Personal Information Notice: Find The Golden Cocoa Bean promotional campaign - Palmer’s (ET Browne UK LTD)
1. Introduction
This notice sets out how E.T. Browne UK (“ETB”) uses, and protects, personal information, including information from participating in promotions organised by ETB and our partners.
The purpose of this notice
ETB uses and stores personal information for the following purposes to:
- Administer the prize draw to which you will participate;
- Maintain our own accounts and records;
- Fulfil our legal obligations and exercise our legal rights (including legal proceedings).
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you in advance and we will explain the legal basis allowing us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, only when required or permitted by applicable Law.
Our lawful basis for using and storing personal information are explained in more details below.
Controller
ETB is the Data Controller for personal information relating to people who have:
- Agreed to receive marketing information from ETB
- Taken part in promotions organised by ETB and partners
Recipients
ETB will only disclose any personal information to organisations outside of ETB:
- To carry out our business and to provide a service or carry out a contract with you
- Where we have your consent
- Where we have justifiable reason (including where legally obliged or authorised and where we are pursuing legitimate interests)
We may share your personal information with the parties set out below, to process as independent controllers or as processers on our behalf, for the purposes set out in this Personal Information Notice.
Specific third parties listed in the table below including, and for the purposes as listed in the table below:
- MW-W Group Ltd, with registered office at 23 Alford Ave, Sheffield, S35 0JQ, United Kingdom;
- Switchstance Ltd, with registered office at 2 Forncett St, Sheffield, S4 7QD, United Kingdom;
- Cloud Nine Incentives Ltd with registered office at NP-105, iCentre, Howard Way, Newport Pagnell, Milton Keynes, Bucks, MK16 9PY, United Kingdom; and
- Richdomar Ltd, with registered office at Rawfolds One, Rawfolds Way, Cleckheaton, BD19 5LJ, United Kingdom.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
2. Website visitors and people engaging with products, prizes, services or promotions
It is necessary for the products, services and promotions we provide to use and store personal information. We are also committed to transparency about how we use personal information and informing people of their rights in relation to the use and storage of personal information. More information about your rights is available at the end of this notice.
3. Your Privacy at A Glance
| Purpose of the processing | Relevant Personal Data | Legitimate Basis | Retention Period | Recipient |
|---|---|---|---|---|
| To administer the prize draw to which you will participate, provide a product, prize or service you have requested |
|
We have a contractual obligation | 1 month from the Prize Draw end date |
MW-W Group Ltd Switchstance Ltd Cloud Nine Incentives Ltd Richdomar Ltd |
| Maintain our own accounts and records; |
|
We have a legal obligation | 1 month from the Prize Draw end date | N/A |
| Fulfil our legal obligations |
|
We have a legal obligation | 1 month from the Prize Draw end date | N/A |
| Exercise our legal rights (including legal proceedings) |
|
We have a legitimate interest to exercise our rights | 1 month from the Prize Draw end date | N/A |
4. Types of personal information and how it is collected:
We may collect and process the following personal information from you, which we have grouped as follows:
- Identity Data, which includes your first name, last name, date of birth, gender and photographs of identifiable individuals
- Contact Data, which includes your address, email address and telephone numbers
- Technical Data, which includes your IP address and your browser type
- Profile Data, which includes details of your interests, preferences and feedback
- Marketing and Communications Data, which includes your preferences in receiving marketing messages from us and our third parties and your communication preferences
- Usage Data, which includes information about how you use our website, products and services
The types of personal information we collect is provided to us directly by you for one of the following reasons:
- Personal Information that you provide by registering or by filling in forms on this site. This includes information provided at the time of subscribing to any services we offer, downloading information posted on our site, posting material or requesting further services
- Personal information that you provide in connection with or participation in any promotions or competitions sponsored, promoted or offered by us and/or any third party and information you provide when giving us feedback or completing profile forms and when you report a problem with our site or information we learn from your use of our service and your visits to our site
- Personal information from your interaction with our site, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from the site, ad data, IP address and standard web log information
- Personal information that you provide through correspondence with us. If you contact us, we may keep a record of that correspondence
- Personal information in relation to your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
5. Personal information - why we are collecting it and how it is used
Under the UK General Data Protection Regulation (“UK GDPR”), the lawful bases we rely on for collecting and processing your personal information are:
- We have a contractual obligation
- We have a legal obligation
- We have a legitimate interest to exercise our rights
The personal information we hold on you will be used in different ways, including:
- To provide a product, prize or service you have requested
- Offer you a personalised experience and understand your needs better
- Inform you of events or updates you have asked for or contact you if we need to obtain or provide additional information.
Specifically, we use your personal information we collect to carry out our business and to provide a service, product or promotion or carry out a contract with you:
- To fulfil product, prize, service or promotion requests
- Provide the best possible customer services and to help us with internal administration
- Contact you with important information relating to products, prizes, services or promotions, such as confirming your order, reminding you of an upcoming event or letting you know about changes that may affect you.
- If you do not provide personal information necessary for a specific service, product or promotion, we may not be able to provide the service or product or you may not be able to take part in the promotion.
6. Personal information - sharing and international transfers
We share information with partner organisations, which are involved in the products, prizes, services or promotions. In addition, we may have to share information with regulators such as the ASA or HMRC.
We do not transfer your personal data outside the UK and Ireland.
7. Personal information - storing
Your personal information is securely stored. To help ETB operate our service and meet our legal obligations, we will store personal information for 1 month after the date of the product, service or promotion for which the information was used and/or stored. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
8. Your rights
Under data protection law, you have the following rights:
- The right to be informed personal information relating to you is being used or stored (which is what this privacy notice is for)
- The right to access personal information relating to you which we use or hold
- The right to object to the use of personal information relating to you carried out on the ground of legitimate interests.
- The right to withdraw consent to the use or storage or personal information relating to you where the ground for the use or storage is your consent. The withdrawal of consent will not affect any use or storage of personal information relating to you which was based on consent before it was withdrawn. If you withdraw consent, we may not be able to provide the service or product or you may not be able to take part in the promotion. If you wish to withdraw consent, please contact us via the contact details below.
- The right to erasure of information relating to you that we use or hold (only in some circumstances)
- The right of data portability where your personal data is part of a processing (i) based on (a) a contract with you or (b) your Consent, and (ii) is carried out by automated means.
- The right to have personal information relating to you rectified if it is inaccurate or completed if it is incomplete.
- The right to have personal data relating to you restricted or blocked from being used or stored.
- The right to make a complaint with the national data protection authority, the ICO.
Please be aware that these rights are not always absolute and there may be some situations in which you cannot exercise them or they are not relevant.
No fee usually required
We do not charge a fee to give you access to your personal information or to exercise any of the other rights described above. We may, however, charge a reasonable fee if your request for access is clearly unfounded or excessive or we may refuse to comply with the request.
What we need from you
Where we hold reasonable doubt about your identity, we may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
11. Complaints
If you have any cause for concern about ETB’s or its partners handling of personal information, you have the right to make a complaint at any time with the national data protection authority, the ICO at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the chance to address your concerns before you approach such regulatory authority. Please contact us using the details below.
12. Contact details
E.T. Browne UK Ltd.
Unit 5, Loughton Business Centre
5 Langston Rd
Loughton
ESSEX IG10 3FL, UK
[email protected]
ETB may modify this Personal Information Notice and you should therefore periodically visit this page to be sure that you have read and agree with our most current Personal Information Notice. If there are any substantial changes to Personal Information Notice, we will inform you of such changes. For further information, please see ETB’s Privacy Notice at uk.palmers.com. We are not responsible for the content of external sites.