Privacy policy

“Policy on the protection of your Personal Data”

WISMETTAC HARRO FOODS LTD (“the Company”) values your privacy and is committed to protecting your personal data in accordance with applicable privacy laws. This Privacy Policy (the “Policy”), explains how we collect and use your personal data, both on our website (the “Site”) and generally. The use of this Site is subject to this Policy.

This notice explains how information about you is used. The Company will be the data controller and can be contacted as follows:

In this Policy, references to ‘we’ or ‘us’ mean the Company and our group companies.

This Policy will provide you information about the following:
  1. What personal data is collected about you?
  2. How and for which purposes does the Company use the personal data that has been collected?
  3. Legal Grounds
  4. With whom may your personal data be shared?
  5. The kind of security measures that are in place to protect your personal data
  6. Which rights do you have and in particular how can you request access, rectification and deletion of your personal data?
  7. To whom can you address questions regarding this Policy and/or the protection or processing of your personal data?
  8. Access
  9. Retention
  10. Cookies
  11. Last Update
  12. Changes to this Policy
  13. Your Country Contact
1. What personal data is collected about you?

Certain activities carried out by the Company, including on our Site, require the collection and processing of your personal data. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and the Data Protection Act 2018, and we are responsible for that personal information for the purposes of those laws.The categories of personal data we may collect and process include:

  • contact information that assists us in communicating with you, including your name, job title, mailing address, telephone numbers, email address or other addresses that allow us to send you messages, company information and registration information you provide on our website;
  • relationship information that assists us in doing business with you, such as the types of products that may interest you, contact and product preferences, languages, marketing preferences and demographic data;

  • transactional information about how you interact with us, including purchases, inquiries, customer account information, order and contract information, delivery details, billing and financial data, details for taxes, transaction and correspondence history, and information about how you use and interact with our websites; and

  • security and compliance information that assists us to secure our interests, including information for fraud prevention and internal verification, as well as information necessary for the security of our premises, such as visual recordings.
2. How and for which purposes does the Company use the personal data that has been collected?

We use your personal data collected on the Site and by other means to (i) manage our customer relationship, including interacting with you, fulfilling your orders and requests; (ii) send you from time to time information or updates on products and services, promotions and other marketing materials, subject to your consent where required; (iii) to facilitate the Company’s online operations, to understand the Site usability and performance and to maintain and improve the services offered on this Site; and to (iv) manage our business needs, such as payment processing and account management, product development, contract management, corporate governance, audit, and compliance

The provision of information by you is entirely voluntary. If you do not provide your information it may not be possible for us to provide any goods or services.

We gather information directly from you and also via other technical systems. These may include, for example, our: computer networks and connections, communications systems, email systems, intranet and Internet facilities, telephones, CCTV systems, and other hardware and software owned, used or provided by or on behalf of us and our group companies.

3. Legal Grounds

Processing can take place when it is necessary to perform a contract between us, or where we are both taking steps to enter into a contract. It can also take place based on our legitimate interests or those of a third party. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests may be that we are carrying or may carry on business with your employer. There is a limited privacy impact on you, and we think that you will expect that we will process your data in this way. Sometimes processing will take place based on your consent, such as when you give us your clear and express permission to do something with your personal data. Whenever you have given consent you can withdraw it at any time.

We process information about you for the following reasons:

*What we use your information for;
To provide our goods and services

For the performance of our contract with you or to take steps at your request before entering into a contract, or for our legitimate interests if we are entering into a contract with your employer

Providing customer services, analysing preferences and improving services

For the performance of our contract with you, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price, and to comply with our legal and regulatory obligations

To improve user experience

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Operational reasons, such as recording transactions, training and quality control, security (including CCTV) and ensuring business policies are adhered to

For our legitimate interests or those of a third party, i.e. for security purposes and to be as efficient as we can so we can deliver the best service for you at the best price

Conducting checks to identify our customers and verify their identity, screening for financial and other sanctions or embargoes, and other processing necessary to comply with professional, legal and regulatory obligations, corporate governance obligations and good practice that apply to our business, e.g. under health and safety regulation or rules issued by any regulator

For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you, and to comply with our legal obligations

Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
To comply with our legal and regulatory obligations
Security vetting, preventing fraud, investigating claims, complaints and allegations of criminal offences

For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you, and to comply with our legal obligations

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information, and to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you, and to comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract, to comply with our legal and regulatory obligations, and for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations, and for our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standard, and to comply with our legal and regulatory obligations

Marketing our business and those of our group

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including promotions or new products or services. We have a legitimate interest in processing your personal information for promotional purposes (see above). Where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never share it with other organisations outside our group for marketing purposes. You have the right to opt out of receiving promotional communications at any time by contacting our Data Protection Manager.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

4. With whom may your personal data be shared?

The Company will share your personal data only with the following business partners and third parties:

(i) Service Providers

The Company sometimes uses third parties, such as marketing companies, logistics partners or IT service providers, to perform tasks on its behalf and may need to share your personal information with them to provide the services above to you. Any processing of that personal data will be on our instructions and compatible with the original purposes for which the data was collected. We only share information with such service providers if we are happy that they take appropriate measures to protect your personal information.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

(ii) Legal Obligations

As required by law, the Company may disclose your personal data to law enforcement officials, in order to comply with legal requirements, court orders, government or law enforcement agency requests, including to meet national security or law enforcement requirements, and including to agencies and courts in the countries where we operate. Where permitted by law, we may also disclose such information to third parties (including legal counsel) when necessary for the establishment, exercise or defense of legal claims or to otherwise enforce our rights, protect our property or the rights, property or safety of others, or as needed to support external audit, compliance and corporate governance functions.

