Privacy Policy Effective July 20, 2020 INTRODUCTION Thank you for visiting this website Tate & Lyle Sugars (Site), which is owned and provided by T&L Sugars Limited. T&L Sugars Limited and its related, affiliated, or subsidiary companies are together Tate & Lyle Sugars. All references to “we”, “us”, and “our” in this privacy policy (Privacy Policy) are deemed to refer to Tate & Lyle Sugars. “Personal Data” means any information relating to an identified or identifiable individual. Tate & Lyle Sugars recognises that many people are concerned about the Personal Data they provide on-line or offline and how such information is maintained and used. To address these concerns and to demonstrate Tate & Lyle Sugars’ commitment to privacy, we have developed and implemented this Privacy Policy. Any Personal Data you provide to us will be treated in accordance with this Privacy Policy. Please read this Privacy Policy, together with any other privacy policy we may provide on specific occasions, to understand our views and practices before you provide us with any Personal Data. By using our Site or otherwise providing us with Personal Data, you agree to accept the practices described in this Privacy Policy (as amended from time to time). If you do not agree with these practices, please do not provide us with your Personal Data or use our Site. This Privacy Policy supplements other notices, such as terms and conditions of use of the Site, and is not intended to override them. CHANGES TO THE PRIVACY POLICY From time to time, we may make changes to our Privacy Policy. If we do make changes, the changes will be posted on this page, and we will indicate at the top of this Privacy Policy when the changes went into effect. We encourage you to come back to our Site and review this Privacy Policy frequently so that you are constantly aware of our most current privacy practices. In the event we want to materially change how we use Personal Data which you have previously provided to us, we will notify you by email or by way of a notice on the Site and may give you a choice to consent to or opt out from the desired change. Your inaction or continued use of our Site after any such notification, or your explicit consent to any changes for which we require your prior approval, will signify your agreement with these changes. DATA CONTROLLER For the purpose of the UK Data Protection Act 2018 (Act), Tate & Lyle Sugars is the controller and is responsible for your Personal Data. This means that we determine the purpose and means of the processing of your Personal Data. You will find our contact details at the end of this Privacy Policy (see below: “Get In Touch”). INFORMATION COLLECTION AND USE Information Collection Tate & Lyle Sugars may collect various types of information from you. The types of information we collect will vary depending on how you interact with us (e.g. online via our Site, online via a social media platform, offline). The information we collect may include the following: “Personal Contact Information” such as your, name, address, email address and phone number; “Demographic Information”, being any information that describes your demographic or behavioural characteristics, such as your gender, age, birthdate, product preferences, hobbies and interests, and other related information; “Login Information” is any information that you create or set up when registering for an account through our Site or other forum. This may include, for example, username, password and/or security question and answer; “Technical Data” is information including your browser type and version, time zone setting and location, browser plug-in types and versions and operating system and platform. “Usage Information” may be collected as you navigate and interact with our Site, or when you interact with correspondence that we send you, and is information about your usage actions e.g. the links you click on, which pages or content you view. This information is captured using automated technologies such as cookies and web beacons. For further information on cookies and web beacons, see the “Web Beacons and Cookies” section below. “Marketing and Communications Data” includes your preferences in receiving marketing from us, your communication preferences and any information that you voluntarily share with us about your experience using our products. “Consumer-Generated Content” is any content that you create and then share with us via our Site, third party social networks or any other means and may include, for example, photos, videos and personal stories. “Social Media Profile Information” means any information that you allow social media sites to share with third parties and profile information that we may receive when you interact with us on social media. Please note that if you are providing any Personal Data to us via a social media platform, we suggest that you also familiarise yourself with the privacy information of that platform. We may also collect, use and share “Aggregated Data”, such as statistical or demographic data for any purpose. While Aggregated Data could be derived from your Personal Data, it is not considered personal data in law as this data will not directly or indirectly reveal your identity. However if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as Personal Data, which will be used in accordance with this Privacy Policy. We do not collect any special categories (as provided for in the General Data Protection Regulation) of Personal Data about you. How We Collect Personal Data We use different methods to collect Personal Data from and about you including through: Direct interactions: You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email, social media, our website or otherwise. This includes (without limitation) the Personal Data you provide