PRIVACY POLICY

PRIVACY POLICY - DEVON FARM KITCHEN
Policy Statement
At Devon Farm Kitchen we are committed to acting within our group values of Honesty & Integrity, Generosity of Spirit, Respect and as Team Players.  We believe we are all responsible for delivering our purpose and ensuring we behave in an ethical, values-driven, and customer-focussed way.  At the very centre of this are our customers. We value your support and we take your privacy very seriously; we are committed to protecting your personal data. 
This policy explains how we use any information we collect about you, and how we have put procedures in place to meet our legal obligations and to ensure that we protect your privacy.

Scope
This Privacy Policy applies to Devon Farm Kitchen Ltd, including your use of our website www.devonfarmkitchen.co.uk, and covers:
  1. Important information and who we are
  2. The data we may collect about you
  3. How and why we collect your personal data
  4. How we use your personal data
  5. Who we share your data with and why
  6. International transfers
  7. Keeping your personal data secure
  8. Length of time we keep your personal data
  9. Your rights regarding your data
  10. Definitions

Important information and who we are
Who we are
Devon Farm Kitchen Ltd (company no: 12353512) is a trading subsidiary of Rowcroft House Foundation Ltd (Rowcroft), which is a company limited by guarantee (company no: 1561601) and registered charity (charity no: 282723). As such we share certain systems and processes with Rowcroft as well as relevant personnel and policies. We will make clear in this policy where this applies to processing of your personal information.
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how Devon Farm Kitchen Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to a mailing list, comment on an article, purchase a product, engage with a service, or take part in a competition or survey.
This website is not intended for children and we do not purposefully collect data relating to children except where it is provided by, or with the explicit consent of, their legal guardian.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
Data Controller
Devon Farm Kitchen Ltd is registered as a data controller with the Information Commissioner’s Office. If you have any queries about our use of your personal data under this Privacy Policy, please email hello@devonfarmkitchen.co.uk.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy or related privacy notices. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO.
Data Protection Officer
Jonathan Hill, Rowcroft House Foundation Ltd
Email: jonathan.hill@rowcrofthospice.org.uk 
Rainbow House, Avenue Road, Torquay TQ2 5LS
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 address your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the Privacy Policy
Although we endeavour to ensure this Privacy Policy is maintained and up to date, there may be instances where legislative changes are yet to be satisfied. Where any part of this policy becomes invalid or inappropriate due to these changes, it will be the provision within the relevant regulation that will apply but this will not affect the validity of any remaining terms.
Your duty to inform us
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.
Third-party links
Our website may include links to third-party 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 these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Social media
Where we operate a social media page or channel and it is identified that we have a responsibility for your personal data as either a controller or joint-controller with that social media website, we will make this clear to you via a privacy notice.
2. The data we may 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 (known as anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  • a) Identity Data includes first name and last name. We may ask for further identity data (such as title, marital status, date of birth and gender) but only in situations where we believe this can enhance your experience and interaction with us.
  • b) Contact Data includes correspondence addresses, email address and telephone numbers.
  • c) Financial Data includes bank account and payment card details.
  • d) Transaction Data includes details about orders and payments from you and other details of products and services you may have purchased from us.
  • e) Technical Data 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 this website.
  • f) Profile Data may include the history of purchases made by you, your interests, preferences, feedback and survey responses.
  • g) Usage Data includes information about how you use our website, products and services.
  • h) Marketing and Communications Data includes your preferences in receiving marketing products from us and our third parties, and your communication preferences.
  • i) Still and moving images includes video footage and photographs taken at our events at which you might be present and visible. Where this takes place there will be clear signage indicating such with further information as required. We may also ask for your consent in certain specific circumstances. 
Aggregated Data
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 is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect 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 Policy.
Special Categories (of personal data)
Other than as part of our recruitment process or where it might be required for accessibility purposes (see below), we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation or behaviours, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions or offences.
We may ask for some very basic information about your health where this could impact the quality of our service delivery for you. For example, where our drivers may need to provide additional assistance to you in delivering, unpacking, or collecting used products due to a medical condition. Or where there may be someone who is clinically vulnerable and our delivery drivers need to take additional infection control measures to help protect those individuals when delivering or collecting from your home. We will only record what is absolutely necessary for this purpose and will never disclose or share this information with a third party without your consent. 
For more information on the Special Categories of Personal Data collected as part of a recruitment process, please refer to the privacy notice provided to you at the point of application. 
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods you have purchased from us). In this case, we may have to cancel a product or service you have with us, and we will notify you if this is the case at the time.
3. How and why we collect your personal dataWe use different methods to collect data from and about you including through: direct interactions; automated technologies or interactions; and third parties or publicly available sources.
Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• make an enquiry
• purchase our products or services
• subscribe to our service or publications
• request marketing products to be sent to you
• attend events at which your image might be captured in video or still image
• enter a competition, promotion or survey
• or give us some feedback
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. 
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below: 
• Technical Data from the following parties: 
a. analytics providers (such as Google) 
b. advertising networks 
c. search information providers

