1: About Us
users of this site;
customers (or prospective customers) who purchase (or wish to purchase) goods and/or services from us (“Customers”);
suppliers (or prospective suppliers) of goods and services to us (“Suppliers”);
employers, agents, contractors and other representatives of Customers and Suppliers (“Business Representatives”).
This site is not intended for children and we do not knowingly collect data relating to children.
2: How to Contact Us
This site is operated by Harlech Foodservice Limited. We are a limited company registered in England and Wales under company number 1413059. Our registered address is Harlech Foodservice Limited, Parc Amaeth, Llanystumdwy, Criccieth, Gwynedd, LL52 0LJ.
3: The Data We Collect About You
Personal data means any information relating to an identifiable individual. It does not include any data or information which relates to a person that cannot be identified or where the person's identity has been removed (i.e. anonymous data). It will include personal information about you when acting in a business or professional capacity (such as your job title and work contact details), but not information which relates solely to the business you work for or own.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity and Contact data – information which identifies you and your contact details, which may include your name, date of birth, gender, title, email address, telephone number, delivery address, account code, job title, employer and business address.
Financial and Transaction data – if you are an individual Customer we may collect your personal data when you purchase our products (such as your bank account and payment card details, details about your purchase from us and correspondence or communications with you in respect of your order). If you are a Business Representative of a Customer or a Supplier we may collect this type of personal data from you to the extent that you use personal payment details.
Profile data – we may record your account and website preferences, feedback and survey responses in conjunction with your Identity and Contact data. We may also collect and process personal data in connection with your registered account for our online store (if you have one or have access to one), including your account code and password, and details of purchases or orders made by you.
Marketing and Communications data – this includes data which we capture when you sign up to receive newsletters from us (including your preferences regarding receiving these types of communications from us and third parties).
Usage data – we may collect information about how you use our site, including how you navigate our site and if you encounter any problems.
Social Media data – we may have access to your personal data through a social media platform if you connect with us or like or follow our social media accounts (including your social media handle, photograph, date of birth, location, occupation, interests and other information and content you make available via your social media accounts).
Technical data – this comprises electronic information which is automatically logged/stored by processing equipment, which may include 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 site).
CCTV data – information obtained through our CCTV system when you visit our premises.
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.
4: How We Collect Information
Direct interactions: The majority of the personal data we hold about you is collected when you interact with us or correspond with us directly (via this site, by email, telephone or otherwise). This includes personal data you provide when you:
Fill out an enquiry form on this site, or otherwise make an enquiry;
Subscribe to receive our newsletters;
Create an account for our online store;
Place an order for any of our products;
Enter a competition, promotion or survey;
Connect with us, follow us or "like" us on social media; or
Provide feedback to us.
Automated technologies or interactions: When you interact with our site, our systems will automatically collect information about your equipment, browsing actions and patterns. We collect this personal data (namely Technical and Usage data) by using cookies server logs and other similar technologies. Please see our Cookies Policy and section 11 below for more information.
Other third parties: We may also receive personal data about you from various third parties as set out below:
Identity and Contact data and Financial and Transaction data from our third party payment provider (currently Sage Pay);
We will obtain Social Media data from the operators of social media platforms, including Facebook, Twitter, LinkedIn, Pinterest and YouTube who are based inside and outside of the EU;
Usage data and Technical data from analytics providers (such as Google Analytics, Cloudfare and MailChimp);
We may sometimes obtain additional information from your employer or colleagues (where you are a Business Representative);
Trade brochures and publicly available websites.
5: How and Why We Use Your Personal Data
We will only collect and process your personal data where we have a legal basis to do so. This legal basis will vary depending on the manner and purpose for which we are collecting your personal data. We will use your personal data as follows:
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. For example, we may collect and process your Identity and Contact data in order to process and perform a contract between us for the supply or purchase of products. We may also process Financial and Transaction data for the same purpose.
Where it is necessary to comply with a legal or regulatory obligation that we are subject to. For example, in order to comply with anti-money laundering obligations we may use your Financial and Transaction data.
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 (please see below).
Where we have your consent to do so. For example, we may collect your Social Media data, on the basis that you have provided consent for us to do so where you have connected with us on social media or you have liked or followed our social media accounts. We may also use your Identity and Contact data and Marketing and Communications data to send you marketing emails if you have asked to receive these from us. You may withdraw your consent at any time by disconnecting wish us on the social media platform or otherwise informing us by email (please see section 13 below).
