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BakkaVor – PRIVACY NOTICE

  1. Important notice

    This is the Privacy Notice of BAKKAVOR GROUP PLC (company number 10986940) whose registered office is at Fitzroy Place 5th Floor, 8 Mortimer Street, London, W1T 3JJ (“BAKKAVOR”). Bakkavor is part of a group which is made up of a number of legal entities, including Bakkavor Foods Limited, Bakkavor Limited, BV Restaurant Group Limited, Bakkavor Desserts Leicester Limited, Bakkavor Pension Trustees Limited and any other subsidiaries of Bakkavor Plc that may process personal data from time to time (“Group”) so where this Privacy Notice refers to “Bakkavor”, “we”, “us” or “our”, it is referring to the relevant company within the Group. This Privacy Notice sets out how we collect and process your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.

    This Privacy Notice relates to personal information that identifies “you” meaning customers or potential customers, suppliers, shareholders, individuals who browse our website or visit any one of our premises or any other individuals outside our organisation with whom we interact. If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead. This Privacy Notice is not intended for children and we do not knowingly collect personal data relating to children.

    This Privacy Notice may vary from time to time so please check it regularly. This version of this Privacy Notice was first published on April 21, 2020 and has not been updated since.

  2. how to contact us

    This Privacy Notice applies where we are a controller in respect of your personal data – this is where we decide how and why your personal data is processed.

    If you need to contact us in connection with our use or processing of your personal data, to correct your personal data held by us or change any preferences or gain access to it then our contact details are:

    Email: dataprotection@bakkavor.com
    Address: FAO General Counsel and Company Secretary, Bakkavor, Fitzroy Place, 5th Floor, 8 Mortimer Street, London, W1T 3JJ

  3. CATEGORIES OF PERSONAL DATA WE COLLECT

    The categories of personal data about you that we may collect, use, store, share and transfer are:

    • Individual Data. This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier and your contact details such as your email address and telephone numbers;
    • Preference Data. This includes personal data which relates to your preferences, such as information about your preferences in receiving information from us through our Alert Service;
    • Information Technology Data. This includes personal data which relates to your use of our website, such as your traffic data, and other communication data, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access our website;
    • Economic and Financial Data. This includes personal data which relates to your finances, such as your bank account and payment card details and information which we collect from you for the purposes of the prevention of fraud;
    • Sales Data. This includes personal data which relates to the transactions you have conducted with us;
    • Audio and Visual Data. This includes personal data which is gathered using our CCTV or other recording systems in the form of images, video footage and sound recordings that is taken at any of our locations or otherwise by us for promotional purposes;
    • Health Data. This includes personal data which is gathered for health and safety purposes including any accident report or claim log or any information you provide about allergies or other medical conditions during the booking process or in one of our locations;

    We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint, for example about our services or goods, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.

    We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Information Technology Data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

    In addition, we may obtain data concerning health, which is considered a special category of personal data, and this Privacy Notice specifically sets out how we may process this type of personal data.

    We do not collect any information about criminal convictions and offences.

  4. THE SOURCES FROM WHICH WE OBTAIN YOUR PERSONAL DATA
    We obtain your personal data from the following sources:
    • Directly from you, either in person (at our locations or otherwise), via our website or by telephone or other devices. This could include personal data which you provide when you:
      1. buy or sell shares in Bakkavor;
      2. contact us by email or telephone;
      3. subscribe to our Alert Service;
      4. request information on our products or services or for other marketing to be sent to you;
      5. enter into a competition or promotion; and
      6. complete a survey from us or give us feedback.
    • Via automated technologies, such as CCTV or other recording systems, cookies, server logs and other similar technologies. We may automatically collect Information Technology Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Information Technology Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
    • From someone else, such as:
      1. search information providers (such as Google);
      2. providers of technical, payment and delivery services;
      3. providers of social media platforms (such as Facebook, Twitter and Instagram) for example where you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter; and
      4. website providers (such as Q4 Inc).
    • From publicly available sources, such as:
      1. Companies House;
      2. the electoral roll;
      3. HM Land Registry; and
      4. credit reference agencies.
  5. How we use your personal data

    We collect personal data about you in order to:

    1. perform our contractual obligations to you. This would include:
      • processing and performing our obligations towards you;
      • orders placed by us where you are a supplier;
      • making or receiving payments, fees and charges; and
      • collecting and recovering money owed.
    2. manage our relationship with you including:
      • to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);
      • to provide you with important real-time information about products you have ordered from us (e.g. a change of time or location due to unforeseen circumstances); and
      • to send you information you have requested; and
      • to deal with your enquiries;
    3. if you are a shareholder to manage our relationship to you and comply with our obligations;
    4. administer our business and carry out business activities;
    5. make suggestions and recommendations to you about goods that may be of interest to you, deliver relevant website content and alerts to you via our Alert Service and to measure or understand the effectiveness of our communications;
    6. communicate with you about, and administer your participation in, special events, programs, promotions, any prize draws or competitions.
    7. for internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, products, marketing, customer relationships and experiences;
    8. protect our business including to deal with any misuse of our website and to comply with our security policies at our locations;
    9. use your personal data to comply with our own legal and industry obligations e.g. to comply with health and safety requirements, or to assist in a police investigation;
    10. enforce or apply our terms of use, terms and conditions of supply and other agreements with third parties;
    11. to detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies in relation to the same);
    12. finance, restructure, sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers;
    13. use our knowledge of any personal data you disclose to us in the event of illness or injury or some other related emergency or to record any accident or injury or other incident you may suffer when visiting any of our locations; and
    14. investigate and defend any third-party claims or allegations.
  6. our lawful basis for processing your personal data

    Where we may rely on consent

    For certain purposes it may be appropriate for us to obtain your prior consent (such as when you sign up to our Alert Service). The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.

