Bel UK Consumer Personal Data Protection Policy

The entity responsible for processing personal data for this website is BEL UK, as part of FROMAGERIES BEL SA. Before communicating your personal data to us and to give us a consent for their processing, we recommend you read this Policy on the protection of our consumers’ privacy carefully. 1. THE BEL GROUP’S COMMITMENT TO PROTECTING CONSUMERS’ PRIVACY AND PERSONAL DATA “Personal data” (hereinafter “PD”) means any information collected about our consumers who are natural persons that enables us to identify them directly or indirectly. To better meet the requirements of all our consumers and to forge a close relationship with you, the Group collects personal data in various ways. You need to be confident that the information you communicate to us and our brands is not disclosed. Our Group gives an undertaking that it will not contravene your privacy and that your personal data will be collected and retained in a totally transparent and secure way. As part of our commitment to meet your requirements, we have implemented a privacy protection policy for our customers. This Policy describes the conditions in which BEL uses your personal data. The entity responsible for processing personal data for this website is BEL UK, as part of FROMAGERIES BEL SA. 2. PERSONAL DATA PROTECTION OF CONSUMERS: THE PRINCIPLES Legitimacy: the data will be collected only for particular, explicit and legitimate purposes. Processing will not concern sensitive data (racial or ethnic origins, political, philosophical or religious views, trade union membership, health, sex life, offences, criminal convictions or security measures). Relevance and Accuracy: we ensure that the data collected are appropriate, relevant and not excessive given the purposes for which they are collected, and that they are accurate, complete, and, if necessary, updated. Transparency: when collecting your PD, you will be informed of any information regarding the collection and processing of data about you, in particular about why the data are collected. Retention limit: the PD will be retained for a period which does not exceed the period required for the purposes for which the data are collected and processed; Consent: your consent will be required before any collection of PD for purposes which will be described at the time of its collection; Access, correction, objection: at any time, you may access and request the correction or deletion of your PD. You may also object to the use of your PD. To exercise these rights, please refer to Article 11 of the Policy. Privacy & Security: The BEL Group undertakes to process your PD in a way that guarantees the privacy and security of the PD by implementing appropriate technical and organisational measures. 3. SCOPE This policy applies to all processing of the website and the UK websites belonging to the entities of the Bel group to which you could be redirected during your navigation: 4. PERSONAL DATA COLLECTED Depending on the type of relationship we have with you, we may need to ask you for information about yourself and/or your family members, such as: Contact information (last name, first name, telephone No, email, address etc.) Location / city Any other information necessary for us to provide the requested service (e.g. to resolve a customer service query or to enable your participation in a marketing / promotional initiative). 5. TIME OF COLLECTION Depending on the purposes for which your “PD” will be processed, the collection may take place at different times including: When your contact the consumer service (Questions, Complaints, etc.) When you take part in marketing programmes or initiatives (contests, games, subscription to newsletters, etc.) When you visit the BEL group’s websites 6. DATA COLLECTION PURPOSES Meet all your requests as regards the consumer service Improve our products, in particular, thanks to improved knowledge of your needs and wishes To provide coupons Send you newsletters, promotions or offers from partners, when you have authorised us to do so. At any time, you may unsubscribe from these newsletters by clicking on the link provided at the bottom of these e-mails; Participate in a competition, prize draw or other specific marketing initiative. Reach you with relevant advertising content on partner or publisher websites Secure and enhance your use of the BEL group’s websites (navigation, data security, etc.). To build “lookalike audiences” for media targeting with 3rd parties including Facebook and Google. See point 6.1 below for more information. 6.1 Lookalike Audiences Building lookalike audiences involves passing our email data to the aforementioned third parties, who build a profile of traits common to those signed up to our email marketing lists. The purpose is to enable us to target our advertising at people more likely to respond positively, to minimise wasted ad spend. Data passed to third parties in this way may only be used for this specific purpose and not for any other, by any other party There is no impact on your privacy or on the advertising you would see from any other organisation. You will not see additional advertising from us as a result of lookalike audiences as the source data used to build lookalike audiences is excluded from the targeting. We are relying on having a legitimate interest, as laid down in the GDPR, for processing your data in this way, but you may object to this usage at any time by contacting us via any of the channels mentioned in clause 11 below. 