Social Media Privacy Policy

The Sunday Times Wine Club operated by 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 and social media handle;
  • 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, address and additional information to verify your age before we deliver a prize to you);
  • the content of any social media posts you share with us (including any photographs, videos or copy contained in those posts); and
  • the content of any comments you post on our social media accounts or 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, images or creative content you share with us (including via hashtags or tags) in our printed or online marketing materials (including emails) and credit them with your social media handle;
  • 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;
  • to improve products and services;
  • to measure your social media engagement with our brand; 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 terms and conditions 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;
    • to contact you via your social media account if you make an enquiry, complaint or request to one of our social media accounts; to improve products and services;
    • to measure your social media engagement with the brand and understand the success of our marketing strategies; and
    • to contact you via your social media account to ask for permission to use content you have tagged us in.

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

  • Consent: We may use and share your data with third parties when we have your consent to do so. For example, if you have agreed that we may use a photo you’ve taken in our advertising material.
  • 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?

We share data with third parties that help us provide certain services to you, including in relation to information technology, product fulfilment and delivery, customer support, administration of competitions, age verification and marketing. Where you have consented to the same, we may share your data publicly (e.g., for inclusion in advertising material or on our own social media). We will only share data that is necessary to perform the relevant service.

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 UK), 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.

What does it mean if you give us permission to use a photo or video?

We love to see our customers engaging with and enjoying The Sunday Times Wibe Club. If you’ve taken a photo or video and tagged us in some way (by using a competition hashtag etc.), we may ask for your permission to repost it or use it in our marketing materials. We have a great in-house team that put together our marketing content, but we may also send things out to external marketing agencies.

By giving us permission:

  1. You agree to grant Direct Wines and its direct or indirect licensees, assignees and agencies a royalty free, exclusive, worldwide, assignable, sub-licensable and irrevocable licence to use, publish, reproduce, edit, exhibit, project and display the photo or video for the purposes of advertising, marketing and promotional activity, in connection with promoting The Sunday Times Wine Club;
  2. You agree to waive your moral rights under section 205 of the Copyright, Designs and Patents Act 1988 and waive any right you may have to inspect and approve any use made of the photo or video within the scope of the licence granted above;
  3. You agree to release Direct Wines from any claims for remuneration associated with the use of the photo;
  4. You warrant that you are the author and owner of all rights in the photo or video and no other person has any claim to ownership or any other legal rights in the photo;
  5. You warrant that you have full legal capacity to give permission for the photo to be used; and
  6. You warrant that you are 25 years or older.

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