This is the privacy notice of Weetabix Limited of Weetabix Mills, Burton Latimer, Kettering, Northamptonshire NN15 5JR (Registered Company Number: 00267687) (“Weetabix” or “we” or “our” or “us”). We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you (where you are acting in your capacity as a consumer of our products or services (“Consumer”); or as a representative of a business or organisation that interacts with us (“Business Contact”) as to how we use and look after your personal data, when you:
(1) Visit our website (“Website”); or
(2) Participate in any competitions which we offer (“Competitions”); or
(3) Interact with us in respect of customer service, marketing related matters or business related matters; (whether that is through phone, email, online contact forms, letter, meetings or other communications (for simplicity, we refer in this privacy notice to all such communication methods as being made via the “Channels”); or
(4) Attend on-site at our premises (“Attendance”).
We refer to the Website, Competitions, or Channels or Attendance as each being “Communication Channels” in this privacy notice. We refer to interactions between you and us via the Communications Channels as “Communications”.
This privacy notice also tells you about your privacy rights and how the law protects you. Please also use the Glossary in Section 10, at the end of this privacy notice, to understand the meaning of some of the terms used in this privacy notice.
This privacy notice contains the following information in the respective Sections below:
- Important Information
- The data which we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
Purpose of this privacy notice
This privacy notice provides information on how Weetabix collects and processes your personal data, as a result of the various Communications.
The Communication Channels are not intended for children, and we do not knowingly collect personal data relating to children who are under the age of 16 for marketing purposes.
It is important that you read this privacy notice, together with any other privacy notice or fair processing notice which we may make available to you on specific occasions, when we are collecting or processing personal data about you, so that you are aware of how, and why, we are using your personal data. This privacy notice supplements the other notices, and is not intended to override them.
Weetabix Limited is the controller in respect of the personal data which you make available via the Communication Channels.
We have appointed a data protection officer (“DPO”), who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (as referred to in Section 9 below), please contact the DPO using the details set out below.
Contact details and complaints
Our full details are:
Full name of legal entity: Weetabix Limited (Registered Company Number: 00267687)
Contact Name: The Weetabix Data Protection Officer
Email address: DPO@weetabix-arabia.honeydigital.co.uk
Postal address: The Weetabix Data Protection Officer, Weetabix Limited, Weetabix Mills, Burton Latimer, Kettering, Northamptonshire NN15 5JR
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), 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 the ICO, so please feel free to contact us in the first instance.
Changes to the privacy notice
and your duty to inform us of changes
This version was last updated on 11 May 2018.
It is important that the personal data which we hold about you, is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third party links
Our Website may include links to third party websites, plug-ins, cookies, media 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 those third party websites, and we are therefore, not responsible for their privacy notices. When you leave our Website, we encourage you to read the privacy notice of every website which you visit.
The data which we collect about you
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).
In respect of the Communication Channels, we may collect, use, store and transfer different types of personal data about you, which we have grouped together as follows:
- Identity Data – this consists of data used to identify you (and where you are providing information in respect of a dependent for the purposes of a complaint, enquiry or feedback, their details), and so includes: name; title; age; date of birth; (and the same categories of information in respect of dependents, where applicable). It also includes in respect of Attendance: visitor log information which you provide (including applicable vehicle details and your business name); CCTV images and footage captured by our security systems; and any health, safety and security information related to your visit.
- Contact Data – this consists of data used to contact you or your dependent, and so includes: contact address; contact email address; and contact telephone numbers.
- Financial Data – this consists of financial data in respect of you, and so includes: bank account and payment details.
- Transaction Data – this consists of transactional data, and so includes: details about payments to and from you; voucher or coupon details which you have used in respect of our products; and other details of products and services which have been made available by us either directly or indirectly (so ‘indirectly’ would be products which we manufacture, but which have been supplied by our third party distributors or retailers).
- Technical Data – this consists of technical data related to your interactions with our Website, and so includes: internet protocol (IP) address; browser type and version.
- Profile Data – this consists of your profile data, and so includes: details of purchases or orders made by you in respect of products which we manufacture; your food, drink and shopping preferences; your dietary preferences; health and allergy data which you choose to provide to us; feedback and survey responses.
- Usage Data – this consists of details of how you use our Communication Channels, products and services.
- Marketing and Communications Data – this consists of details in relation to marketing and communications, and so includes: your preferences in receiving marketing from us; information provided by you in respect of our marketing activities, including in respect of our surveys, interviews, observations and competitions; and your communication preferences.
- Other Data – this is other personal data which you choose to share with us, at your sole discretion.
