Last Updated: 01/10/2020
2. IMPORTANT INFORMATION AND WHO WE ARE
- setting out the basis on which any personal data we collect from you, your employer, or that you provide to us or that we collect from other sources, will be processed by us when you visit our website at foodsconnected.com (regardless of where you visit it from) and any downloadable software application that we may from time to time provide (together “the Site”); and
- telling you about your privacy rights and how the law protects you.
Foods Connected will collect, use and have responsibility for certain personal data about you. When we do so, we are regulated under the General Data Protection Regulation (“GDPR”) and we are responsible as “controller” of the information for the purposes of the GDPR. We may also process your personal data in the day to day operation of the Site as further detailed under “Purposes for which we may use your personal data” below.
The Site is not intended for children and we do not knowingly collect data relating to children.
The DPO is:
Mr Andrew McCracken
Foods Connected Ltd
3rd Floor, 12 - 16 Castle Lane
BT1 5DA Belfast
Any data subject may, at any time, contact our DPO directly with all questions and suggestions concerning data protection.
RIGHT TO COMPLAIN TO A SUPERVISORY AUTHORITY
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. The UK supervisory authority being the Information Commissioner’s Office ("ICO") (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority 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.
3. DATA WE MAY COLLECT FROM USERS OF THE SITE
Personal data means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We may process different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting 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.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preference.
- Usage Data includes information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic information. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
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 offences.
4. 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 and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- engage in the online support features of FC;
- enter a competition, promotion or survey; or
- give us some feedback
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from Google Analytics to enable Foods Connected to determine whether it can stop developing on certain platforms and to facilitate an analysis of a user’s use of the Site.
- Identity and Contact Data from our customers who are using the system for their business and have identified you as a customer or supplier to their business and request you to use the system to conduct business activities with them. However, a user’s personal data will only be added to the Site when the user has registered to use the Site.
5. HOW WE WILL USE YOUR PERSONAL DATA
We will only use your personal information when the law allows us to. Most commonly we will use your personal data in the following circumstances:
- To communicate email notifications on activities that have been requested or completed by our customers or suppliers (as applicable).
- To communicate our information services newsletter on a daily basis.
- Where we need to perform the contract we are about to enter into or have entered into with your employer.
- Where we need to perform the contract we have entered into with a customer of ours who has identified you or your employer as a supplier to their business.
- To notify you about changes to FC.
PURPOSES FOR WHICH WE MAY USE YOUR PERSONAL DATA
The table below provides 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. It also identifies what our legitimate interests are, where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are 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.
||Type of data
||Lawful basis for processing including basis of legitimate interest
|To register you as a new user
|Necessary for our legitimate interests for running our business
To process and deliver your company’s orders including:
(a) To manage payments, fees and charges
(b) To collect and recover money owed to us
(c) Marketing and Communications
Necessary for our legitimate interests (to recover debts due to us and for the proper running of the business).
To manage our relationship with you which will include:
(b) Communicating our information services newsletter by email
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services and for the functioning of the Site).
|To enable our customers to communicate with you on behalf of your employer through the Site
(b) Necessary for our legitimate interests (for the functioning and running of the Site).
|To enable you on behalf of your employer to communicate with our customers through the Site
(a) Necessary for our legitimate interests (for running our business and for performance of a contract with your employer).
|To administer, protect and improve our business and this website (including troubleshooting, 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
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
USE OF YOUR PERSONAL DATA FOR MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. At all times, we will ensure that we comply with the applicable rules and privacy laws when marketing to you.
We will get your express opt-in consent in any circumstances whereby we wish to share your personal data with any company outside Foods Connected for marketing purposes.
You have the right to opt-out of any marketing communications by changing your privacy settings. We will endeavour to deal with your opt-out request as quickly as possible.
6. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal information with the following categories of recipients:
- Companies within the Foods Connected group, if a group company is a data processor (Article 28 GDPR), if the transfer is subject to an adequacy decision (Article 45 GDPR) or if it is subject to appropriate safeguards (Article 46 GDPR).
Selected third parties including:
Service providers based in the United Kingdom, Ireland, USA and Australia who provide IT and system administration services;
- Google Analytics;
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances; and
- other companies and users who are registered to use the Site.
We may disclose your personal information to third parties:
- if Foods Connected is, or its business and assets are, acquired by a third party, in which case personal data held by it about users of the Site will be one of the transferred assets; and/or
We require all third parties to respect the security of your personal information 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 written instructions.
7. INTERNATIONAL DATA TRANSFERS
The personal data that we collect from you may be accessed from a destination outside the European Economic Area (“EEA”). It may also be processed by our staff who operate outside the EEA in Australia.
When you sign up to use our site, you expressly consent to your data being accessed outside the EEA. If you wish to withdraw your consent please notify us by emailing us at email@example.com or by deleting your account.
8. HOW WE SECURE YOUR DATA
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. Other than users of the Site with whom you have connected, 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.
9. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
10. YOUR RIGHTS
Under the GDPR, you have a number of important rights free of charge. These include the right to:
- Request access to your personal data (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.
- Request correction of the personal data that we hold about you. 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.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data in certain circumstances. 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Please note, however, that 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.
- Object to processing of your personal data 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 to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds o process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this 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. You may withdraw consent by contacting the DPO or simply by deleting your account.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing at our registered address or by email.
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 may 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 will respond to your request within one month. Occasionally it may 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.