The Compleat Food Group Limited (company number 05515026) is the parent company for a number of subsidiaries including (but not limited to) Addo Food Group Limited and Winterbotham Darby & Co Ltd (together known as The Compleat Food Group and referred to hereinafter as “we”, “us” or “our” in this Privacy Policy). We are committed to the protection and promotion of individuals’ privacy.

This Privacy Policy, and the privacy notices that it contains (together with any other documents referred to in it) tells you about how and why we collect, use and process personal data which you provide to us or which we collect about you. We want you to be fully informed about how we use your data, how we keep it secure and your rights.

Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. The position is different depending on who you are so please read the relevant section to you below – this Privacy Policy explains how we deal with personal data of (i) job applicants, employees, workers and pension scheme members; (ii) consumers; and (iii) our suppliers and our customers.

We may need to update this Privacy Policy from time to time by updating this page. This version of our Privacy Policy was updated on 13 June 2022. We will notify you of any significant changes but would encourage you to come back and review it from time to time.

We trust this Privacy Policy will answer any questions you have, but if not, please get in touch with us using the contact details below:

By email: dataprotection@compleatfood.com

By post: FAO Data Protection
The Compleat Food Group
Granville House
Gatton Park Business Centre
Wells Place
Redhill
Surrey
RH1 3AS

OVERVIEW

ACCESS TO INFORMATION

You have the following rights in relation to the personal information we hold about you as more particularly detailed in the relevant Privacy Notice (subject to exceptions in some cases), to request:-

• access to the personal data that we hold about you including a copy of it;
• the correction of the personal information that we hold about you if it is incomplete or inaccurate;
• the deletion or removal of personal data we hold about you where there is no good reason for us continuing to process it or where you have exercised your right to object to processing;
• for our processing of your personal information to be restricted in certain circumstances, for example if you want to establish its accuracy or the reason for processing it;
  to obtain a copy of the personal information you’ve provided us with and to reuse it elsewhere or to ask us to transfer it to a third party of your choice; and
• to withdraw any consent you have provided to our use of your personal data where we rely on it. Where you withdraw consent, we will stop using your data for the specific purpose unless we have an alternative legal basis to use it.

We may ask you for proof of your identity before dealing with your request, as a security measure to protect your data.

RETENTION OF PERSONAL DATA

We will only keep your personal data for as long as we need to for the reason we collected it, as set out in this Privacy Policy. For example, for as long as needed to allow us to provide our services or to provide any support you have requested – this will typically be for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law.

We may also keep hold of some of your personal data if we are required to do so for legal purposes, for example to meet our legal or regulatory requirements or to prevent fraud and abuse.

SECURITY

We are committed to ensuring that your personal data is secure and we have put in place suitable administrative, technical, physical or managerial measures to protect your personal data from loss, theft, unauthorised use, disclosure or modification.

We also vet the security measures of our third-party suppliers, to ensure that they meet our standards and require our suppliers to protect your personal information by contractual means. Unfortunately, no transfer data over the internet can be 100% secure.

PRIVACY NOTICES

JOB APPLICANTS, EMPLOYEES, WORKERS AND PENSION SCHEME MEMBERS

This notice explains how we handle the personal information of job applicants, employees, former employees, temporary agency workers, dependents, beneficiaries and pension scheme members in the course of our human resources activities. We may amend this notice from time to time, should it become necessary to do so. This notice may be supplemented by other statements as needed to comply with local site requirements or where employees’ representation agreements exist.

INFORMATION WE MAY COLLECT FROM YOU

We may process your personal information for legitimate business purposes to administer our employment or contractual relationship with you and to run our businesses. We may collect, use and transfer your personal information through automated, electronic and/or paper-based data processing systems. We have established routine processing functions (such as processing for regular payroll).

We also process personal information on an occasional ad hoc basis (such as when an employee is being considered for a particular new position or in the context of changes to their marital status, for example).

In the normal course of human resources activities, we can collect the following types of personal information:-

1. Personal identification information, such as your name, home address, date of birth, gender, work-related photographs and home/personal mobile phone number.
2. Government-issued identification numbers, such as your national insurance number for payroll purposes;
3. Immigration, right-to-work and residence status;
4. Family and emergency contact details;
5. Job-related information such as years of service, work location, employment ID, work record, vacation absences and contract data;
6. Educational and training information, such as your educational awards, certificates and licences, vocational records and in-house training attendance;
7. Recruitment and performance related data, such as objectives, ratings, comments, feedback results, career history, work equipment, career and succession planning, skills and competencies and other work-related qualifications;
8. Information relating to your usage of our assets;
9. Information needed for compliance and risk management, such as disciplinary records, background check reports and security data;
10. CCTV footage in operation at our premises; and
11. Payroll and payment or benefits-related information such as salary and insurance information, dependents, government identifier or tax numbers, bank account details and employment related information.

