CONTENTS
1. Introduction
2. How We use personal data
3. Sharing your personal data with others
4. International transfers of personal data
5. Retaining and deleting personal data
6. The rights of Data Subjects
7. Cookies
8. Our details
9. Contacting Us concerning the contents of this
Privacy Policy
10. Amendments to this Policy
1. Introduction
1.1 We are
committed to safeguarding the privacy and accuracy of the personal data of Our
website visitors, service users and email recipients.
1.2 This policy
applies where We are acting as a Data Controller with respect to the personal
data of Our website visitors, service users, email recipients and personal data
collected from public sources; in other words, where We determine the purposes
and means of the processing of that personal data.
1.4 In this policy,
“We”, “Us” and “Our” refer to Used Food Machines LtdFor
more information about Us, see Section 12.
1.5 Reference to a Data
Subject means a natural person whose personal data is processed by a Data Controller
or a Data Processor, in other words, You.
2.How We use Your personal data
2.1 In this Section
2 We have set out:
1. The general categories of personal
data that We may process;
2.
in the case of personal data that We
did not obtain directly, the source and specific categories of that data;
3. the purposes for which We may process
personal data; and
4. the legal bases of the processing.
2.1.1 The General Categories Of Personal Data That We May Process
2.1.1.1
Usage Data
We may process data about Your use of Our website and services (“Usage Data“).
The Usage Data may include Your IP address, geographical location, browser type
and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency
and pattern of Your service use. The source of the Usage Data is Google
Analytics as well as Our analytics tracking system. This Usage Data may be
processed for the purposes of analysing the use of the website and services.
The legal basis for this processing is Our legitimate interests, namely
monitoring and improving Our website and services, and tailoring any
communication with You.
2.1.1.2
Account Data
We may process Your Account Data (“Account
Data“). The Account Data may include Your name and
email address. The source of the Account Data is You or Your employer. The
Account Data may be processed for the purposes of providing Our services,
ensuring the security of Our website and services, maintaining back-ups of Our
databases and communicating with You. The legal basis for this processing is
the performance of a contract between You and Us and/or taking steps, at Your
request, to enter into such a contract.
2.1.1.3
Service Data
We may process Your personal data that are provided in the course of the use of
Our services (“Service Data“). The Service Data may include name, email address
and telephone number. The source of the Service Data is You or Your employer.
The Service Data may be processed for the purposes of providing Our services
and communicating with You. The legal basis for this processing is the
performance of a contract between You and Us and/or taking steps, at Your
request, to enter into such a contract.
2.1.1.4
Enquiry Data
We may process information contained in any enquiry You submit to Us regarding
goods and/or services (“Enquiry Data“). The Enquiry Data may be processed for the
purposes of Us offering, marketing and selling relevant goods and/or services
to You. The legal basis for this processing is consent which may be withdrawn
by You at any time by contacting Us.
2.1.1.5
Notification Data
We may process information that You provide to Us for the purpose of
subscribing to Our email notifications and/or newsletters (“Notification Data“). The Notification Data may be processed for the
purposes of sending You the relevant notifications and/or newsletters. The
legal basis for this processing is consent which may be withdrawn by You at any
time by contacting Us.
2.1.1.6
Correspondence Data
We may process information contained in or relating to any communication that
You send to Us (“Correspondence Data“). The Correspondence Data may include Your name,
email address and the communication content and metadata associated with the
communication. Our website will generate the metadata associated with
communications made using the website contact forms. The Correspondence Data
may be processed for the purposes of communicating with You and record-keeping.
The legal basis for this processing is Our legitimate interests, namely the
proper administration of Our website and business and communications with
users.
2.1.1.7
Public Data
We may process information found on public social networking profiles (“Public Data“). This data may include name and job title. Public
Data may be processed for the purposes of offering, marketing and selling
relevant goods and/or services to Your employer. The legal basis for this
processing is Our legitimate interests, namely proper administration of Our business.
2.1.1.8
Legal Claims Data
We may process any of Your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. (“Legal Claims Data”)
The legal basis for this processing is Our legitimate interests, namely the
protection and assertion of Our legal rights, Your legal rights and the legal
rights of others.
2.1.1.9
Professional Use Data
We may process any of Your personal data identified in this policy where
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice. (“Professional Use Data”). The legal basis for processing Legal Claims
Data is Our legitimate interests, namely the proper protection of Our business
against risks.
