Privacy Policy

PRIVACY NOTICE

Princes Limited and its group companies respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. CUSTOMERS AND SUPPLIERS
5. HOW WE USE YOUR PERSONAL DATA
6. DISCLOSURES OF YOUR PERSONAL DATA
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY
9. DATA RETENTION
10. YOUR LEGAL RIGHTS

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how the Princes Group collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children. In the event that there is a special campaign, competition or promotion for children to participate in we shall ensure that any required consents are obtained from a parent or guardian and supplemental privacy notices may be provided setting out very clearly how and why that data is being used.

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. This privacy notice supplements the other notices and is not intended to override them.

Controller

The Princes Group is made up of different legal entities, details of which can be found below. Such legal entities own or licence the various brands of the Princes Group including Princes, Napolina, Cookeen , Crisp n Dry, Mazola, Crosse and Blackwell, Aqua-Pura, Trex, Branston (under licence) Batchelors (under licence), Farrows, Flora (under licence), Hungerbreaks, Jucee, Olivio (under licence), Shippams, Vier Diamanten and Wielkipolski.

This privacy notice is issued on behalf of the Princes Group so when we mention “Princes”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Princes Group responsible for processing your data. Edible Oils Limited is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the following details: dpo@princes.co.uk or write to the Data Protection Officer, Royal Liver Building, Pierhead, Liverpool L3 1NX.

You have the right to make a complaint at any time to the appropriate supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authorities so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 20^th May 2018.

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

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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. 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 follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• 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 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 also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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.

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) unless this is required in order for us to process a customer services complaint or claim that you log. Nor do we collect any information about criminal convictions and offences.

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, if you have won an on-line promotion or competition and we need personal information to provide you with such prize). We will notify you if this is the case at the time.

3. 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 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;
• log a customer services issue;
• enter a competition, promotion or survey; or
• give us some feedback;
• request further information is sent to you;
• when you report a problem with the website.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer.   Cookies contain information that is transferred to your computers hard drive. They help us improve our websites and to deliver a better and more personalised service. They enable us to estimate its audience size and usage pattern, store information about your preferences (where our legitimate interest does not override your rights and freedoms) and to speed up your searches. You may refuse to accept cookies (see below).

• Third parties or publicly available sources. We may receive personal data about you from analytics providers as set out in our cookie policy.
• Data relating to Health. If you log a customer service issue or you make a complaint relating to a product and the information is relevant to the claim.

4. Customers and Suppliers

Whilst the vast majority of data shared between us and our customers and suppliers is business related there may be some personal data exchanged. Such personal data may be provided to us directly from employees, workers and contractors of our customers and suppliers or by the customer or supplier company. We would categorise this data as Reference Data including name, job title, contact details and enables us to manage our contract and relationship with our customers and suppliers. For emergency situations such as in the event of a product safety or integrity issue we may retain out of hours contact details of the employees, workers and contractors of our Customers and Suppliers to ensure that we can respond to any emergency product safety or integrity or other emergency mattes and mitigate any harm.

5. 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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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, 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.

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:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have provided your specific opt-in consent to receive such information.

Refuse to Accept 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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies 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 compatible with the original purpose.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above.

• Internal Third Parties – other companies in the Princes Group acting as joint controllers or processors and who are based in the United Kingdom, Holland, Italy, Poland and France and other applicable European jurisdictions.
• External Third Parties:
  • service providers acting as processors based in the United Kingdom, Holland, Poland and France and other European jurisdictions who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, Holland, Poland and France or other European Jurisdictions who provide consultancy, legal, insurance and accounting services.
  • Tax authorities, regulators and other authorities acting as processors or joint controllers based in the appropriate European jurisdiction who require reporting of processing activities in certain circumstances.
  • PR and marketing consultancy agents acting as processors based in the European Economic Area (particularly UK, Holland, Italy, France or Poland or other European jurisdictions).

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.

7. International transfers

In the event that your personal data is transferred outside the European Economic Area (EEA) (which includes the United Kingdom following Brexit), we ensure that appropriate safeguards are in place so that your personal data is treated with the same level of security.

8. 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. 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.

9. Data retention

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. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact the Data Protection Officer.

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 try to respond to all legitimate requests 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.

Princes Group Entities

Princes Limited based in the UK; Princes Foods B.V. based in the Netherlands with two European branch offices (Princes France based in France and Princes Polska based in Poland); Edible Oils Limited (based in the UK) is joint venture company owned between Princes and Archer Daniels Midland