Social Media Privacy Policy

The Sunday Times Wine Club is Direct Wines Limited (“Direct Wines”), a private company registered in England and Wales with company number 01095091. Direct Wines will be the controller of the personal data that you provide to us in connection with our social media accounts.

What categories of personal data do we collect, and how do we collect it?

When you engage with us through our social media accounts, you may provide us with:

  • your account name;
  • any other contact details you might provide to us directly (for example, if you win one of our social media competitions, we shall ask you for your name and address to deliver a prize to you);
  • if you win one of our social media competitions, we may ask you to send us additional information to allow us to verify your age;
  • the content of any social media posts you share with us (including any photographs contained in those posts); and
  • the content of any direct messages you send to us.

We obtain all of this information from you directly.

Legal basis for collecting and processing your data

We’ll use your personal data to:

  • re-post any messages or images you share with us via our social media accounts;
  • with your permission, re-use any messages or images you share with us in our printed or online marketing materials;
  • contact you via your social media account if you make an enquiry, complaint or request to one of our social media accounts;
  • to administer our social media competitions fairly and properly, and if you are a winner, to tell you that you’ve won the competition and to make any further arrangements with you, including to repost your winning entry on social media, to deliver your prize to you; and
  • if you promote yourself as contactable for affiliate or social influencer marketing, contact you to explore any suitable opportunities.

The lawful bases for us processing your personal data in connection with our social media accounts are as follows:

  • Legitimate interests: This means the interests of our company in conducting and managing our business to enable us to give you the best products and services, and the best and most secure experience. In connection with our social media accounts, we rely on our legitimate interests to process your personal data :
    • to run any competition fairly and properly (including to enforce or apply our T&Cs if necessary), to tell you if your competition entry is a winner, and, if your photo is selected to deliver your prize to you, to repost your winning entry on social media;
    • to re-post any messages or images you share with us via our social media accounts; and
    • to contact you via your social media account if you make an enquiry, complaint or request to one of our social media accounts.

For further information about our reliance on our legitimate interests to process your personal data, please refer to our Privacy Policy.

  • Legal compliance: If the law requires us to, we may need to collect and process your data. For example:
    • we may pass on your details to verify your age to ensure that we only give products containing alcohol to those aged 18 or over; and
    • the CAP Code requires us (as the promoter of any competition) to either publish or make available certain information about prize winners. You can object to this information being published or made available by contacting us on 03330 142 776 or dpo@thesundaytimeswineclub.co.uk Please note that, even if you opt out, we may still have to provide the information and winning entry to the ASA.

When do we share your personal data?

So that we can provide you with our products and services, administer our social media competitions and respond to any queries, complaints or requests you may have, we have to share some of your personal data with certain third parties.  For example:

  • if you win one of our social media competitions, we share your details with our core service providers include the courier companies we use to deliver your prize to you; companies we use to carry out age verification checks (if required); and IT services providers; and
  • we may also disclose your information to third parties in order to enforce or apply our T&Cs, if necessary.

How long do we retain your personal data for?

In relation to any posts you make on social media, you should contact the social media provider for details of their retention policy and how to delete your posts.  Where we obtain information from you directly, for example where we obtain your address details to send you a prize if you win a competition, please see the section called ‘How long do we hold your personal data for?’ in our Privacy Policy.

For further information in relation to the processing of your personal data (including your rights and processing outside of the EEA), please refer to our Privacy Policy.

If you have any questions about how we look after your personal data, you can contact us:

  • in writing, at One Waterside Drive, Arlington Business Park, Theale, Berkshire, RG7 4SW. Please mark your letter for the attention of the Data Protection Officer;
  • by email to this address: dpo@thesundaytimeswineclub.co.uk; or
  • by telephone on 03330 142 776.

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