Our legitimate interests in processing your personal data for our own business purposes include (without limitation):
Processing Identity and Contact data and Profile data to set up and manage access to Customer accounts for our online store;
Processing Identity and Contact data and Financial and Transaction data to process orders for products, including managing payments and collecting and recovering money owed to us;
Processing Identity and Contact data to respond to enquiries submitted to us via this site, or social media accounts, or by post, email or telephone;
Processing Technical data and Usage data to administer and protect our business, this site and our online store (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
Processing Technical data and Usage data to use data analytics to improve this site, our services, marketing, customer relationships and experiences;
Processing Technical data and Usage data to deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of such advertising by monitoring or tracking responses and engagement;
Processing Identity and Contact data to create and maintain accurate business records;
Processing Identity and Contact data, Marketing and Communications data, and Profile data provided you have previously purchased products from us and have not opted out of receiving such communications) to promote our services, including sending marketing emails and offering promotions.
Processing CCTV data to maintain our CCTV systems for the purpose of ensuring the safety and security of our people and premises.
You have the right to object to the above processing conducted for our legitimate interests, in which case we would assess your complaint and determine whether or not we are still entitled to continue the processing and whether additional safeguards are required.
We may also process personal data to fulfil our legal, regulatory and risk management obligations, including for the purpose of establishing, exercising or defending legal claims.
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 require further detail about the specific legal ground we are relying on to process your personal data.
Marketing communications from us: We may send you marketing communications by email or post if you:
have subscribed to receive newsletters from us via this site;
have purchased a product from us and you have not opted out of receiving marketing communications from us;
have otherwise consented to receive marketing communications from us.
Opting out: You can ask us to stop sending you marketing communications at any time, by:
Clicking on the unsubscribe button in the footer of any marketing emails from us;
Contacting us at [email protected].
7: 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 we wish 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.
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.
8: If You Fail to Provide Personal Data
Where we need to collect personal data from you in order to comply with our legal obligations or to perform a contract we have with you and you fail to provide that data when requested, we may not be able to perform the relevant contract (for example, to supply or purchase products to or from you). In this case, we may have to cancel the relevant contract.
9: How We Protect Your Personal Data
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, the personal data you provide to us is only available to our authorised personnel who need access to it in order to fulfil their duties. They will only process your personal data on our instructions and they shall be subject to a duty of confidentiality.
Although we will do our best to protect your personal data, the transmission of information via the internet is not completely secure, therefore we cannot guarantee the security of any personal data transmitted to this 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.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Once we no longer require your personal data, we will take reasonable steps to destroy it in a secure manner.
10: How Long We Hold Your Personal Data For
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. For example, we will generally retain Identity and Contact data of Customers and Suppliers for as long as they remain our Customers and Suppliers.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in order to develop our business methods and strategy or for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We shall not have any liability whatsoever to you for the deletion of personal data in accordance with our data retention policy.
For more information about the cookies we use and the reasons why we use them, please see our Cookies Policy.
12: Sharing Your Personal Data with Third Parties
We may share your personal data with third parties where required by law, where it is necessary to administer the contract with a Customer or Supplier, or where we have another legitimate interest in doing so. We do not sell your personal data to third parties.
We may share your personal data with third parties who provide services to us, including our IT software provider (currently Lady Lodge Systems Ltd), our payment provider (currently Sage Pay), and our marketing and advertising provider (currently MailChimp).
We may also share your personal data with the following third parties:
Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accountancy services;
Other companies and organisations for the purposes of fraud protection and credit risk reduction, HM Revenue & Customs, the police, regulators and other authorities and public bodies where we are required to do so by law.
We require all our data processors to respect the security of your personal data and to treat it confidentially and in accordance with the law. We do not allow our data processors 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 as set out in our data sharing agreements.
13: Your Rights
You have the following rights in respect of the personal data that we process about you (where we determine the purpose and means for which that personal data shall be processed):
The right to request access to your personal data that we hold and to receive certain information relating to that data (commonly known as a "data subject access request");
The right to ask us to rectify inaccurate data or to complete incomplete data (though we may need to verify the accuracy of the new data you provide to us);
A right to receive or ask for your personal data to be transferred to a third party in a structured, commonly used and 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);
The right to request the erasure of personal data if it is no longer necessary in relation to the purposes for which it was collected or processed or if you have successfully objected to processing (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);
The right to object to how we process your personal data in certain circumstances, including the right to ask us not to process your personal data for marketing purposes;
The right to restrict processing of your personal data, for example if you want us to establish the accuracy of the data or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it; and
Where we are processing personal data relating to you on the basis that we have your consent to do so, you may withdraw your consent at any time (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 or purchase certain products or services to or from you.
If you wish to exercise any of the rights set out above in respect of your personal data, please contact us by email at [email protected].
We may ask you to verify your identity if you make a request to us to exercise any of the rights set out above. 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.
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.
We will 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.
14: How to Complain
Please let us know if you are unhappy with how we have used your personal data. You may contact us by email at [email protected].
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance and we shall endeavour to resolve your complaint.
15: Changes to Your Data
Please let us know if you change your contact details. You have the right to question any data we hold about you that you think is wrong or incomplete. Please contact us if you want to do this.