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Privacy Policy

1. Introduction

Dairy Crest Limited (trading as Saputo Dairy UK and Wensleydale Creamery), and Bute Island Foods Ltd (trading as Bute Island Foods) are referred to in this policy as the “SDUK Group”, “we”, “us” or “our”.

For information on the SDUK Group’s brands, see https://uk.saputo.com/brands/

We operate a number of websites designed to provide information to you about our products, including: uk.saputo.com, vitalitedairyfree.co.uk, cathedralcity.co.uk, frylight.co.uk, buteisland.com, gosguthealth.com and yorkshirecreamery.co.uk (our “Websites”) and a number of social media pages.

We also operate two e-commerce websites for sales from Davidstow and Wensleydale Creamery (our “E-commerce Websites”). Our E-Commerce Websites have separate privacy notices, so please refer to www.davidstowcheddar.co.uk/privacy-policy/ or www.wensleydale.co.uk/privacy-policy-i4  if you are using these sites.

We respect your privacy and are committed to protecting your personal data.

This privacy notice sets out what type of personal data we collect from individuals how we use this personal data, and how this data is collected, for example when:

  • You visit one of our Websites;
  • You contact us via:
    • a form on one of our Websites;
    • a post or direct message on social media;
    • a phone call, email or letter; or
    • speaking to a retailer about one of our products;
  • You visit our premises; or
  • You enter a competition that we are running.

This notice will also tell you about your privacy rights and how the law protects you.

If you do not want your personal data processed as detailed in this privacy notice, please do not use the Websites or our services.

2. Important information

Children

Our social media pages and Websites are not intended for children and we do not knowingly collect data relating to children unless such information is disclosed by a parent or guardian when contacting us.

Data Controller

We have appointed a Data Privacy Manager (for Dairy Crest Limited) and a Data Protection Officer (for Bute Island Foods Ltd) to oversee compliance with this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, or if you require more detail about the legal bases for processing your personal data please contact the Data Privacy Manager or Data Protection Officer using the details set out in paragraph 10 below.

Third-party links

Our Websites and social media pages 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 or social media pages, we encourage you to read the privacy notice of every website you visit.

3. The data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store, disclose and transfer different kinds of personal data about you which we have grouped together as follows:

 

“Identity Data”

Includes first name, last name, marital status, title, date of birth and gender, location.

 

“Contact Data”

Includes personal contact details such as address, e-mail address, telephone numbers and social media contact details.

 

“Correspondence Data”

Includes records of your correspondence with us (including e-mails, postal correspondence, web contact forms/details and social media correspondence), incident number and call recordings.

 

“Contest Data”

Includes information provided when entering into a contest with us, such as your name, address and e-mail address, and for contest winners, may include supplemental information, such as identification documents.

 

“Business Contact Data”

Includes business contact details such as name, job title, telephone number, e-mail address, business address, organisation, correspondence history, order history, sales history, trade passes and licences, qualifications, permit to work, proof of ID/background information and documents, lifestyle, social circumstances and personal preferences (including in relation to the use of personal data, diet and marketing communications), reasonable adjustments or accommodations, expenses, payment records and details, meeting records, social media records (e.g. LinkedIn profile).

 

“Transaction Data”

Includes details of products you have purchased which are manufactured by us or by a third party on our behalf.

“Profile Data”

Includes your interests, preferences, behaviours, hobbies, activities, household or lifestyle information, feedback, opinions, survey responses and qualifications.

 

“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 the Websites and/or otherwise use our services.

 

“Usage Data”

Includes information about how you use our Website(s) and social media pages and/or use our services.

 

“CCTV Data”

Includes moving and still images and audio recordings captured by CCTV devices.

 

“Visitor Data”

Includes information collected about visitors to our premises and sites, such as name, organisation representing, entry/exit time, access card records, signature, purpose of visit, the person you are attending our premises/site to visit, other people you are visiting with and vehicle details.

