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PRIVACY POLICY

 

 

TWG Tea Company Pte Ltd and TWG Tea’s affiliated companies (“TWG Tea”, “us”, “we”, “our”) has developed this Privacy Policy (“Policy”) to explain our use of your personal data and information (“ Personal Data”) that you may provide to TWG Tea. The Policy informs you of our policies regarding the collection, use and disclosure of your Personal Data as well as all reasonable precautions which TWG Tea takes to keep your Personal Data confidential and secure.

Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time. We reserve the right to modify our Policy and invite you to check the latest version of this Policy regularly.

This Privacy Policy applies to the Personal Data collected by TWG Tea, including Personal Data collected via TWG Tea’s website at https://TWGTea.com and all related domains and sub-domains and its mobile application (“Website”).
By using our Website and/or providing the Personal Data to order our products and use our services, including the MyTWG Membership Programme, you hereby acknowledge that you have read this Privacy Policy and agree to the collection, use and disclosure of Personal Data by TWG Tea in accordance with this Policy, as amended from time to time by us and to the transfer of the Personal Data to the other companies or entities within the TWG Tea group.
We will post any update to the Policy on our Website. If you do not agree to the terms of this Policy, please do not access this Website or provide the Personal Data.
The terms of this Policy are without prejudice to any contractual terms you may enter into with TWG Tea which shall prevail over the terms of this Policy.

Personal Data

“Personal data” means data about a person who can be identified (i) from that data, or (ii) from that data and other information to which TWG Tea has or is likely to have access. Examples of personal data that may be collected by TWG Tea include your name, contact number, email address, residential address, NRIC number or passport number, payment information and other personal data that TWG Tea may require in order to provide our services or Website to you.

  1. PLEDGE ON PRIVACY

    TWG Tea does not collect, use and process Personal Data except when voluntarily provided by you. We ensure compliance by our staff with strict standards of security and confidentiality and in using, disclosing and processing your Personal Data we pledge to fully comply with industry recognized standards of privacy protection.


  2. COLLECTION OF PERSONAL DATA

    2.1. TWG Tea collects and uses Personal Data only for specific and limited purposes which we inform you when you wish to order our goods, use certain services and to join or use MyTWG Membership Programme, including but not limited to the following, when you

    (a) Apply to be a registered user of the Website;
    (b) Submit an application form to be a MyTWG Member;
    (c) Use the services of the MyTWG Membership Programme;
    (d) Visit or access the Website that can be accessed without the need for registration;
    (e) Conduct any online shopping;
    (f) Make an online purchase through the websites of our third party service providers, or such other service provider that TWG Tea May use from time to time;
    (g) Enter promotions or contests that are available to you without having to be a registered user of the Website;
    (h) Subscribe to our mailing list for either email subscription or postal promotions;
    (i) Submit a comment, question or feedback to us using a “Contact Us” or similar feature on the Website, send us an email, or in any other way, submit Personal Data to us via the Website; and
    (j) Submit your Personal data to TWG Tea for any other reason.


    2.2. In addition, we may use your Personal Data to evaluate the effectiveness of and improve our services to our visitors and customers, for our own internal statistics to evaluate customer interests as well as purchasing and other trends among customers and to better determine product development and marketing strategies.


  3. USE OF PERSONAL DATA

    3.1. We collect and use your Personal Data to allow us to provide services and/or offer you programmes, including MyTWG Membership Programme, and to customise and improve our services, programmes and online shopping. We only collect Personal Data that we consider reasonably necessary for achieving these purposes.

    3.2. Generally, we may collect, use and disclose your Personal Data for any or all of the following reasons:

    (a) To verify your identity;
    (b) To process and manage your application, shopping order, payment or otherwise;
    (c) To register you as a MyTWG Member under the MyTWG Membership Programme;
    (d) To administer the MyTWG Membership Programme;
    (e) To fulfil your requests for online shopping;
    (f) To communicate with you, including any ongoing promotions or TWG Tea news;
    (g) To customize and personalize the contents of the Website;
    (h) To evaluate your preferences and facilitate future works on the Website;
    (i) To manage our internal infrastructure and business operations, including but not limited to where required for compliance with internal policies and procedures;
    (j) To conduct audits, reviews, and analyses of our internal processes;
    (k) To prevent, detect and/or investigate error, fraud, crime and criminal activity;
    (l) To protect and enforce our contractual and legal rights and obligations;
    (m) To respond to requests for information from government or public agencies, regulatory authorities or other similar authorities or non-government agencies authorised to carry out specific Government services or duties;
    (n) To ensure our compliance with all relevant laws, regulations, guidelines and codes of practices; and
    (o) Any other purposes relating to the purposes stated above, or which may be notified and consented by you on or before collection or use of the Personal Data.