Information may be held at our offices and those of our group companies, and service providers, representatives and agents as described above. Information may be transferred internationally to Japan and other countries around the world, including those without data protection laws equivalent to those in the UK, for the reasons described above. We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our information security and data protection policies, which are available on request.

Japan has received a finding of adequacy from the European Commission, so you can be satisfied that you continue to enjoy equivalent data rights whenever your data has been transferred to Japan. For international data transfers to other countries outside the European Economic Area, we protect your data by using Standard Contractual Clauses, as per GDPR Article 46(2).

If you would like further information, please contact our Data Protection Manager. We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

5. The kind of security measures that are in place to protect your personal data

We apply technical, physical and organizational measures that are designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and against other unlawful forms of processing. Access to personal data is restricted to authorized recipients on a need-to know basis. We also maintain a data security practice that is proportionate to the risks associated with the processing of your personal data. The practice is continuously adapted to protect personal data, taking into account industry-accepted practices. The Company is not responsible for the safety of your personal data transmitted to the websites of any other companies that may be linked to this Site. Visitors to any such websites should refer to such websites’ privacy policies or terms of use.

6. Which rights do you have and in particular how can you request access, rectification and deletion of your personal data?

You have a number of important rights, which can be exercised free of charge. You have the right to request:

access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address require us to correct any mistakes in your information which we hold require the erasure of personal information concerning you in certain situations receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations object at any time to processing of personal information concerning you for direct marketing object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you object in certain other situations to our continued processing of your personal information otherwise restrict our processing of your personal information in certain circumstances.

We will not do anything with your data not outlined in this notice.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, or if you have any complaints, please contact our Data Protection Manager at gdpr@wismettacuk.co.uk, providing enough information to identify you and let us know which information to which your request relates.

If you are not satisfied with any complaint you have with us, you also have the right to make a complaint to the Information Commissioners Office, which is the supervising authority in the UK in relation to data processing. You can contact the Information Commissioner at ico.org.uk/concerns/ or by telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

7. To whom can you address questions regarding this Policy and/or the protection or processing of your personal data?

In the event that you have any questions regarding this Policy and/or the protection or processing of your personal data, please contact us at: gdpr@wismettacuk.co.uk

In the event that the Company receives your inquiry about this Policy and/or the protection or processing of your personal data, your personal data will only be used for the purposes of responding to your inquiry.

For any additional questions and for your information, our Data Protection Managers are: Mel Abert, Matthew Rogers, and Branwyn Darlington.

8. Access

By accessing and using the Site, you understand and agree to the collection, processing, international transfer and use of your personal data as set forth in this Web Privacy Policy. As this Web Privacy Policy can be modified at any moment without prior notice, you are advised to regularly consult this Web Privacy Policy.

Where required by law, we will ask your explicit consent. You may always object to the use of your personal data for direct marketing purposes or withdraw any consent previously granted for a specific purpose by clicking on relevant links on our websites, following the directions contained in an email or by contacting us at the email address above.

9. Retention

We may retain your personal data no longer than necessary for the purposes for which it was collected or as required by applicable law, in line with our retention policy.

10. Cookies

As is the case with many websites, our Site may use cookies and other automated information collection means, subject to your consent where required. Cookies are information about you from our website that is stored on your browser or hard drive. Cookies save you time because you do not need to manually re-enter the information stored on your hard drive. Cookies also help us upgrade our website by showing when and how users use our website. You can set your browser to notify you when a cookie is sent or refuse cookies altogether, but certain features of our website might not work without cookies.

Our website may also use IP addresses for the same purposes identified above, as well as to analyze trends, administer our website, track users' movements and online activity and gather broad demographic information for aggregate use.

We may use web beacons on our website to access and set cookies and otherwise help us to better understand how users are moving through our website. Information provided by the web beacon includes the computer's IP address, the type of browser being used and the time that the web beacon was viewed. We may also use web beacons in emails and newsletters so that we know when such communications have been opened and to otherwise help us tailor our communications to individual users.

11. Last Update

This Web Privacy Policy was last updated on: 7 October 2021

12. Changes to this Policy

Without limiting your rights as described in this Policy, the Company reserves the right to alter or otherwise update this Policy at any time. When the Company makes changes to this Policy, the date of the occurrence of such changes will be indicated on this Site under section 11.

13. Your Country Contacts

Mel Abert
gdpr@wismettacuk.co.uk

Matthew Rogers
gdpr@wismettacuk.co.uk

Branwyn Darlington
gdpr@wismettac.co.uk