This website (https://www.metcalfessnack.co.uk/) is owned and operated by Kettle Foods Ltd (“we,” “us,” or “our”). At Kettle Foods Limited, we are committed to protecting your privacy. We take the issue of security of your personal information very seriously.
This Policy tells you about:
What information do we gather from you and how is it collected?
How is your personal information used and on what legal bases?
How is your personal information shared?
Transferring your information outside of the European Economic Area
Protection of your personal information and retention
Questions or complaints
We are Kettle Foods Limited (company number 2238320) a leading manufacturer of premium hand cooked potato chips and snacks in the UK. Our registered office address is at 38 Barnard Road, Bowthorpe, Norwich, Norfolk NR5 9JP, UK. We are the data controller for the purposes of data protection laws, in respect of your personal information collected and used through your use of the website. We dictate the purpose for which your personal information is used and how we use your personal information. See “Questions or complaints” section below for more information on how to contact us.
As described in the section below entitled “How is your personal information shared?” we may share your personal information with other organisations, such as other entities in the Kettle Foods Family, that may receive and process your personal information as a controller in their own right.
What personal information do we gather from you and how is it collected?
We gather personal information from you, such as first and last names, telephone numbers, credit or debit card/bank details and email addresses, that you provide voluntarily when you fill in appropriate sections of our website or when we directly message with you via our social media channels or when you make a purchase direct from us. For example when you complete our “Contact Us” section, you provide us with personal information which we hold and use for the purposes set out in the next section. We may also obtain information about you when you contact us about products (e.g., nutrition/ingredient queries, product availability) or when you enter one of our competitions via our website, on pack promotions or through social media. We may collect your postal and/or email address in order to send you information you have requested or to send you a competition prize. If you make a purchase direct from us, we will collect your name and contact details as well as your debit or credit card information in order to facilitate payment due.
We also collect technical information (to the extent such information constitutes personal information) through your activity and use of the website. For example, we collect information about the devices you have used (such as the IP address you use to connect your device to the internet and the browser type and version you use on your device); and information about your use of the website and any services we offer (such as the pages you have viewed). We may receive information from other sources, such as information from any of the other websites we operate or the services we provide, if you use any of them. We make use of Google Analytics and Facebook pixels which are subject to separate terms and conditions issued by the relevant companies https://policies.google.com/privacy/update and https://www.facebook.com/about/privacy/update.
How is your personal information used and on what legal bases?
Our main aim in gathering your personal information is to provide you with a customised service. In particular, your personal information may be used by us, our employees and service providers and disclosed to third parties for the following purposes. For each of these purposes, we have set out the legal basis on which we use your personal information.
|To provide the website to you.||This is in our legitimate interest (i.e., the provision of the website to you).|
|To provide you with the services we offer (including any promotions, sweepstakes or contests).||This is in our legitimate interest (i.e., the provision of the services to you), and depending on the circumstances, to perform a contract between you and us.|
|To communicate with you and other individuals and to carry out your requests and respond to your communications.||This is in our legitimate interest (i.e., the provision and support of the website and service)|
|To carry out our obligations arising from any contracts entered into between you and us.||This is to perform a contract between you and us.|
|To notify you about changes to the website.||This is in our legitimate interest (i.e., the provision of the website and service).|
|To audit and monitor the use of the website and to improve the quality of the website.||This is in our legitimate interest (i.e., the provision of the website and service, as well as to improve and ensure the security of the website and those services).
We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law (e.g., in relation to our use of certain cookies).
|To manage complaints, feedback and queries.||This is in our legitimate interests (i.e., the provision and support of the website and service and improvements and development of our business operations).|
|To comply with any legal or regulatory obligations||This is in our legitimate interests (i.e., protection of our business, employees and customers) and for compliance with legal obligations to which we are subject.|
|To facilitate the purchase of products direct from us||Processing is necessary to fulfil a contract (a contract is created between you and Kettle Foods Ltd when you purchase products direct from us) your name, postal address, email address and credit/debit card details are required for this purpose.|
We may also use aggregate personal information and statistics for the purposes of monitoring website usage in order to help us develop the website and our services and may provide such aggregate personal information to third parties. These statistics will not include any data that can be used to identify any individual.
How is your personal information shared?
We do not share personal information with third parties unless certain safeguards and contractual arrangements are in place. We may share personal information within the Kettle Foods Family and certain selected companies. By “Kettle Foods Family”, we mean the companies within the same group as Kettle Foods Ltd. The Kettle Foods Family will process your personal information in accordance with this Policy and all applicable data protection legislation.
All selected companies may have access to personal information if needed to perform such functions, but will only be permitted by us to use such personal information for the purpose of performing that function (which may include one to which you have expressly given your consent) and not for any other purpose.
We reserve the right to use or disclose any personal information as needed to satisfy any law, regulation or legal request, to protect the integrity of the site, to fulfil your requests, or to cooperate in any law enforcement or regulatory investigation. Save for this, we do not sell, rent, transfer or disclose personal information we have collected from you in connection with our website activities, to third parties outside the Kettle Foods Family.
