We take privacy seriously. In line with our Code of Business Principles, we apply the following principles to privacy and data protection:
- We respect and protect privacy and safeguard personal data in line with all applicable laws and regulations.
- We will limit use and processing of personal data to the purposes we need it for, and only with explicit permission or other legal basis.
- We will be critical, transparent and clear about when, how and where we use personal data.
- We will follow the standards of “privacy by design and default”, and assess the impact of privacy when developing new product or service initiatives.
- We make sure we do not retain personal data any longer than we have to and will follow all applicable data retention schedules and terms.
WHO ARE WE?
Frozen Fish International GmbH
Am Lunedeich 115
WHAT INFORMATION DO WE COLLECT?
- Your contact details. Your name, postal address and other contact details, such as your telephone number and e-mail address.
- Information regarding your use of our online Services. This includes data regarding the pages you visit and the products and services you like.
- Your details regarding contests. The data we collect if you participate in a survey, contest, promotion or competition we provide from time to time.
- Your reviews. The opinions, experiences, preferences and interests, and product or event reviews that you publish on our website or share with us online or through social media.
- Your communication data. Your requests, any complaints you may have and any other data that we receive if we communicate with you via e-mail, by telephone, online or via social media.
- Information collected from other sources. We may collect information from commercially available sources such as data aggregators and public databases. We may combine this information (e.g. name, interests, publicly observed data) with the information we collect from you to help us tailor our communications to you and to improve our services and products and might request for your explicit consent separately if this is requested by law.
SPECIAL CATEGORIES OF PERSONAL DATA:
- Special categories of Personal Data provided by you. We will also collect health information you voluntarily provide to us when you interact with us, for example in relation to food allergies you may have. Further, we may collect health related data of customers that claim damages via our customer care service.
HOW DO WE USE THIS INFORMATION?
We collect and use your Personal Data for the purposes below. Please know that insofar as we already hold information about you, we may use that information for the same purposes.
- For the performance of our agreement with you: In order to carry out our obligations arising from any contract entered into between you and us and to provide you with the information and Services that you request, including handling your requests, inquiries or complaints. In order to develop and manage a contest, competition or promotion which you may have entered, to conduct the promotion and contact you if you win. In case it is possible to order products online, we process this data in order to manage and handle your purchases.
- For our legitimate commercial interests: We may use your Personal Data (both on an aggregated and on an individual basis), such as your contact details, your account and electronic identification data, for the purpose of advertising our products and services and making contact with you for marketing or other commercial purposes if you are an existing customer. We may also use your Personal Data for analysing and improving the quality of our products and services, as well as to understand you as a customer and to give you a better user experience. This enables us to create personal profiles and to assess what may interest you, to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising.
- We may also use your Personal Data, for other legitimate commercial interests such as to generate aggregated statistics about the users of our Services, to assist in security and fraud prevention, to administer our website and for internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes), for system integrity purposes (for example the prevention of hacking, spamming etc.), to allow you to participate in interactive features of our Services, to facilitate our business operations, to operate company policies and procedures, to enable us to make corporate transactions such as any merger, sale, divesture, reorganisation, transfer of assets or businesses, acquisition, bankruptcy or similar event, or for other legitimate business purposes permitted by any applicable law.
We may use your Personal Data referred to above in section ‘What information do we collect?’ for marketing communications (based on your profiles) via email, SMS or other electronic means but we will only do so after we have received your consent to do so.
You can withdraw your consent at any time; see the section ‘Your Privacy Rights’ below.
- To comply with our legal obligations Any information referred to above in section ‘What information do we collect?' may be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
WHOM DO WE SHARE YOUR INFORMATION WITH?
We share your Personal Data with the following parties:
- Service Providers and Processors.We engage third party vendors, from time to time, including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or to provide services on our behalf;
- Advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others. We do not disclose information about identifiable individuals to our advertisers but we will provide them with aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the Personal Data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;
- Analytics and search engine providers that assist us in the improvement and optimisation of our website.
