Privacy Policy

Introduction

TWA CASK UK Ltd ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or purchase our products.

Information We Collect

Legal Basis for Processing (GDPR)

We process your personal data only where we have a lawful basis under the UK GDPR and Data Protection Act 2018:

• Contract (Art. 6(1)(b)): To fulfil your orders, process payments, and deliver membership benefits you've signed up for.
• Consent (Art. 6(1)(a)): For marketing communications, referral tracking, and non-essential cookies. You may withdraw consent at any time.
• Legal obligation (Art. 6(1)(c)): To retain records for tax, VAT, and accounting purposes as required by HMRC.
• Legitimate interests (Art. 6(1)(f)): To prevent fraud, secure our platform, and improve our services, provided this doesn't override your rights.

How We Use Your Information

We use the information we collect to:

• Process and fulfill your orders
• Send you order confirmations and updates
• Provide customer support
• Send marketing communications (with your consent)
• Improve our website and services
• Prevent fraud and ensure security
• Comply with legal obligations

Sharing Your Information & Processors

We do not sell, trade, or rent your personal information to third parties. We share your data with the following processors, each under a written contract that meets GDPR requirements:

• Stripe — payment processing (name, email, billing/shipping address, card details handled by Stripe's PCI-DSS compliant system)
• Base44 — application hosting, authentication, and database (account details, order history, membership status)
• Google (Gmail & Sheets) — internal order logging and customer communications (name, email, address, order details)
• Royal Mail / shipping carriers — delivery (name, shipping address, tracking)
• Legal authorities (e.g., HMRC) when required by law

Data Retention

We retain your personal data only as long as necessary:

• Order & payment records: 6 years (HMRC / VAT record-keeping requirement)
• Membership data: For the duration of your membership plus 6 years for tax records
• Marketing consent records: Until you withdraw consent
• Account data: Until you request deletion, unless we have a legal obligation to retain it

International Data Transfers

Some of our processors (Stripe, Google, Base44) are based outside the UK/EEA, primarily in the United States. We only transfer data to these processors where appropriate safeguards are in place, including the UK International Data Transfer Agreement (IDTA) or the EU-US Data Privacy Framework. You may request a copy of these safeguards by contacting us.

Referral Tracking

When you visit our site via a member's referral link, we store the referrer's ID in your browser's local storage to attribute your purchase correctly. This data is processed based on our legitimate interests and is deleted once the referral is completed or after 30 days. You can clear this at any time by clearing your browser's local storage.

Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

Your Rights

Depending on your location, you may have the following rights:

• Access to your personal information
• Correction of inaccurate information
• Deletion of your information
• Restriction of processing
• Data portability
• Object to processing
• Withdraw consent at any time

To exercise these rights, please contact us at office@twacasks.com.

Right to Complain to the ICO

If you believe we have not handled your personal data in accordance with this policy or data protection law, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority. You can contact the ICO at ico.org.uk or call their helpline on 0303 123 1113. We encourage you to contact us first so we can address your concerns.

Cookies

We use cookies to enhance your browsing experience. For more information, please see our Cookie Policy.

Age Restrictions

Our products are only available to individuals aged 18 and over. We do not knowingly collect personal information from individuals under 18.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last updated" date.

Contact Us

If you have any questions about this Privacy Policy, please contact us at: