BRINDISA LTD. PRIVACY POLICY

Introduction

Brindisa Ltd. is committed to protecting your privacy and processing your personal data in accordance with the Data Protection Act (DPA) 1998 up to 24 May 2018 and the General Data Protection Regulation (GDPR) from 25 May 2018.

Brindisa Ltd. is the data controller of the information we collect and hold about you.

This policy explains how the information we collect is used and kept securely.

We have reviewed the purposes of our data processing activities and selected the most appropriate lawful basis for each activity.

Data processing activities

PROVISION OF GOODS AND SERVICES

Lawful basis

We will process your data on the basis of legitimate interests.

A Legitimate Interests Assessment (LIA) has been conducted and we have concluded it is the most appropriate basis.

Our legitimate interests are:

• Registering and maintaining you as a trading (wholesale) partner and administering your account as efficiently as possible.
• As an online customer, the legitimate interests lie in processing and fulfilling your purchase order with a high level of customer service, including the option to review your experience to allow us to improve our services and offer.
• When you enter a Brindisa Ltd. competition, the legitimate interest is to ensure the prize reaches you if you are successful.

DIRECT MARKETING

Lawful basis

Existing trade customers

Our purpose is to provide you with information about our goods, services and events, to enhance our trading relationship, offering the right to object at any time using our contact details provided below.

Potential trade customers (attending trade events)

We will process your data on the basis of legitimate interests.

Our purpose is to provide you with information about our goods, services and events of interest, offering the right to object at any time using our contact details provided below.

Online and customers attending retail events

We will only send you special offers, promotions and information of goods and events that may be of interest if you have consented to receive them.

If you give us your relevant consent we will share your name and email address with our sister company, Brindisa Kitchens Ltd., who will send you marketing emails. Please read Brindisa Kitchens Ltd.’s Privacy Policy

You can choose to receive digital marketing communications, by ticking the opt-in box:

• Through our online sign-up form when you visit our website,
• When you create an online account.
• During the Brindisa Ltd. website checkout process.
• When filling in a physical consent form handed out during Brindisa Ltd. events.

You can withdraw your consent at any time: if you do not wish to continue to receive marketing from us, click on the ‘Unsubscribe’ link in any email communication or update your preferences by logging into your account. Alternatively, you can contact us in writing:

Brindisa Ltd
9B Weir Road
London
SW12 0LT

gdpr@brindisa.com

OTHER MARKETING ACTIVITIES

Lawful basis

During closed Retail events organised by Brindisa Ltd. we may take photographs. These may be used for promotional activities, only with your express consent.

GENERAL ENQUIRIES

Lawful basis

When you contact us to seek information, we will process your data on the basis of legitimate interests.

Our interest is to respond to your enquiry as efficiently as possible and to provide you with the requested information.

Depending on the nature of your enquiry, we may put you in direct contact with our customers or suppliers who we believe could provide more accurate and relevant answers.

The information we collect about you

When you set up a trade (wholesale) account with us, we may collect the following information about you:

• Your name, email address, billing and delivery address, telephone numbers, payment details, IP addresses.
• References requested from third parties for credit control purposes.

When you purchase goods from Brindisa Ltd. through www.brindisa.com, we may collect the following details:

• Your name, email address, billing and delivery address, telephone numbers, payment details, IP addresses.
• If you set up an online account, your password will be encrypted on the secure server.

When you attend any of Brindisa Ltd. events, we may:

• Take photographs to be used for promotional activities.
• Ask you to fill in a Health and Safety questionnaire where your name and signature are collected.

When you enter a Brindisa Ltd. competition, we may collect:

• Your name and email address.
• Your delivery address and telephone number if we require to contact you to deliver the prize.

When you visit brindisa.com website, we or third party providers of advertisements may also collect information regarding your visits. This may include where you are located geographically, how you were referred to us, your browser and device type, the pages you viewed, the duration of your visit and any search terms used. This information may be collected even if you do not open an account.

Why we collect it

• To process the necessary and appropriate data for the purposes of administering our trading relationship.
• When you make a purchase online, to process the necessary and appropriate data to fulfil your order including delivery, payment and to deal with any subsequent queries.
• To increase our store of marketing images which may be used to promote Brindisa Ltd. and its events.

How we may use your personal information

• To deal with your requests and enquiries;
• To contact you for reasons related to the provision of Brindisa Ltd. goods and services;
• To provide payment processing and account management;
• To notify you about Brindisa Ltd. offers and events;
• To notify you about our sister company Brindisa Kitchens Ltd. offers and events;
• To analyse visitor browsing and buying habits in order to continuously improve our Brindisa Ltd. website and the products and services offered to our customers; please see link to our Cookies Policy.
• To process orders made on the Brindisa Ltd. website using the secure site Shopify;
• To comply with our legal obligations;
• To prevent, detect, mitigate, and investigate fraudulent or illegal activities;
• For use in print and digital marketing materials;
• To contact you if you are successful when entering any of our competitions for prize draws;
• To contact you via a third party review company about your shopping and service experience.

We will only disclose relevant data to our third-party couriers required for the purpose of fulfilling your order. Our courier may contact you with any update relating to the delivery of your goods.

We will only disclose your personal information to third party service providers if it is required to provide you with our goods and services.

We may share your data with our sister company Brindisa Kitchens Ltd. for fulfilling prize draws.

We do not sell, rent or otherwise disclose your personal information to third parties for the purposes of marketing or advertising.

Protecting your information

We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorisation controls.

By providing your personal data, you agree to this transferring, storing or processing. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy.

Our commitment to Children’s privacy

Protecting the privacy of the very young is especially important. For that reason, we never collect store or process this information knowingly.

Data retention: How long we hold your information for

We will only retain your information for as long as is necessary for the purpose or purposes for which we have collected it.

Trade customers: We will retain your data for such time as you are in trading relationship with Brindisa Ltd. If you stop trading with Brindisa Ltd. or your account is suspended for any other reason, your personal data may be retained on our system for a period of up to seven years.

Online customers: We will retain your data for such time as you are in trading relationship with Brindisa Ltd.

At any time you may amend or delete any personal data that we hold, or request us to do so.

Customers attending Brindisa Ltd. closed events:

We will store images indefinitely unless a request is made to remove them for our archives. Photographs used in print cannot be removed.

We will store any personal data to fulfil our legal obligations (e.g. accidents investigation).

At any time, you may request us to amend or delete any personal data that we hold.

If we receive your data through a competition entry, we will retain it for as long as is necessary to administer the competition.

Your rights

You have the following rights under data protection legislation:

• To access a copy of the information comprised in your personal data;
• To object to processing of your personal data that is likely to cause or is causing damage or distress;
• To prevent processing for direct marketing;
• To object to decisions being taken by automated means;
• In certain circumstances, to have inaccurate personal data rectified, blocked, erased or destroyed;
• To claim compensation for damages caused by a breach of data protection legislation.

Finding out what information Brindisa Ltd. holds about you

If you would like access your personal data or have any questions or comments about this Privacy Policy, please contact:

gdpr@brindisa.com

Brindisa Kitchens Ltd. Privacy Policy

If you have opted in to receive communications from Brindisa Kitchens Ltd. your details will be shared with our sister company in a safe and secure way. Please read Brindisa Kitchens Ltd.’s Privacy Policy for information on how they will store and use your data.