Website Privacy Policy
Fresh-Pak respects your privacy and is committed to protecting your personal data. This privacy notice tells you what personal data we collect about you, how we will use and look after it and about your privacy rights under the data protection law.
Important information and who we are
Controller
Fresh-Pak is the data controller and decides how your personal data is processed (referred to as “Fresh-Pak”, “we”, “us” or “our” in this privacy notice).
Our Data Protection Manager (Leyon Scott) is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice or if you would like to make a request to exercise your legal rights, please contact the Data Protection Manager using the contact details set out below.
Contact details
Full name of legal entity: Fresh-Pak Chilled Foods Ltd
Email address: DPO@fresh-pak.co.uk
Postal address:
Waterside Park
Valley Way
Barnsley
S73 0BB
This privacy notice is overseen by the Data Protection Manager. If you have any queries, complaints or requests relating to Fresh-Pak, please contact the Data Protection Manager at [DPO@fresh-pak.co.uk]. You also 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). In certain circumstances you might also have the right to bring a complaint to other regulators or in the Courts although we would hope that you give us the chance to deal with any concerns you might have first by contacting our Data Protection Manager.
Purpose of this privacy notice
This privacy notice provides you with information about how Fresh-Pak collects and processes your personal data. This privacy notice applies to you if you visit our website (https://www.fresh-pak.co.uk/) (regardless of where you visit it from), if you enquire about our services, purchase our services, or otherwise interact with us. However, please note that if you we are processing your personal data because you are an employee our Employee Privacy Notice will apply.
Changes to our website
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. For example, if you are an employee then your personal data will also be processed in accordance with our Employee Privacy Notice. This privacy notice supplements other notices and privacy policies and is not intended to override them unless this is clear from the context.
Changes to our privacy notice and the need for you to inform us of changes
We keep our privacy notice under regular review. This version was last updated on 19/09/2024. We may update this privacy notice at any time by posting an amended version to our website. Please refer to this notice regularly.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
Third party links
This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Children’s data
Our website is not intended for children and we would ask that users to not provide personal data to us via the website. Please contact the Data Protection Manager on the contact details above if this raises any concerns.
Information we collect about you
Personal data is any information about an individual from which that person can be identified. It does not include information derived from personal data where the identity has been removed, such that the person can no longer be directly or indirectly identified from the information (anonymous data).
We may collect, use, store and transfer different types of your personal data which we have grouped together as follows:
- Identity Data includes your first and last name, your business/employer’s name and your job role.
- Contact Data includes your business email address, phone number and address.
- Financial Data: includes your bank account and payment card details.
- Customer Service Data: includes details of any enquiries you have made to us, services you have purchased from us, and feedback or survey responded you have provided to us.
- Profile Data: includes your username and password, your preferences and details of how you use and interact with our services.
- Log Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the type of device you are using, its operating system, unique device identifiers, your device settings and geo-location data, the pages you visit, the time you spend on each page and the date and time of your visit.
- Marketing and Communications Data: includes your interests, your preferences in receiving marketing from us 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 offences.
If you don’t provide us with your personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you don’t provide us with 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 our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
How we collect your personal data
We use different methods to collect data from and about you, including through:
- Direct interactions: you may give us your personal data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes personal data you provide us when you:
- Purchase our goods or services
- Supply us with good or services, as part of our supply chain
- ive us feedback
- fill out a survey; or
- fill out a ‘contact us’ form on our website.
- Automated technologies or interactions: as you interact with our website, we will automatically collect your Profile Data and Log Data. We collect this data by using cookies, server logs and other similar technologies. We may also receive Log Data about you if you visit other websites employing our cookies. Please see our [Cookie Policy] for further details.
- Third parties [or publicly available sources]: we will receive your personal data from various third parties [and public sources] as set our below:
- [analytics providers [such as Google based outside the UK]];
- [advertising networks [such as [NAME] based [inside OR outside] the UK];
- [providers of technical, payment and delivery services [such as [NAME] based [inside OR outside] the UK]; and
- [publicly available sources [such as [NAME] based [inside OR outside] the UK].
