Effective Date: 5th August 2019.
This website is not intended for children and we do not knowingly collect data relating to children.
Contact details for the Data Controller and DPO Email: firstname.lastname@example.org Postal address: Data Protection Officer, Ocado Retail, Apollo Court, 2 Bishop Square, Hatfield Business Park, Hatfield, Herts, AL10 9EX.
You have the right to make a complaint at any time to a supervisory authority. The Information Commissioner’s Office (ICO) is 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 a supervisory authority so please contact us in the first instance.
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.
“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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name and last name.
- Contact Data includes postal address, email address and telephone number.
- 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.
- Profile Data includes your username and password.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving newsletters from us.
Except as outlined in our recruitment policy (which will be available in due course), 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.
If you fail to provide personal data
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.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you contact us or subscribe to our newsletter(s).
- Automated technologies or interactions. As you interact with our website, we will 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. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We will receive personal data about you from analytics providers, such as Google, based outside the EU.
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:
- 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.
- Where we need to comply with a legal obligation.
We do not rely on consent as a legal basis for processing your personal data other than in connection with sending you our newsletter where you have requested us to do so. You have the right to withdraw consent to marketing at any time by contacting us or unsubscribing via any link or instructions contained in the direct marketing communication you receive from us.
Purposes for which we will use your personal data
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 we rely on our legitimate interests as the legal basis for processing your personal data.
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 need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and correspond with you)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(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 analytics to improve our website and visitor experiences||(a) Technical
|Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To send you our general newsletter||(a) Identity Data
(b) Contact Data
(c) Marketing and Communications
|Consent (you consent to receive our general newsletter by subscribing using the forms on our website)|
|For fraud detection, monitoring, prevention and investigation||(a) Identity
(b) Contact Data
|Necessary for our legitimate interests (to prevent fraud)|
You can ask us or third parties 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.
Please note that if you decide to opt out or unsubscribe it could take up to 72 hours to process the update through our systems.
Cookies and similar technologies
When you visit our website, our web server collects some basic information such as your internet service provider’s domain name, which pages you accessed on our site, and when.
Types of cookies used
We use the following types of cookies on our website for the following purposes:
Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features, including accessing secure areas, such as the privacy centre.
Functional cookies. These cookies allow our website to ensure or check certain functionality is working on our website such as various lines of code.
Analytical/performance cookies. These cookies collect information about how you and other visitors use our websites. This can be anything like which pages you go to most often, and if you get error messages from web pages. We use data from these cookies to help test designs and to ensure a consistent look and feel is maintained on your visit to our websites. We use third-party web analytics software on our websites and apps (such as Google Analytics), further information about which is set out below.
Social media extensions. These technologies allow you to share what you’ve been doing on our websites on social media, such as Facebook and Twitter. For example, by clicking the ‘Facebook Like’ icons that may appear on our product pages. Although we enable these tools to be displayed on our websites so that you may interact with them, if you choose to do so, they are not within our control. Please refer to the relevant third party privacy policies for how these functionalities work.
Managing and disabling cookies
If you do not want to allow cookies at all, or only want to allow the use of certain cookies, please refer to your browser settings.
Further information about cookies
To opt-out of Google Analytics for Display Advertising and customize Google Display Network ads please go to https://www.google.com/settings/ads or Google Analytics’ currently available opt-outs for the web.
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 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.
We may share your personal data with the parties set out below for the purposes set out in the table above.
- External Third Parties as set out in the Glossary.
We contractually 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.
Our operations are principally based in the UK and the personal data that we collect from you is mainly processed, stored and used within the UK and other countries in the European Economic Area (EEA). However, in order to offer you the best service we can provide, we also work with service providers from other parts of the world. This means that the data we collect sometimes needs to be transferred, stored and used by companies operating outside the EEA who work for us or one of our service providers. We want you to know that we have taken steps to ensure there is an appropriate level of security for the processing carried out in these countries, such that data is protected in the same way as if it was being used within the EEA.
This includes it going through one of the following safeguards:
- The use of European Commission-approved standard contractual clauses in contracts for the transfer of personal data to third countries.
- The transfer to organisations that are part of the EU-US Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
- Transfers to a non-EEA country with privacy laws that give the same protection as the EEA.
You can find out more about the above data protection safeguards on the European Commission Justice website here: https://edps.europa.eu/data-protection/data-protection/reference-library/international-transfers_en
For more information on how we safeguard transfers of your personal information, please contact us at email@example.com. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.
In some circumstances we will 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- [Request access to your personal data].
- [Request correction of your personal data].
- [Request erasure of your personal data].
- [Object to processing of your personal data].
- [Request restriction of processing your personal data].
- [Request transfer of your personal data].
- [Right to withdraw consent].
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 could 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 could 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data 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.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
EXTERNAL THIRD PARTIES
- Service providers based inside and outside the EU which provide:
- IT, system administration and business support services.
- Applicant tracking systems and recruiting software providers.
- Data analytics providers to help us understand how you use our services.
- External companies to provide post or delivery services.
- General service companies such as printers and mailing houses.
- Companies that help us track and record the way you navigate our websites and use our applications to understand how you use those websites and applications.
- Other companies that help us provide our website and applications, improving functionality.
- Enforcement companies, based inside and outside the EU when we believe it is necessary to comply with the law or enforce our rights under our terms and conditions or to protect the rights, property or safety of the Ocado Group, our employees or customers, our business partners or others.
- Certain third parties, based inside and outside the EU, where we have reason to suspect fraud or the commission of any other criminal offence offence. Such third parties may include business partners, law enforcement bodies, providers of fraud prevention and detection services, and recipients of fraud prevention and detection services.
- Professional advisers including lawyers, bankers, auditors and insurers based inside and outside the EU which provide consultancy, banking, legal, insurance and accounting services.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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 (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.
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.
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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
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 provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
FULL LIST OF COOKIES USED
|Name of cookie||Type of cookie||Session or persistent cookie (expiry date if persistent)||First or third party cookie?||Purpose|
|cookie_notice_accepted||Strictly necessary||Persistent (1 year)||Third party||Tracks whether user has consented to placement of non-essential cookies on their device.|
|pojo-a11y||Optional||Session (1 month)||Third party||Local browser storage of what accessibility option(s) is selected.|