Privacy Policy

Privacy, Security and Cookies Policy            14.05.2018

  1. Introduction and General Terms

Luckett’s Dairy Ltd is committed to protecting your personal information when you are using the Luckett’s Dairy Ltd website and services. We want our services to be safe and enjoyable environments for our customers. This Privacy Policy relates to our use of any personal information you provide to us through the Luckett’s Dairy Ltd website.
In order to provide you with the full range of services, we are sometimes required to collect information about you.
This privacy policy explains the following:

What information Luckett’s Dairy Ltd may collect about you, how we will use information we collect about you, whether we will disclose your details to anyone else and your choices regarding the personal information you have provided to us. We also explain the use of cookies on our website and how you can reject these cookies.

Luckett’s Dairy Ltd is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the Data Protection Act 1998 (these laws are referred to collectively in this Privacy Policy as the “data protection laws”).
Occasionally our website and blogs contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies, and we urge you to review them. They will govern the use of personal information you submit or are collected by cookies whilst visiting these other websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

  1. What information will Luckett’s Dairy Ltd collect about me?

When you register for an online account with us we may ask for personal information about you. This can consist of information such as your name, e mail address, postal address, telephone or mobile number. Different web-pages may ask for different personal information.

By entering your details in the fields requested, you enable the Luckett’s Dairy Ltd to provide you with the services and products you select. In fact some services cannot be provided without some of the details mentioned.

Luckett’s Dairy Ltd also uses cookies and collects IP addresses (an IP address is a number that can uniquely identify a specific computer or other network device on the internet). We may use analysis software to look at IP addresses and cookies for the purpose of enhancing your user experience. This information is anonymous and not used to develop a personal profile of you and the log files are regularly purged.

IP addresses are used to identify the location of users, the number of visits from different countries and also to block disruptive use; and to analyse and improve the services offered on our website. e.g. to provide you with the most user-friendly navigation experience.

  1. How will Luckett’s Dairy Ltd use the information they collect about me?

We will use your personal information for a number of purposes including the following:

For providing services to you in the way of delivering goods to your address.

Replying to your enquiries and requests.

Sending emails to you regarding changes to our services, products, prices or delivery schedule.

Sending automated electronic communications relating to your account, such as your bill or payment reminder.

Including you in occasional prize draws or other reward based events run by ourselves.

Where we propose using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for your use other than as listed above.

  1. When will Luckett’s Dairy Ltd contact me?

Luckett’s Dairy Ltd may contact you:

In relation to the order you have placed on the website to ensure that we can deliver the services to you;

When we need to request payment for goods or services provided;

Where you have opted to receive further correspondence;

When we need to advise you of changes to prices or terms of service or delivery days.

  1. Will I be contacted for marketing purposes?

Luckett’s Dairy Ltd won’t contact you for general marketing purposes, or promote new or a third party’s services to you unless you specifically agree to be contacted for these purposes.

We may occasionally contact you with news or information about products you already buy from us (dairy goods and groceries) if the price or product is changing. If you do not wish to be contacted about these please let us know by email.

  1. Will Luckett’s Dairy Ltd share my personal information with anyone else?

We will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies).

  1. Changes to Privacy Policy

This privacy policy may be updated from time to time so you may wish to check it each time you submit personal information to any Luckett’s Dairy Ltd website. The date of the most recent revisions will appear at the top of this page.

8. New GDPR Guidlines

Having read and studied the options and the required lawful basis for processing customer’s data here at Luckett’s Dairy Ltd we have decided on: Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
What is the ‘legitimate interests’ basis?
Article 6(1)(f) gives you a lawful basis for processing where:
“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”
This can be broken down into a three part test:
Purpose test: are you pursuing a legitimate interest?
Necessity test: is the processing necessary for that purpose?
Balancing test: do the individual’s interests override the legitimate interest?
A wide range of interests may be legitimate interests. They can be your own interests or the interests of third parties, and commercial interests as well as wider societal benefits. They may be compelling or trivial, but trivial interests may be more easily overridden in the balancing test.
The GDPR specifically mentions use of client or employee data, marketing, fraud prevention, intra grouptransfers, or IT security as potential legitimate interests, but this is not an exhaustive list. It also says that you have a legitimate interest in disclosing information about possible criminal acts or security threats to the authorities. ‘Necessary’ means that the processing must be a targeted and proportionate way of achieving your purpose. You cannot rely on legitimate interests if there is another reasonable and less intrusive way to achieve the same result. You must balance your interests against the individual’s interests. In particular, if they would not reasonably expect you to use data in that way, or it would cause them unwarranted harm, their interests
are likely to override yours. However, your interests do not always have to align with the individual’s interests. If there is a conflict, your interests can still prevail as long as there is a clear justification for the impact on the individual
Customer data is only ever used in a way a customer can reasonably expect, it is never forwarded on for marketing purposes and may only be used to promote goods or services provided by Luckett’s Dairy that the customer may have a genuine interest in purchasing or using or for the issuing of vital information including invoicing.
Written consent is always gained upon the setting up of a Direct Debit instruction and is provided in the form of a physical mandate with the customers signature. This is a positive opt in service and Luckett’s Dairy will be unable to process your Direct Debit request without this consent.