Transferring your information outside of the UK
Due to the global nature of our business, as part of the services offered to you through our website or competitions, the information which you provide to us may be transferred to countries outside the UK, for example, a company within the Kettle Foods Family in the European Union. Data protection law imposes restrictions on the transfer of personal information outside of the UK but such transfers can be made if the country to which we may transfer the data has an adequate level of protection for your rights, there are appropriate safeguards or a contract is in place allowing the transfer to take place, you have provided your consent or the transfer is necessary for reasons set out in the data protection laws.
Some countries may not have similar data protection laws to the UK. If we transfer your information outside of the UK in this way, we will take reasonable steps and implement appropriate measures to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy and in accordance with data protection law. These measures generally include either transferring personal information to countries that have been deemed to provide an adequate level of protection for personal information by the UK or transferring personal information to a country where the recipient has agreed to an approved data transfer agreement in the form of standard contractual clauses. We use standard contractual clauses to protect the transfer of data to companies in the Kettle Foods Family.
The Data Protection Act 2018 requires us as Data Controller of your personal information to notify any breach of personal information to the applicable regulator and in certain instances to you, the data subject, which we will do as appropriate.
Where individuals under the age of 13 register on our website, we must obtain the consent of a parent or guardian. We also reserve the right to request parental/ guardian consent for anyone between the ages of 12 and 16. Information provided by under 16’s will not be used for marketing purposes but we may from time to time tell you about developments on our site or provide you with information about Kettle Foods Ltd.
A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website, to track the pages you looked at while visiting our website and therefore to improve our service to you. Cookies may also be used to compile aggregate personal information about the areas of our website which are visited most frequently. This aggregate personal information can be used to enhance the content of our website and make your use of it easier. If you wish to reject our cookie (which you can do at any time), you may configure your browser to do so. However, if you do so, you may not be able to use certain features on our website.
Protection of your personal information and retention
The internet is not a secure medium and Kettle Foods Ltd. cannot absolutely guarantee the security of your personal information provided over the internet and any transmission is at your own risk. However we have put in place various security measures as set out below.
We use appropriate technical, physical, legal and organisational measures, which comply with data protection laws to keep personal information secure. For example, the website and associated databases are protected by certified firewalls in order to protect your personal information from access by unauthorised persons and against unlawful or unauthorised processing, accidental loss, destruction or damage. We also keep your personal information confidential. All outgoing and incoming email is scanned for viruses.
We will retain your personal information for as long as is necessary for purposes for which it was collected. The precise period will depend on the reason why it was collected. For example: for marketing purposes your personal information will be retained until you withdraw your consent; for competitions it will be retained until the competition has been administered and in relation to consumer services until your query has been dealt with and a reasonable period thereafter or as long as the law requires; for purchases made direct from us, your personal information, order and credit/debit card details will be held in accordance with applicable financial regulations, the maximum retention period under these regulations is currently 7 years.
KFL has a strict policy in place relating to the processing of cardholder information which all relevant KFL employees are familiar with and abide by; including but not limited to:-
- Any display of cardholder information on a device should be restricted to a minimum of the first 6 and last 4 digits of the cardholder information;
- Access to cardholder information such as Personal Account Number’s (PAN’s) is restricted to employees that have a legitimate need to view such information;
- All KFL employees processing cardholder information are trained appropriately;
- All Point of Sale (POS) and Personal Identification Numbers (PIN) entry devices are appropriately protected and secured; and
- Strict control is maintained over the storage and accessibility of any devices containing cardholder information.
Once the retention period for each situation has expired we will take all reasonable steps to destroy or erase from our systems all personal data that we no longer require in accordance with all our applicable record retention schedules and policies.
You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise those rights using the contact details below.
|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, 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 (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) 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; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) 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 (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) 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 (iv) 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 object to the use of your personal information||You have the right to object to the use of your personal information in certain circumstances. For example (i) 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); and (ii) if you object to the use of your personal information for direct marketing purposes.|
|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 where the use of your personal information is based on your 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 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||You have the right to complain to the relevant data protection authority where you think we have not used your personal information in accordance with data protection law. You may lodge a complaint with the authority in the Member State of your habitual residence or of an alleged infringement of data protection law. For the contact details for the Information Commissioner’s Office in the UK please see the Questions or Complaints section below.|
We keep this Policy under regular review and reserve the right to make changes at any time to take account of changes in our business, legal requirements, and the manner in which we process personal information. Any changes we make to this Policy in the future will be posted on this page. The updated Policy will take effect as soon as it has been updated or otherwise communicated to you. This Policy was last updated in April 2020.
The website may contain hypertext links to other sites, which are not under our control. Please note that we are not responsible for the privacy policies of such other websites and we advise you to read the privacy policies of each website you visit which collects personal information.
Questions or complaints:
If you have any questions, concerns, comments or complaints about this Policy and/or our collection or use of personal information, or if you wish us to stop processing your personal information for any particular purpose or purposes, then please contact our Data Protection Officer on [email protected] or telephone +44 (0)1603 744788.
You can also contact the data protection authority of your country as listed in the table below:
Updated April 2020