We take reasonable steps to ensure that personal information is accurate, complete and current. Please note that you have a shared responsibility with regard to the accuracy of your personal information. Please notify our HR team (or email us at dataprotection@compleatfood.com if you are not an employee) of any changes to your personal information or that of your beneficiaries or dependents.

USES OF YOUR PERSONAL INFORMATION

We process the above personal information for the following purposes:-

1. Work force planning, recruitment and staffing;
2. Work force administration, payroll, compensation and benefit programs;
3. Performance management, learning and development;
4. Advancement and succession planning;
5. Legal compliance, including compliance with government authority requests for information;
6. Workplace management, such as travel and expenses programs and internal health and safety programs;
7. Internal reporting;
8. Audit;
9. To protect our businesses, our workforce, and the public against injury, theft, legal liability, fraud or abuse;
10. Other legal and customary business-related purposes;
11. Pension scheme calculations and management; and
12. To advise and support in accordance with occupational health needs and fitness to work.

In addition, we may process sensitive personal information if it is needed for legitimate business objectives or if it is required to comply with applicable laws. Sensitive personal information will not be collected, processed or transferred except where adequate privacy protection measures are in place.

DISCLOSURE OF YOUR PERSONAL INFORMATION

You agree that we have the right to share your personal information with:-

1. Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
2. We may disclose your personal information to any prospective seller or buyer of our business.
3. We may disclose your personal information to any third party if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or for the performance of any contract we enter into with them or you, or to protect the rights, property or safety of our group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4. Third parties for employment verification purposes.
5. Third parties when reasonably necessary such as in the event of a life-threatening emergency.

WHERE WE STORE YOUR PERSONAL INFORMATION

Please note that the data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, administration of benefits arrangements, and provision of support services. However, we will not transfer personal data outside of the EEA unless there are appropriate safeguards in accordance with data protection law.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

You have the right to ask us not to process your personal data for the above purposes where such processing is not required by law, necessary for the fulfilment of a contractual obligation or required to meet our legitimate needs as an employer. If you do object, please contact dataprotection@compleatfood.com and we will work with you to find a reasonable accommodation.

ACCESS TO INFORMATION

You may reasonably access and update the personal information pertaining to you that is on our files. You can exercise that right by contacting dataprotection@compleatfood.com.

Please note that your right to access your personal information may have some restrictions. For example, access may be denied (i) in the case of recurrent access requests within a short time interval; or (ii) where providing such access or correction could compromise the privacy of another person or unreasonably expose sensitive company information.

If you believe the information we are holding on you is incorrect, incomplete or out of date, please contact dataprotection@compleatfood.com. We will promptly correct any information found to be incorrect.

CONSUMERS

This notice explains how we handle the personal information of consumers in the course of our consumer engagement, promotional and marketing activities. We may amend this notice from time to time, should it become necessary to do so. This notice may also be supplemented by other statements as needed in relation to standalone competitions, promotions or marketing.

Our website may, from time to time, contain links to and from other websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Please view our own Website T&Cs for more detail in respect of your rights and obligations when accessing our website.

INFORMATION WE MAY COLLECT FROM YOU

In the normal course of interacting with you and our consumer engagement activities, we can collect the following types of personal information:-

1. Information that you provide by filling in forms on our website or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address, email address and phone number.
2. We may also ask you for information when you enter a competition or promotion sponsored by our group and when you report a problem with one of our sites. The information you give us may include your name, address, email address, phone number, personal description and a photograph.
3. If you contact us, we may keep a record of that correspondence including details of any complaint or feedback relating to our products or services.
4. Information we receive from other sources – such as information we receive about you if you use any of the other websites that we operate or other services that we provide.

We may process your personal information for legitimate business purposes to manage our consumer engagement with you, including marketing, competitions and complaints. We may process your personal information for direct marketing purposes with your consent.

We also use Cookies on our website. Please visit our Cookies Policy for more information.

USES OF YOUR PERSONAL INFORMATION

We process the above personal information for the following purposes:-

1. To provide you with the information, products and services that you request from us;
2. To administer competitions and promotions that we run;
3. To allow you to participate in interactive features of our websites, when you choose to do so;
4. To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
5. To provide you, or permit selected third parties to provide you, with information about goods or services that we feel may interest you. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please email dataprotection@compleatfood.com;
6. To notify you about changes to our service to ensure that content from our site is presented in the most efficient manner for you and for your computer;
7. To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
8. As part of our efforts to keep our site safe and secure;
9. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
10. To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

In addition, we may process sensitive personal information if it is needed for legitimate business objectives or if it is required to comply with applicable laws. Sensitive personal information will not be collected, processed or transferred except where adequate privacy protection measures are in place.

