Specific Privacy Section for Consumers
This is a specific privacy section which supplements our general privacy information notice which can be viewed here. It applies in addition to all the information in our general privacy information notice.
Our Consumers – by this we mean our consumers to whom we send marketing materials by email and social media and other consumers who send in comments, queries and complaints to our customer care department, visitors to our website and social media pages and our Free From taste panel. In all cases we do not collect more information than we need to fulfil our purposes.
What kind of personal data do we hold about our Consumers?
We collect a variety of personal details including your name, contact details (telephone number, home address, email and any computer or social media tags you provide We also hold health information where this is relevant to establishing, progressing or defending any complaint, claim or potential legal claim you send to us. If we want to use this health information for any other purpose we will obtain your consent. We also collect cookies from our visitors to our website. We are active on social media, but we do not collect any personal details from you through our social media channels unless you are made aware of it at the time. In the case of our consumers for our Free From brand we also collect information about their health with their consent as relevant to the products we sell and for us to better target our free from products to them.
How is your personal data collected?
We collect personal information about our consumers directly from them or in the case of contacts to our customer care team, sometimes a relative, retailer or an organisation dealing with your complaint on your behalf. We may do this via electronic means (e.g email or web page contact form), by telephone or by letter. We also collect details from competition entries and at marketing events and in store trials. Cookie and pixel information is collected in accordance with our cookie policy which is available when you visit our site.
How we use the personal data we collect about our consumers?
We will only use your personal data for the purpose we collected it from you. In the case of consumers who contact our customer care team, we do not use your details for any marketing purposes.
The situations in which we will process your personal information are listed below.
Consumers who we market to, who visit our website and social media pages and our Free From taste panel
- To market our products or brand to you
- To deal with your comments, queries or complaints
- To monitor our product performance
- To gain feedback on our products for development purposes
- For reporting purposes
- For internal record keeping
- To process competitions and circulate prizes to winners
Consumers who contact our customer care team
- To deal with your comments, queries or complaints
- To monitor our product performance
- To gain feedback on our products for development purposes
- To gain feedback on our customer care service
- For quality assurance and food safety purposes
- For reporting purposes
- For internal record keeping
- To monitor for fraudulent claims
- To deal with disputes involving you
- To deal with insurance claims
What is our lawful basis for processing this personal data about our consumers?
For all our consumers we will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to comply with a legal obligation (such as food safety and complaint handling matters);
- 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 (such as handling your query or complaint, for food safety purposes or for product quality assurance purposes);
- Where we have obtained your consent (such as when we market directly to you);
- Where we need to perform a contract we have entered into with you (such as if we provide something directly to you).
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest.
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override this. We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who do we share your personal data with?
We may have to share your data with third parties, including third party service providers and other entities in the group.
We will share your personal information with third parties only where we have a lawful basis to do so.
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities in respect of consumers are currently carried out by third-party service providers: marketing agency service providers, competition fulfilment providers, voucher scheme providers, IT system providers, including Customer Relationship Management database providers, telecoms service providers, courier or sample collection services, accident and injury systems and advisers, legal advisers, insurers, other relevant professional advisers. For some complaints or issues, we may also need to pass on your details to regulatory bodies, for example Trading Standards, Environmental Health or the Food Standards Agency.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Changes to this Specific Privacy Section
We reserve the right to update this specific privacy section at any time. This specific privacy section was last updated in May 2018.
