CATERING DESIGN GROUP LIMITED
PRIVACY AND COOKIE NOTICE
1.1 Welcome to Catering Design Group Limited’s (“CDG”, “we”, “us” or “our”) privacy and cookie notice.
1.2 We respect your privacy and are committed to protecting your personal data. This privacy and cookie notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and when you do business with us and tell you about your privacy rights and how the law protects you.
1.3 For the purpose of the General Data Protection Regulation 2016/679 (“GDPR”) and the Data Protection Act 2018, the data controller is Catering Design Group Limited (company number 02570700) whose registered office is at Central Chambers, 45-47 Albert Street, Rugby, Warwickshire, CV21 2SG (with registration number Z7157985).
1.4 This privacy and cookie notice aims to give you information on how CDG collects and processes your personal data through your use of our website and our doing business with you, including when you receive news updates from us or provide any data to us through our website when completing an enquiry form.
1.5 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.
2.1 If you have any questions about this privacy and cookie notice, including any requests to exercise your legal rights, which are set out in paragraph 12 below please contact our Commercial Director by:
2.1.1 writing to the Commercial Director at The Design House, 6 Cottesbrooke Park, Heartlands, Daventry, NN11 8YL; or
2.1.2 emailing the Commercial Director whose email address is firstname.lastname@example.org.
3 THIRD-PARTY LINKS
3.1 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 website, we encourage you to read the privacy and cookie notice of every website you visit. Issue 1 May 2018
4 THE DATA WE COLLECT ABOUT YOU
4.1 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).
4.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
4.2.1 Identity Data: includes first name, last name, title and place of work.
4.2.2 Contact Data: includes billing address, delivery address, email address and telephone numbers.
4.2.3 Transaction Data: includes details about payments to and from your business and other details of products and services you have purchased from us.
4.2.4 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 this website.
4.2.5 Profile Data: includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
4.2.6 Usage Data: includes information about how you use our website and services.
4.2.7 Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
4.2.8 Photograph Data: includes your image on a site photograph.
4.3 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. 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 and cookie notice.
4.4 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 and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Issue 1 May 2018
4.5 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5 HOW IS YOUR PERSONAL DATA COLLECTED?
5.1 We use different methods to collect data from and about you including through:
5.1.1 Direct interactions: you may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our services, request marketing to be sent to you, enter a promotion or survey, work together with us on a project or give us some feedback.
5.1.3 Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
188.8.131.52 Technical Data from analytics providers, advertising networks, and search information providers;
184.108.40.206 Contact and Transaction Data from providers of technical, payment and delivery services;
220.127.116.11 Identity and Contact Data from providers of online directories used by us; and
18.104.22.168 Identity and Contact Data from other third parties we work with as part of a project.
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:
6.1.1 where we need to perform the contract we are about to enter into or have entered into with you;
6.1.2 where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We define what legitimate interests are further below in this paragraph; or Issue 1 May 2018
6.1.3 where we need to comply with a legal or regulatory obligation.
6.2 Generally we do not rely on consent as a legal basis for processing your personal data. Where we do rely on consent, you have the right to withdraw consent to marketing at any time by contacting the Commercial Director (please find the contact details in paragraph 2).
6.3 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. Please 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.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register your business as a new client
|Performance of a contract with you (in other words, it is necessary for the performance of a contract to which your business is a party or to take steps at your business’ request before entering into such a contract)
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(d) Marketing and Communications
|(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:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(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 clients use our services)
|To manage your project as part of providing services to you. For example, we may be required to share your data with other businesses via a project directory to ensure that everyone on a specific project has each other’s contact
details in order for the project to run smoothly.
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to ensure that the project runs as smoothly as possible and there is transparency among those working on the project)
|To administer and protect our business and this 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 use data analytics to improve our website, services, marketing, client relationships and experiences
|Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about services that may be of interest to you
|Necessary for our legitimate interests (to develop our services and grow our business)
|To take and post pictures of site photographs (which may display people) on our website or on social media.
|(a) Photograph Data
|Necessary for our legitimate interests (for profile raising, marketing and to grow our business)
6.4 We may use your Identity, Contact, Technical, Usage and 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 services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing. Issue 1 May 2018
6.5 You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time (please see paragraph 2). Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of our general management of your project, service purchase or other transactions we have entered into with you.
6.6 In this paragraph 6, when we say “legitimate interest”, we mean the interest of CDG’s business in conducting and managing our business to enable us to give you the best service 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).
7.3 What are cookies? Cookies are small text files containing information that is stored on an internet user’s device when visiting a website. The information a cookie contains and its purpose is determined by the website operator and can be used by that web server every time you visit that site. Cookies are used to save time and make visiting websites more efficient and enjoyable.
8 DISCLOSURES OF YOUR PERSONAL DATA
8.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 6.3 above;
8.1.1 service providers acting as data processors who provide IT, CRM and system administration services;
8.1.2 professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
8.1.3 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances;
8.1.4 other businesses working on a project including, but not limited to, architects, main contractors, subcontractors and consultants; and Issue 1 May 2018
8.1.5 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 and cookie notice.
8.2 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.
9 INTERNATIONAL TRANSFERS
9.1 We do not transfer your personal data outside the European Economic Area (“EEA”). However, some of our external third parties which we use from time to time are based outside the EEA so, in those instances, their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
9.1.1 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; or
9.1.2 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 the EU.
10 DATA SECURITY
10.1 We have put in place appropriate security measures 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.
10.2 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 HOW LONG WE KEEP 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 Issue 1 May 2018
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 By law, or as required by our insurers, we have to keep basic information about you in relation to a client project (which will include Contact, Identity and Transaction Data). As a general rule, we will retain personal data on client project files for 12 years after the conclusion of the project however we may have a reason to hold on to your personal data for a longer period where we think it is necessary and in accordance with our retention policy.
11.4 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. You have the right to:
12.1.1 request access to your personal data (commonly known as a “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 (please 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; Issue 1 May 2018
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; and
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.
12.2 You have the right to make a complaint at any time to the 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.
13 CHANGES TO THE PRIVACY NOTICE
13.1 Any changes we may make to our privacy and cookie notice in the future will be posted on our website and, where appropriate, notified to you by email or, where you have not provided us with an email address, by post. Please check back frequently to see any updates or changes to our privacy notice.