Privacy policy
This Privacy Policy describes how tinwaredirect.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.
Contact
After reviewing this policy, if you have additional questions, want more information about our privacy practices, or would like to make a complaint, please contact us by e-mail at info@tinwaredirect.eu or by mail using the details provided below:
Tinware Direct BV, De Hooge Akker 18, 5661 NG, Geldrop, Nederlands
Collecting Personal Information
When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information about an identifiable individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.
- Device information
- Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
- Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
- Disclosure for a business purpose: shared with our processor Shopify, Lead Forensics a reverse IP tracking service and our CRM system HubSpot.
- Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
- Order information
- Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
- Source of collection: collected from you.
- Disclosure for a business purpose: shared with our processor Shopify, Shopify Payments, DPD or other distributors used required to fulfill your order and our CRM system provider HubSpot.
- Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
Minors
The Site is not intended for individuals under the age of 16. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address above to request deletion.
Sharing Personal Information
We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, 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 may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
- We use DPD or other fulfillment services in order to deliver your ordered products.
Behavioural Advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:
- We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
- We use Shopify Audiences to help us show ads on other websites with our advertising partners to buyers who made purchases with other Shopify merchants and who may also be interested in what we have to offer. We also share information about your use of the Site, your purchases, and the email address associated with your purchases with Shopify Audiences, through which other Shopify merchants may make offers you may be interested in.
- We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK - https://www.facebook.com/settings/?tab=adsGOOGLE - https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/.
Using Personal Information
We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.
Lawful basis
Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:
- Your consent;
- The performance of the contract between you and the Site;
- Compliance with our legal obligations;
- To protect your vital interests;
- To perform a task carried out in the public interest;
- For our legitimate interests, which do not override your fundamental rights and freedoms.
Retention
When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.
Automatic decision-making
If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.
We DO NOT engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.
Services that include elements of automated decision-making include:
- Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
- Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.
Personal Information
We DO NOT sell your personal information to any third parties or companies.
Your rights
GDPR
If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above or visit our GDPR compliance page https://tinwaredirect.com/pages/gdpr-compliance.
Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.
CCPA
If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above.
If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address above.
Cookies
A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.
We use the following cookies to optimize your experience on our Site and to provide our services.
https://www.shopify.com/legal/cookies
Cookies Necessary for the Functioning of the Store
| Name | Function | Duration |
|---|---|---|
| _ab | Used in connection with access to admin. | 2y |
| _secure_session_id | Used in connection with navigation through a storefront. | 24h |
| _shopify_country | Used in connection with checkout. | session |
| _shopify_m | Used for managing customer privacy settings. | 1y |
| _shopify_tm | Used for managing customer privacy settings. | 30min |
| _shopify_tw | Used for managing customer privacy settings. | 2w |
| _storefront_u | Used to facilitate updating customer account information. | 1min |
| _tracking_consent | Tracking preferences. | 1y |
| c | Used in connection with checkout. | 1y |
| cart | Used in connection with shopping cart. | 2w |
| cart_currency | Used in connection with shopping cart. | 2w |
| cart_sig | Used in connection with checkout. | 2w |
| cart_ts | Used in connection with checkout. | 2w |
| cart_ver | Used in connection with shopping cart. | 2w |
| checkout | Used in connection with checkout. | 4w |
| checkout_token | Used in connection with checkout. | 1y |
| dynamic_checkout_shown_on_cart | Used in connection with checkout. | 30min |
| hide_shopify_pay_for_checkout | Used in connection with checkout. | session |
| keep_alive | Used in connection with buyer localization. | 2w |
| master_device_id | Used in connection with merchant login. | 2y |
| previous_step | Used in connection with checkout. | 1y |
| remember_me | Used in connection with checkout. | 1y |
| secure_customer_sig | Used in connection with customer login. | 20y |
