PRIVACY AND COOKIES POLICY
Introduction to our Policy
Who we are and how can you contact us re data and privacy concerns?
This site and our services are operated by The Chiltern Mix.
The Chiltern Mix registered office is at:
The Chiltern Mix Limited
14 Whittle Parkway
Progress Business Centre
How do we collect personal information?
We collect personal information when you interact with us. This may include purchasing online or over the phone, when you contact our Customer Happiness Team and when you sign up to receive emails from us. We also look at how customers use and interact with the website, so that we can offer the best possible shopping experience and product selection for you to make great cocktails at home.
We collect information in a number of ways including:
When you register or use TwelveBelow.co.uk
When you contact TwelveBelow.co.uk by telephone, email, social channels or chat
When you enter any event, prize draws or competitions run by TwelveBelow.co.uk
When you complete any surveys that we send to you for research purposes (although you are under no obligation to complete these)
When completing any forms for transactional, employment or other purposes
When you buy products and or gift cards (and the details of the transaction you make from TwelveBelow.co.uk)
When you visit TwelveBelow.co.uk we automatically record your public internet protocol ('IP') address
What types of information do we collect?
We only collect information necessary to carry out our business, provide the particular service you’ve requested and to keep you up to date about TwelveBelow.co.uk products and services so you can keep your favourite spirits in stock at home for those awesome parties you always have with your mates.
What information do we obtain directly from you?
Below are some examples of information we may collect about you when you interact with TwelveBelow.co.uk:
Name and Surname
Date of Birth
Contact phone number(s)
Interactions with us e.g. contacting our Customer Service
Delivery address and details
Preferences regarding categories, brands and services
Automatically populated IP address
Information from cookies
What information may we obtain independently?
How do we ensure your personal information is only used where lawful?
In order for us to use your personal information we comply with applicable data protection law. Examples of lawful reasons include use of your personal information necessary for the purchase of goods or services, or for compliance with a legal obligation.
Note that where your personal information is anonymised, we do not require a legal basis to use it as the information no longer constitutes personal information regulated under data protection laws.
Why do we collect your personal information and how do we use it?
We use information about you in a number of ways, including providing services that you have requested, offering you a personalised experience and informing you about special events or exciting new products and other related content about great drinks and other ways to imbibe. We may also use the information to contact you in order to process your orders, returns or customer service queries in case an order gets messed up somewhere along the way. We need to share your personal information with our delivery partners and some third parties in order to get the stuff to your door. We share your personal information with credit card companies and other payment providers in order to get paid for the stuff you’re getting sent to you or your friends and business associates.
We make sure we check up on any third party we use to ensure that they are able to provide guarantees regarding the confidentiality and security of any personal information.
When and if you give us your consent we’ll…
Send you marketing updates via email about all the latest news, offers and cool new things to drink and serve at TwelveBelow.co.uk. You can unsubscribe at any time by clicking the link in any email. We share your personal information with our email marketing blaster partner who assist us in delivering our fascinating and intriguing email marketing campaigns to you.
We use your details to show you cool advertising on Social Media platforms like Facebook and Instagram and third party ads that may appear on other websites you surf around on.
We may tailor emails and online advertising to the things you love, so they’re relevant to your location, what you have shown an interest in and the things you like to drink from us.
When we have a good reason (in legal-speak that’s ‘legitimate interest’), we’ll…
Respond to customer service enquiries raised online, via social media or on the phone.
Send an abandoned basket email via a third party supplier.
Ask you to provide feedback about our products and services in the form of online or email surveys. We use this information to help us do our best and improve the quality of service and products we offer.
Sometimes send stuff the old-fashioned way in the post.
Look at aggregate anonymous customer information together with other customers in order to continually improve the TwelveBelow.co.uk experience and products and services we offer – things like Google Analytics and CRM systems help us do this stuff.
Of course, you’ll be able to refuse receiving these communications when we first collect your contact details and you will be able to unsubscribe in any communication you get from us.
Sometimes we have to share your info…
In certain situations, we are obliged to share your personal information for business administration and legal compliance purposes with third parties.
We may have to use your personal information if we’re doing a big business deal for our company and where it’s in our ‘legitimate interest’ (remember that one from above?) to do so (things like a merger or getting bought by another company). If this happens then we may have to share your personal information with external professional advisors such as lawyers and or insurers.
If things get real serious we may use your personal information for legal predicaments and to enforce our legal rights. If some of this legal stuff ever happens then it will be necessary to share your personal information with external parties such as administrative authorities (like the gang at HMRC), police and public prosecutors (like you see on TV box sets) or to comply with a court order (yikes!). It is our legal obligation to do so (or else!)
How can I unsubscribe from marketing communications?
Why would you? You won’t know what awesome new drinks are out there or what some of the best bars in the world are concocting… but if you really don’t want to hear from us then we’ve got a few ways you can unsubscribe and you won’t hear from us again.
Click onto the "unsubscribe" link in any communication we send you by email which will unsubscribe you from that mode of communication. Be aware though that each "unsubscribe" link generally relates to that specific type of communication (e.g. marketing communications or shopping journey communications). This means that unsubscribing from marketing communications will not automatically unsubscribe you from our shopping journey communications.
Alternatively, you can contact our Customer Happiness Team email them on info@TwelveBelow.co.uk.
Our site and communications can sometimes contain links to and from other websites; obviously if you follow a link to any of these websites we can’t accept responsibility or liability for these guys’ privacy policies so think twice before you give them personal stuff.
Our site and some marketing communications contain certain cookies, pixels, records and other technologies which help us give you great service and sell you the goods. If you don’t want us to cookie you then changing the settings on your browser is the best advice but it might mess up your use of the site as it does with any other site. If we can’t throw a cookie at you then sometimes it won’t let you finish your order and other things like that.
How long do we keep personal information for?
We keep personal information in line with our company retention policy. We only retain information for as long as it is required.
Confidentiality and the safeguarding of your personal information is key for us.
We are totally committed to keeping the personal information secure and private and we take all precautions necessary to protect your personal information from loss, misuse or alteration. We won’t sell your personal information for any purpose whatsoever.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
Any of our employees who have access to, and are involved in the processing of personal information, are obliged to respect the confidentiality of the personal information of each and every one of our customers. They have been trained and continue to be trained in all areas of data protection and the safeguarding of any personal information.
You can get access to your information any time…
You now have lots of rights when it comes to personal information:
Your right of access
If you ask us, we’ll tell you whether we’re processing personal information and, if so, provide you with a copy of that personal information. If you require lots of copies of this we may charge you a reasonable fee if it’s a lot of work to get this done.
Your right to correct information
If you find that your personal information is inaccurate or incomplete, you’re entitled to have it corrected. If possible and lawful to do so, we’ll also tell you who we’ve shared personal information with so that you can contact them directly to ask them to help you out.
Your right to delete information
You can ask us to delete or remove your personal information in some situations such as where we no longer need it or if you withdraw your consent. If possible and lawful to do so, we’ll also tell you who we’ve shared personal information with so that you can contact them directly to ask them to help you out.
Your right to restrict information
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If possible and lawful to do so, we’ll also tell you who we’ve shared personal information with so that you can contact them directly to ask them to help you out.
Your right to data portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
Relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing;
Processing your personal information for direct marketing.
Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO) – google ‘ICO concerns’ and you’ll see what to do next.