ABOUT THIS NOTICE
Coregeo Limited is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
Data protection law says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely
If you have any questions about this notice or how we collect and use personal information about you please contact us using the contact details set out in paragraph 1.2.
1 INFORMATION ABOUT US
1.1 We are Coregeo Limited. Our registered office is at Henwood House, Henwood, Ashford, Kent, TN24 8DH and our registered company number is 03812840.
1.2 If you have any questions, our contact details are:
1.2.1 Orwell Place, 172 Tonbridge Road, Wateringbury, Kent ME18 5NS
1.2.2 01622 816999
2 COMPETITION INFORMATION AND OTHER CORRESPONDENCE
2.1 When you enter into a competition or prize draw with us (or someone running a competition in partnership with us) there will be personal information about you relating to that entry such as your name, contact details, entry details, and correspondence with us about the entry. We may also ask for information about certain preferences, such as your preferred retailer.
2.2 We (or the partner running the competition) need certain information to accept entries and you must provide this in order to enter a competition or prize draw with us, if you do not, your entry may not be accepted. Competition information will generally set out what information is strictly required when the relevant information is collected from you, but in particular, you must provide your name and contact details.
2.3 Other correspondence or interaction (for example by email, telephone, post, SMS or via our website) between you and us will include personal information (such as names and contact details) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organisation.
2.4 We will keep and use that information to operate any competitions we run, to comply with any legal requirements for us to maintain certain records or carry out certain verifications, and/or for our legitimate interests in dealing with a complaint or enquiry and administering your (or your organisation’s) account or order and any services we offer, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
2.5 If you are a competition winner, we may publish your name and location on our website or otherwise make it publically available in order to comply with our legal obligations and for our legitimate interests in publicising the competition.
2.6 Where your information relates to a competition, it is kept for a period of up to 12 months after the competition closes to enable us to deal with any enquiries or claims.
2.7 Any other information is generally kept for 24 months after our last correspondence.
2.8 In order to enter any competition with Pink Lady, you must subscribe to the newsletter database, but you can unsubscribe at any time.
3.1 We may collect your name and contact details (such as your email address, phone number or address) in order to send you newsletters about the brands which we represent. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so.
3.2 You always have the right to “opt out” of receiving our marketing. You can exercise the right at any time by contacting us using the contact details set out in paragraph 1.2 above. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing.
3.3 If you are acting as a business we use your contact details as necessary for our legitimate interests in marketing to you and maintaining a list of potential customers.
3.4 If you are not acting as a business, we will only contact you for marketing purposes with your consent (whether we have collected your details directly from you, or through a third party).
3.5 We never share your name or contact details with unrelated third parties for marketing purposes unless we have your consent to share your details with those specific third parties. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
3.6 We retain your details on our marketing list until you “opt-out” at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we don’t accidentally send you any more marketing.
4 WEBSITE INFORMATION
4.1 We may collect information about you and your use of our website via technical means such as in, webpage counters and other analytics tools. We use this as necessary for our legitimate interests in administering our website and to ensure it operates effectively and securely.
4.2 For detailed information on the cookies we use and the purposes for which we use them see our Cookie Notice.
4.3 We keep this website information about you until the relevant cookie expires.
4.4 Our website may, from time to time, contain links to and from the websites of our brand partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
5.1 This is information about you which you provide when you post content on our website. This may include reviews, photographs, videos and other content which you post on our website.
5.2 We may display and publish this information on our platforms as part of our contract with you or as necessary for our legitimate interests in providing content to our users.
5.3 This information is kept for as long as you have an account with us and may be retained and displayed indefinitely after you close your account. You may request that your content is removed by contacting us using the contact details set out at paragraph 1.2 above.
6 EMPLOYEE INFORMATION
6.1 If you work for one of our customers, suppliers, licensees, growers or other business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you, or provided by your organisation. Your organisation should have informed you that your information would be provided to us, and directed you to this policy. We use this as necessary for our legitimate interests in managing our relationship with your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation.
6.2 We keep this information for up to seven years after the end of our relationship with your organisation.
7 JOB APPLICANTS
7.1 We will collect and hold information on job applicants, including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide.
7.2 We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.
7.3 If you are successful in your application, your information will be used and kept in accordance with our internal privacy notice. If you currently work for us, or used to work for us, you can request a copy of this from us. If you are not successful in your application, you information will be held for up to 12 months after the relevant round of recruitment has finished.