How we use your personal data
We collect and use your personal data for different purposes depending on how you interact with us and the services that we supply to you or your business. Data protection law requires us to have a legal basis to process your personal data for each particular purpose. We will only use your personal data when we have a legal basis for doing so. Most commonly, we will rely on one of the following legal bases:
- Where it is necessary to perform the contract, we are about to enter into or have entered into with you (“Performance of a contract 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 (“Necessary for our legitimate interests”).
- Where we need to comply with a legal obligation (“Necessary to comply with a legal obligation”).
- We may also rely on your consent as a legal basis for processing your personal data (“Consent”).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of purposes for which we may use your personal data, which of the legal bases we rely on to do so and the types of personal data processed for each purpose. We have also identified what our [legitimate interests] are where appropriate.
In some cases we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your personal data. Please contact us if you would like more detailed information about how we process your personal data.
We may also inform you of additional purposes for processing your personal data when that information is collected from you.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our [Cookie Policy].
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 lawful and 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 intend to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Please note that, in limited circumstances, we may process your personal data without your knowledge or consent where this is required or permitted by law.
How we use special category personal data
Special category personal data (this term is explained in the Definitions section below) attracts a higher level of protection. Data protection law requires us to have an additional condition where we are collecting, storing and using special category personal data.
The conditions that we most commonly rely on to collect, use or share your special category personal data include:
- In limited circumstances, your explicit consent.
- Where we need to carry out our legal obligations or exercise rights in the field of employment.
- Where it is needed in the public interest, such as for equal opportunities monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else’s vital interests) and you are not capable of giving your consent, or where you have already made the information public.
Purposes for which we use your special category personal data
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.
Criminal offence data
We do not normally collect personal data relating to criminal convictions and offences (“Criminal Offence Data”). Should we collect any of your Criminal Offence Data, we would only do so if this was appropriate in the circumstances; appropriate safeguards were implemented to protect the Criminal Offence data and the processing was lawful.
International data transfers
We store and process your personal data in the UK and outside of the UK. In addition, some of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of that data outside the UK.
Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK;
- using approved standard contractual clauses which give personal data the same protection it has in the UK; or
- transferring when one or more of the conditions set out in Article 49 UK GDPR are met.
Data security
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. These include limiting access to your personal data to our employees, contractors, agents and other third parties who have a business need to access it. We have also 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.
How long we keep your personal data for
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. These purposes may include satisfying legal, regulatory, tax, accounting or reporting requirements. We may also retain your personal data if we reasonably believe it may be needed in relation to a complaint or in order for us to exercise or defend a legal claim.
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, as well as any other relevant legal, regulatory, tax, accounting or other requirements.
If you want to know more about how long we keep your data please contact us (DPO@fresh-pak.co.uk). In some circumstances you can ask us to delete your data: see your legal rights section below for more details.
Your legal rights
Under certain circumstances, you have rights under data protection law in relation to your personal data. You have 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 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 to 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:
- 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 no longer require it as you need it to establish, exercise or defend legal claims; or
- 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, where technically feasible, another data controller where you have provided it 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 wish to exercise any of the rights set out above, please contact us at DPO@fresh-pak.co.uk.
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. 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.
What we ask of you:
- Keeping your information accurate and up to date: please inform us if there is a change in your contact details or any other information that you have provided to us so that we can ensure our records are kept accurate and up to date.
- Third party personal data: If you provide us with personal data about another person, please make sure that you have informed them of our identity, the purposes for which their personal data will be processed; and obtained their permission and/or complied with any other data protection requirements. If you are unsure whether their personal data can be shared with us, please contact us before providing us the data.
Automated Decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We will only use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you the opportunity to request a reconsideration of that decision.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If the automated decision-making is based on special category personal data (see above), we will only proceed if
- We have your explicit written consent; or
- There are substantial public interest grounds to justify the decision and we have put in place appropriate measures to safeguard your rights.
