The Security and privacy of your personal information is very important to us and we are committed to protecting it. This privacy notice explains how we collect and use your personal information when you visit our website or interact with us. You should read this notice carefully as it sets out your rights and our obligations to you.
PRIVACY NOTICE FOR SUPPLIERS/CUSTOMERS AND BUSINESS PARTNERS
During the course of your business relationship with Pilgrim’s Food Masters UK Ltd. (Company number: 13352340) (“PFM”), we will process your personal data in accordance with this privacy notice. We are committed to protecting and respecting your privacy. PFM is the controller in relation to the personal data which is collected and processed in connection with our business relationship.
1. COLLECTION OF PERSONAL DATA
Personal data, or personal information, means any information from which a person can be identified. It does not include data where the identity of the person has been removed (anonymous data).
We will collect and process the following personal data about you:
• Contact information (name, email address, telephone number, job title, organisation details, address)
• Delivery address and invoice address
• Bank account details
• IP address and device details
We do not 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, genetic and biometric data). We do not collect any information from you about criminal convictions or offences.
We may, from time to time, operate an ethics and compliance hotline to allow both employees and third parties to raise any concerns they might have in relation to our operations that employees and third parties cannot or do not feel able to raise in other ways. We have appointed an independent third party provider to operate the ethics and compliance hotline to allow for an element of confidentiality. However, you will appreciate that in order to investigate and deal with certain reported matters, it may be necessary for the information you provide to the ethics and compliance hotline (which may include personal data) to be shared with us, or our group companies. We will use any data for the purposes of investigating the matter to which it relates.
2. PROCESSING OF PERSONAL DATA
We process the information, including personal data, which we receive in connection with our business relationship for the following purposes:
• to register you as a new customer;
• to register you as a new supplier or business partner;
• to enable us to procure goods and services from our suppliers;
• to provide goods and services to our customers;
• where applicable, to arrange payment for both goods and services provided and received;
• to give suppliers’ details to retail customers (and third parties dealing with traceability) for the purposes of maintaining supply chain visibility and ensuring the provenance and traceability of food products and compliance with laws;
• to carry out credit checks (if you are a customer). We will supply your personal information to Credit Reference Agencies (CRAs) and they will give us information about you, such as your financial history and we do this to assess your suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time.
The primary basis of our processing of your personal data is for the performance of the contract between you and PFM. We may also process your personal data on the basis of our legitimate interests (e.g. prior to entering an agreement with you or to recover debts due to us) or as is necessary to comply with legal obligations (e.g. supply chain traceability and visibility). Furthermore, in very limited circumstances, your personal data may be processed on the basis of your consent.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may combine any information we receive from other sources (e.g. credit reference agencies) with information you give us and information we collect about you. We may use this information for the purposes set out above.
The list of reasons and purposes may be ongoing and updated in order to comply with other business needs and/or statutory requirements.
If you fail to provide certain information when requested, we may not be able to perform the contract we are trying to enter into with you or have entered into with you, or we may be prevented from complying with our legal obligations.
3. WITH WHOM WILL WE SHARE YOUR PERSONAL DATA
In the normal course of business, your information may be transferred/disclosed to the following recipients:
• Retail customers;
• Logistics providers;
• IT software and service providers;
• Other business partners, suppliers and sub-contractors for the performance of any contract we enter into with you (including any 3rd parties dealing with traceability); and
• Legal advisors, insurers, auditors, bankers, accountants
In addition, we may give information about you (‘Debtor Information’) to our bank (‘The Bank’) to allow them to provide services to us and to manage our account. The Debtor information may also identify the names or other personal information (such as address information) of your owners, partners or directors.
The Debtor Information may include details of account balances, historical payment experiences, and other information regarding the conduct of your account such as disputes, defaults etc.
The Bank may store and process the Debtor Information on their computer system (s) and in any other way. Such information may be used by them and other companies within their Group for training purposes, credit or financial assessments, market and product analysis, making and receiving payments, recovering monies and preparing statistics. They may also use such information to prevent fraud, bad debts and money laundering.
The Bank may also give information about your account and its indebtedness to: their insurers or re-insurers so they can quote for and issue any policy or deal with any claim; any guarantor or indemnifier of our obligations to them (if any); and Group company of them or any advisor acting on our or their behalf.
Certain personal data may also be reported to government authorities such as HMRC, where required by law.