DISCLOSURE OF YOUR PERSONAL INFORMATION

You agree that we have the right to share your personal information with:-

1. Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
2. We may disclose your personal information to any prospective seller or buyer of our business.
3. We may disclose your personal information to any third party if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or for the performance of any contract we enter into with them or you, or to protect the rights, property or safety of our group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL INFORMATION

Please note that the data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, administration of benefits arrangements, and provision of support services. However, we will not transfer personal data outside of the EEA unless there are appropriate safeguards in accordance with data protection law.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

We need your consent to use your personal data for direct marketing purposes. Whenever you choose to fill in a form on the website, look for the box that you must tick to indicate that you agree to the information being used for these purposes.

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting dataprotection@compleatfood.com.

ACCESS TO INFORMATION

You may reasonably access and update the personal information pertaining to you that is on our files. You can exercise that right by contacting dataprotection@compleatfood.com.

Please note that your right to access your personal information may have some restrictions. For example, access may be denied (i) in the case of recurrent access requests within a short time interval; or (ii) where providing such access or correction could compromise the privacy of another person or unreasonably expose sensitive company information.

If you believe the information we are holding on you is incorrect, incomplete or out of date, please contact dataprotection@compleatfood.com. We will promptly correct any information found to be incorrect.

SUPPLIERS AND BUSINESS CUSTOMERS

This notice explains how we handle the personal information of suppliers and business customers in the course of our trading activities. We may amend this notice from time to time, should it become necessary to do so. This notice may also be supplemented by other statements as needed to comply with local site requirements.

INFORMATION WE MAY COLLECT FROM YOU

We may process your personal information for the legitimate business purposes of trading with our suppliers and customers, or for administering our contractual relationship with you and for the running of our businesses.

We may collect, use and transfer your personal information throughout automated, electronic and/or paper-based data processing systems. We have established routine processing functions (such as processing for regular payment administration and via our supplier and customer set up processes).

We also process personal information on an occasional or ad hoc basis (such as when a customer or supplier requests a change in details).

In the normal course of our trading activities, we can collect the following types of personal information (this is generally however only where determining a supplier/customer’s ultimate beneficial owner for our set up processes, where a supplier or customer operates as a sole trader or partnership or provides a personal guarantee, or where a supplier or customer visits our premises):-

1. Personal identification information, such as your name, home address, and home/personal mobile phone number;
2. Payment related information, such as your government identifier or tax numbers or bank account details; and
3. CCTV footage in operation at our premises.

We take reasonable steps to ensure that personal information is accurate, complete and current. Please note that you have shared responsibility with regard to the accuracy of your personal information. Please notify your existing central contact at our business in the event of any changes to your personal information or otherwise notify us at dataprotection@compleatfood.com.

USES OF YOUR PERSONAL INFORMATION

We process the above personal information for the following purposes:-

1. To collect information about your business’ qualifications as a potential supplier or customer;
2. To contact or identify you throughout the supplier evaluation process;
3. To allow our businesses to partner and trade with each other; and
4. Other legal and customary business-related purposes.

In addition, we may process sensitive personal information if it is needed for legitimate business objectives or if it is required to comply with applicable laws. Sensitive personal information will not be collected, processed or transferred except where adequate privacy protection measures are in place.

DISCLOSURE OF YOUR PERSONAL INFORMATION

You agree that we have the right to share your personal information with:-

1. Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
2. We may disclose your personal information to any prospective seller or buyer of our business.
3. We may disclose your personal information to any third party if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or for the performance of any contract we enter into with them or you, or to protect the rights, property or safety of our group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4. Third parties for credit verification purposes.

WHERE WE STORE YOUR PERSONAL INFORMATION

Please note that the data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, administration of benefits arrangements, and provision of support services. However, we will not transfer personal data outside of the EEA unless there are appropriate safeguards in accordance with data protection law.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

You have the right to ask us not to process your personal data for the above purposes where such processing is not required by law, necessary for the fulfilment of a contractual obligation or required to meet our legitimate needs as your business partner. If you do object, please contact dataprotection@compleatfood.com and we will work with you to find a reasonable accommodation.

ACCESS TO INFORMATION

You may reasonably access and update the personal information pertaining to you that is on our files. You can exercise that right by contacting your existing central contact at our business or by contacting dataprotection@compleatfood.com.

Please note that your right to access your personal information may have some restrictions. For example, access may be denied (i) in the case of recurrent access requests within a short time interval; or (ii) where providing such access or correction could compromise the privacy of another person or unreasonably expose sensitive company information.

If you believe the information we are holding on you is incorrect, incomplete or out of date, please contact our existing central contact at our business or dataprotection@compleatfood.com. We will promptly correct any information found to be incorrect.

‍