PICCOLO FOODS LIMITED – Privacy notice

Welcome to Piccolo Foods Limited’s privacy notice

We respect your privacy and are committed to protecting your personal data. This privacy notice tells you how we look after your personal data, as well as letting you know about your privacy rights and how the law protects you.

Please click on the links below to find out more about each topic.

• What does this Privacy Notice cover?
  • This privacy notice sets out how we collect and use your personal data through your use of this website, including any data you may provide through this website when you join the Piccolo Family Club, sign up to our newsletters or register with us, take part in a competition or promotion, or participate in any other activities or interactive services on the website.
  • It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we collect or use your personal data, so that you are fully aware of how and why we are using it. This privacy notice supplements any other notices and is not intended to override them.
• Who are we and who is responsible for your personal data?
  • We are Piccolo Foods Limited. We are a private limited company, registered in England and Wales with company number 9213668. Our registered office address is Piccolo Foods 112 St. Augustine Street C/O Portt & Co, Suite 1.02, Collar Factory, Taunton, Somerset, United Kingdom, TA1 1QN.
  • Piccolo Foods Limited is the controller of and responsible for your personal data.
  • If you have any questions about this privacy notice or our use of your personal data, please contact us using the following details: email info@piccolofoods.uk, telephone our customer service line on +44 (0)208 050 3202 or write to us at Piccolo Foods 112 St. Augustine Street C/O Portt & Co, Suite 1.02, Collar Factory, Taunton, Somerset, United Kingdom, TA1 1QN
  • If you visit our website or receive emails from us, you may find links to third-party microsites or 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 any of those third-party websites, plug-ins or applications, and are not responsible for their privacy statements. When you click on a link, whether it be on our website or in our emails, newsletters, or other communications, you will leave our website or other communication, and when this happens, we encourage you to read the privacy notice of every microsite, website or application you access.
  • For example, if you decide to join the Shopmium community in order to take advantage of money saving deals, you will be directed from the link we provide on our website or in our email or newsletter, to a microsite which is owned and managed by Shopmium. Whilst Shopmium is one of our third party partners, we do not control its website and are not responsible for its collection and use of your personal data. We never share your personal data with Shopmium and it is for you to read its privacy notice and decide whether to provide your personal data to it.
• What type of personal data do we collect?
  • Personal data, or personal information, means any information about you from which you can be identified. It does not include data where your identity has been removed. This is called anonymous data.
  • We may collect, use, store and transfer different kinds of personal data about you, as follows:
    • identity data: includes your full name, username or similar identifier, marital status, title, date of birth and gender;
    • contact data: includes your email address and telephone numbers;
    • technical data (when you visit our website): includes internet protocol (IP) address, your login data, 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 website;
    • profile data: this includes your username and password, your interests, preferences, feedback and survey responses;
    • usage data: includes information about how you use our website, products and services and sign up and usage data relating to any registration and use you make of Shopmium; and
    • marketing and communications data: includes your preferences in receiving marketing from us and your communication preferences.
  • 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.
  • Our website is not intended for use by children (who are under 13 years of age) and we do not seek to collect or otherwise process children’s data in the ordinary course of our business. However, as a manufacturer of baby food products, we have to respect the legal requirements for the communication and marketing of baby food products, and we may therefore need to ask for your expected birth date or age of your child in order to personalise the information and content we provide to the stage of your pregnancy or age of your child, in order to comply with those legal requirements.
  • There are also occasions when we collect personal information about children who are under 13 years of age from the parent or guardian directly, and with that parent or guardian’s explicit consent. We do this in order to provide you with personalised offers, news and competitions, and we only do so if you provide us with your prior explicit consent, which is voluntary. For example, if you join the Piccolo Family Club, we will ask you to provide your child’s (or children’s) first name(s) and date(s) of birth. If you provide this information to us, we will use it to personalise your use of the Piccolo Family Club and to supply content and offers that are appropriate to your life stage and that of your child (or children).
  • 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.
• How do we collect your personal data?
  • We use different methods to collect your personal information, through direct interactions with you, through our use of automated technologies and your interaction with our website, and indirectly, through third parties. These are described in more detail below.
  • Direct Interactions. You may give us certain information, such as identity and contact data, by filling in forms on our website, by visiting us in person, or by corresponding with us by post, phone, email or other method. This includes personal data you provide when:
    • you register as a user of our website or for an account with us or join the Piccolo Family Club;
    • subscribe to our services or publications via our website, email or social media channels;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies. As you interact with our website, 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. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties (including publicly available sources). We will receive personal data about you from various third parties or public sources, as follows:
    • identity and contact data, and usage data, from our third party partner, Shopmium, based in the EEA;
    • technical data from analytics providers such as Google Analytics and Facebook Custom Audiences;
  • How do we use your personal data?
    • We use your personal information for our general business activities. In particular, we may use your personal information to:
      • register you as a new customer, as a new user of our website, and/or as a new member of the Piccolo Family Club;
      • manage our relationship with you, including as a member of the Piccolo Family Club. This may include providing you with information that you request from us, responding to your queries or asking our own queries, notifying you of changes to our terms of privacy notice, and asking you to leave a review or take a survey;
      • enable you to participate in any interactive features of our website, when you choose to do so;
      • enable you to partake in a prize draw, competition or complete a survey;
      • deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
      • administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
      • use data analytics to improve our website, the products and services we provide, our marketing, customer relationships and experiences;
      • to make suggestions and recommendations to you about goods or services that may be of interest to you;
      • enforce or apply any contract we have with you; and
      • comply with any legal or regulatory obligation which is imposed on us.
    • We also use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
    • You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
    • You can ask us 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 at any time.
  • What lawful basis do we have to collect and use your personal data?
    • 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. Our legitimate interest is in conducting and managing our business to enable us to give you the best goods and services, and to provide you with the best and most secure experience when using our website. We make sure that 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);
      • where we need to perform the contract we are about to enter into or have entered into with you; and/or
      • where we need to comply with a legal or regulatory obligation we are subject to.
    • For example, as a manufacturer of baby food products, we have to respect the legal requirements for the communication and marketing of baby food products. In order to comply with those legal requirements, we may need to ask for certain personal data relating to you or your child (or children). Please see section 3.4 of this privacy policy for further information.
    • Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent:
      • before sending direct marketing communications to you via email or text message; and
      • before collecting any personal data relating to your child (or children) for the purpose of providing you with personalised offers, news and competitions, as explained in section 3.5 of this privacy policy;

