Privacy Policy

INTRODUCTION

Bridgmans respects your privacy and is committed to protecting your personal data. This privacy policy aims to give you information on how we collect and look after your personal data when you visit our website, www.bridgmans.co.uk (regardless of where you visit it from), when you purchase products and services from us (through contacting us or in store), when you open a customer account or when you otherwise contact us. It will also tell you about your privacy rights and how the law protects you.

References to “you” or “your” are to you as an individual using our website or otherwise contacting us (either on behalf of yourself, your business or another individual or organisation).

THE DETAIL

1 IMPORTANT INFORMATION
2 WHO WE ARE
3 THE DATA WE COLLECT ABOUT YOU
4 IF YOU FAIL TO PROVIDE PERSONAL DATA
5 HOW WE COLLECT YOUR PERSONAL DATA
6 HOW WE USE YOUR PERSONAL DATA
7 DISCLOSURES OF YOUR PERSONAL DATA
8 CCTV
9 INTERNATIONAL TRANSFERS
10 DATA SECURITY
11 DATA RETENTION
12 YOUR LEGAL RIGHTS
13 CONTACT DETAILS AND COMPLAINTS

1 IMPORTANT INFORMATION

1.1 It is important that you read this privacy policy together with our cookie policy and any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

1.2 This version was last updated on 29 June 2018.

1.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4 Our website is not intended for children and we do not knowingly collect data relating to children.

1.5 Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.

2 WHO WE ARE

2.1 D. & I. Bridgman and Son Limited is a company registered in England and Wales with company registration number 03051464 and registered office at Exmoor House Lime Way, Pathfields Business Park, South Molton, Devon, EX36 3LH, United Kingdom and is referred to as “Bridgmans“, “we“, “us” or “our” in this privacy policy.

2.2 We operate the website, www.bridgmans.co.uk, and various retail stores. We provide products and services to business and consumer customers, and we operate customer accounts. As such, we need certain personal information to be able to deliver our products and services and operate our customer accounts.

2.3 We are bound by applicable data protection laws in respect of the handling and collection of your personal data. We are registered as a data controller with the Information Commissioner’s Office (ICO) under the ICO registration number ZA498433.

2.4 If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out in section 12, please contact us using the contact details in section 13.

3 THE DATA WE COLLECT ABOUT YOU

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or data relating to a corporate entity.

3.2 We may collect, use, store and transfer different kinds of personal data about you, your staff or your business, which we have grouped together as follows:

• Identity Data includes first name, last name, title, date of birth, customer account numbers, country parish holding (CPH) number and Red Tractor membership number.
• Contact Data includes business or home address, billing and delivery address(es), email address(es), landline and mobile number(s) and fax number(s).
• Financial Data includes bank account number, sort code, payment card details and credit references and checks.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
• Profile Data includes your purchases and orders made by you, your browsing history, feedback and survey responses.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and, where applicable, third parties and your communication preferences.

3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or Transaction Data for financial reporting and analysis. 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.

3.4 We do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, we may process certain special categories of personal data and/or information about criminal offences when you:

• have an accident in or near our store that is then logged in our accident record book;
• are involved in carrying out criminal activity that is captured on one of our CCTV systems; and
• include such information in your CV which you (or a third party) send to us about employment opportunities with us.

4 IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services or open up a customer account). In this case, we may have to suspend or cancel a product or service you have with us but we will notify you if this is the case at the time.

5 HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

5.1 Direct interactions. You may give us your Identity, Contact, Financial, Transaction, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

• purchase any of our products and services from us (over the phone or email) or in store;
• set up a customer account with us (as an individual, sole trader or on behalf of a corporate entity);
• meet with one of our members of staff to discuss our products and services or otherwise contact us;
• request marketing and publications to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

5.2 Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy.

5.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Identity, Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Verifone Limited based outside the EU.
• Financial Data from credit reference agencies such as Experian;
• Technical Data from analytics providers such as Google based outside the EU;
• Identity and Contact Data from data brokers or aggregators such as Marketlocation based inside the EU; and
• Identity and Contact Data from publicly availably sources such as websites of relevant, prospective customers, Companies House, Red Tractor (Assured Food Standards) and Government agencies such as DEFRA.

6 HOW WE USE YOUR PERSONAL DATA

6.1 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:

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can contact us for further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
• Consent means where we have obtained your agreement to process your personal data. Consent must be freely given, specific, informed and be an unambiguous indication of your wishes for us to process your personal data (this may be collected by you ticking a box). Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing material to you via email, post, phone, text message and social media. You have the right to withdraw consent to marketing at any time by contacting us (see section 6.2 below).

We have set out below, in a table format, a description of all the ways we plan to use 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

6.2 Prospecting

In a business-to-business context, we may make contact with you to provide or seek information in connection with our products and/or services. The legal basis we rely on for making contact with you and processing your personal data is our shared legitimate interests in doing business together. When we make contact with you, you can exercise your right to object to such contact (please see section 12.1.4).

