do this will depend on the browser you use
What happens if I disable cookies?
This depends on which cookies you disable, but in general the website may not operate properly if cookies are switched off. If you disable all cookies, you will be unable to complete a purchase on our site.
How to complain
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
This policy was last updated in November 2022.