7.4 You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.
7.5 If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant’s information.
7.6 If you are listed as an emergency contact by someone who works for us, we will hold your name, contact details and details of your relationship with that worker. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that worker, and for our legitimate interests in administering our relationship with that worker. Your information will be kept until it is updated by that worker, or we no longer need to contact that worker after they have stopped working for us.
8 LEGAL CLAIMS
8.1 Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.
9 OTHER TYPES OF INFORMATION
9.1 We may also receive information about you from the following sources:
9.1.1 Our service providers. We work closely with third parties (including, for example, advertising partners and PR agencies) who may provide us with information about you, to be used as set out above.
9.1.2 Businesses we have bought. If we have acquired another business, or substantially all of its assets, which originally held your information, we will hold and use the information you provided to them, or which they otherwise held about you, in accordance with this privacy notice.
9.1.3 Our other channels. This is information we receive about you if you use any of the other websites we operate or the other services or products we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data.
9.2 We do not collect any “special categories” of more sensitive personal information 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, as well as information about criminal convictions and offences).
10 WHY ELSE DO WE USE YOUR INFORMATION?
10.1 Common uses of your information. We will only use your personal information when the law allows us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally use your information in the ways set out in this notice because:
10.1.1 we need to perform a contract we have entered into with you.
10.1.2 we need to comply with a legal obligation.
10.1.3 it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
10.1.4 we need to protect your interests (or someone else’s interests) or where it is needed in the public interest (although these circumstances are likely to be rare).
10.2 Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
11 SHARING YOUR INFORMATION
We work with fresh produce brands to take their products to market. Where we hold your information in relation to a specific brand, we will be responsible for the decisions around how we use your information, and for keeping it secure while it is in our control. If you have any queries about how we use your information as set out in this notice, you can contact us using the contact details set out in paragraph 1.2 above. If we share your information with those brand owners, we will only do so if it is allowed under data protection law, and the brand owners will then be directly responsible to you for their use of that information.
As well as any sharing listed above, we may also share your information with other third parties, including third-party service providers and other entities in our group. Third parties are required to respect the security of your personal information and to treat it in accordance with the law. We never sell your data to third parties.
11.1 Why might we share your personal information with third parties?
We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
11.2 Which third-party service providers process your personal information?
We also may need to share your personal information for third-party service providers (including contractors and designated agents) so that they can carry out their services.
The following activities are carried out (in full or in part) by third-party service providers: legal advice, competition administration, IT services.
11.3 When might we share your personal information with other entities in the group?
We may share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data.
11.4 How secure is your information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. Where third parties process your personal information on our behalf as “data processors” they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
11.5 What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. We may also need to share your personal information with a regulator or to otherwise comply with the law.
12 WHERE WE STORE YOUR INFORMATION
12.1 Our office headquarters are based in Wateringbury and our main data centre is located in the UK. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be processed by staff operating outside the UK and EU who work for one of our service providers.
12.2 We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
12.3 Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an “adequacy decision” in place, meaning the EU considers them to have an adequate data protection regime in place. These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
12.4 If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required. To obtain more details of these safeguards, please contact us.
13 DATA SECURITY
13.1 As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
13.2 We have 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 necessary.
14 HOW LONG WILL WE KEEP YOUR INFORMATION FOR?
14.1 We have set out above indications of how long we anticipate holding your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
14.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
14.3 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
15 YOUR RIGHTS
15.1 Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner’s Office (ICO). Under certain circumstances, by law you have the right to:
15.1.1 Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
15.1.2 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
15.1.3 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
15.1.4 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
15.1.5 Object to processing of your personal information 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 us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
15.1.6 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
15.1.7 Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
15.1.8 Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.
15.1.9 Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us using the contact details set out in paragraph 1.2 above.
15.2 No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
15.3 What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
15.4 Timescale. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
16 CHANGES TO THIS PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.
For the same reason, we may obtain information about your general internet usage by using a cookie file, which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate.
The cookies we currently use are as follows:
- Session cookie: this cookie is used to ensure you are recognised when moving from page to page within our website. For example, if you are a registered user then it prevents you from having to log in separately on every page. It is deleted when you close your browser.
- Google Analytics (__utma, __utmb, __utmc, __utmz): these cookies are used to collect information about how visitors use our site. The information includes the time of the current visit, whether you have been to the site before, what site referred you here, demographics and interest reports. We use this information to estimate our audience size and usage pattern, so that we can improve our site by understanding how people use it. Click here for further information from Google on Google Analytics and your privacy.