Privacy Policy - James Robinson Speciality Ingredients

James RobinsonCustomer Privacy Policy

1. Introduction

In this privacy policy:

1.1 references to we, us or our means James Robinson Speciality Ingredients Limited (CRN 00069842) whose registered office is at PO BOX B3, Leeds Road, Huddersfield, West Yorkshire, HD1 6BU which is the entity that supplies you with goods or services and is identified in the contract we have with you or the Customer;

1.2 references to you or your means any individual who we supply goods or services to or is otherwise engaged or employed by one of our Customers;

1.3 references to Customer means any organisation that we supply goods or services to; and

1.4 references to Websites means http://www.jrsi.com/

2. Privacy Policy

2.1 This Privacy Policy (together with the terms of engagement or contract which governs our supply of goods or services) sets out the basis on which we collect and use personal information about you when we supply goods or services to you or our Customer.

2.2 This Privacy Policy describes:

2.2.1 who is responsible for the personal information that we collect about you;

2.2.2 the personal information we collect about you;

2.2.3 how we will use it;

2.2.4 who we may disclose it to; and

2.2.5 your rights and choices in relation to your personal information.

This is to make sure you have a full picture of how we collect and use your personal information.

2.3 In this Privacy Policy where we use the words personal information we use these words to describe information that is about you and other individuals (for example, your emergency contact/next of kin) and which identifies you or those individuals.

2.4 You have the right to object to our use of your personal information in certain circumstances. A summary of your right to object (along with other rights under data protection law) and the details of who to contact if you want to exercise them can be found at paragraphs 10 and 12 below.

3. Who is responsible for the personal information that we collect?

We are the data controller for the purpose of data protection law in respect of your personal information collected and used in connection with the provision of goods or services by us to you or our Customer. This is because we dictate the personal information we collect about you and the purpose or purposes for which we use it.

4. What personal information do we hold about you?

4.1 We collect and use personal information about you in the course of us providing goods or services to you or our Customer.

The personal information we hold includes:
4.1.1 Information that you provide to us/we collect from you The information that you provide to us/we collect from you may include the following:

General

Type of Personal Information	Example
Identity Information	Includes name, e-mail address and business address.
Contact information	Postal address, email address and telephone number.
Log in details	Username and account number for access to the Website and systems provided under our contract with you or the Customer.
Transaction Information	Details about payment to and from you and other details of products and goods or services you have purchased from us.

Financial

Type of Personal Information	Example
Financial information and account details	Bank account number or other financial account number and account details

Marketing

Type of Personal Information	Example
Marketing preferences (including details of subscriptions to any newsletters)	Details of any marketing preferences that you express including any opt outs you provide

Other

Type of Personal Information	Example
CCTV footage	Images captured on CCTV provided by our landlord, Syngenta, if you visit our premises
Through our use of cookies on our Websites	Cookies are pieces of information stored directly on the device you are using. Cookies allow us to recognise your device and to collect information such as internet browser type, time spent using the Websites, pages visited, language preferences and relevant country website. We may use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalise your experience while using the Websites. You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Websites and some online applications.

This information will be provided:

(a) in the course of communications between you and us (including by phone, email or otherwise);

(b) when you fill in forms for us (including those on our Websites);

(d) when you provide personal information via our Websites or using other systems which we provide to you or the Customer.

4.1.2 Information we receive / collect from other sources We may collect personal information from publicly available sources such as LinkedIn, including your name, role and business contact details.

5. How do we use the personal information we collect about you?

5.1 We use your personal information for a variety of different purposes during the course of us providing goods or services to you or our Customer. The main purposes for which we use your personal information are set out below. Under data protection law, we can only use your personal information if we have a legal basis to do so.

Examples of where we have a legal basis to process your personal information, includes when:

5.1.1 we have your consent;

5.1.2 it is necessary to enter into or perform a contract we have with you (or to take steps at your request prior to entering into that contract);

5.1.3 it is necessary to comply with a legal obligation;

5.1.4 it is necessary in order to protect your vital interests; or

5.1.5 it is in our legitimate interests to process your personal information.