when you: Agree to marketing communications being sent to you; Enter a competition, promotion or survey; Give us feedback or contact us; or Interacting with us on our Site or through social media platforms. Automated technologies or interactions: As you interact with our Site, read our emails or otherwise interact with us through a computer or mobile device, we may automatically collect technical data about your equipment, browsing actions and patterns. This information may include details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, your IP address, operating system, browser type, dates and times you access the Site, any keywords you may have used in a search engine to find the Site and the internet address of the website which brought you directly to the Site. We collect this personal data by using cookies. Please see the “Web Beacons and Cookies” section below. If You Choose Not To Provide Personal Data To Us If you wish to participate in any of the services and opportunities our Site may offer, in Tate & Lyle Sugars’ promotional activities (including promotions, competitions and surveys) or if you wish to give us feedback or contact us, we may ask you to provide certain Personal Data. If you fail to provide us with your Personal Data, we may not be able to provide the services. How We Use Your Personal Data We will only use your Personal Data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where you have given clear consent for us to process your personal data for a specific purpose; Where it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests; Where is it is necessary to comply with our contractual obligations; or Where we need to comply with a legal obligation. We have set out below, in a table format, a description of purposes for which we may process your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Purpose/Activity Lawful basis for processing including basis of legitimate interest To manage our relationship with you, which may include: Notifying you about changes to our terms or privacy policy; Responding to inquiries, complaints and suggestions. Where we need to comply with a legal obligation; and Necessary for our legitimate interests (to handle, adequately and in a timely manner, customer inquiries, complaints and suggestions. To enable you to partake in a prize draw, competition or complete a survey. You have consented to our use of your personal data for the purpose of a prize draw, competition or survey; Performance of a contract (in accordance with our promotion terms and conditions, to allow us to send you prize draw or competition winnings); and Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business). To engage with you on third party social networks. Necessary for our legitimate business interests (to develop our products and grow our business). To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Necessary for our legitimate business interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and Necessary to comply with a legal obligation To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. You have consented to the receipt of marketing material (via an opt-in option); and Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy). To use data analytics and data aggregation across our Site and other social media platforms to improve our Site and social media platforms, products, marketing, customer relationships and experiences. Necessary for our legitimate interests (to define types of customers for our products, to keep our website and social media platforms updated and relevant, to develop our business and to inform our marketing strategy). To make suggestions to you about goods or services that may be of interest to you Necessary for our legitimate interests (to develop our products and grow our business). To comply with our legal obligations in connection with any potential or actual corporate transaction, including in the event of a merger or acquisition of all or part of Tate & Lyle Sugars or our parent company by a third party. Necessary to comply with a legal obligation. To comply with our legal obligations in connection with a corporate reorganisation, insolvency proceeding or other similar event. Necessary to comply with a legal obligation. To comply with our legal or regulatory obligations, including responding to any legal claims, enforcing or applying our Terms and Conditions or protecting the safety or rights of Tate & Lyle Sugars, our consumers, or the public. Necessary to comply with a legal obligation. Where we rely on consent as a lawful basis to process your personal data, you have the right to withdraw your consent at any time. To do this, please telephone, email or write to us (see below: “Get in Touch”). Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law. Information Sharing We may transfer or disclose Personal Data to our processors, for example companies, agents, or contractors (each a Vendor) that assist Tate & Lyle Sugars with processing activities. Such sharing is consistent with our legitimate business interests. These Vendors are only given access to the information they need in order to perform the specific tasks they are contracted to do and are prohibited from using your Personal Data for any other purpose. Tate & Lyle Sugars may share non-identifiable Aggregated Data about the Site and its users with advertisers, business partners, sponsors, and other third parties in an effort to customise or enhance the content and advertising on our Site for our users. Information Retention We will retain your Personal Data for as long as is necessary for the purposes for which such personal information was originally collected. Once this purpose has come to any end, we may retain your personal information for a period of time that enables us to: maintain business