Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website, or by providing us with any information about yourself, you are accepting and agreeing to the practices described in this policy.
All your personal Information shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 ("GDPR") and national laws implementing GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data. The data controller is Mike Norledge, The Spread Food LTD, 27 Old Gloucester Street, London, WC1N 3AX
Our Data Protection contact for the purpose of Data Protection Law is Mike Norledge contactable by email at firstname.lastname@example.org
1. Information we collect from you
We will collect and process the following data about you:
1.1 What information do we collect on our website?
When you visit our Website (including the mobile optimised version of the website accessible from your portable hand-held device) you may provide us with personal information such as name, email address and information about other traders who might be interested in our services ("Information"). You may provide us with Information in a number of ways:
a) by supplying us with the Information as listed above, on an individual basis by registering as a trader or subscribing to receive updates from us. To become a registered trader you must provide us with your name, postcode, date of birth (month and year only), email address, business documentation, credit, debit, or account details but you may also provide us with additional information if you choose to do so.
b) by corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses;
c) by booking a pitch, or applying for a job with us;
1.2 We may collect Information about your computer, including where available your IP address, operating system, browser type and the geographical location of your computer, for system administration purposes. We may also report aggregate information to our advertisers. This is statistical data about browsing actions and patterns and does not identify you as an individual.
2. What Information do we collect at our sites?
2.1 When you are at one of our sites, we may collect the following Information:
a) your name and contact details (date of birth), email address, postcode and mobile telephone number
b) This comprises video or still images that we record when you visit our premises together with information such as your actual name or a nickname.
3. Information we receive from other sources
3. 1 This is information we receive about you from sources other than directly from yourself, which may include:
Social media such as Linked In, Facebook, Twitter and Instagram
Third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
4. How we use your Information
4.1 We will hold, use and disclose your Information for our legitimate business purposes including:
a) to keep you up to date about important changes to our business;
b) to direct-market products and services, advise you of news and industry updates, events, promotions and competitions and other information. An option to unsubscribe will also be provided with each communication;
c) to apply profiling technology which analyses our customers’ engagement with our direct marketing communications, activity and interests so that we can send you content that is relevant to you;
d) to answer your queries;
e) Very limited third parties, such as business partners, suppliers and sub-contractors for the performance of any contract we enter into with them.
4.2 Additionally, we may disclose your personal information to third parties:
4.2.1 If we outsource any aspect of our business or systems, then we may disclose your personal data to our service provider(s).
4.2.2 In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If we or a substantial part of our assets are acquired by a third party, in which case personal data held by us about our customers may be one of the transferred assets.
4.2.3 f we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the terms of any agreement or policy to which we are a party, or to protect the rights, property, or safety of The Spread, our customers, or others. This may include exchanging information with other companies and organisations for the purposes of site security, fraud protection and credit risk reduction.
5. The legal basis for processing your Information
5.1 Under GDPR, the main grounds that we rely upon in order to process your Information are the following:
a) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your Information. We may also be obliged by law to disclose your Information to a regulatory body or law enforcement agency;
b) Necessary for the purposes of legitimate interests - either we, or a third party, will need to process your Information for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your Information protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
c) Consent – in some circumstances, we may ask for your consent to process your Information in a particular way.
5.2 If you provide us with any special categories of personal data (that is to say information as to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sex life or sexual orientation or genetic or biometric data) or personal data relating to criminal convictions and offences, it is a condition of us receiving that information that you expressly consent (and you hereby do) to us processing that personal data for the purposes set out in clause 3. Accordingly, if you do not want us to process any such categories of personal data, please do not provide it to us.
6. How we share your Information
6.1 In certain circumstances we will share your Information with other parties. Details of those parties are set out below along with the reasons for sharing it.
a) Trusted third parties: In order to provide certain services, we will share your information with third party service providers such as IT infrastructure companies and email logistics providers. We will not share your data with any third party where it is not necessary to do so to provide a service to you.
b) Regulatory and law enforcement agencies. As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
c) In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
7. How long we hold your Information
We will only retain your Information for as long as is necessary for the purpose or purposes for which we have collected it. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept. For example, if we receive your Information through a competition entry, we will retain your data for as long as is necessary to administer the competition. If we receive your Information when you apply for a job, we will retain your data for as long as is necessary to process your application, and maintain application statistics. We will not directly market to you for longer than three (3) years, unless you consent to receive direct marketing by opting in again before the expiry of that three (3) year period. In certain circumstances, once we have deleted or anonymised your data, we may need to retain parts of it (for example, your email address), in order to comply with our obligations under GDPR or other legislation, or for fraud detection purposes.
8. Your rights
8.1 You have various rights under Data Protection Law. These include:
8.1.1 The right to ask us not to process your personal data for direct marketing purposes, even if you have given consent;
8.1.2 If our processing is based on your consent, the right to withdraw any consent you may have given for our processing of your data – if you exercise this right, we will be required to stop such processing if consent is the sole lawful ground on which we are processing that data;
8.1.3 The right to ask us for access to the data we hold about you (see section 9 below for further details);
8.1.4 The right to ask us to rectify any data that we hold about you that is inaccurate or incomplete;
8.1.5 The right to ask us to delete your data in certain circumstances;
8.1.6 The right to ask us to restrict our processing of your data in certain circumstances;
8.1.7 The right to object to our processing of your data in certain circumstances;
8.1.8 In certain circumstances, the right to require us to give you the data we hold about you in a structured, commonly used and machine-readable format so that you can provide the data to another data controller.
8.2 You can exercise any of the rights set out above, free of charge, by using any applicable methods set out in our communications with you, or by contacting us at email@example.com. In respect of certain of the rights referred to above, your right may be qualified by the GDPR (which we will discuss with you following your request) or we may need more information from you, which we will ask you for following your request. We may ask you to provide further information in order to confirm your identity. Please also note that if you submit unfounded or excessive (for example repetitive) requests to exercise any of these rights, we reserve the right to make a reasonable charge for providing the requested information or taking the requested action, or to decline your request.
8.3 You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) if you are concerned that we are not respecting your rights under Data Protection Law. The Information Commissioner’s Office is the authority in the UK which is responsible for overseeing the application of, and enforcing, Data Protection Law.
9. Accessing your data
You have the right to obtain from us:
9.1 Confirmation as to whether we are processing (including holding) personal data about you; and
9.2 If we are processing personal data about you, you are entitled to be provided with:
9.2.1 Information as to the purposes for which we process the data;
9.2.2 Information as to the categories of the data that we are processing;
9.2.3 Information as to the recipients or categories of recipients to whom the data has or will be disclosed;
9.2.4 Information as to the envisaged period for which we will store the data, or the basis on which that period will be determined;
9.2.5 A copy of the data (further copies are available at a reasonable charge, which we will inform you of should you request further copies). Please note that this right is subject to the rights of others in relation to their own personal data, meaning that we cannot disclose data to you if it would involve disclosing data about someone else.
9.3 Please see section 8.2 above as to how to exercise your rights under this section 9. Section 8.2 applies in full to the exercise of these rights.
11. Other websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. Changes to this privacy notice