5.2 We have set out the main reasons for using your personal information in the table below under the heading Legal Basis. Where we rely on our legitimate interests, we have set out those interests in the table below.

Purpose	Legal Basis
To register you as a new customer	Performance of a contract we have with you. This will only be applicable if you are a sole trader or individual to whom we are providing goods or services to.
To communicate with you and other individuals.	Legitimate interests: We require your personal information in order to enable us to supply the goods or services to you or the Customer. Performance of a contract we have with you. This will only be applicable if you are a sole trader or individual to whom we are providing goods or services to.
To process and deliver your order including: (a) manage payments, fees and charges; (b) collect and recover money owed to us.	Legitimate interests: It is in our legitimate interest to comply with the terms of a contract we have in place with a Customer and to recover debts due to us. Performance of a contract we have with you. This will only be applicable if you are a sole trader whom we are providing goods or services to.
To carry out our obligations arising from any contracts entered into between you and us or in preparation of entering into a contract with you or the Customer.	Legitimate interests: It is in our legitimate interest to comply with the terms of a contract we have in place with a Customer. Performance of a contract we have with you. This will only be applicable if you are a sole trader or individual to whom we are providing goods or goods or services to.
To manage our relationship with you which will include: (a) notifying you about changes to our terms of privacy policy; and (b) asking you to leave a review or take a survey about our service and goods.	Legitimate interests: It is in our legitimate interest to study how customers use our products/goods or services to develop them and grow our business and to comply with the terms of a contract we have in place with a Customer. Performance of a contract we have with you. This will only be applicable if you are a sole trader or individual to whom we are providing goods or services to.
To send you direct marketing communications about our products/goods or services and to share your personal information with other members of the group of companies so that they can send you direct marketing communications about their products/goods or services.	Legitimate interests: It is in our legitimate interest to contact you about goods or services that we offer. Consent: In some circumstances, we may rely on your consent to send direct marketing communications to you.
To manage any service or quality related issues, complaints, feedback and queries in relation to the supply of goods or services in accordance with the terms of the supply contract.	Legitimate interests: We require your personal information in order to ensure the goods or services we supply are fit for purpose. Performance of a contract we have with you. This will only be applicable if you are a sole trader or individual to whom we are providing goods or services to.
To analyse the goods or services we provide to you and improve the quality/performance of our goods or services.	Legitimate interests: We require your personal information in order to improve the goods or services we provide.
To comply with any legal or regulatory obligations (including in connection with a court order).	Necessary for compliance with a legal obligation to which we are subject.
To carry out credit reference checks on the Customer.	Legitimate interests: We undertake these checks to certify and assess your financial standing to ensure we receive payment for the provision of our goods and services.
CCTV recordings in the UK captured by equipment on our premises for security purposes.	Legitimate interests: We require your personal information in order to manage our security on our premises and to keep them secure.
To enable you to gain access onto our premises via a third party concierge system operated by our landlord, Syngenta.	Legitimate interests: We require your personal information in order to assist us in managing and carrying out our business operations.

5.3 Where we process your personal information on the legal basis of our legitimate interests (as set out in the table above), we have carefully considered and assessed your rights and freedoms which require protection of your personal information in respect of each specific purpose. Having undertaken this assessment, we have determined that our legitimate interests are not overridden by your rights under data protection laws. If you would like further information about how we have balanced your rights and freedoms against our legitimate interests, please get in touch using the details at the How to contact us section below.

5.4 We may be required to obtain your personal information to comply with our legal requirements, to enable us to fulfil the terms of our contract with you or our Customer (as applicable) or in preparation of us entering into a contract with you or our Customer (as applicable). If you do not provide the relevant personal information to us, we may not be able to perform our obligations pursuant to your contract with us.

6. Who may we disclose your personal information to?

6.1 We may share your personal information with:

6.1.1 our business partners, service providers and sub-contractors for the performance of any contract we enter into with you (for example, our IT providers, payroll and pension service providers, security service providers, financial service providers, insurance providers and document storage providers);

6.1.2 our landlord, Syngenta, when its employees take your personal details in order to book you on and off our premises when you come to visit us;

6.1.3 our professional advisors (including accountants, lawyers and auditors) that assist us in carrying out our business activities (for example Grant Thornton accountants and Womble Bond Dickinson (UK) LLP); and

6.1.4 external agencies and organisations (including the police, local authorities and other law enforcement agencies) for the purpose of complying with legal and regulatory obligations.