 

“Health Data”

Includes details of your health and wellbeing, illness, injury, allergies, and / or disability.

 

 

 

 

 

We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, or to tailor our Websites, in which case we may use this information indefinitely without further notice to you.

Sensitive personal data

“Special categories” of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, transferring, storing and/or using this type of personal data. We have in place a Data Protection Policy and safeguards which we are required by law to maintain when processing such data.

Apart from Health Data collected in accordance with this privacy notice, we do not knowingly collect any other “special categories” of personal data about you (including e.g. details about your race or ethnicity, political opinions or religious beliefs).

If you fail to provide personal data

If you contact us but fail to provide certain personal data when requested, we may not be able to help you, investigate the issue raised or respond to or resolve your complaint or query. We will use reasonable efforts to notify you if this is the case at the time.

4. How is your personal data collected?

We collect personal data about you from the following sources:

  1. From You. You may give us your Identity Data, Contact Data, Transaction Data, Profile Data, Correspondence Data, Contest Data, Business Contact Data, Visitor Data and / or Health Data by corresponding with us by post, phone and email or via a contact form on one of our Websites or a message on social media, by interacting with us as part of your job, by visiting the Websites or by entering into a contest we are holding.

     

  2. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including:
    • Identity, Contact, Profile, Transaction, and / or Health Data from third parties such as a supermarket from where you bought one of our products, if you ask for details of your complaint, query or feedback to be passed to us for investigation or resolution.
    • Technical Data from analytics providers such as Google.
    • Identity, Contact, Profile and Transaction Data from third parties such as fraud prevention agencies based within the UK who may gather information from publicly available sources such as Companies House and the Electoral Register or from social media.
    • Business Contact Data from your employer or another member of your organisation.
  3. Automated technologies or interactions. As you interact with our Websites or social media pages, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.

How we use your personal data

We will only use your personal data when the law allows us to. We have set out below a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so.

Purpose/Activity

Lawful basis for processing, including basis of legitimate interest

To enable us to investigate and deal with your complaint, question, feedback or compliment

(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (e.g. for quality monitoring and improvements, to carry out an investigation, to take appropriate action and to provide a meaningful response)
(c) Necessary for the establishment, exercise or defence of legal claims (d) Necessary for the performance of a contract (e) Necessary for reasons of substantial public interest

To provide feedback to the business on the performance of our products and staff, and as needed to investigate any product issues.

(a) Necessary for our legitimate interests (e.g. for quality monitoring and product improvements, new product development and investigations and for customer service monitoring)
(b) Necessary for the establishment, exercise or defence of legal claims (c)
Necessary for reasons of substantial public interest

To check for fraud or malicious or unfounded claims

(a) Necessary for our legitimate interests (e.g. prevention of fraudulent claims)
(b) Necessary for the establishment, exercise or defence of legal claims

To manage our relationship with you which will include:
(a) Providing you with updates and a response to your question or complaint.
(b) Notifying you about changes to our privacy policy if we contact you directly in order to do so
(c) Asking you to leave a review or take a survey

(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (e.g. keeping you informed as to the progress of your question or complaint, to keep our records updated and to study how consumers use our products)

To administer and protect our business and Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Necessary for our legitimate interests (e.g. 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 Websites and other services

Necessary for our legitimate interests (e.g. to keep our Websites and other services updated and relevant)

To deliver to you by e-mail or by post press releases and publications and to notify you of products or special offers that may be of interest to you

(a) Consent

(b) Necessary for our legitimate interests (e.g. to promote our business)

Publishing external facing materials for marketing and public relations purposes, such as where we mention individuals in our marketing materials, social media posts and press releases

(a) Necessary for our legitimate interests (e.g. to promote our business)

(b) Consent

 

To run contests

(a) Necessary for performance of a contract (b) Necessary for our legitimate interests (e.g. to increase consumer engagement)

 

To enable people to visit our sites

(a) Necessary for our legitimate interests (e.g. to enable business to be conducted on our sites, to enable social/educational visits)

