This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
This website is not intended for children and we do not knowingly collect data relating to children.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you, why and for how long
The law requires us to determine under which defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
Marketing: from time to time we will contact you with information regarding promotions, recipes and new products via e-communications. You will have the choice to opt in or opt out of receiving such communications by indicating your choice at the checkout stage. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
WHAT DATA DO WE COLLECT
Identity Data includes first name, last name, username or similar identifier, title.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
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 username and password, purchases or orders made by you, 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. You can choose to opt out of any email marketing by clicking on the unsubscribe box online.
INFORMATION WE PROCESS
a. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
b. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage business risk
b. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
WHEN DO WE COLLECT YOUR PERSONAL DATA
- When you visit our website, and use your account to buy products and services, or redeem vouchers or coupons on the phone or online.
- When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
- When you create an account with us.
- When you purchase a product by phone but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask one of our Partners to email you information about a product or service.
- When you enter prize draws or competitions.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.
- When you fill in any forms online.
- When you’ve given a third party permission to share with us the information they hold about you.
We will only keep your personal data for as long as you have your account, or as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
In some circumstances we may anonymise your personal data (so that you cannot be identified) in which case we may use this information indefinitely without further notice to you for research or statistical purposes.
If you leave a comment on the website, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
SECURING YOUR DATA
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
Furthermore, we secure access to all transactional areas of our websites using ‘https’ technology.
Information relating to your method of payment
We take the following measures to protect your payment information:
- We keep your payment information encrypted on our servers using SSL technology so that they can be securely transferred over the Internet.
- If you are ordering via the telephone your payment information is entered directly to our payment gateway and is not stored on paper or internally.
- We do not keep all your payment information so as:
- to prevent the possibility of our duplicating a transaction without a new instruction from you;
- to prevent any other third party from carrying out a transaction without your consent
- Payment information is never taken by us or transferred to us through our website. Our employees and contractors never have access to it.
- At the point of payment, you are transferred to a secure page on the website of SagePay or PayPal. That page may be branded to look like a page on our website, but it is not controlled by us.
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
INTERNATIONAL DATA TRANSFER
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America.
We will ensure that all such transfers take place in accordance with the applicable data protection laws, including by entering into data transfer agreements with recipients where necessary.
YOUR DATA PROTECTION RIGHTS
Under certain circumstances, by law you have the right to:
Request access – to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of some or all of the personal data we hold about you and to check that we are processing it lawfully.
Object to processing – You have the right to object to the processing of your personal information.
Request Correction – If the personal information we hold about you is incorrect or inaccurate you can ask us to correct it.
Request erasure – of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below) or where we may have processed your information unlawfully. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request restriction of processing – You have a right to ask us to restrict how we use your personal information.
Withdraw consent anytime – where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please at firstname.lastname@example.org
CHOICE/ OPT OUT
You may “opt out” of receiving Fresh Network’s email updates or newsletters by clicking the ‘unsubscribe’ button found at the bottom of each email. The choice to opt out of such communications is also generally available during the sign-up process. Fresh Network will still contact you when there are changes to the Terms of Service, as applicable.
In addition, we will still send you service-related emails such as order confirmation, refund and delivery information, including, but not limited to, a registration email and emails automatically triggered by actions you took on the Site relating to an order. Generally, you may not opt-out of these communications, which are not promotional in nature. If you wish not to receive them, you have the option of deactivating your account.
HOW CAN YOU COMPLAIN
DISCLOSURES OF YOUR INFORMATION
We do not sell any of your personal data to any third party – including your name, address, email address or credit card information.
However, we may have to share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this statement:
Service providers (acting as processors) based in the United Kingdom who provide IT and system administration services;
Delivery partners (who may be acting as joint processors or controllers) based in the United Kingdom who provide delivery services;
Professional advisers (who may be acting as processors or joint controllers) including lawyers, bankers, accountants and insurers based the United Kingdom who provide legal, banking, accounting, insurance or other consultancy services;
HM Revenue & Customs, regulators, courts and other authorities (who may be acting as processors or joint controllers) based in the United Kingdom;
Social media: You may be able to access third party social media services through our website before coming to our website.
Email Software companies
Royal Mail and any printers (to print postal marketing messages)
Conversant (for marketing and advertising purposes)
Facebook, Twitter and Instagram (for marketing and advertising purposes)
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in our site
- to record your answers to surveys and questionnaires on our site while you complete them
- to record the conversation thread during a live chat with our support team
- To estimate our audience size and usage pattern.
a. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
b. Our use of re-marketing and Google Analytics
We use Remarketing with Google Analytics to advertise online.
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
When you are using the Fresh Network website, Fresh Network is the data controller.
COMPLIANCE WITH THE LAW
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website.