2.2 In addition to
the specific purposes for which We may process Your personal data set out in
this Section 2, We may also process any of Your personal data where such
processing is necessary for compliance with a legal obligation to which We are
subject, or in order to protect Your vital interests or the vital interests of
another natural person.
2.3 Please do not
supply any other person’s personal data to Us unless We prompt You to do so.
3. Sharing Your personal data with
others
3.1 We may disclose
Your personal data to any member of Our group of companies (this means Our
subsidiaries, Our ultimate holding company and all its subsidiaries) (together
known as “Group Companies”) insofar as reasonably necessary for the purposes,
and on the legal bases, set out in this policy.
3.2 We may disclose
Your personal data to Our insurers and/or professional advisers insofar as
reasonably necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, obtaining professional advice, or the establishment,
exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.
3.3 In addition to
the specific disclosures of personal data set out in this Section 3, We may
disclose Your personal data where such disclosure is necessary for compliance
with a binding legal obligation arising under EU law to which We are subject,
or in order to protect Your vital interests or the vital interests of another
natural person. We may also disclose Your personal data where such disclosure
is necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of Your
personal data
4.3 You acknowledge
that personal data that You submit for publication through Our website or
services may be available, via the internet, around the world. We cannot
prevent the use (or misuse) of such personal data by others.
4.4 This privacy policy
applies only to our Websites not those external Websites that we link to, who
will have their own privacy policies. We are not responsible for these external
Websites and their privacy policies and practices. In addition, if you linked
to our Website from an external site, we cannot be responsible for the privacy
policies and practices of the owners and operators of that external Website and
recommend that you check the privacy policy of that external site.
5. Retaining and deleting personal
data
5.1 This Section 5
sets out Our data retention policies and procedure, which are designed to help
ensure that We comply with Our legal obligations in relation to the retention
and deletion of personal data.
5.2 Personal data
that we process for any purpose or purposes shall not be kept for longer than
is necessary for that purpose or those purposes.
5.3 Notwithstanding
the other provisions of this Section 5, We may retain Your personal data where
such retention is necessary for compliance with a legal obligation to which We
are subject, or in order to protect Your vital interests or the vital interests
of another natural person.
6. Cookies
6.1 By using Our
website and agreeing to this policy, You consent to Our use of cookies in
accordance with the terms of Our Cookie Policy.
7. The Rights of Data Subjects
7.1 In this Section
7, We have summarised the rights that You have under data protection law. Some
of the rights are complex, and not all of the details have been included in Our
summaries. Accordingly, You should read the relevant
laws and guidance from the regulatory authorities for a full explanation of
these rights.
7.2 Your principal
rights under data protection law are:
5. the right to restrict processing
6. the right to object to processing
7. the right to data portability
8. Rights related to automated decision making
including profiling
9. the right to complain to a supervisory authority; and
10. the right to withdraw consent.
7.2.1 The Right to be
Informed
This is the right of Data Subjects to
know details regarding the processing of their data and this information is
included in this Privacy Policy
7.2.2 The Right To Access
You have the right to confirmation as to whether or not We process Your
personal data and, where We do, access to the personal data, together with
certain additional information. That additional information includes details of
the purposes of the processing, the categories of personal data concerned and
the recipients of the personal data. Providing the rights and freedoms of
others are not affected, We will supply to You a copy of Your personal data
upon request and within one month of verification of Your identity (We may
extend the time within which We must provide the information by a further two
months if the request is particularly complex or if there are numerous requests
and We will let You know if this is the case. The first copy will be provided
free of charge, but additional copies may be subject to a reasonable fee.
7.2.3 The Right to Rectification
You have the right to have any inaccurate personal data about You rectified
and, taking into account the purposes of the processing, to have any incomplete
personal data about You completed. If the request is accepted by Us, the
rectification will be completed within one month (may be extended by Us by a
further two months if complex).
We will use all reasonable endeavours to notify any third party with whom we
have shared the data of any rectifications made.
7.2.4 The Right to Erasure (also
known as the “Right to be Forgotten”)
In some circumstances You have the right to the erasure of Your personal data
without undue delay. Those circumstances include:
·
the personal data are no longer
necessary in relation to the purposes for which they were collected or
otherwise processed;
·
You withdraw consent to consent-based
processing;
·
You object to the processing under
certain rules of applicable data protection law and there is no over-riding
legitimate interest for continuing the processing;
·
the processing is for direct
marketing purposes;
·
the personal data has to be erased to
comply with a legal obligation; and
·
the personal data have been
unlawfully processed.