    3.4. In addition, we may collect, use and disclose your personal data for any or all of the following purposes,
     
    (a) If you are applying for or you are a member of MyTWG Membership Programme:

      (i) To verify and process your personal particulars in order to process your application;
      (ii) To maintain, manage and renew your membership with us;
      (iii) To create a Member account or profile in order to manage and improve our relationship with you;
      (iv) To provide you with Membership benefits and privileges;
      (v) To send you our publications, newsletters, cards, updates and other communications;
      (vi) To inform you of changes to our policies and/or terms and conditions;
      (vii) To handle requests, enquiries and/or complaints;
      (viii) To conduct surveys and market research; and
      (ix) To process your personal data in relation to any of the purposes stated above, or any other purpose for which we have notified you and obtained your consent to use or disclose your data.
         
    (b) If you are a job applicant who wishes to seek employment with TWG Tea:

      (i) To verify and process your personal particulars in order to process your application;
      (ii) To evaluate your suitability for a position at TWG Tea including to conduct pre-employment checks with previous employers and referees;
      (iii) To communicate with you;
      (iv) For complying with legal or regulatory obligations or risk management procedures that may be required by law or internal processes;
      (v) For any other purposes relating to the purposes stated above, or any other purpose for which we have notified you and obtained your consent to use or disclose your personal data;
      (vi) By providing your curriculum vitae (“CV”), you agree that we may keep your CV in our databases for a reasonable period after which it will be deleted and you agree that we can use your CV and personal data to process your job application and to have such CV and personal data communicated to other companies with the TWG Tea group and to our partners, who have agreed to keep such CV and personal data confidential and secure and to this end being transmitted across national borders.
      (vii) TWG Tea undertakes to use your CV and personal data only in relation to your job application.


    3.5. By submitting your Personal Data, you expressly consent to our use of your Personal Data both in Singapore and overseas especially in countries that TWG Tea is operating. TWG Tea keeps your Personal Data only for as long as is reasonably needed for such purposes and in accordance with the applicable laws on ethical reporting or document retention requirements. Where our services require registration, you may need to choose a user name and password upon registration. In this situation, if you chose to withhold any Personal Data requested by us, it may not be possible for you to gain access to certain parts of our Website and for us to respond to your queries.

    3.6. TWG Tea also automatically receives and records information from your browser on our server logs including but not limited to your Internet protocol address, cookie information and the page you requested. Should you wish to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies.

    3.7. In order to provide the Website and the MyTWG Membership Programme to you, TWG Tea may share your Personal Data with our subsidiaries and affiliated companies worldwide or third-party service providers who are employed to perform functions such as marketing, payment, fulfilment and delivery of orders. You hereby acknowledge and consent to the use and disclosure of the Personal Data for this purpose. These service providers are subject to confidentiality obligations and may only use your Personal Data to perform the necessary functions and not for other purposes. Where there is a legal obligation to do so, TWG Tea may also disclose your Personal Data to any relevant regulatory body or pursuant to a court order.

    3.8. To help ensure that your online shopping experience with us is safe, simple and secure, TWG Tea uses Secure Socket Layer (SSL) technology. We take reasonable care, in so far as it is in our power to do so, to keep the details of your Personal Data, shopping order and payment secure, but in the absence of negligence on our part we cannot be held liable for any loss you may suffer if a third party procures unauthorized access to any data you provide when accessing or ordering from the Website.


  4. NON-DISCLOSURE OF DATA

    TWG Tea shall never sell, rent, share or otherwise distribute or make available your Personal Data to third parties outside the TWG Tea group of companies or affiliates, except when required to do so for legal or regulatory purposes. However, your Personal Data may occasionally be transferred to third parties who act for and on behalf of TWG Tea, for further processing in accordance with the purposes for which your Personal Data was originally collected. When disclosure of your Personal Data to third parties is likely or necessary for whatever reason, TWG Tea shall ensure that such third parties provide the same level of protection as TWG Tea, and that they are required to process your Personal Data transferred only for the purposes authorized by you and on a confidential and secure basis.


  5. RIGHT OF ACCESS

    You have the right to access and update your Personal Data. If you wish to access, correct or change your Personal Data held by us, please contact TWG Tea in writing at Digital@TWGTea.com and addressed to the Data Protection Officer. We will process any updates to your Personal Data as soon as reasonably practicable upon receipt of your request. Your Personal Data will be retained for as long as it is necessary to fulfil the purpose for which it is collected or in accordance with the applicable laws.


  6. WITHDRAWAL OF CONSENT

    You may withdraw your consent to our continued use and disclosure of your Personal Data by writing to us at Digital@TWGTea.com and addressed to the Data Protection Officer. We will delete your Personal Data as soon as reasonably practicable upon receipt of your request unless its retention is permitted or required by any applicable law.

    At the point of collection of the Personal Data, you shall have the opportunity to indicate whether you would like to "opt in" to receiving promotional and/or marketing information from TWG Tea and its related companies and associated companies by joining our mailing list.

    You may choose to unsubscribe from our mailing list at any time by clicking the “Unsubscribe” button in our emails or by writing to us.

