AIMIA respects your right to privacy and complies with the current legislation on personal data protection, including the new General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, applicable from 25 May 2018, as well as any other rules that may develop or supplement it in the future.
2. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?
The data controller is the legal person that determines the purposes and means of the processing of personal data. In other words, the controller decides how and for what purpose personal data are processed.
3. WHO CAN YOU CONTACT AT AIMIA REGARDNG THE PROTECTION OF YOUR PERSONAL DATA?
If you have any questions or wish to receive more information regarding the processing or protection of your personal data, you may contact us via any of the following:
Data controller: Aimia Foods Limited
Penny Lane, Haydock, Merseyside, WA11 OQZ
Telephone: 01942 272900
You may also contact us by email at GDPR.Inquiries@aimiafoods.com
4. WHAT IS PERSONAL DATA?
Personal data is any information relating to an identified or identifiable natural person.
5. WHAT PERSONAL DATA ARE PROCESSED BY AIMIA?
a) Identifying data: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
b) Contact information: postal address, email address, landline telephone number, mobile telephone number.
c) Transaction data: information on purchases, orders, contracts, billing and collection, payment methods, bank details and any other data relating to your transactions with us.
d) Electronic data: IP address, device type and ID, browser type and language, domain through which the Website is accessed, browsing information, Website activity.
6. COLLECTION AND OBTENTION OF PERSONAL DATA
AIMIA collects and processes personal data that you voluntarily provide us when interacting with our Website, in particular when:
- requesting information or quotes for our products and services;
- acquiring AIMIA products or services;
- sending us your CV with the aim of taking part in recruitment processes.
You are only obliged to provide personal data that is necessary for AIMIA to provide you services or make available to you the functionalities of the Website that you have requested.
For example, if request information from us or would like us to contact you, you must provide us with the contact information needed for these purposes. If you wish to acquire any product or service that AIMIA makes available on its Website, it will be necessary that you provide, among other information, a postal address to which we can send your order. If you do not provide us with this personal data, it would not be possible for us to provide you with our services.
In any event, you guarantee and are liable for the truthfulness, accuracy, validity and authenticity of the personal data provided and undertake to keep them duly updated.
It is not necessary to provide us with your personal data to browse the Website. However, when visiting our Website, AIMIA collects, automatically and through cookies, depending on your browser specific settings, the following information: IP address, device type and ID, browser type and language, domain through which the Website is accessed, browsing information, Website activity. For more information, please refer to our Cookies Policy.
7. WHAT DO WE USE YOUR PERSONAL DATA FOR? PURPOSES AND LEGAL BASIS FOR DATA PROCESSING
In general, the personal data you provide to us and that we obtain from you are used to process your requests and transactions, to provide you with high-quality service and to inform you about opportunities we believe may interest you.
Below are the specific purposes for which we process your personal data:
a) To provide you with information you request, including quotes of products and services. In this case, your consent is the legal basis for processing your data.
b) To send you our newsletter with information, promotions, campaigns and news on products and services of AIMIA and products and services of third parties marketed and distributed by AIMIA. In this case, your consent is the legal basis for processing your data.
c) To register you as a customer, process your transactions, manage the contractual relationship with you, grant you access to the private customer area, send you relevant information on products and services, notifications of delivery, maintenance, invoicing, collections and payments, process transactions and payment methods as well as any other service communication or communications related to your contact and transactions, management of loyalty programmes, discounts and promotions, perform satisfaction surveys or surveys related to products and services marketed and distributed by AIMIA. In this case, the legal basis for processing your data is, if you are a residential customer, the performance of the product sales contract or the service provision contract with AIMIA; and, if you are a corporate customer, our legitimate interest in contracting and providing our services to the company at which you are employed or provide services to.
d) To store your data and contact you regarding recruitment and staff selection processes at AIMIA, as well as to manage your participation in said processes. In this case, your consent is the legal basis for processing your data.
e) If you give your consent, to send you marketing communications on our products and services and on products and services of third parties marketed and distributed by AIMIA, our publications, opinion surveys, promotional and advertising information, coupons, offers (including customized offers) and recommendations of our products and services as well as of products and services of third parties marketed and distributed by AIMIA, according to your interests and based on a profile developed by us, by phone, post, email, SMS and MMS. In this case, your consent is the legal basis for processing your data.
f) To guarantee the security of our Website and of the information. In this case, the legal basis for processing your data is the legitimate interest in providing a secure environment and preventing harm to AIMIA’s systems and to the users’ information, as well as unauthorized access to and misuse of AIMIA’s systems and users’ information.
g) For internal management purposes: planning, resource allocation, policy development, quality improvement, strategic analysis, marketing and commercial development, monitoring, audit, legal, evaluation and reporting. In this case, the legal basis for processing your data is our legitimate interest in understanding and analysing the development of our business, improving our products and services, and exploring ways to develop and enhance our business.
h) With regard to the use and purpose of cookies, please refer to our Cookies Policy. In this case, your consent is the legal basis for processing your data.
Bear in mind that receiving marketing information is not essential to maintain the relationship we have with you. If you prefer not to receive marketing communications, you may inform us at any time through the means indicated or opt-out at the link provided for these purposes in the marketing communications that you receive by email, or if the communications are provided by other means, through the procedure indicated for these purposes.
To what extent is decision-making automated?
AIMIA does not use completely automated decision-making processes to engage in, develop or terminate a contractual relationship with you. If we were to use these processes in a specific case, we would inform you, communicate your rights in this respect and comply with our legal obligations in accordance with applicable regulations.
