Find out here what we do with your data and why.
We are required to process your data under strict data laws: General Data Protection Regulations 2018 (GDPR). GDPR gives you strong rights over your personal data.
This document helps you to understand what is happening with your data, why and how you can stop that happening when you buy products from and visit the website.
1. Who is collecting data? What does this company do?
TLC Design Limited is the designer of eto and owns the etowine.com website. TLC Design Limited is a small and simple company based in England. It works with a warehouse and various delivery services to send eto orders every day.
2. Which data do we collect?
TLC Design Limited does not collect, control or store sensitive personal information like sexual orientation, political views or health of customers.
2.1 Information you give to us
We collect the personal information you give us, such as name, address, email address, telephone number and items ordered. We see parts of your payment information but not the complete information.
When you write to us with questions and feedback, we store this information. This helps us to refer to past questions when you return, to track the process of problems being solved and to provide refunds at the correct time. Further information on the way we use the information is in Appendix II.
2.2 Information we collect when you use our website
When you visit, our website automatically collects technical information, including the IP address used to connect your computer to the internet, . browser type, browser version, information about your visit such as the products you viewed in our shop, and the interactions you made with our website, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the website by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
TLC Design Limited advertises eto on social media. When you view eto adverts and visit www.etowine.com this information is collected by our website and in the analytics of the relevant social media website. We may also share information about your use of our site with our social media, advertising and analytics partners. For more detail see the section on Cookies below, in Appendix I.
3. Information collected by a third party
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here https://www.shopify.com/legal/privacy.
We use Email Marketing Service Provider Klaviyo to manage and send emails to You. Their Privacy Policy can be viewed at https://www.klaviyo.com/privacy
We use Bold Commerce to allow you to pay in currencies other than GBP and to collect information for gift messages and pesronalization. Their Privacy Policy can be viewed at https://boldcommerce.com/legal#our-privacy-policy
We use Judge.me to send review & feedback requests following fulilment of your order. Their Privacy Policy can be viewed at https://judge.me/privacy
We also use third party payment processors such as Stripe and PayPal to process your payments. Your payment will be processed by them and they collect, use and process your information, including payment information, in accordance with their privacy policies. You can find them here https://stripe.com/gb/privacy and here https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
It’s a good idea to check their privacy policy when you provide your information to understand fully how they will process your data.
4. Links to Other Websites
Our website may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. 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.
5. Legal basis for collecting data
Under the GDPR we must have a legal basis for doing anything with your data.
The legal basis for accepting, storing and having access to your personal data - name, address, ordered items, email address and telephone number - is the contract we have when you complete an order. In order for TLC Design Limited to send your parcel to the requested address with your gift message or personalisation, we must process this information.
The legal basis for using your email address to send emails about new products, offers and competitions is the consent you give when you opt in to our newsletter at the check out, sign up on the website, or otherwise request to be added to our mailing list.
The legal basis for processing your personal information for monitoring and analysing your use of our website and for remarketing, and for sending review requests using your email address and to send reminders about items left in your basket is the consent you give when you click the privacy and cookie "Accept" button.
6. How long is your information stored?
We may hold your personal information at least 14 months after your order has arrived. This enables us to ensure delivery is complete, to solve delivery problems with you by contacting you, letting you know if delivery is not possible and to allow for refunds to be made or warranty claims to be resolved.
We may send you email updates until you unsubscribe.
7. How to unsubscribe
You may unsubscribe at any time by emailing us at hello@etowine.com or by clicking on the link at the foot of any of our newsletters.
8. Transfer of Your Personal Data
Your information, including personal data, is processed at our operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your country, state, province, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
9. Processing your personal data
Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data but it is not possible to guarantee the security of your data transmitted to our site; any transmission is at your own risk.
Once we have received your information, we will use trustworthy business partners, strict procedures and security features to try to prevent unauthorised access.
10. Your rights under the GDPR
We undertake to respect the confidentiality of your personal data and to guarantee you can exercise Your rights.
You have the right by law if You are within the EU, to:
- Request access to your personal data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist You. This also enables You to receive a copy of the personal data we hold about You.
- Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.
- Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.
11. Exercising your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
12 . How to raise a complaint
If you believe we are processing data unlawfully you can complain to us via email at hello@etowine.com. If the complaint is not complex we must respond within 1 month. If the complaint is complex, more time may be required to respond.
You may complain to the independent regulatory body Information Commissioner's Office (ICO) online https://ico.org.uk/concerns/
13. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
14. Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be sent via the contact form.
Last updated on: 27 January 2022
APPENDIX I
Cookies
Bold cookies
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The etowine website allows you to see pricing in and pay in a choice of currencies. Bold cookies may enable prices to display properly on your device, remember your currency, and store your order information as you move from page to page through the website.
These cookies may stay longer on your computer, so that you can see what you left in your basket or which currency you choose.
Google cookies
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Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.co.uk/intl/en/analytics/privacyoverview.html
Facebook cookies
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When you see eto advertising on Facebook or Instagram, then you visit our website or order something from our website, this process is visible to us via cookies. These cookies allow us to see whether our advertising on Facebook is working or not. When you sign up to Facebook, they ask you to agree to their cookie policy.
We also use remarketing services to advertise on Facebook and Instagram to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our website.
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
APPENDIX II
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
For the performance of a contract: for the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through our website.
To manage Your Account: to manage your registration as a user of the website. The personal data You provide can give you access to different functionalities of our website that are available to you as a registered user.
To ensure that content from our site is presented in the most effective manner for you and for your computer or mobile device.
To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes. If you have asked to be placed on our mailing list and/or to receive our newsletter, we will retain your email address. We will only do this if you have asked us to do so, and we will remove your address from the list on request.
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our service.
DISCLOSURE OF YOUR INFORMATION
In order to send your order to you we send the details of your order to our warehouse and the relevant shipping, courier or postal service.
If you have chosen to receive our newsletter and/or subscribed to our blog updates by email, or taken part in our surveys, we disclose your email address to our newsletter software provider Klaviyo and any associated software providers.
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If our business or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of our business, our customers, or others.
This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.