We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of sale, terms and conditions of purchase, terms of any contract with you and other agreements; or to defend or make any legal claim; or to protect the rights, property or safety of PFM, our customers or others. This includes exchanging information with other companies for the purposes of fraud protection and credit risk reduction.
A more detailed list of the lawful purposes for which we may use your personal information can be found at the end of this notice.
4. INTERNATIONAL TRANSFERS
Your personal data may be disclosed to our ultimate parent company Pilgrim’s Pride Corporation and its majority shareholder JBS USA.
If your personal data is transferred to countries outside the United Kingdom and the EEA, including group entities, such transfer will be safeguarded by either the Standard Contractual Clauses issued by the Information Commissioner pursuant to section 119A of the Data Protection Act 2018, other appropriate safeguards, or any approved derogations under applicable data protection legislation. Otherwise, you will be asked to provide your explicit consent to the transfer.
5. STORAGE OF PERSONAL DATA
As a general rule, your personal data will be kept 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. To determine the appropriate retention period for personal data, we may 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.
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.
If our business relationship no longer exists, we will store your personal data for seven years after cessation of our relationship.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
7. YOUR RIGHTS
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org. We may ask you to provide evidence to prove your identity to ensure we are complying with your request.
You will not have to pay a fee to access your personal data (or exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We will inform you and seek your acceptance of the fee and the reasons for the fee prior to complying with your request.
Alternatively, we could refuse to comply with your request, in part or completely depending on the nature of your request. In these circumstances we will advise you of the grounds for the refusal or part refusal.
Right to withdraw consent
In the very limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that processing of your personal data at any time. To withdraw your consent, please contact email@example.com
Once we have received notification that you have withdrawn your consent, we will no longer process your personal data and we will dispose of your personal data securely, unless we are permitted or required by law or regulatory requirements to process your personal data without your knowledge or consent. In such a case, we will not process more personal data than is required under the circumstances.
8. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to update this privacy notice at any time and any changes will be posted on our website. Please check back frequently to see any updates or changes to our privacy notice. We may also notify you in other ways from time to time about the processing of your personal information.
9. CONTACT AND COMPLAINTS
If you want to exercise any of your rights, if you have any questions regarding this privacy notice or the processing of your personal data, you may contact: firstname.lastname@example.org
If you have any complaints regarding the processing of your personal data, please do not hesitate to contact us. You also have the right to make a complaint at any time to:
England: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF: Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate). Email: email@example.com
Scotland: Information Commissioner’s Office, 45 Melville Street, Edinburgh, EH3 7HL: Telephone 0303 123 1115 (local rate). Email: firstname.lastname@example.org
Wales: Information Commissioner’s Office, 2nd Floor Churchill House, Churchill Way, Cardiff, CF10 2HH. Telephone 02920 678400 (national rate). Email: email@example.com
Northern Ireland: Information Commissioner’s Office, 3rd Floor, 14 Cromac Place, Belfast, BT7 2JB. Telephone 0303 123 1114 (Local rate) or 02890 278757 (national rate). Email: firstname.lastname@example.org
Ireland: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28.
We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.
|Purpose/Activity||Possible Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||Performance of a contract with you|
|To process and deliver your order including:||(a) Manage payments, fees and charges|
(b) Collect and recover money owed to us
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate 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)|
(b) 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||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To market and make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Where you have consented to receive such marketing communications|
(b) Necessary for our legitimate interests (to develop our products/services and grow our business)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
If you fail to provide personal information
If you fail to provide certain data when requested, we may not be able to enter into or perform our contract with you or provide you with our services.
Where we require your personal data to enter into a contract and to provide you with our services, we will make this clear.
Change of purpose
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 unless this is otherwise required or permitted by law (in which case we may process your personal data without your knowledge or consent).
How we use particularly sensitive personal information
Special categories of particularly sensitive personal data require higher levels of protection.
We may process special categories of personal data where we need to carry out our legal obligations or where it is needed in the public interest
Less commonly, we may process this type of data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We will use information about your physical or mental health, or disability status, to ensure your health and safety when you are availing of our services and to ensure that we comply with the equality legislation.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We may contact you by mail, email and telephone and social media about our products and services and other events which might be of interest to you, but will only do so if we have your specific and explicit consent to do so.
You have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, please send us an email to email@example.com.
Pilgrim’s Food Masters UK Ltd.