Privacy Notice Updated Dec 2020 1.INTRODUCTION Direct Produce Supplies Limited is committed to safeguarding the privacy of personal and sensitive personal data and is bound to comply with the UK Data Protection Act 1998 and EU General Data Protection Regulation (GDPR), along with similar and applicable laws in other countries around the world. This Privacy Notice forms part of Direct Produce Supplies Limited’s obligation to be open and fair with all individuals whose personal and sensitive personal data Direct Produce Supplies Limited processes and to provide details around how it processes such personal data and what it does with it. Direct Produce Supplies Limited processes the personal data of its customers such as names, contact details and email addresses, amongst other things. Processing of this data implies collecting, storing, using, disclosing or disposing of individuals’ personal data. Existing or prospective customers who leverage Direct Produce Supplies Limited’s product and services, or use Direct Produce Supplies Limited website, may be provided with further privacy notices which may be contained in a separate supplemental notice. These additional privacy notices shall supplement this Privacy Notice. This Privacy Notice relates to the processing of personal data by Direct Produce Supplies Limited. Unless otherwise stated, all references to “we” or “our” shall imply Direct Produce Supplies Limited (“DPS”) that processes personal or sensitive personal data. None of the lists, or examples provided in this Privacy Notice, are intended to be exhaustive or fully representative of every individual. 2. SCOPE The scope of this Privacy Notice covers customers (e.g. Supermarkets, wholesalers) and suppliers (e.g. Producers, Growers, Farms) both existing and prospective, personal data in respect of the following: – Collecting Personal Data Using Personal Data Disclosing Personal Data Retaining Personal Data Securing Personal Data International Data Transfers Subject Access Requests Updates / Amendments Third Party Websites Direct Produce Supplies Limited Website – Use of Cookies Opt-in / Opt-out Our Details Complaints 3. COLLECTING PERSONAL DATA We may collect and store the following kinds of personal data: – Information about your computer and about your visits to Direct Produce Supplies Limited website, including your IP address, geographical location, browser type and version. Information that you provide to us for the purpose of subscribing to our marketing communications. Information that you provide to us when using any of our products or services (Customers example Email addresses, Home address, Contact Number, Sales invoices etc, Suppliers example contact details, statutory certificates, purchase orders etc) or that is generated during the course of using those solutions and services. Information that you post on our social media platforms. Information contained in, or relating to, any communication that you send to us through our website, email or in writing. Information related to the security and access of our premises, systems and applications. Information to help us comply with our legal and regulatory obligations, including reporting to and being audited by regulators and external auditors. Information to help us comply with court orders and to exercise and defend our legal rights. Any other personal information that may be sent to us and which we use for legitimate business purposes. Before you disclose to us the personal data of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal data in accordance with this Privacy Notice. 4. USING PERSONAL DATA We may use your personal information to: Administer, personalise and secure our website. Enable your use of any product or service that we may provide through our website. Supply you with our product and services. Send invoices and payment reminders to you or collect payments from you. Send you marketing communications. Deal with enquiries and complaints. Ensure appropriate access to premises, systems and applications. Comply with our legal and regulatory obligations. 5. DISCLOSING PERSONAL DATA We only disclose your personal data in the ways set out in this Privacy Notice or subject to any agreements in place between us. The following circumstances may apply: Across our different lines of business, as part of a need to know or as part of improving our existing products and services or as part of providing new solutions and services. To third parties who process personal data on our behalf, such as systems providers. To third parties who process personal data on their own behalf but provide us, or you, with a service on behalf of us. To third parties with whom information is shared for fraud and crime prevention purposes, such as law enforcement agencies. To any prospective buyer in the event we sell any part of our business, or its assets, or if substantially all of our assets are acquired by a third party. To any regulator, external auditor or applicable body or court where we are required to do so by law or regulation or as part of any investigation. To any central or local government department and other statutory or public bodies, such as the HMRC, Food Standards Agency. We do not sell, rent or trade any of your personal data. We will not, without your consent, disclose or supply your personal data to any third party for the purpose of their or any other third party’s direct marketing. 