    In the event that we rely on your consent, you may at any time withdraw the specific consent you give to our processing your personal data. Please contact us using the contact details set out in paragraph 1 to do so. Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other lawful bases to process your personal data for other purposes.

    Other legal bases we may rely on

    Where we are relying on a basis other than your consent, the lawful basis for processing personal data will be one of the following:

    1. the processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering legislation or communicating with our shareholders (for example to provide the Annual Report or notify of meetings);
    2. the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
    3. processing is necessary for the establishment, exercise or defence of legal claims; or
    4. the processing is necessary for the pursuit of our legitimate business interests. In particular, our legitimate interests include:
      • the provision of goods and services;
      • facilitate the payment of dividends to our shareholders;
      • the recovery of debt;
      • the provision of administration and / or IT services;
      • the security of our IT network;
      • the prevention of fraud;
      • marketing of goods and services and promotion of our business;
      • the reorganisation or sale or refinancing of the business or a group restructure;
      • the study in how to develop and the update of our products;
      • the development of our business strategy;
      • protecting our business and property; and
    5. the processing is necessary in order to protect the vital interests of an individual e.g. where there is a medical emergency at one of our premises.

      Extra conditions for special category personal data

      Where we are processing your special category personal data one of the following conditions will also apply:

      1. you have given your explicit consent to the processing;
      2. the processing relates to personal data which are manifestly made public by you;
      3. the processing is necessary for the establishment, exercise or defence of legal claims;
      4. the processing is necessary for archiving purposes in the public interest; scientific or historical research purposes or statistical purposes;
      5. the processing is necessary to protect an individual’s vital interests where the individual cannot give consent; or
      6. the processing is necessary for reasons of substantial public interest.
  7. WHO RECEIVES YOUR PERSONAL DATA
    We may disclose your personal data to:
    • our group companies and affiliates or third party data processers who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;
    • our registrar (currently Richard Davies Investor Relations Limited);
    • our website provider (currently Q4 Inc.);
    • HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
    • external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
    • law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
    • third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
    • third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation); and
    • third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with.
  8. Personal data about other people which you provide to us

    If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

    You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

  9. ACCURACY OF YOUR PERSONAL INFORMATION

    It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you.  Please keep us informed if your personal data changes during your relationship with us either by logging onto your account on the website or by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

  10. INTERNATIONAL TRANSFERS OF PERSONAL DATA

    It is possible that personal data we collect from you may be transferred, stored and/or processed outside the European Economic Area. In connection with such transfers we will ensure that:

    1. there are appropriate safeguards in place such as the approved EU model contractual clauses between us and the recipient (as per Article 46 GDPR (or English law equivalent)); or
    2. the transfer is to a country that the European Commission has decided provides an adequate level of protection such as to a country approved by the European Commission or to certain organisations with the US pursuant to the Privacy Shield (as per Article 45 GDPR (or English law equivalent)); or
    3. one of the derogations for specific situations in the first sub-paragraph of Article 49(1) GDPR (or English law equivalent) applies to the transfer including explicit consent or necessary for the performance of a contract or exercise or defence of legal claims.
  11. How long we will STORE your personal data for

    We will store your personal data for the time period which is appropriate in accordance with the following criteria:

    1. the on-going business operation / relationship that we have with you;
    2. the completion of the purpose for which the personal data was given;
    3. our legal obligations in relation to that personal data and other legal requirements;
    4. the type and size of the data held and whether any if it is deemed to be special category personal data; or
    5. our accounting requirements in relation to that personal data.

      We keep the length of time that we hold your personal data for under review. These reviews take place annually.

  12. contractual or statutory requirements on you to provide personal data

    In certain circumstances the provision of personal data by you is a requirement to comply with the law or a contract, or necessary to enter into a contract.

    It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of failing to provide your personal data means we may not be able to perform to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so.

  13. YOUR RIGHTS in relation to your personal data

    Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see paragraph 6), you may have a number of rights in connection with the processing of your personal data, including:

    • the right to request access to your personal data that we process or control;
    • the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
    • the right to request, on legitimate grounds as specified in law:
      1. erasure of your personal data that we process or control; or
      2. restriction of processing of your personal data that we process or control;
    • the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
    • the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
    • the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.

    If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.

  14. technical and security measures

    We take the security your personal data seriously and have technical and organisational measures to ensure a level of security appropriate to the risk.

    We use a mixture of measures including utilising technology to combat cybersecurity, data management techniques, user access and management procedures, physical security and guidelines for personnel.

    Our measures are aimed at having the ability to:

    • ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; and
    • restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
  15. links to other websites

    This policy only applies to us. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third party websites.