Will you use profiling?
With the aim of being able to offer you products and/or services in accordance with your interests and to improve your user experience, we may develop a “commercial profile” based on the information provided. However, automated decisions will not be taken based on said profile.
8. WHO WILL WE SHARE YOUR PERSONAL DATA WITH?
We will share or give third parties access to your personal data when necessary to achieve one of the objectives described below and in accordance with current legislation:
b) Legal obligations: AIMIA may communicate your personal data when the transfer is necessary to comply with a legal obligation, including the transfer to competent authorities, judges and courts. This includes complying with requests made by authorities regarding the prevention of money laundering and the financing of terrorism.
d) International data transfers. Your data may be disclosed to other companies within the Primo Group and to data processors, within and outside the European Economic Area (EEA). In some cases, the laws of countries outside the EEA do not provide the same level of protection of your personal data as those inside the EEA. However, to the extent that your personal data is transferred outside the EEA, such transfers will be based on adequacy decisions or standard contractual clauses adopted by the European Commission.
9. WHAT MEASURES DO WE APPLY TO KEEP YOUR PERSONAL DATA SAFE?
AIMIA takes the appropriate technical and organisational measures in accordance with current regulations to protect your personal data against any misuse, destruction, loss, accidental or illicit modification, disclosure or unauthorised access, including the measures necessary to deal with any suspected data breaches.
10. HOW LONG DO WE RETAIN YOUR DATA?
AIMIA shall retain your personal data for the time necessary to fulfil the purposes for which they were collected, or while you do not exercise your right to erasure or to withdraw your consent.
The data will be subsequently deleted, unless a longer retention period is required or permitted by law (for instance, for the establishment, exercise or defence of legal claims) in which case they will be duly retained as long as required before deleting them.
To determine an appropriate retention period of your data, we apply the following criteria:
a) The data necessary to provide you with the information you request, including quotes of products and services, shall be retained for the time necessary to attend to and process said requests, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation.
b) The data related to the acquisition of AIMIA products and services in the context of a contractual relationship shall be retained during the term of the contract with AIMIA or for the time necessary to exercise the rights and comply with the obligations of the contract with AIMIA, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation.
c) When you consent to receive marketing communications, your data shall be retained so long as you do not withdraw your consent or inform us of your wish to not continue receiving these communications, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation.
d) The data sent with a view to participate in recruitment/staff selection processes shall be retained on a general basis for 3 years, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation.
e) When cookies are placed on your device, the data shall be retained in accordance with the applicable legal requirements and the recommendations made by the competent authorities.
11. WHAT ARE YOUR RIGHTS WITH RESPECT TO THE PROCESSING OF YOUR PERSONAL DATA?
In accordance with the applicable legislation, you have specific rights with regard to the collection and processing of your personal data.
These rights are the following:
a) Right to information: You have the right to be informed about the use and processing of your personal data in a concise, transparent, intelligible and easily accessible manner, and with clear and simple language.
b) Right of access: You have the right to request from us, at any time, that we confirm if we are processing your personal data, that we provide you with access to said data and to the information about the processing of them, and to obtain a copy of said data. The copy of your personal data that we provide you shall be free, although the request for additional copies could be subject to a reasonable fee based on administrative costs. On our part, we may request that you give proof of your identity or require more information from you in order to handle your request.
c) Right to rectification: You have the right to request the rectification of inaccurate, outdated or incomplete personal data that concerns you. You may also request that any personal data that may be incomplete is completed, including by means of providing a supplementary statement.
d) Right to erasure: You have the right to request the erasure of your personal data when, among other things, the data are no longer necessary for the purposes for which they were collected or processed. However, this right is not absolute so that AIMIA may continue to keep them, duly blocked, in those cases laid down in the applicable regulations.
e) Right to restriction of processing: You have the right to request that we restrict the processing of your personal data, which means that we may continue storing them, but may not continue processing them if any of the following conditions is met:
– that you contest the accuracy of the data, during a period that allows us to verify the accuracy of said data;
– the processing is unlawful and you oppose the erasure of the data and request the restriction of their use instead;
– AIMIA no longer needs the data for the purposes of processing, but you need them for the establishment, exercise or defence of legal claims;
– You have objected to the processing, pending the verification whether AIMIA’s legitimate grounds override yours.
f) Right to data portability: You have the right to have your data transferred to another data controller in a structured, commonly used and machine-readable format. This right is applied when the processing of your personal data is based on consent or on the execution of a contract, and said processing is carried out by automated means.
g) Right to object: This right allows you to object to the processing of your personal data, including profiling. We shall no longer process your data unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.
h) Right to withdraw consent: In those cases in which we have obtained your consent to process your personal data in connection with certain activities (for example, with the aim to send you marketing information), you may withdraw it at any time.
i) The right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with the Information Commissioners Office (ICO) Helpline 0303 123 1113 with further details available at http://www.org.uk
You may exercise your rights by sending a communication to GDPR.Inquiries@aimiafoods.com, including your name and address for communication and verification purposes and providing the necessary details to process your request.
If you wish to withdraw the consent given to receive marketing communications, you may inform us at any time through the means indicated or opt-out at the link provided for these purposes in the marketing communications that you receive by email, or if the communications are provided by other means, through the procedure indicated for these purposes.
If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, considering the relevant administrative costs, or we may not act on the request.
12 . AMENDMENTS