6.2 For a full list of the third parties with whom your particular personal information may be shared, please contact us using the details at paragraph 12 below.

6.3 We will also disclose your personal information to other third parties, for example:

6.3.1 in the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets;

6.3.2 if we or substantially all of our assets are acquired by a third party, personal information held by us will be one of the transferred assets; and

6.3.3 if we are under a duty to disclose or share your personal information in order to comply with any legal obligation.

7. Where will we process your personal information?

7.1 We will process your personal information both within the UK and European Economic Area (EEA).

7.2 When we transfer personal information outside the EEA, we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law, for example, we will seek to anonymise it.

7.3 If we can’t anonymise your personal information, we will take reasonable steps to ensure that your personal information is protected. To do this we use a set of standard data protection clauses, which have been approved by the European Commission. For further information as to the safeguards we implement and to obtain a copy of such information, please contact the Data Privacy Officer whose details are set out in paragraph 12 below.

8. How long will we keep your personal information?

8.1 We will retain your personal information for no longer than is necessary for the purposes for which the personal information are processed. The length of time we hold on to your personal information will vary according to what that information is and the reason for which it is being processed.

8.2 For further information about how long we keep your personal information, please contact us using the details at paragraph 12 below.

9. Data Security

9.1 We have put in place appropriate security measures to guard against your personal information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For further information about these measures, please contact us using the details at paragraph 12 below.

9.2 We have also 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.

10. Your Rights

You have certain rights with respect to your personal information. The rights will only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. Details of who to contact to exercise these rights can be found in paragraph 12.

	Summary of your rights
Right of access to your personal information	You have the right to receive a copy of your personal information that we hold about you and information about how we use it, subject to certain exemptions.
Right to rectify your personal information	You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information	You have the right to ask that your personal information be deleted in certain circumstances. For example: where your personal information is no longer necessary in relation to the purposes for which it was collected or otherwise used; - if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; - if you object to the use of your personal information (as set out below); - if we have used your personal information unlawfully; or - if your personal information needs to be erased to comply with a legal obligation.
Right to restrict the use of your personal information	You have the right to suspend our use of your personal information in certain circumstances. For example: - where you think your personal information is inaccurate but only for so long as is required for us to verify the accuracy of your personal information; - the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; - we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or - you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.
Right to data portability	You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies: - to personal information you provided to us; - where we rely on the following legal bases: - consent; or - for the performance of a contract; and - when the use of your personal information is carried out by automated (i.e. electronic) means.
Right to object to the use of your personal information	You have the right to object to the use of your personal information in certain circumstances and subject to certain exemptions. For example: - where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); - if you object to the use of your personal information for direct marketing purposes; and - where we use your personal information to take a decision which is based solely on automated processing - where that decision produces a legal effect or otherwise significantly affects you.
Right to withdraw consent	You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Right to complain to the relevant data protection authority	If you think that we have processed your personal information in a manner that is not in accordance with data protection law, you can make a complaint to the relevant data protection regulator. In the UK this is the Information Commissioner's Office (ICO) and they can be contacted on 0303 123 1113 or please see www.ico.org.uk. If you live or work in an EEA member state, you may complain to the regulator in that state.

11. Changes to our Privacy Policy

Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, we will give you reasonable notice of any changes.

12. Queries

12.1 If you have any questions regarding this Privacy Policy or the way we use your personal information, please contact us by:

12.1.1 telephone on 01484 320307 and ask to speak to the Data Privacy Officer, Vikki Harling;

12.1.2 email at vikki.harling@jrsi.com; or

12.1.3 post at FAO The Data Privacy Officer, Vikki Harling, James Robinson Speciality Ingredients Ltd, PO Box B3 Leeds Road, Huddersfield, West Yorkshire, HD1 6BU. This Privacy

Policy was last updated in July 2020.