6. RETAINING PERSONAL DATA Personal data that we process, for any purpose or purposes, shall not be kept for longer than is necessary. Direct Produce Supplies Limited bases its record retention on any legal, regulatory or contractual obligations. You have the right to request we erase your data, where we do not have any overriding legal, regulatory or contractual obligations for continued retention of such data. 7. SECURING PERSONAL DATA Where Direct Produce Supplies Limited acts as the controller of personal data, it will ensure that all necessary and adequate safeguards are in place to prevent unauthorised access, loss, misuse or alteration of your personal data. We store all personal information on secure servers with relevant access and firewall controls. Any personal data sent to us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery. Passwords must be kept confidential and not disclosed to a third party. Direct Produce Supplies Limited does not ask you for your password. 8. INTERNATIONAL DATA TRANSFERS Personal data that we collect, is stored in the UK and not outside the European Economic Area. Should we need to transfer personal outside of the UK or European Economic Area in the future, such personal data will be covered by binding corporate rules or contractual arrangements to ensure it is processed appropriately. When data is processed (or will be processed) outside of the UK or European Economic Area, we will notify you. 9. SUBJECT ACCESS REQUESTS You may instruct us to provide you with any personal data we hold about you as part of a Subject Access Request. The provision of such information will be subject to: – The payment of a £10 fee up to the 24th of May 2018 and no fee from the 25th May 2018 and onwards; and Appropriate evidence of your identity, such as a passport, driving licence as well as a recent bank statement or utility bill. In certain instances, where exemptions exist, we may withhold personal data that you request, and which are permissible by law. You have the right to rectification and may wish to contact us if the personal data that we hold about you needs to be corrected or updated. You have the right to object to us processing your data, and the right to request we restrict the processing of your data. We do not perform any auto-profiling of individuals. 10. UPDATES / AMENDMENTS In order to remain compliant with any legal and regulatory obligations, or as part of our evolving business practices, we may update this Privacy Notice from time to time by publishing a new version. In certain instances, we may notify you. 11. THIRD PARTY WEBSITES We are not responsible for the practices employed by Third Party Websites linked to or from our Website nor the information or content contained therein. Often links to other websites are provided solely as reference points to information on topics that may be useful to the users of our Website. Please remember that when you use a link to go from our Website to a Third-Party Website, our Privacy Notice will no longer apply. Your browsing and interaction on any other Website, including Third Party Websites, which have a link on our Website, are subject to that Website’s own Privacy Notice. 12. DIRECT PRODUCE SUPPLIES LIMITED WEBSITE – USE OF COOKIES Direct Produce Supplies Limited records the number of visitors to the relevant sections of our Website and tracks movement between the sections by means of ‘cookies’. Cookies are small data/text files containing anonymous information placed on your computer and are automatically downloaded to a user’s hard drive in order to recognise a user that has visited our Website previously. Direct Produce Supplies Limited reserves the right to use cookies in order to analyse trends and to improve the design and layout of its Website. You cannot be identified as an individual from this type of information. 13. OPT IN / OPT OUT You have the right, at any time, to ask us not to process your personal data for marketing purposes. You can opt-out of receiving email communications simply by clicking the unsubscribe link, which is contained within marketing emails. You may instruct us at any time not to process your personal data for marketing and communications purposes by means of ‘opting-out’. Please note it can take up to 30 days for a request to be fulfilled because of pre-planned or ongoing marketing activity. 14. DATA PROTECTION REGISTRATION We are registered as a data controller with the UK Information Commissioner’s Office and our data protection registration number is ZA352023. 15. OUR DETAILS Direct Produce Supplies Limited is registered in England and Wales under company number 1336601. Its trading office is at 57 Church Road, Wimbledon, SW19 5SB, UK You can contact us as follows: – Email: enquiries@dpsltd.com Web: www.dpsltd.com Telephone: +44 (0)20 7350 4600 In Writing: Data Protection Manager 57 Church Road, Wimbledon, SW19 5SB United Kingdom. 16. COMPLAINTS If you feel your rights have not been respected, or do not feel a situation was resolved satisfactorily, you have the right to raise a complaint with the UK Information Commissioner. You can contact them as follows: – Web: https://ico.org.uk/concerns/ Telephone: +44 (0)303 123 1113 In Writing: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF © 2021 dps ltd Privacy NoticeModern Slavery Statement Tel: 020 7350 4600