records for analysis and/or audit purposes; comply with record retention requirements under law; defend or bring any existing or potential legal claims; and deal with any complaints. We will delete your Personal Data when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data. CHILDREN AND PRIVACY Our Site is not intended for children and we do not knowingly collect data relating to children. MARKETING COMMUNICATIONS You can opt-in to receive marketing materials via our Site. You may also opt in to receive Tate & Lyle Sugars marketing materials via other means as well. If you do not opt-in, we will not share these materials with you. If you change your mind, and wish to no longer receive marketing materials please contact us using the details in the “Get in Touch” section at the end of this policy. From time to time, we are approached by reputable third party companies and organisations that provide products or services that we believe may be of interest to you. As a result, if you have opted in to receive Tate & Lyle Sugars’ marketing materials, these third party materials may be delivered to you together with some of our own materials. We see this as a value-added service helping you find special offers on products and services that may be of interest to you. Please remember that the materials we send you in connection with this particular service come directly from Tate & Lyle Sugars and, therefore, do not require us to share your personal information with third party companies. We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business. WEB BEACONS AND COOKIES We may use web beacons or other similar technology (Beacons) on our Site or include them in an email message we send you. Beacons are small strings of code that provide a method of delivering a graphic image on a web page or in an email message for the purpose of transferring data back to us. The information collected via Beacons may include information about how a user responds to an email campaign from Tate & Lyle Sugars (for example, the time the email is opened, where does the user link to from the email etc). We use Beacon information for a variety of purposes, including but not limited to, Site traffic reporting, unique visitor counts, advertising and email auditing and reporting, and personalisation. Tate & Lyle Sugars may also use “cookie” technology on our Site. A “cookie” is a non-executable element of data that a website stores on your browser or your computer's hard drive. These cookies help us to provide you with a good experience when you browse the Site and also allow us to improve the Site. The “cookie” does not extract personal information about you. Most browsers provide a simple procedure that will enable you to control whether you want to receive cookies by notifying you when a website is about to deposit a cookie. We use the following cookies: Strictly necessary cookies. These are cookies that are required for the operation of the Site. They include, for example, cookies that enable you to log into secure areas of the Site. JQuery Cookies: a plugin for reading, writing and deleting cookies. Datepicker Cookies: allows users to sort events by date. Big Pipe Module Cookies: allows us to flush the initial page first, and then stream the replacements for the placeholders. This results in hugely improved front-end/perceived performance. Comment Module Cookies: When enabled, the Drupal comment module creates a discussion board for each Drupal node. Users can post comments to discuss a forum topic, weblog post, story, collaborative book page, etc. Cookies for testing: uploads a test to a private node and checks access for development purposes. Hal Module: When enabled, the HAL module serializes entities using HAL (Hypertext Application Language). History Module: verifies that the history endpoints work. Zend: provides methods for parsing HTTP response strings, collecting cookies, and easily accessing their properties. It also allows checking if a cookie matches against a specific scenario, IE a request URL, expiration time, secure connection, etc. Symfony: facilitates long-term maintenance and scalability by complying with standard development rules. Squizlabs: a client-side JavaScript application that checks a HTML document or source code, and detects violations of a defined coding standard. Phantom JS: used for automating web page interaction. Guzzle: a PHP HTTP client that makes it easy to send HTTP requests and trivial to integrate with web services. Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily. Google Analytics: allows anonymous recognition, counts number of visitors and sees visitor movement around the Site to help improve how the website works. To disable Google Analytics in your browser click here. Hotjar: anonymously tracks movement and user behavior on our Site. To disable Hotjar in your browser, click here. ShareThis: allows users to share pages from the Site to their social channels or email while anonymously gathering data on which social channels are used most frequently. To disable ShareThis data tracking, you can opt out here. Functionality cookies. These are used to recognise you when you return to the Site. This enables us to personalise our content for you, greet you by name and remember your preferences. Targeting cookies. These cookies record your visit to the Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. DoubleClick: this a product from Google that allows the personalization of ads based on pages a consumer visits. To disable DoubleClick in your browser, you can opt out here. AGKN: enables real time targeting and aggregates anonymous ads based on the user’s preferences. To disable AGKN in your browser, you can opt out here. If you continue to use the Site, or you agree to receive marketing communications from us, you agree to Tate & Lyle Sugar's use of cookies and beacons. If you do not wish to have cookies placed on your computer then you should disable cookies on your browser settings and delete cookies already stored. However, if you use your browser settings to block all cookies (including strictly necessary cookies) certain features of the Site may not function properly and your experience of the Site may be less enjoyable. Unless you have adjusted your browser settings so that it will refuse cookies, cookies will be issued as soon as you visit the Site. SECURITY OF INFORMATION Tate & Lyle Sugars employs appropriate security measures to protect the loss, misuse and alteration of the information under our control. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are a subject to a duty of confidentiality. For certain areas of the Site, Secure Sockets Layer (SSL) software is employed, which encrypts information you input, as an additional security measure. 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 warrant or 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. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. You always have an option not to give us any of your Personal Data. If you do not want to receive communications or materials from Tate & Lyle Sugars, our affiliates, and/or our third party partners, please opt-out from the relevant communications or materials at the time of registration or when the information is collected. Further, when you receive the requested communication, you are given the opportunity to unsubscribe from receiving any future communications or to change your information. If, at the time of registration, you also agreed to receive information directly from one of our affiliates, or directly from our third party partners, you may need to contact these other companies separately to opt-out from their communications. Please note that after making an opt-out request, you may continue to receive residual communications from Tate & Lyle Sugars for a short time thereafter. Please note that regardless of your opt-out selections, we reserve the right to continue sending you administrative or operational communications, such as important email confirmations or to inform you about updates to our Site (e.g. updates to our terms and conditions or Privacy Policy, Site maintenance, etc.). CROSS-BORDER TRANSFER OF DATA In accordance with the “Information Sharing” section above, we may share your personal data within Tate & Lyle Sugars, with our affiliates or with our Vendors. Some members of the Tate & Lyle Sugars’ group and/or our Vendors may be based outside of the European Economic Area (EEA). Where this is the case, the Personal Data that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for Tate & Lyle Sugars, its affiliates or for one of our Vendors. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following applies: An adequacy finding has been made in respect of the territory to which the data is being transferred; Binding corporate rules are in place; or Standard data protection clauses are in place; the transfer is necessary to establish, exercise or defend legal claims; you have provided explicit consent to the proposed transfer after being informed of any potential risks. By submitting your Personal Data to Tate & Lyle Sugars, you agree to the transfer, storing or processing of your data outside of the EEA. Tate & Lyle Sugars will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. YOUR RIGHTS You have a right to request a copy of the information we hold about you. You can always ask to review any personal information that Tate & Lyle Sugars may have collected from you, have it corrected, in certain situations deleted (if Tate & Lyle Sugars still has the information in our databases), in certain situations restrict our processing of your personal data, in certain situations the right to data portability, instruct Tate & Lyle Sugars not to use this information in the future and/or exercise your right not to be subjected to automated individual decision making. If you wish to exercise these rights, simply contact us at the address stated below in the “Get in Touch” section of this notice. We reserve the right to make a small charge for this service to meet our reasonable costs in complying with your request where the law allows. For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. You also have the right to register a complaint with Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. CHANGES TO YOUR PERSONAL DATA Please let us know if you change your name, address or any other personal detail (see below: “Get in Touch”). LINKS TO OTHER WEBSITES Tate & Lyle Sugars does its best to make sure that every link on our Site sends you to a safe place on the Internet. However, Tate & Lyle Sugars cannot and does not guarantee the content or privacy practices of every website for which it provides a link. Tate & Lyle Sugars does not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy notice of every website you visit. GOVERNING LAW Our Site is intended for residents of EEA. This Privacy Policy is intended to meet the laws and requirements of the UK and align with the General Data Protection Regulations implemented in the EEA. This Privacy Policy is governed by and construed under English Law and disputes arising in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the English courts. GET IN TOUCH If you have any questions or concerns about this Privacy Policy or your dealings with our Site, please contact us at: T&L Sugars Limited ATTN: Legal Department Thames Refinery, Factory Road, Silvertown, LONDON, E16 2EW. UK. Tel: +44 (0) 207 476 4455 Fax: +44 (0) 207 540 1848 Alternatively, you can contact us via the “Contact Us” section on this Site. 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