You have the right to withdraw these consents at any time by contacting us.

• If you would like to find out more about the types of lawful basis that we rely on to process your personal data, please contact us.

• Who do we share your personal data with?
  • We may share your personal data with the following entities:
    • Mailchimp (an online marketing platform) operated by The Rocket Science Group LLC (a company headquartered in the State of Georgia in the United States) which provides us with services relating to the sending and management of email campaigns and advertisements, and real-time data analytics services. Please see section 7.3 for more information about Mailchimp and our use of its services.
    • other companies and persons who provide services to us. For example, we engage other companies to provide us with services such as:
      • postal and courier companies such as Royal Mail (based within the EEA);
      • data analytics service providers such as Google and Facebook Custom Audiences (based in the United States);
      • Campaign Monitor an email newsletter management platform;
    • companies and other persons with whom we engage to provide prizes for competitions or promotions we may hold from time to time. These third parties will change depending on the competition or promotion, but the rules applicable to the competition or promotion will tell you who those third parties are;
    • professional advisers (such as lawyers, bankers, auditors and insurers in the UK who provide us with consultancy, banking, legal, insurance and accounting services);
    • government bodies, regulators and other authorities in the UK who require reporting of activities in certain circumstances (such as HMRC);
    • third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners must use your personal data in the same way as set out in this privacy notice.
  • We 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 service providers to use your personal data for their own purposes, and we only allow them to process your personal data for specified purposes and in accordance with our written instructions.
  • We use Mailchimp to provide us with services relating to the sending and management of email campaigns and advertisements, and real-time data analytics services. In order to send an email campaign or use the services which Mailchimp provides, we need to share your personal data with Mailchimp, such as your name, email address, address or telephone number. Mailchimp uses this information to provide the services we ask for in accordance with your instructions. Mailchimp is required to keep your personal data secure, and is not permitted to sell it. It may however share your information with its own third party service providers who help it to provide and support the services it provides to us. We encourage you to read Mailchimp’s own privacy policy which can be found online at https://mailchimp.com/legal/privacy/.
• Where do we process your personal data?
  • Some of our external third parties with whom we share your personal data are based outside of the EEA so their processing of your personal data will involve a transfer of your personal data outside of the EEA.
  • Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
    • we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
    • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
    • where we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States.
  • In particular, Mailchimp (who we engage to provide us with services relating to the sending and management of email campaigns and advertisements and real-time data analytics services) is a company headquartered in the State of Georgia in the United States. Its servers and offices are located in the United States, which means that when we share your personal data with Mailchimp, it may be transferred to, stored, or processed in the United States. Mailchimp participates in and has certified its compliance with the EU-US Privacy Shield Framework, which requires it to provide similar protection to personal data as is provided by the laws of England and Wales and is one of the safeguards implemented to ensure that your personal data remains safe. You can learn more about the Privacy Shield Frameworks and view Mailchimp’s certification by visiting the US Department of Commerce’s Privacy Shield website here: https://www.privacyshield.gov/welcome
  • Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
• How do we keep your personal data secure?
  • 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 confidentiality obligations.
  • 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 use your personal data for?
  • We will only use your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
  • To determine the appropriate retention period for your personal data, we consider its amount, nature, and sensitivity and the potential risk of harm from unauthorised use or disclosure of it. We also look at the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as the applicable legal requirements.
  • Details of our 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 we may 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.
• Your legal rights
  • Under certain circumstances, you have rights under data protection laws in relation to your personal data, as follows:
    • 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 personal information 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 personal information unlawfully or where we are required to erase your personal information 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 information 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
    • request us to port 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 (including consent to the use of your child’s (or children’s data) as explained in section 3.4 of this privacy policy. 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 you with access to the Piccolo Family Club, or provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • If you wish to exercise any of your legal rights, please contact us.
  • You will not have to pay a fee to exercise any of your legal 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.
  • We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of your legal 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.
  • 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.
• Changes to this Privacy Notice
  • This privacy notice was last updated on [17/10/2023] and will be reviewed and updated from time to time. Older versions can be obtained by contacting us. Where there is a significant change to our privacy notice, we will use reasonable endeavours to notify you.23