We know that you care about your personal data and how it is used, and we want you to trust that Upfield uses your personal data carefully. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it.
As you read our Notice, please keep in mind that it applies to Upfield Holdings B.V. and the Upfield entities within Ireland (collectively ‘Upfield”).
Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by sending us an email or submitting a request through the “Contact Us” form on our websites.
We have tried to keep this Notice as simple as possible, but if you’re not familiar with terms, such as cookies, IP addresses, and browsers, then please read about these key terms first.
This Privacy Notice applies to personal data collected by Upfield in connection with the services and products we offer. Any personal data provided to or collected by Upfield is controlled by Upfield Holdings B.V. and the Upfield entities within Ireland.
This Privacy Notice also applies to Upfield’s marketing content, including offers and advertisements for Upfield products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.
Personal data means any information that can be used to identify directly or indirectly a specific individual.
You are not required to provide Upfield the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.
We may collect personal data from a variety of sources. This includes:
You may be asked to provide your personal data when you are in contact with us. Upfield companies may share this personal data with each other and use it in a manner consistent with this Privacy Notice. We may also combine it with other information to improve our products, services, content, and advertising.
We may collect personal data from a variety of sources. This includes:
Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and benefit from additional protection under the European data protection legislation.
We limit the circumstances where we collect and process these special categories of data.
Upfield sometimes collects data related to your health such as allergies, pregnancy or skin type to send you tailored ads and relevant promotions. Upfield only collects and uses this personal data where you have provided us with your explicit consent for us to do so. In some instances, you may have requested services or products that do not directly involve the collection of any special categories of data, but may imply or suggest your religion, health or other special categories of data.
To illustrate circumstances where Upfield collects and processes special categories of data we have provided the following examples:
We understand the importance of taking extra precautions to protect the privacy and safety of children using Upfield products and services.
Most of Upfield’s websites are designed and intended for use by adults. Where one of our websites is intended for use by a younger audience, we will obtain consent from the person with parental responsibility before we collect personal data where it is required by applicable laws and regulations (the age at which consent is necessary varies from Country to Country).
If you are a child under the age where parental consent is required in your Country, you should review the terms of this Privacy Notice with your parent or guardian to make sure you understand and accept them. If we discover that we have collected personal data from a child without consent from a parent or guardian where such consent should have been obtained, we will delete that personal data as soon as practical. Access to certain parts of the Upfield’s websites and/or eligibility to receive prizes, samples or other rewards are generally limited to users over a certain age.
We sometimes use your personal data to carry out age verification checks and enforce any such age restrictions.
We collect, process and disclose your personal data only for specific and limited purposes. For example, to process your payments, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised products, communications and targeted advertising as well as product recommendations to you.
We also create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.
Additionally, Upfield processes your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.
We collect, process and disclose your personal data for the following purposes:
When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.
Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.
In some cases, we rely on legitimate interest for processing your personal data. A legitimate interest could exist for example, when you sign up for a loyalty scheme with one of our brands and we use the personal data collected to conduct data analytics to improve our products or services. This ground will only be used where it is necessary to achieve a legitimate interest, for example to assist in the performance of a contract, or to optimise a service, and does not outweigh your rights as an individual. This legal basis will only be relied upon where there is no less intrusive way to process your personal data. We can assure you that if legitimate interest is used as a ground for processing your personal data, we will keep a record of this and you have the right to ask for this information.
We process your personal data to perform a contract to which you are or will be a party. For example, we need to process your personal data to deliver a product or a service you bought, to allow you to take part in one of our competitions, or to send you samples that you have requested.
We also process your personal data when we have a legal obligation (e.g., tax or social security obligations) to perform such processing. For example, a court order or a subpoena may require us to process personal data for a particular purpose, or we may be compelled to process personal data to report suspicious transactions under the local anti-money laundering rules.
Upfield uses your personal data to build profiles. We create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments. These segments are used by Upfield to personalise the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you), and to display relevant offers and advertisements from the Upfield brands on the Upfield sites, and via third-party websites. The segments can also be used for third-party campaigns on the Upfield sites. Upfield profiles your data where you have provided consent for us to do so; for example, accepting the setting of cookies on your browser online or signing up for email newsletters from one of our brands.
You can withdraw your consent to prevent your personal data being used this way at any time using the manage cookies section of our Cookie Notice or unsubscribing to the use of your email address if you have logged into one of our websites or signed up to any marketing newsletters.
By way of example –
In some instances, Upfield processes your personal data using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data. For example:
We will not make decisions based solely on automated processing of personal data that produces legal effects concerning you or similarly significantly affects you. If we do so we notify you and provide you with clear information about our decision to rely on automated processing to make our decision and our lawful basis for doing so. For example, Upfield processes your personal data using automated means only if it is necessary for the entering into or the performance of a contract with you, or when you have given your explicit consent.
You have the right not to be subject to a decision which is based solely on automated processing and which produces legal or other significant effects on you. In particular, you have the right:
As a global business, Upfield shares your personal data internally and with selected third-parties. For example, we share your personal data with third-party service providers, other third-parties, as well as in case of business transfers or legal disclosure.
As a global business, Upfield shares your personal data internally and with selected third-parties in the following circumstances:
Upfield shares personal data internally or with third-parties for purposes described in this Privacy Notice.
Upfield will only send personal data collected within the European Economic Area (EEA) to foreign countries in circumstances such as:
If we do transfer personal data to outside of the EEA, Upfield will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of the following safeguards:
Upfield takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure.
Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise personal data wherever possible.
Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.
We will keep your personal data for as long as necessary for the purpose it is being processed for. For example, where you make a purchase online with us we will keep the data related to your purchase, so we can perform the specific contract you have entered and after that, we will keep the personal data for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.
Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.
We retain the personal data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.
We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.
Your rights in relation to your personal data how it is processed. You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email or submitting a request through the “Contact Us” form on our websites.
Where we process your personal data, you have a number of rights over how the data is processed and can exercise these rights at any point.
Further information and advice about your rights can be obtained from the data protection Regulator in your Country.
Upfield nominated a Data Protection Officer who can be contacted at email.
If you have any questions or concerns about Upfield’s Privacy Notice or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please do so by sending an e-mail or submitting a request through the “Contact Us” form on our websites.
When a privacy question or access request is received we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant Supervisory Authority in your Country. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this Privacy Notice, we will revise the “last updated” date at the top of this Notice. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes). We will also keep prior versions of this Privacy Notice in an archive for your review.
We will not reduce your rights under this Privacy Notice without your consent.
In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.