However, there are exclusions of the
right to erasure. The general exclusions include where processing is necessary:
·
For exercising the right of freedom
of expression and information;
·
for compliance with a legal
obligation for the performance of a public interest task or exercise of
official authority;
·
for archiving purposes in the public
interest, scientific research or historical purposes; or
·
for the establishment, exercise or
defence of legal claims.
We will use all reasonable endeavours to notify any third party with whom we
have shared the data of any actioned erasure requests.
7.2.5 The Right to Restrict
Processing
In some circumstances You have the right to restrict the processing of Your
personal data. Those circumstances are:
·
You contest the accuracy of the
personal data (We will restrict processing for a period enabling Us to verify
the accuracy of such data);
·
processing is unlawful but You oppose
erasure;
·
Where You have objected to the
processing (where it was necessary for the performance of a public interest
task or purpose of legitimate interests), and We are considering whether Our
organisation’s legitimate grounds override those of the individual;
·
We no longer need the personal data
for the purposes of Our processing, but You require personal data for the
establishment, exercise or defence of legal claims;
Where processing has been restricted we may continue to store Your personal
data. However, We will only otherwise process it: with
Your consent or for the establishment, exercise or defence of legal claims; for
the protection of the rights of another natural or legal person; or for reasons
of important public interest.
We will use all reasonable endeavours to notify any third party with whom we
have shared the data of any restriction placed on the processing of Your data.
7.2.6 The Right to Object to
Processing
You have the right to object to Our processing of Your personal data on grounds
relating to Your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for:
·
The performance of a task carried out
in the public interest or in the exercise of any official authority vested in
Us (including profiling);
·
the purposes of the legitimate
interests pursued by Us or by a third party;
·
direct marketing (including
profiling); or
·
purposes of scientific/historical
research and statistics
If You make such an objection, we will cease to process the personal
information unless We can demonstrate compelling legitimate grounds for the
processing which override Your interests, rights and freedoms, or the
processing is for the establishment, exercise or defence of legal claims.
7.2.7 The Right to Data Portability
To the extent that the legal basis for Our processing of Your personal
data is:
(a) consent; or
(b) that the
processing is necessary for the performance of a contract to which You are
party or in order to take steps at Your request prior to entering into a
contract and
(c) such processing
is carried out by automated means,
You have the right to receive Your
personal data from Us in a structured, commonly used and machine-readable
format. However, this right does not apply where it would adversely affect the
rights and freedoms of others.
7.2.8 Rights related to automated
decision making including profiling
We do not use automated
decision making (including profiling) when processing your data.
7.2.9 Right to Complain
If You consider that Our processing of Your personal information infringes data
protection laws, You should first contact Us. If
You are dissatisfied with the outcome, You have a
legal right to lodge a complaint with a Supervisory Authority responsible for
data protection. You may do so in the EU member state of Your habitual
residence, Your place of work or the place of the alleged infringement.
7.1.10 Right to Withdraw Consent
To the extent that the legal basis for Our processing of Your personal
information is consent, You have the right to withdraw
that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal. To withdraw Your consent, please contact Our
Us.
7.13
You may exercise any of Your rights in
relation to Your personal data by written notice to Us.
8. Contacting Us concerning the
contents of this Privacy Policy
8.1 If Your query
relates to this Privacy Policy or should you wish to exercise one of Your Data
Protection Rights as a Data Subject, You can contact
Us in the following ways:
By post to Our registered office
By email at: Harry@usedfoodmachines.com
By telephone on: 01277 369814
9. Amendments to this policy
9.1 We may update
this policy from time to time by publishing a new version on Our website.
9.2 You should
check this page occasionally to ensure You are happy with any changes to this
policy.
9.3 We may notify
You of changes to this policy by email.
This policy was last updated on 24
May 2018
Third Party Processors
Our carefully selected partners and service providers may process
personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing
activity on our behalf, such activity may result in the compliant processing of
personal information. Our appointed data processors include:
(i)
Prospect Global Ltd (trading as Sopro) Reg. UK
Co. 09648733. You can contact SoPro and view their
privacy policy here: http://sopro.io. Sopro
are registered with the ICO Reg: Z123456 their Data Protection Officer can be
emailed at: dpo@sopro.io.