(b) Necessary to comply with a legal obligation

To maintain the security of our sites

Necessary for our legitimate interests (e.g. keeping our sites secure, keeping our staff and visitors safe and deterring and reporting criminal activity)

To conduct business with our customers/suppliers

(a) Necessary for our legitimate interests (e.g. to enable us to purchase products and services required for the running of our business and to ensure that function is efficient)

(b) Necessary to comply with a legal obligation

(c) Necessary for the performance of a contract (e.g. to sell our products)

To make reasonable adjustments and accommodating for health/diet/religious requirements

Consent

 

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 personal data.

Marketing

We do not use and will not share with any external third parties, any of the information you have given us via our SDUK Consumer Care Teams, Websites or social media pages for direct marketing purposes without obtaining your consent.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when Websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Websites may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Please note that 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.

5. Data Sharing

We may have to share your data with third parties, including third-party service providers, other entities in the SDUK Group and other entities within the wider Saputo Inc. group.

We will only share your personal data with third parties where required by law or where we have another legitimate interest in doing so. The categories of third party with whom we share information are as follows:

  • Third party service providers who provide our IT software and systems;
  • Service providers who provide social media services and contest administration and hosting services;
  • Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers who provide ad hoc legal, auditing and insurance services;
  • Advisors and fraud prevention agencies acting as processors to provide fraud detection services;
  • Sale or restructuring of our businesses;
  • Courts, court-appointed persons/entities, receivers and liquidators; and
  • Governmental/state departments and agencies, anti-fraud organisations, statutory and regulatory bodies, including law enforcement bodies;

We will also share your personal data with other entities in our wider Saputo Inc. group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data and to provide legal and audit services.

All our third-party service providers and other entities in the group are required to take appropriate security and confidentiality measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Transferring information outside the UK or EEA

Some of our third party suppliers transfer or process your personal data outside the UK or EEA. To help ensure that your personal data receives an adequate level of protection, we have put in place the appropriate measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

For example we may use the International data transfer addendum to the EU Commission’s standard contractual clauses for international data transfers approved by the Information Commissioner’s Office from time to time.

If you require further information about these protective measures, please contact the Data Privacy Manager or the Data Protection Officer as applicable.

7. Data security

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the applicable regulator, the Information Commissioner’s Office of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

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 or reporting requirements.

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 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 for data retention.

9. Your legal rights

Under certain circumstances, by law you have the right to:

  1. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  2. Request access to your personal data (commonly known as a “data 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.
  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 exercised your right to object to processing (see below).
  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. You also have the right to object where we are processing your personal data for direct marketing purposes.
  5. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  6. Request the transfer of your personal data to another party.
  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. If you withdraw your consent, we may not be able to help you, investigate the issue raised or respond to or resolve your complaint or query. We will advise you if this is the case at the time you withdraw your consent.

In some circumstances there may be specific legal reasons why we are not able to comply with your request to exercise your rights. Where this is the case, we will inform you of this.

If you wish to exercise any of the rights set out above, please contact the Data Protection Manager or the Data Protection Officer in writing.

You will not usually 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.

What we may need from you

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.

Time limit to respond

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.

10. Data Privacy Manager

Full name of legal entity:

Contact:

Email address:

Postal address:

Dairy Crest Limited

Data Privacy Manager

datacontroller@saputo.com

Data Privacy Manager,
Dairy Crest Limited
5 The Heights, Brooklands, Weybridge, Surrey, KT13 0NY

Bute Island Foods Ltd.

Data Protection Officer

datacontroller@saputo.com

Data Protection Officer,
Bute Island Foods Ltd.,
The Creamery Townhead, Rothesay, Isle Of Bute, PA20 9JH

 

 

 

 

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 contact us in the first instance.

11. Changes to this privacy notice

We reserve the right to make changes to this privacy notice at any time.

This version was last updated on 11 April 2023.

If you have any questions about this privacy notice, please contact datacontroller@saputo.com