In providing their services, the third party vendors will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit use of your Personal Data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your Personal Data and only process it in accordance with our instructions.
- Partners. We can sometimes offer you a Service in co-operation with partners (for example, co-sponsors or licensors, licensees or distributors of our branded products). We will therefore need to disclose your Personal Data to those partners. In accordance with the applicable law, we will take commercially reasonable steps to require third parties to adequately safeguard your Personal Data and only process it in accordance with our instructions or as co-controllers. We will notify you of the sharing and you will have the choice to object to this. Where legally required, we will ask for your prior consent.
- Court orders and other legal requirements.We also disclose your Personal Data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process served on us or to protect the rights or safety of the website, us or our affiliated companies.
- Corporate transaction.In addition, information about our customers, including Personal Data, may be disclosed as part of any merger, sale, divesture, reorganisation, transfer of assets, acquisition, bankruptcy or similar event.
- With consent.We also disclose information about you, including Personal Data, to any other third party where you have consented or requested that we do so.
COOKIES AND OTHER TECHNOLOGIES
IF YOU ARE UNDER 16 YEARS OF AGE
Our online Services are not directed to children under thirteen years of age. If you believe we have collected information about a child under the age of thirteen, please contact us so we can take appropriate steps to delete such information.
If you are at least thirteen years of age but under sixteen years of age, please get consent of your parent or legal guardian before you provide us with any Personal Data.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
In most cases, your Personal Data will be processed within the European Union. However, please be informed that we may transfer and process any Personal Data you provide to us to countries other than your country of residence. The laws of these countries may not afford the same level of protection to your Personal Data. We will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer, in particular for Personal Data transferred to countries outside the EEA. This means that we will enter into the legally necessary contracts with recipients of your Personal Data such as Standard Contractual Clauses as approved by the European Commission or other supervisory authority, where required.
We will take reasonable steps to ensure that your Personal Data is properly secured using appropriate technical, physical and organisational measures so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction and loss.
We retain your Personal Data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period, we consider the amount, nature and sensitivity of the 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, as well as the applicable legal requirements.
For example, we have to keep basic information about our customers (including contact information and financial data) for seven years after they cease being customers.
In some circumstances you can ask us to delete your data: see section ‘Your Privacy Rights’ below for further information.
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.
YOUR PRIVACY RIGHTS
Subject to the conditions stated in the applicable law you have the following rights with regard to our use and processing of your Personal Data:
Right to access your Personal Data - You have the right to request access to any of your Personal Data that we may hold and to check that we are lawfully processing it.
Right to correct your Personal Data – You have the right to have any incomplete or inaccurate Personal Data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to deletion of your Personal Data – You have the right to ask us to delete or remove Personal Data where there is no good reason for us to continue 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). Please note, however, that we may not always be able to comply with your request of deletion for specific legal reasons which will be notified to you, if applicable, when we reply to your request.
Right to restrict use of your Personal Data - You have the right to restrict our use of your Personal Data where (i) you contest the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the Personal Data for the relevant purposes but you require them for the establishment, exercise or defence of legal claims; or (iv) you have objected to data use justified on our legitimate interests pending verification as to whether we have indeed compelling interests to continue the relevant data use.
Right to object - To the extent that we are relying on our legitimate interests to use your Personal Data, you have the right to object to such use and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your rights and interests or where we need to process the data for the establishment, exercise or defence of legal claims.
For further information regarding your rights or to exercise any of your rights, please contact us via the Contact Us link on our website.
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.
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.
Our website may, from time to time, contain links to and from third party websites such as the websites of our partner networks and customers (such as the retailers that sell our products), social media networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their content. Please consult the relevant third party privacy policies before you submit any Personal Data to these websites.
CHANGES TO THE POLICY
CONTACT AND QUERIES
Our Data Protection Officer can be contacted via email at [email protected] or by writing to Data Protection Officer, 1 New Square, Bedfont Lakes Business Park, Feltham, Middlesex, TW14 8HA, UK.