GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

We are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you

provide to us, will be processed by us. Please read the following carefully to understand how

we will use your personal data.

The rules on processing of personal data are set out in the General Data Protection ​Regulation

(the “GDPR”) [Regulation (EU) 2016/679 of the European Parliament and of the Council of 27

April 2016 on the protection of natural persons with regard to the processing of personal ​data

and on the free movement of such data as it forms part of the law of England and Wales,

Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act

of 2018].

Definitions

Data controller - A controller determines the purposes and means of processing personal

data.

Data processor - A processor is responsible for processing personal data on behalf of a

controller.

Data subject – Natural person.

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an

identifiable person who can be directly or indirectly identified in particular by reference to an

identifier (as explained in Article 6 of GDPR). For example name, passport number, home

address or private email address. Online identifiers include IP addresses and cookies.

Processing - means any operation or set of operations which is performed on personal data

or on sets of personal data, whether or not by automated means, such as collection, ​recording,

organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use,

disclosure by transmission, dissemination or otherwise making available, alignment or

combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than

the data subject, controller, processor and persons who, under the direct authority of the

controller or processor, are authorised to process personal data.

Who we are

Food Finders (UK) Ltd is the data controller. This means we decide how your personal data is

processed and for what purposes. Our contact details are: Food Finders (UK) Ltd, Bennett

House, The Dean, Alresford, Hampshire SO24 9BH, email abi@food-finders.co.uk, telephone

07979 336343. For all data matters contact Abigail Spain, on the above number or email

address.

The purpose(s) of processing your personal data

We use your personal data for the following purposes:

• To maintain our own accounts and records;

• To enable us to facilitate contractual obligations;

• To make you aware from time to time of products similar to those you have purchased

or negotiated to purchase in the past;

• If you are an employee of a company, to make you aware of our products from time to

time;

• To undertake credit searches where appropriate;

• Arranging credit insurance.


The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we

process the following categories of your data:

• Personal data which may include your name, address, email address, phone number and

financial information.


Our legal basis for processing your personal data

☐ Processing necessary for the performance • General administration of a Trading

of a contract with the data subject or to take Contract

steps to enter into a contract

☐ Processing necessary for compliance with • HMRC compliance

a legal obligation

☐ Processing necessary for the purposes of • Undertaking searches with credit

the legitimate interests of the data controller agencies and for the purposes of

or a third party, except where such interests arranging credit insurance;

are overridden by the interests or • To maintain our own accounts and

fundamental rights or freedoms of the data records;

subject • To make you aware from time to time

of products similar to those you have

purchased or negotiated to purchase

in the past;

• If you are an employee of a company,

and we have received your contact

details fairly, to make you aware of

our products from time to time.

Sharing your personal data

Your personal data will be treated as strictly confidential, and will only be shared with credit

agencies, credit insurance companies and HMRC from time to time.

How long we keep your personal data

We keep your personal data for no longer than reasonably necessary for the stated purposes

and a period of seven years from the last transaction in order to comply with HMRC

regulations.

To determine the appropriate retention period for personal data, we consider the amount,

nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use

or disclosure of your personal data, the purposes for which we process your personal data

and whether we can achieve those purposes through other means, and the applicable legal

requirements.

Providing us with your personal data

We require your personal data as it is a requirement necessary to enter into a contract.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect

to your personal data:

• The right to request a copy of the personal data which we hold about you;

• The right to request that we correct any personal data if it is found to be inaccurate or

out of date;

• The right to request your personal data is erased where it is no longer necessary to retain

such data;

• The right to withdraw your consent to the processing at any time, where consent was the

lawful basis for processing;

• The right to request that we provide you with your personal data and where possible, to

transmit that data directly to another data controller, (known as the right to data

portability), (where applicable i.e. where the processing is based on consent or is

necessary for the performance of a contract with the data subject and where the data

controller processes the data by automated means);

• The right, where there is a dispute in relation to the accuracy or processing of your

personal data, to request a restriction is placed on further processing;

• The right to object to the processing of personal data, (where applicable i.e. where

processing is based on legitimate interests (or the performance of a task in the public

interest/exercise of official authority); direct marketing and processing for the purposes

of scientific/historical research and statistics).


Automated Decision Making and Transfer of Data Abroad

We do not use any form of automated decision making in our business, or transfer personal

data outside the EEA.

Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy

Notice, then we will provide you with a new notice explaining this new use prior to

commencing the processing and setting out the relevant purposes and processing conditions.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page ​and,

where appropriate, notified to you by email. Please check back frequently to see any updates

or changes to our privacy policy.

How to make a complaint

If you have any concerns about our use of your personal information, you can make a

complaint to Abigail Spain at abi@food-finders.co.uk, telephone 07979 336343. If this does

not resolve your complaint to your satisfaction, you have the right to complain to the

Information Commissioner’s Office (www.ico.org.uk, telephone 0303 123 1113).