Luckett’s Dairy collect and hold a range of data including:Customer full name including title

Customer full address including postal code

Customer mobile telephone number

Customer home telephone number

Customer email address

Customer holiday information

Customer account numbers

Customer sort codes

Customer bank address

It is your right at any time to request the information that we hold on your account, make any alterations to the information we have on your account and also to have this information permenantly erased. Luckett’s Dairy has the capability to ensure the safe and correct disposal of any sensitive information that we hold. Requests for information will be dealt with in a timely fashion and well within the new GDPR guidlines of 28 days. Information will be provided in a clear, understandable and transparent format that is widely accessable and may be provided in printed form upon request. Requests for access to the information we hold may be made either in writing or verbally. It is a legal requirement that access to data may only be provided upon proof of the identity of the persons requesting it.

The right to rectification or completion of data. Individuals have the right to have personal data rectified if it is inaccurate or completed if it is incomplete. An individual can make a request for rectification verbally or in writing. Luckett’s Dairy will respond to any request within 28 days of receipt. Verification of a persons identity must be carried out before any alterations to an account may be made. Luckett’s Dairy will continue to complete regular reviews of the information held to ensure it is up to date, correct and adequate for the purposes we are processing for.

Right to erasure including retention and disposal. Individuals have the right to be forgotten and request erasure when deliveries have ceased and are no longer required as long as the account has been settled and there are no outstanding balances. Individuals also have the right to be forgotten and request erasure if data has been collected unlawfully or unlawfully processed. Individuals may request to be forgotten either verbally or in writing. Luckett’s Dairy will carry out ID verification before any request to be forgotten is processed. Luckett’s Dairy will respond to any request to be forgotten within the 28 days GDPR timescale. Luckett’s Dairy may refuse a request to be forgotten if there is a need to exercise or defend a legal claim or if the information is required for statistical purposes

The right to limit the processing of your data. Individuals have a right to block or restrict the processing of their personal data. When processing is restricted, we are permitted to store the personal data, but not further process it. We can retain just enough information about the individual to ensure that the restriction is respected in the future. A restriction may be placed on your account either in writing or verbally however checks will be made to ensure proof of identity.

Right to Data Portability – The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. They can receive personal data or easily move, copy or transfer that data from one business to another in a safe and secure way. Luckett’s Dairy has systems enabling the secure transfer, copy or movement of personal data via CSV file. Luckett’s Dairy is able to provide CSV file data free of charge and can transfer the data directly to another business if required. Requests for data porting may be made verbally or in writing however reasonable measures will be taken to ensure customer identity. Requests will be dealt with within the recommended GDPR timescale of one month from receipt of the request.

The Right to Object – Individuals have a right to object to the processing of their personal data in certain circumstances. Luckett’s Dairy does not and does not intend to share or distribute data with any third party. Data will only be used by Luckett’s Dairy for the purposes of providing a service and as such the right to object is overall not needed. However, if the individual feels their data has been processed outside of their legitimate interest, Luckett’s Dairy will cease processing that data immediately and investigate further. Requests for objection may be made verbally or in writing  however reasonable measures will be taken to ensure the personal identity of the individual. Requests will be dealt with within the recommended GDPR timescale of one month from receipt of the request.

Rights related to automated decision making including profiling – Luckett’s Dairy has identified that none of its processing operations constitute automated decision making and have therefore included no addition procedures. The GDPR defines profiling as any form of automated processing intended to evaluate certain personal aspects of an individual, in particular to analyse or predict their: * performance at work; * economic situation; * health; * personal preferences; * reliability; * behaviour; * location; or * movements. If an individual disagrees with Luckett’s Dairy’s decision on this matter contact must be made immediately either verbally or in writing, reasonable measures will be taken to ensure personal idenitity. Requests will be dealt with within the recommended GDPR timescale of one month from receipt of the request.

Accountability – Luckett’s Dairy believes this is an appropriate Privacy Policy and is updated for GDPR. This policy sets out the approach to data protection and the responsibilities of the management. Management has approved this policy and it has been made available for all staff and customers to view. A copy has also been printed for all staff members. The privacy policy is also openly available to view on the website at www.luckettsdairy.co.uk/privacy-policy. Luckett’s Dairy continually monitors and updates its policy in line with new regulation to remain compliant. A DPO has been appointed for this task. Training is provided to those members of staff that require data protection awareness and non disclosure agreements have been included in each contract for a period of 12 months following the termination of any contract.

Luckett’s Dairy does not use any outside of third party processor and therefore it is not applicable at this time to ensure a contract is in place for these purposes. If however in future a third party processor was required, Luckett’s Dairy would only appoint processors who can provide ‘sufficient guarantees’ that the requirements of the GDPR will be met and the rights of data subjects protected.

 

         9. Contacting Luckett’s Dairy Ltd about this Privacy Policy

If you have any questions or comments about this Privacy Policy please contact;

Write:

Luckett’s Dairy Ltd

415 Beake Avenue
Coventry
CV6 2HN

Tel : 024 7649 1823

Email: Info@luckettsdairy.co.uk

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© 2018 Luckett's Dairy Ltd

Lucketts Dairy Ltd
415 Beake Avenue
Coventry
CV6 2HN

Tel : 024 7649 1823

Company Reg No. 8914148
VAT No. 695279379

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