| shopify_pay | Used in connection with checkout. | 1y |
| shopify_pay_redirect | Used in connection with checkout. | 30 minutes, 3w or 1y depending on value |
| storefront_digest | Used in connection with customer login. | 2y |
| tracked_start_checkout | Used in connection with checkout. | 1y |
| checkout_one_experiment | Used in connection with checkout. | session |
| checkout_session_lookup | Used in connection with checkout. | 3w |
| checkout_session_token_<<token>> | Used in connection with checkout. | 3w |
| identity-state | Used in connection with customer authentication. | 24h |
| identity-state-<<token>> | Used in connection with customer authentication. | 24h |
| identity_customer_account_number | Used in connection with customer authentication. | 12w |
| Localization | Used to track country of origin to provide the most suitable website experience and to localise language, currency and products available in their region. | 1yr |
| hubspotutk | Online form submissions, back in stock notifications, automated discount emails and chat sessions | 9mths |
Reporting and Analytics
| Name | Function | Duration |
|---|---|---|
| _landing_page | Track landing pages. | 2w |
| _orig_referrer | Track landing pages. | 2w |
| _s | Shopify analytics. | 30min |
| _shopify_d | Shopify analytics. | session |
| _shopify_s | Shopify analytics. | 30min |
| _shopify_sa_p | Shopify analytics relating to marketing & referrals. | 30min |
| _shopify_sa_t | Shopify analytics relating to marketing & referrals. | 30min |
| _shopify_y | Shopify analytics. | 1y |
| _y | Shopify analytics. | 1y |
| _shopify_ga | Shopify and Google Analytics. | session |
| customer_auth_provider | Shopify analytics. | session |
| customer_auth_session_created_at | Shopify analytics. |
session |
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.
Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.
Do Not Track
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
Call Recording
Purpose
Call recording is utilised to:
- Identify employee training and development requirements.
- Protect employees from nuisance or abusive calls.
- Support customers with their enquiries during and post call.
- Identify business improvements to processes and procedures.
How Call Recording is Operated
Call recording is controlled in accordance with the GDPR and data protection requirements.
Customers will be informed of the use of call recording by pre-recorded message. This does not imply that a call will be recorded, only reasonable notice that call recording provisions are in place and where to find more information.
Calls made to any Tinware Direct switchboard numbers are automatically recorded. These numbers are the numbers published specifically on any Tinware Direct website domains and publicly available marketing materials.
When calling a member of our team directly using a direct telephone number for them, we will explicitly request consent when call recording is taking place, before beginning the call. If consent is withdrawn, call recording will be stopped by us.
Where we initiate call recording during a call, an automated message will play informing you that call recording is taking place. We will also request your consent prior to beginning the recording.
You have the right to request call recording stops at any time during your call. You may also request copies of transcripts and recordings we hold.
When leaving a message for us, the message will be transcribed and stored in the company’s systems with consent inferred by the recording from the customer.
Access to Recordings
Call recordings are converted by AI to transcripts and stored against a customer record.
Access to recordings and transcripts are strictly controlled and are stored securely on company systems.
Use of Artificial Intelligence (AI)
Purpose
Tinware Direct Limited utilises AI technology to assist both customers and employees, and to help improve our products and services. AI is utilised by Tinware Direct in two ways:
- To Process and Summarise Data
This process does not record or create Personal Information or utilise automated decision-making. Instead it is used to assist in the summary of information stored within the company’s systems. This helps us to support customers and employees more efficiently and streamlines processes. In this instance AI is used to:
- Provide automatic call or business summaries, add notes, and add tags to customer records.
- Identify key topics discussed in calls, or products and services purchased by a customer. This helps employees to assist customers with future or current purchases and enquiries.
- Provide call analysis to support employee training and development, and to improve customer service.
- Automate company reporting.
- To Process Personal Data
This process utilises Personal Information and creates data and is therefore subject to the GDPR and Data Protection regulations. It does not include automated decision-making. In this instance AI is used to:
- provide automatic transcripts of permissively recorded calls where this has taken place.
- predict interests in new or existing products and services, or future activities.
- combine company records with publicly available information to complete customer records.
Changes
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.
Complaints
As noted above, if you would like to make a complaint, please contact us by e-mail or by mail using the details provided under “Contact” above.
If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://ico.org.uk/make-a-complaint/
Last updated: 16/05/2023