6.3 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

• Unsubscribe link displayed on every email newsletter and marketing communication (which links to your online preferences).

6.3.1 Marketing from Us

Our newsletters:

We will send our customer account holders our monthly newsletters as we believe this is one of the benefits of being an account holder. The legal basis on which we process personal data for these purposes is our legitimate interest to develop our products and services and grow our business, and your interest in receiving discounts on products.

You can ask us to stop sending you the newsletter at any time (see section 6.3.3 below).

Marketing calls and post:

Where you are an account holder, we may contact you by phone or via post to tell you about new products, services and offers from us and our carefully selected third parties. The legal basis on which we process personal data for these purposes is our legitimate interest to make our products and services available to those that may need them and to grow our business, and your interest in receiving information about new products, services and offers.
You can ask us to stop calling or contacting you in this way at any time (see section 6.3.3 below).

Other marketing communications:

We will only send other marketing communications to you as a customer account holder and/or other customer if you have provided your express, opt-in consent. We may use your Identity, Contact, Technical, Usage and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us after you have requested information from us or opened a customer account and, in each case, you have opted-in to receiving that marketing.

You can withdraw your consent at any time.

6.3.2 Marketing from third parties

We will get your express opt-in consent before we share your personal data with any company outside Bridgmans for marketing purposes.

6.3.3 Opting Out / Unsubscribing

You can ask us to stop sending you marketing messages at any time by following the opt-out / unsubscribe links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, you may still receive messages for other purposes (such as providing the services to you).

6.4 Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7 DISCLOSURES OF YOUR PERSONAL DATA

For the purposes set out in section 6, we may have to share your personal data with the following parties:

7.1 Internal Third Parties such as other companies in the Mole Valley Farmers group of companies where they provide services on our behalf.

7.2 External Third Parties such as:

• Service providers and suppliers acting as processors based in the UK who provide delivery, haulage, storage, IT, operating system and system administration services.
• Original equipment manufacturers, suppliers and retailers acting as processors or joint controllers based in the UK who provide the products and services to us (or sometimes straight to you) and they may answer your product specific queries or contact you about a delivery. We may also contact these providers to seek a quote on your behalf, but would not pass your personal data on to them until one provider has been selected.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators, law enforcement bodies, police and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances (such as criminal activity, suspected or actual fraud or tax evasion).
• Marketing and PR providers where you have agreed to a publication or article with us.
• Third party references where we have requested a reference from you in order to open a customer account for you.
• Other third party companies (who act as a controller) where we have an agreement in place and only where you have agreed that we may share your Identity and Contact Data with them, such as our other group companies and our joint venture companies for marketing if you have opted in to receive such marketing.

7.3 Specific Third Parties such as:

• Experian plc based within Europe who provide us with credit check data and references when you request to open a customer account.

7.4 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

7.5 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8 CCTV

8.1 We may operate CCTV and other surveillance systems in (and around) our stores which capture images of you. We may be able to identify you from the CCTV data. We will only use this data to prevent, detect, deter and report on crime, to protect buildings and assets from crime, to protect the health and safety of customers, staff and other visitors and/or to assist with criminal investigations and support law enforcement bodies.

8.2 We use CCTV systems in this way for our legitimate interests (to prevent and detect crime), to comply with legal or regulatory obligations (to law enforcement bodies) and/or to protect the vital interests of you or another individual.

8.3 Data from CCTV cameras will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are requested by a law enforcement body, data will be kept by them for as long as they need it. In all other cases, recorded images will be kept for no longer than 60 days. We will maintain a comprehensive log of when data is deleted.

9 INTERNATIONAL TRANSFERS

Certain of our external third parties are based outside the European Union (EU) so their processing of your personal data will involve a transfer of data outside the EU.

Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.

10 DATA SECURITY

We have put in place appropriate security measures (including SSL technology) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11 DATA RETENTION

How long will you use my personal data for?

11.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

11.2 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.

11.3 We will generally retain our customers’ data for a period of 7 (seven) years after a contract has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect, or defend our legal rights, or for tax purposes.

11.4 We will retain customer’s data in relation to a direct debit mandate for a period of two years after the direct debit was last used

11.5 Where we have processed your personal data to provide you with marketing communications with consent, we may contact you at least every twelve (12) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a “do not contact” list).

11.6 Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with services), subject to section 11.3 and 11.4, we will retain your data for twelve (12) months.

11.7 In some circumstances you can ask us to delete your data: see section 12.1.3 below for further information.

11.8 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

12 YOUR LEGAL RIGHTS

12.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below:

12.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

12.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

12.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

12.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

12.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

12.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

12.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us directly.

12.2 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

12.3 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

12.4 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13 CONTACT DETAILS AND COMPLAINTS

Our full details are:

Full name of legal entity: D. & I. Bridgman and Son Limited

Data Protection Officer: Vicky Hosegood

Email address: [email protected]

Postal address: Mole Valley Farmers Limited
Moorland House
South Molton
EX36 3BH
United Kingdom

Telephone number: 01769 576433 or 07772 898618

You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.