This policy explains how we look after your personal data when you visit our TRS food website i.e., legal entity of Vibrant Foods Group (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.
If you witness any breaches, please let your manager know as soon as possible. In many cases, conduct issues can be dealt with informally; the right word at the right time can work wonders. However, in all significant cases of misconduct the formal disciplinary process will be followed.
- We do not knowingly collect data about children.
- This policy specifically relates to the collection and processing of personal data through our website. This policy supplements other notices and privacy policies and is not intended to override them.
Important information and who we are
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third party links
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes; first name, surname, username, or similar identifier, marital status, title, date of birth, gender.
- Contact Data includes; billing address, delivery address, email address, and telephone number.
- Technical Data includes; internet protocol (IP) address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes; your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes; information about how you use our website, products and services.
- Marketing and Communications Data includes; your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
Nor do we collect any information about criminal convictions and offenses.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :Subscribe to our service or publications
- Request marketing to be sent to you
- Give us feedback or contact us
- Third parties or publicly available sources We will receive personal data about you from various third parties and public sources as set our below technical data from the following parties:
- Analytics providers such as Google, advertising networks search information providers
- Advertising networks such as Google absence who may be based outside the UK
- Search information providers
- Identity and contact data from data brokers or aggregators
- Identity and contact data from publicly available sources such as companies house and the Electoral Register based inside the UK
- Other companies and service providers such as Mail chimp and WordPress
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation
To find out more about the types of lawful basis that we will rely on to process your personal data, please visit https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/#:~:text=(a)%20Consent%3A%20the%20individual,before%20entering%20into%20a%20contract.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data We have set out below (appendix 1), in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which were using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below (appendix 1). Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Opting out: You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences Or by following the opt-out links on any marketing message sent to you Or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, warranty registration, product/service experience or other transactions].
Third Party Marketing We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Disclosures of your personal Data
We may share your personal data with the parties set out below for the purposes set out in the table (Appendix 1)
- Internal Third Parties (our Group Entities)
- External Parties (as set out within the Cookies Policy)
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process. Your personal data for specified purposes and in accordance with our instructions.
Third party service providers we use (Survey Monkey or Mail Chimp) may transfer your Personal Information outside the European Economic Area. We have taken reasonable steps to ensure that these service providers are Privacy Shield registered and provide an adequate level of protection to your Personal Information.
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. More information about these rights can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
The right to request access
Commonly known as a “data subject access request”, this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
The Right to request correction
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
The right to request erasure
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (se below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
The Right to object to processing
You may wish to object to processing where we are relying on a legitimate interest(or those of a third party) and there is something about your particular situation which makes you want t object to processing your personal data for direct marketing purposes. In some cases we may demonstrate that we have compelling rights, please contact us.
The Right to request restriction of processing
This enables you to ask us to suspend the processing of you personal data in the following scenarios:
- If you want us to establish the data’s accuracy
- Where our use of the data is unlawful but you do not want us to erase it
- Where you need us to hold the data even if we not longer required it as you need it to establish, exercise or defend legal claims
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
The Right to Transfer
In such cases, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
The right to withdraw consent at any time
In such cases where we are relying on consent to process your personal data, withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
GLOSSARY –Meanings & Explanations
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties means other companies in the Vibrant Brands Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
External Third Parties means;
- Service providers acting as processors based in the UK and who provide IT and systems administration services
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, insurance, banking and accounting services.
- HR Revenues and Customs, regulators and other authorities acting as processors or joint controllers based in the UK
- We may receive personal information from third parties (I.e., other companies and service providers such as Mail Chimp, google, Google Analytics and Google AdWords, WordPress).
This policy has been authorised by the Group People Director.
We reserve the right to review, change or replace the content of this policy to reflect the changing needs of the Company and/or to comply with new legislation.
Owner -People Team
Last updated –12/12/22
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|Performance of a contract with you
|(a)Identity(b)Contact(c)Profile(d)Marketing and Communications
|(a)Performance of a contract with you(b)Necessary to comply with a legal obligation(c)Necessary for our legitimate interests(to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including trouble shooting, data analysis, testing,system maintenance, support, reporting and hosting of data)
|(a)Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b)Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
|(a)Identity(b)Contact(c)Profile(d)Usage(e)Marketing and Communications(f)Technical
|Necessary for our legitimate interests (to study how customer see our products/ services, to develop them, to grow our business and to inform our marketing strategy)
|To used at a analytics to improve our website, products/ services, marketing, customer relationships and experiences
|Necessary for our legitimate interests ( to Definity peso customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that maybe of interest to you
|(a)Identity(b)Contact(c)Technical(d)Usage(e)Profile(f)Marketing and Communications
|Necessary for our legitimate interests(to develop our products/services and grow our business)