• Identity and Contact Data from publicly available sources, such as social media (when you engage with our social media channels such as Facebook, Instagram, Twitter, LinkedIn or YouTube). Where information is received or likely to be received from third parties or publicly available sources, we will communicate this to you at the earliest opportunity through either a privacy notice or other communications.
4. How we use your personal data
We only use your personal data when the law allows us to. Most commonly, we use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you (for example, when you have purchased goods from us).
• 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 only rely on consent as a legal basis for processing where no other lawful basis exists. This includes the sending of unsolicited general marketing (i.e. marketing not related to an existing relationship or a previous interaction with us) or third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing hello@devonfarmkitchen.co.uk
We ask for your information so that we can:
• process your order and communicate with you about that order
• send you information you have asked for
• keep a record of your relationship with us
• manage how you would like to receive information and news from us, and what information you would like to receive
• understand how we can improve our services, products or information
• provide you with information that we think you would like to receive, based on your relationship with us and what you have told us is of interest to you
• invite your feedback or engagement with a particular matter.
We may also use this information to undertake data analytics to understand and improve our website, products/services, marketing, customer relationships and experiences.
We will use the information processed about you to identify the most efficient, effective and appropriate way to interact with you.  This means we may use your previous interactions with us to determine what products and experiences are most relevant to you.  We will adhere to the marketing preferences that you have provided us with, and we always welcome feedback on whether or not we’re getting this right.  
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside of Devon Farm Kitchen for their own marketing purposes. This includes our parent charity, Rowcroft House Foundation Ltd.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites use cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information on cookies, please refer to our Cookie Policy. 
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact <insert email>.
If we need to use your personal data for an unrelated purpose, we will notify you and either explain the legal basis that allows us to do so, or request your consent to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law.
5. Who we share your data with and why
We may share your data with organisations that work on our behalf or supply us with services to deliver the purposes set out in section 4 above. This can include:
a. our parent charity, Rowcroft House Foundation, through the normal course of sharing back-office resources to support the business (such as financial management, personnel and HR support or ICT support) 
b. a marketing partner or service provider who is assisting us 
c. a third-party mailing house or email distribution software provider
d. screening companies to check that our records remain up to date and accuratee. preference services such as TPS (Telephone Preference Service) 
f. our audit partner as part of our routine audit or control checks
g. our ecommerce provider (currently Shopify Inc.). 
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 to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also need to disclose your personal information if required by law. This can include the police, regulatory bodies or legal advisors.
6. International transfers
Some of our third-party service providers (named in section 5 above) may store personal data outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside 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 will use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield (or similar) framework which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside of the EEA.
7. Keeping 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 requirement. They only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Length of time we keep your personal data
We will only retain your personal data for as long as 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 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.
In some circumstances, you can ask us to delete your data. For further information, see ‘Request erasure’ within section 9.
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.
Transactions
We will keep information about your purchases for six years after the end of the accounting period for which it relates (for example, if your last purchase was on 1st June 2021, this would fall within our 2021/22 financial year (ending 31st March 2022) so your relevant information would be retained until 31st March 2028). This is necessary to comply with financial regulations and reporting. 
9. Your rights regarding your data
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 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 data 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. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will notify you of, 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), you have the right to object to processing if you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data 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
d. where 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. 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. 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 information 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 the rights set out above, please email hello@devonfarmkitchen.co.uk.
Fees
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 speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month of verification of your identity. 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 at the earliest opportunity and keep you updated.
10. Definitions
Lawful basis for processing Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure 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). Please contact us to obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities.
Performance of Contract means 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. This includes fulfilling an order you’ve placed with us.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means asking an individual for their permission to process their personal data, offering them real choice and control. It requires a positive action from the individual.
Key roles
Data Controller is an entity that determines the purposes, conditions and means of the processing of personal data. Controllers have a legal obligation to give effect to the rights of Data Subjects. This includes the obligation to ensure that the rights of the individual are upheld at all times.  
Data Processor is a natural or legal person, authority or agency or any other body which processes personal data on behalf of the Controller. Data Processors are obliged to act only under the instructions of the Data Controller, comply with the Controller’s obligations and assist the Controller with regards to Data Subject rights and handling any requests.
Data Subject is a living individual who is the subject of the personal data.