7. SHARING YOUR PERSONAL DATA As part of management of our relationship, we will transmit, or give access to your “PD” to internal and external recipients for the following purposes. Internally, to authorised staff in our entities, for the purpose of maintenance / management of the data: IT services Marketing services Externally, to the following types of company, for the following purposes: Technology providers providing a service to Bel and / or yourself – e,g, a provider of coupons like Shopmium, or an emailing marketing tool like Mailchimp Externally sourced Customer service and social media community management teams (typically the first point of contact when you contact us) Marketing agencies / suppliers managing our email marketing communications Marketing / PR agencies managing promotions/ competitions for your benefit Media owners (including e.g. Facebook and Google) , and by extension media agencies for the sake of building lookalike audiences (as per clause 6.1 above). Marketing / Consultancy suppliers for the purposes of analysing marketing performance All third parties who receive (access to) your data do so under contractual obligations not to share or otherwise abuse access to the data. They may use it for no other purpose as that directed by Bel More specific information regarding current suppliers who currently or previously have had access to your data can be provided on request We cannot provide more specific information within this privacy policy as suppliers vary over time, and the exact journey your data has taken depends on how and when you provided it to us for what purpose). We may also need to forward your information to local authorities due to a legal obligation or at the request of an administrative authority empowered to make this type of request. 8. SECURITY BEL makes every effort, by taking appropriate technical measures, to protect you against the destruction, accidental or otherwise and the accidental loss or alteration or unauthorised disclosure of or access to your “PD”. 9. COOKIES BEL informs you that it may use temporary “cookies” that are valid only during a session of visiting the Website. 9.1 What is a cookie? Cookies are data placed in your browsers or mobile devices. They can be distinguished by their unique identifiers, associated with your browser or device. Common uses include: Enabling anonymised website analytics Remembering your login information and other preferences (e.g. location or language) Personalising content for you based on previous visits Reaching you with advertising on other websites / platforms These “cookies” are stored in RAM in your computer. They do not allow us to identify you as an individual, they only allow the anonymous association of your device or browser with a visit (or visits) to our website(s) (date, time, pages visited etc) pages and with certain preferences (logins etc ). Cookies are non-permanent – but how long they last varies based on the type of cookie and its use.  Some might be 24 hours, others might be up to 540 days. 9.2 What do we use cookies for on this website? Analytics Cookies These cookies allow us to assess the website traffic, We use this information to: Identifying problems with the site Make improvements to the site and content Understand how digital media driving traffic to the site is performing All data gathered by analytics cookies is used anonymously : we do not know what “you” have done. The specific cookies currently in use are: Google Analytics – primary analytics tool Facebook Pixel – being used ONLY for analysis of traffic driven by Facebook & optimisation of Facebook Ads. Facebook Pixel does enable retargeting of visitors to our website on Facebook, but we will not be using data collected for this purpose until we have an explicit “opt in” on site for that purpose. If you have not ticked such an option – you will not be retargeted in such a way. We are relying on having a legitimate interest, as laid down in the GDPR, for automatically delivering these cookies when you land on the site, however you are still able to delete them using the instructions below. 9.3 Deleting & managing cookies You can delete or block cookies in your browser / device in the following ways: Internet explorer: Chrome & Android devices: Firefox: Safari or Apple devices: For any other browsers or devices please refer to the appropriate support websites. 10. DATA RETAINED BY BEL In compliance with the laws in force, the PD will be retained only for the period required for the purpose for which the data have been collected and processed. We will retain your data for the following periods dependent on the type of data: Data gathered as a result of contacting customer services: Up to 2 years after last contact between us, or until you ask us to delete your information if earlier Email data & other data gathered for marketing purposes : Up to 2 years after last contact from us, or until you choose to unsubscribe if earlier. Cookies: The duration varies but the maximum duration of any cookie is 540 days, or when you choose to delete cookies from your browser / device if earlier. 11. YOUR RIGHTS REGARDING YOUR PERSONAL DATA You enjoy all the rights under the applicable legislation as regards personal data protection. In this regard, you may, in particular, at any time, request access to your “PD” collected by BEL and make a request to change them, by contacting our Customer Service using the contact details below BEL Consumer Service Address: Bel UK, 160 London Road, Sevenoaks, London, TN13 2JA Phone: 0800 030 4596 (Open Mon-Fri, 9-5) Email: More contact information including available social channels: Similarly, if your “PD” are not accurate, complete or up-to-date, you can communicate any changes to be made to them to the above address. You can also assert your right of opposition by contacting the Consumer Service at the above address. In particular, where processing of the PD is based on your consent, you have the right to withdraw your consent at any time in order to object to any subsequent processing. All requests will be processed as soon as possible and in accordance with the applicable law. 12. PROTECTION OF PERSONAL DATA OF CHILDREN BEL considers that parents must be informed of the relationship that the company and its brands establish with their children. Therefore, the BEL group undertakes to request the electronic address of parents/guardians of web users who are under 15, when Bel is aware of that fact, in order to send them a copy of the registration email sent to their children. At any time, on simple request by contacting the consumer service, parents/guardians may have access to the personal data stored about their child and, if they wish, request that they are deleted from our databases. Similarly, parents/guardians may exercise all the rights which their child has in accordance with the rules applicable regarding personal data rights by contacting the consumer service according to the terms set out in Article 11 of this Policy. 13. UPDATES TO THIS POLICY This Policy may change periodically. If we hold contact information on you and there are relevant changes then we will inform you.