Changes to our Privacy Notice
We reserve the right to revise, alter and reissue this Privacy Notice at any time. If we make changes to our Privacy Notice we will update this page and would therefore ask that you check it from time to time and contact us if you have any queries (DPO@fresh-pak.co.uk). If we make material changes to our Privacy Notice, we may also provide you with additional notification of those changes via email therefore we would also ask that you notify us if your contact details change. This version of the Privacy Notice was last updated on 19/09/2024.
| Purpose/ Activity | Legal basis for processing (including details of legitimate interests) | Type of personal data processed | Parties we might share your personal data with |
| Business contact details of contacts in our supply chain, customers and other business partners are processed so that we can deliver our goods/ services | Depending on the context, the lawful basis will be performance of a contract, legitimate interests because processing is necessary to comply with a legal obligation or possibly consent (although this is rare) | Business contact details and other personal data that is very limited and unlikely to be particularly sensitive or confidential in nature |
|
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our [Cookie Policy].
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 lawful and 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 intend to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Please note that, in limited circumstances, we may process your personal data without your knowledge or consent where this is required or permitted by law.
How we use special category personal data
Special category personal data (this term is explained in the Definitions section below) attracts a higher level of protection. Data protection law requires us to have an additional condition where we are collecting, storing and using special category personal data.
The conditions that we most commonly rely on to collect, use or share your special category personal data include:
- In limited circumstances, your explicit consent.
- Where we need to carry out our legal obligations or exercise rights in the field of employment.
- Where it is needed in the public interest, such as for equal opportunities monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else’s vital interests) and you are not capable of giving your consent, or where you have already made the information public.
Purposes for which we use your special category personal data
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.
Criminal offence data
We do not normally collect personal data relating to criminal convictions and offences (“Criminal Offence Data”). Should we collect any of your Criminal Offence Data, we would only do so if this was appropriate in the circumstances; appropriate safeguards were implemented to protect the Criminal Offence data and the processing was lawful.
International data transfers
We store and process your personal data in the UK and outside of the UK. In addition, some of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of that data outside the UK.
Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK;
- using approved standard contractual clauses which give personal data the same protection it has in the UK; or
- transferring when one or more of the conditions set out in Article 49 UK GDPR are met.
Data security
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. These include limiting access to your personal data to our employees, contractors, agents and other third parties who have a business need to access it. We have also 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.
How long we keep your personal data for
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. These purposes may include satisfying legal, regulatory, tax, accounting or reporting requirements. We may also retain your personal data if we reasonably believe it may be needed in relation to a complaint or in order for us to exercise or defend a legal claim.
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, as well as any other relevant legal, regulatory, tax, accounting or other requirements.
If you want to know more about how long we keep your data please contact us (DPO@fresh-pak.co.uk). In some circumstances you can ask us to delete your data: see your legal rights section below for more details.
Your legal rights
Under certain circumstances, you have rights under data protection law in relation to your personal data. You have 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 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 to 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:
- 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 no longer require it as you need it to establish, exercise or defend legal claims; or
- 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, where technically feasible, another data controller where you have provided it 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 wish to exercise any of the rights set out above, please contact us at DPO@fresh-pak.co.uk.
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. 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.
What we ask of you:
- Keeping your information accurate and up to date: please inform us if there is a change in your contact details or any other information that you have provided to us so that we can ensure our records are kept accurate and up to date.
- Third party personal data: If you provide us with personal data about another person, please make sure that you have informed them of our identity, the purposes for which their personal data will be processed; and obtained their permission and/or complied with any other data protection requirements. If you are unsure whether their personal data can be shared with us, please contact us before providing us the data.
Automated Decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We will only use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you the opportunity to request a reconsideration of that decision.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If the automated decision-making is based on special category personal data (see above), we will only proceed if
- We have your explicit written consent; or
- There are substantial public interest grounds to justify the decision and we have put in place appropriate measures to safeguard your rights.
Changes to our Privacy Notice
We reserve the right to revise, alter and reissue this Privacy Notice at any time. If we make changes to our Privacy Notice we will update this page and would therefore ask that you check it from time to time and contact us if you have any queries (DPO@fresh-pak.co.uk). If we make material changes to our Privacy Notice, we may also provide you with additional notification of those changes via email therefore we would also ask that you notify us if your contact details change. This version of the Privacy Notice was last updated on 19/09/2024.
