FRESCA GROUP EXTERNAL PRIVACY NOTICE Fresca Group Limited and its subsidiary trading entities are committed to protecting and respecting your privacy. Scope This notice sets out the basis on which any personal data we collect from you (the Data Subject) in the course of business, or that you provide to us through our websites, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of data protection legislation, the Data Controller is Fresca Group Limited of The Fresh Produce Centre, Transfesa Road, Paddock Wood, Kent, TN12 6UT, UK. What information do we collect about you? We may collect and process the following data about you and store it for the amount of time set out below: Type of information Where collected? How long will it be stored for? Name Company name Email address Address Telephone On registration at a Fresca Group site Where you contact us directly At Industry events and exhibitions Via our web capture forms on our websites During the course of closing a sale Details of your visits to our websites including, but not limited to, traffic data, location data and other communication data and the resources that you access. We collect information about your computer, including your IP address, operating system and browser type. We use cookies on our websites in order to optimise functionality. For customers & suppliers – for as long as you have an account with us You may receive marketing communications on an opt-out basis from us. We will retain your details for a period of 2 years following no opens/interactions with us. Where you contact us directly with a complaint, enquiry or request, we will retain that information in line with our legitimate interests. CV Application form When applying for a position on one of our company websites, in hard copy or via email and submitting contact details and accompanying CV or application For candidates – our retention period is 1 year from the date of your application. What do we use this information for? Type of data Purpose for processing Legal basis for processing Submitted Information When you apply for a position using one of our company websites Legitimate Interest – to allow us to process your information and provide you with updates on your application Submitted Information To provide you with information that you request from us Legitimate Interest – to provide you with information about us Submitted Information To provide you with products and services that you request from us Necessary for the performance of a contract (otherwise we could not provide the services to you) Submitted Information To provide you with information about goods or services we feel may interest you and (where appropriate) to alter the information that we provide based upon your preferences Legitimate Interest – to keep you up to date with goods and services that we provide and to generate new business Submitted Information To notify you about changes to our services or website Necessary for the performance of a contract (otherwise we could not notify you of changes) Submitted Information To check how content is presented and change it if necessary. Legitimate Interests of us and you to improve our website and ensure that content from our website is presented in the most effective manner for you and for your device. Submitted Information To allow you to participate in interactive features of our Service, when you choose to do so. Legitimate Interest of allowing you to better navigate our services and to tailor the services to you Cookies We use cookies to distinguish you from other users when you visit one of our websites. This helps us to provide you with a good experience when you use the site and also allows us to improve its performance. We may use cookies for the following purposes: Category 1: Strictly Necessary Cookies These cookies are essential in order for you to use the website. They help us to provide services you have specifically asked for. Category 2: Performance Cookies These cookies collect information about how visitors use a website, for instance which pages visitors go to most often. These cookies don’t collect information that identifies a visitor. The data collected is aggregated and therefore anonymous. It is only used to improve how a website works. Fresca Group use these cookies with services such as Google Web Analytics to enable us to improve user experience and navigation. Category 3: Functionality Cookies These cookies allow the website to remember choices you make (such as your user name or language) in order to improve the user experience. These cookies are used on our website for log-in and subscriber services functionality. Category 4: Marketing Cookies Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. Category 5: Statistics Cookies These cookies help us to understand how you interact with our websites by collecting and reporting information anonymously. You may block cookies by adjusting setting on your browser. Please note that if you restrict all cookies (including essential cookies) you may not be able to access all or parts of our site. Unless you have configured your browser to refuse cookies, our system will issue cookies as soon you visit our websites. Your first visit to any of our sites will generate a pop-up header alerting you to this Privacy Notice and will re-appear only in the event that new cookies are published or your cookie settings are changed. More information about cookies can be found at www.aboutcookies.org IP addresses We may use IP addresses to help diagnose problems, to administer our website, and to gather demographic information. We may also use IP addresses to determine which pages on our sites are being visited and topics that may be of interest so we can provide you with information about relevant products and services. Generally, Fresca Group will aggregate such data and profile on a legitimate interest basis. When you visit our sites, we may recognise your domain name and collect your IP addresses (and other technical information such as browser type). Use of Google Analytics Our websites may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users browse the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the website. Additionally you can use this plugin: http://tools.google.com/dlpage/gaoptout?hl=en. Google has developed the Google Analytics Opt-out Browser Add-on. It offers website visitors more choice on how their data is collected by Google Analytics. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. Links to other sites Our websites may contain links to other sites. Fresca Group is not responsible for the privacy practices or the content of other websites outside the Fresca Group of companies. Third party links Our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the site or the services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services. Disclosure of your information We may collect and possibly share personal data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the terms of use of companies within Fresca Group, or as otherwise required by law. We may respond to subpoenas, court orders, or legal process by disclosing your personal data and other related information, if necessary. We also may choose to establish or exercise our legal rights or defend against legal claims. We may also disclose the data we collect from you to the following third parties: Category of data Recipient Purpose Personal Data Companies in the Fresca Group In connection with processing your enquiries and orders, to help improve our products and services and for processing and storage. You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, as defined in Section 1159 of the Companies Act 2006. In the event that we sell or buy any business or assets we may disclose your personal data to the prospective seller or buyer of such business or assets if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. We may also disclose your personal data in order to enforce or apply agreements, to investigate potential breaches; to protect our rights, our property or the safety of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Security of your personal data All businesses within the Fresca Group are committed to protecting the personal data you share with us and which we collect from you by your use of our websites. Fresca Group uses a combination of industry-standard security technologies, procedures, and organisational measures to help protect your personal data from unauthorised access, use or disclosure. Fresca Group supports online security using secure server technology because we want your data to be safe. There are state-of-the-art security arrangements and facilities on Fresca Group sites to prevent abuse. We require all of our employees to observe your privacy and confidentiality rights. Where we store your personal data All personal information you provide to us in the course of business is stored securely Submitting data over the internet Although we will do our best to protect your personal data, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our websites; any transmission of data is made at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Certain services may include social networking features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. Your rights Processing of your personal data is based on legitimate interest, where you can ask us to refrain from processing your personal data if you wish. You have the following rights. You can exercise these rights at any time by contacting us at The Fresh Produce Centre, Paddock Wood, Kent, TN12 6UT or by email to dpo@frescagroup.co.uk. You have the right: To ask us not to process your personal data for marketing purposes; To ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing; To ask us not to process your personal data for scientific or historical research purposes, where relevant, unless the processing is necessary in the public interest; To request from us access to personal information held about you; To ask for the information we hold about you to be rectified if it is inaccurate or incomplete; To ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate grounds for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation or the data is children’s data and was collected in relation to an offer of information society services; To ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing); To ask us not to use your data for profiling (in order to tailor the services and information that we provide to you) To ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract. To ask for data portability if the processing is carried out by automated means and the legal basis for processing is legitimate interest. In the event that you are unhappy with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO) in the UK, at any time. The ICO’s contact details are available here: https://ico.org.uk/concerns/ Changes to Privacy Notice Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you when you next start to use the website so that you are always aware of the way we collect, use and disclose information. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the website or the services. Contact Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to The Data Protection Officer, The Fresh Produce Centre, Transfesa Road, Paddock Wood, Kent, TN12 6UT, UK or sent by email to: dpo@frescagroup.co.uk.