We also collect, use and share “Aggregated Data”, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but it is not considered personal data at law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate and anonymize your Usage Data, to calculate the percentage of users accessing a specific website feature; or we may aggregate and anonymize your Profile Data, for statistical analysis, trend analysis, and to improve our products, services and marketing activities. However, if we combine or link Aggregated Data with your personal data, so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.
Special Categories of Personal Data 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. The only Special Categories of Personal Data which we process about you, are the allergy or health related data which you expressly consent to provide to us, or which is required for legal reasons.
We do not collect, nor process, any information about criminal convictions and offences, in the context of the scope of what this privacy notice relates to.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract which we have with you, and you fail to provide that data when requested, we may not be able to perform the contract which 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 which you have with us, but we will notify you if this is the case at the time. Where we require health, safety and security information for Attendance purposes, and you choose to refuse to provide this, then we cannot provide you with access to our premises.
How is your personal data collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your personal data by using the Communication Channels. This includes personal data which you provide when you:
- complete an online form on our Website;
- request marketing information or products to be sent to you;
- enter a competition, promotion or survey;
- give us some feedback, raise an enquiry or make a complaint; or
- engage in Attendance.
- Automated technologies or interactions. 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 and other similar technologies. Please see our Cookies Policy for further details. We also automatically collect CCTV images and footage from our CCTV systems on our premises.
- Third parties or publicly available sources. Where you are acting as a Consumer, we may receive personal data about you, from various third parties and public sources, as set out below:
- Technical Data from analytics providers such as Google;
- Identity Data, Contact Data, Transaction Data, Profile Data from our third party distributors or retailers in respect of your feedback, enquiries or complaints;
- Identity Data, Contact Data, Transaction Data, Profile Data from social media, public websites, news agencies and reporters, in respect of your feedback, enquiries or complaints;
- Identity Data, Contact Data, Transaction Data, Profile Data, Marketing and Communications Data from our third party marketing organisations that undertake surveys, competitions, interviews or focus sessions on our behalf;
- In respect of Business Contacts, Identity and Contact Data from publicly availably sources, such as Companies House.
How we 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 (further elaboration of the respective terms, is included in the Glossary in Section 10):
- For contractual purposes.
- 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 or regulatory obligation.
Generally, we do not rely on consent as a lawful basis for processing your personal data, other than in relation to:
- Sending direct marketing communications to you (in circumstances in which we are not relying upon legitimate interests); or
- Processing special categories of personal data in relation to health and allergy data which you choose to provide to us. However, for Attendance purposes, our lawful basis for processing such personal data, will be either: (a) our legitimate interests to safeguard (as applicable) you, our premises, equipment, staff, contractors, visitors, products and services; or (b) legal basis to comply with health and safety law; in either of such circumstances, we may additionally request your consent, when this is required as an additional requirement pursuant to the applicable data protection laws for processing Special Categories of personal data.
You have the right to withdraw consent at any time, by contacting us (contact details are shown in Section 1 above).
Purposes for which we will use your personal data
We have referred to in the privacy notice, including in the details below, a description of the ways in which we plan to use your personal data, and which of the legal bases we rely upon to do so. We have also identified what our legitimate interests are where appropriate.
Please note, that we may process your personal data pursuant to more than one lawful basis, depending upon the specific purpose for which we are using your personal data. Please contact us (contact details are shown in Section 1 above), if you need details about the specific lawful basis upon which we are relying, 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, where applicable)|
|Where you are a Business Contact, interacting with you in respect of our, and your business, including:
|To manage our relationship with you, which will include:
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
||Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services which may be of interest to you||
|To deal with customer complaints, enquiries and issues||
||Legitimate interests (to keep our records updated, to seek to resolve complaints, enquiries and issues, to sustain and build our brand and customer loyalty and relationships)|
We may use your Identity Data, Contact Data, Usage Data, Profile Data, Marketing and Communications Data for marketing purposes in respect of our products and services, provided that you have opted into receiving such marketing communications (in circumstances in which we have confirmed, that we are not relying upon legitimate interests as our lawful basis, for processing your personal data for such purposes).
You can ask us or our third parties to stop sending you marketing communications at any time, by selecting the opt-out links on any marketing communications sent to you, or by contacting us at any time (contact details are shown in Section 1 above). You also have a separate right to object to marketing, where we are using legitimate interests for such processing of personal data; you can object by again using the contact details shown in Section 1 above.
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 (contact details are shown in Section 1 above).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that 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.
Disclosures of your personal data
We may share your personal data with the parties set out below, for the purposes set out in this privacy notice, including in the table in Section 4 above:
- Internal Third Parties, as set out in the ‘Internal Third Parties’ section of Section 10 below.
