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FAYREFIELD FOODS LTD PRIVACY NOTICE The treatment of personal data is important to us. This notice outlines the information we hold and the way in which we treat it. Fayrefield Foods Ltd is the data controller of your information. Personal data – How we collect it? Fayrefield Foods Ltd deals primarily with other businesses in the dairy and related industries. The vast majority of information it holds is therefore not personal information but information on other businesses. We may however hold limited personal information as a result of our trading activities including: - details on our own employees and agency workers; - details of our customers and suppliers (who operate as sole traders or partnerships) which they give to us on setting up an account; - the details of individuals who work for corporate entities with which we do business including for example information from their business cards or of their email addresses; - the names and addresses of individuals who return products bought through third parties to us as the manufacturer; - CCTV images recorded for security reasons at our various sites; - Information obtained from third parties in the usual course of business including credit insurers. All this information is obtained either because it is required for the purpose of performing a contract with you or for the purpose of legitimate business interest. Our privacy notice in respect of employees and agency workers information is held on our internal share point site. For details regarding Information obtained from users of our website, please refer to our website privacy policy which is displayed online. Personal data – What we do with it? We use your information to transact business with you. This includes informing you of product updates, price changes and other information by email. We may use the information to run a credit check on your business or to appoint a debt collection agency in the event of none payment. We store the information on our servers in the UK. Whom we share personal data with? We do not generally share your data with third parties but this would happen with: - IT service providers that help us with internal IT issues; - companies that provide credit reports; - companies that provide debt collection services; - insurers; - transport, storage and logistic companies who process and deliver our goods. How long we keep your data? As the majority of data we keep is business related it would be our usual policy to keep this for a period of ten years after a business transaction has taken place. Data profiling We do not use individual details for data profiling. How to contact the Regulator? If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data. you have the right to lodge a complaint with the Commissioner’s Office. You can contact them by calling 0303 123 1113 Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites). How to contact us? Write to: Fayrefield Foods Ltd Englesea House Barthomley Road, Crewe. Cheshire. CW1 5UF Email: www.info@fayrefield.com This policy was last updated on 22rd May 2018. Privacy policy 1. Introduction 1.1 We are committed to safeguarding the privacy of our website visitors and service users. 1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. 1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. 1.4 In this policy, "we", "us" and "our" refer to Fayrefield Foods. For more information about us, see Section 11. 2. How we use your personal data 2.1 In this Section 2 we have set out: (a) the general categories of personal data that we may process; (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing. 2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. 2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. 2.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. 2.6 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. 2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent. 2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business. 2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. 2.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. 2.11 We may information contained in or relating to any communication that you send to us on social media ("social media data"). This data may the communication content and metadata associated with the communication. The source of this data is Twitter, Facebook, Instagram, Pinterest and other third party platforms. This data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is consent. 2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. 2.13 We may process any of your personal data identified in this policy] where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. 2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary in order to protect your vital interests or the vital interests of another natural person. 2.15 Please do not supply any other person's personal data to us, unless we prompt you to do so. 3. Providing your personal data to others 3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. 3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 3.4 Financial transactions relating to our website and services are handled by our payment services providers, PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at www.paypal.com. 3.5 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data. 3.6 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 4. Retaining and deleting personal data 4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. 4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 4.3 We will retain your personal data as follows: (a) personal data will be retained for a minimum period of 12 months, and for a maximum period of 10 years. 4.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria: (a) the period of retention of personal data will be determined based on our requirements to provide service. 4.5 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 5. Amendments 5.1 We may update this policy from time to time by publishing a new version on our website. 5.2 You should check this page occasionally to ensure you are happy with any changes to this policy. 5.3 We may notify you of changes to this policy by email. 6. Your rights 6.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: (a) the payment of a fee (currently fixed at GBP 10); and (b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address). 6.2 We may withhold personal information that you request to the extent permitted by law. 6.3 You may instruct us at any time not to process your personal information for marketing purposes. 6.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. 7. About cookies 7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 7.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 7.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 8. Cookies that we use 8.1 We use cookies for the following purposes: a) Essential cookies Essential cookies are technical cookies that are required for the operation of our sites. Without essential cookies our sites can’t operate properly. Essential cookies include, for example, cookies that enable you to log into secure areas. b) Performance cookies Performance cookies allow us to recognise and count the number of visitors to our sites and to see how visitors move around them. This helps us to improve the way our sites work by enabling us to tailor our sites to the way visitors use them. The information we collect from performance cookies is aggregated which means that we cannot identify you from it. c) Experience cookies Experience cookies allow our sites to remember the choices you make. Our sites use experience cookies to provide you with enhanced and personalised features. For example, we use information collected through what are known as “web-analytic” cookies to compare the choices you make to those of our other customers so that we can learn from those choices. Information collected by experience cookies cannot track your browsing activity when you leave our sites to browse other sites. d) Marketing cookies Marketing cookies record your visits to our sites, the pages you have visited and the links you have followed. We use this information to make our sites and the advertising displayed on them more relevant to your interests. For example sometimes we use marketing cookies to limit the number of times that you see an advert. Sometimes we share information about your browsing activity, (which we have collected from cookies), with our advertising partners. They may use this information to advertise products, which may interest you, on other sites. 9. Cookies used by our service providers 9.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 9.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. 10. Managing cookies 10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/kb/PH21411 (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). 10.2 Blocking all cookies will have a negative impact upon the usability of many websites. 10.3 If you block cookies, you will not be able to use all the features on our website. 11. Our details 11.1 This website is owned and operated by Fayrefield Foods Limited. 11.2 We are registered in England and Wales under registration number 1639747, and our registered office is at Englesea House, Barthomley Road, Crewe, CW1 5UF. 11.3 Our principal place of business is at Englesea House, Barthomley Road, Crewe, CW1 5UF. 11.4 You can contact us: (a) by post, to [the postal address given above; (b) using our website contact form; (c) by telephone, on 01270 589311 (d) by email, using info@fayrefield.com.