    Should you choose to unsubscribe from our mailing list, or should your MyTWG Membership expire, please note that your Personal Data will still be retained on our database although we will stop sending you any further communications.



  7. SECURITY & CONFIDENTIALITY

    We undertake to take all reasonable steps to prevent your Personal Data from beingseen or used by third parties other than those who act for or on behalf of TWG Tea and have agreed to treat your Personal Data as confidential and secure. Access to your Personal Data is restricted to those of our employees on a need to know basis and who have been trained to observe strict standards of confidentiality in handling your Personal Data.

    To ensure the security and confidentiality of your Personal Data that TWG Tea collects online, we use data networks protected, inter alia, by industry standard firewalls and password protection. Although we have tried to create secure, reliable and trustworthy websites or applications for our visitors, please be aware that the Internet is generally not regarded as a complete secure environment and that therefore the confidentiality of the Personal Data provided by you or the information/material transmitted via our Website or by email cannot be guaranteed by TWG Tea. We therefore cannot be responsible or liable for the security of your Personal Data in transit via the Internet or any electronic/digital communications to us.

    All Personal Data which you post in the Website is kept confidential to the best of TWG Tea’s ability. You hereby acknowledge and accept that TWG Tea cannot guarantee the security of any transmission.

    Should you choose to unsubscribe from our mailing list, or should your MyTWG Membership expires, please note that your Personal Data will still be retained on our database although we will cease to send you any further communications.



  8. TRANSFER OF PERSONAL DATA ABROAD

    TWG Tea is an international group and has databases in different jurisdictions. Your Personal Data may be transferred, stored or processed by TWG Tea to one of its databases or to companies within the TWG Tea group of companies or to its partners who have agreed to keep your Personal Data confidential and secure, outside of your country of residence and you consent to such transfer, storage, disclosure, use and/or processing. If the level of privacy protection in a country does not comply with industry recognized standards or in accordance with the requirements prescribed under the Personal Data Protection Act (No. 26 of 2012) and/or EU Regulation No. 2016/679 (General Data Protection Regulation) (as applicable), we will ensure that the transfer of your Personal Data to third parties in such countries does not occur. By submitting your Personal Data, you expressly agree to its possible transfer to other companies within the TWG Tea group and/or its partners and to this end to its trans-border transmission.


  9. ANONYMOUS DATA

    Most of the information we collect from our Website is anonymous information. When you visit our Website, we do not collect any personal information from you unless specifically voluntarily and knowingly provided by you. Anonymous information is processed by TWG Tea to help improve the content of our Website, to customize our Website for our visitors and to learn more about them and how they use our Website. In doing so, TWG tea may use tracking technology (cookies) to gather anonymous information, such as browser type, operating systems and the date and time of access. To see our Cookies Policy, please refer to our Cookies Policy at Cookies Policy.


  10. SPAMMING

    TWG Tea does not conduct “spamming”. Spamming is defined as sending unsolicited emails, usually of commercially nature, in large numbers and repeatedly to individuals with whom the sender has had no previous contact or who have declined to receive such communications. Where we believe that one of our products is of importance to you, we will inform you by email whilst giving you the choice of opting out of such service.


  11. DATA & MINORS

    To respect the privacy of minors (children under the age of 21 years) and to comply with the laws designed to protect minors, TWG Tea will not knowingly collect, use or disclose personal information from minors, without obtaining prior consent from a person with parental responsibility (parent or guardian).

    Our Website/applications are not designed nor intended to collect personal information from children under the age of 21 years. We ask parents/guardians to supervise their children while they are online.



  12. THIRD PARTY LINKS

    As a service to our visitors, our Website may provide hyperlinks to other websites or mobile applications that are not operated or controlled by TWG Tea. Therefore TWG Tea cannot be responsible or liable for the content of such websites or mobile applications or the privacy policies of such other parties. Please note that these privacy practices may differ from our Policy. We encourage you to review and understand their privacy practices before providing them with personal information.


  13. APPLICABLE LAW

    This Policy and the use of the Website shall be governed in all respects by the laws of Singapore without giving any effect to the principles of conflicts of law and you agree to submit to the jurisdiction of the Singapore court.


  14. MEDIATION

    Any dispute, difference, controversy or claim between you and TWG Tea arising out of or in connection with this Policy shall first be submitted to the Singapore Mediation Centre for resolution by mediation in accordance with the Mediation Procedure for the time being in force. You agree to participate in the mediation in good faith and undertake to abide by the terms of any settlement reached.


  15. CONTACT TWG TEA

    Should you have any queries or complaints about our compliance with the Policy, or if you wish to make any recommendations or comments to improve the quality of our Policy please contact us at Digital@TWGTea.com and addressed to the Data Protection Officer. We assure you that we will use our best efforts to constantly improve the protection and security of your Personal Data that you provide to us.


07/2018
© 2018 TWG Tea Company Pte Ltd