- External Third Parties, as set out in the ‘External Third Parties’ section of Section 10 below.
- Specific third parties, such as courier and health data analysis organisations, in the event of a product related complaint which has health or allergy consequences.
- 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 may 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 third party service providers who are acting as our processors, to use your personal data for their own purposes, and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (“EEA”), except in the following circumstances:
- For email security and filtering arranged by our parent company, Post Holdings, Inc in the USA, with a third party email security and filtering company based in the USA.
- If there is a personal data breach or legal claim, in which case we may need to share related personal data with our Chief Privacy Officer, in-house legal team or management team of our parent company.
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.
- Where we use providers based in the USA, we may also transfer data to them, if they have implemented the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the USA. Our parent company has implemented Privacy Shield.
Please contact us, if you want further information on the specific mechanism used by us, when transferring your personal data out of the EEA (contact details are shown in Section 1 above).
We have put in place appropriate security measures, to seek to prevent your personal data from being: accidentally lost; used, accessed, altered or disclosed, in an unauthorised way,. In addition, we limit access to your personal data to those staff, agents, contractors and other third parties, who have a business or legal need to know. They will only process your personal data pursuant to contractual arrangements, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach, and we will notify you and any applicable supervisory authority, of a personal data 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 necessary, to fulfil the purposes which we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
We keep your personal data in accordance with the following retention arrangements (unless we state otherwise):
- Business Contact data for 1 year following the ceasing of the relationship with the respective Business Contact (or 6 years if required in respect of any prospective legal claims or financial accounting or tax reasons; and 12 years in respect of any contractual matters undertaken by deed).
- Consumer personal data for marketing purposes, until the consumer opts out of the marketing which they had previously opted into (by way of consent) or permitted by way of legitimate interests.
- Competition and coupon related personal data, for the period of the competition or coupon promotion, and a further 3 months to resolve any queries.
- Complaints data for 6 years following the resolution of the complaint.
- Personal injury claims for 3 years from the data the injury occurred, or until an individual is 21 years old in respect of claims relating to children.
In some circumstances, you can ask us to delete your data: see ‘Request erasure’ in the ‘Your Legal Rights’ section of Section 10 below, for further information.
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.
With regard to all of our retention arrangements, should a dispute or legal claim arise in respect of any matter, then we will retain the personal data related to that dispute or claim, until the resolution of that dispute or claim, and for a further period to reflect the applicable statutory limitation period.
Your legal rights
Under certain circumstances, you have rights under data protection laws, in relation to your personal data. Please see the ‘Your Legal Rights’ section of Section 10 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 (contact details are shown in Section 1 above).
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 may 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 help us process your request.
Time limit to respond
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 if you have made a number of requests. In this case, we will notify you and keep you updated.
- Legitimate Interest as a lawful basis, involves processing your personal data, in the interest of our business, so that we conduct and manage our business in a prudent manner. 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). You can obtain further information about how we assess our legitimate interests, against any potential impact on you, by contacting us (contact details are shown in Section 1 above).
- Performance of Contract as a lawful basis, involves 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 or regulatory obligation as a lawful basis, involves processing your personal data, where it is necessary for compliance with a legal or regulatory obligation, that we are subject to.
- Consent as a lawful basis, involves processing your personal data where you have freely provided your consent. We wish to assure you, that you may withhold consent (or withdraw it subsequently), without any detriment to you as a result.
Internal Third Parties
Our parent company, Post Holdings, Inc, acting as a controller in respect of material claims and disputes; and as processors in respect of IT and system administration services.
External Third Parties
- Service providers acting as processors, who are based in the EEA, and who provide: IT and system administration services; health and safety services; facilities management and security services.
- Service providers acting as controllers, who are based in the EEA.
- Professional advisers acting as controllers, including lawyers, bankers, auditors and insurers, within the EEA, who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities, acting as controllers based in the United Kingdom, who require reporting of processing activities in certain circumstances.
- Our marketing agencies acting as processors.
- Our market research companies acting as controllers.
- Our couriers acting as controllers.
- Our health and allergy specialist testing organisations, acting as processors.
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 which we hold about you, and to details in respect of the processing of such personal data.
- Request correction of the personal data which we hold about you. This enables you to have any incomplete or inaccurate data, which we hold about you corrected, though we may need to verify the accuracy of the new data which 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 for erasure, for specific legal reasons, which will be notified to you, if applicable, following 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms. However, you also have the right to object, where we are processing your personal data for direct marketing purposes.
- 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 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. Please note, that this right only applies to automated information, in respect of which you initially provided consent for us to process the personal data, or where we processed 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 that you