Privacy

R&R Ice Cream (UK) Ltd Privacy Policy (14th February 2019)

Welcome to R&R Ice Cream (UK) Ltd’s (“R&R”) privacy policy. R&R is part of the Froneri Group of
companies. You can find out more about our Group of companies on www.froneri.com.

R&R respects your privacy and is committed to protecting your personal data. This privacy policy will
inform you as to how we look after your personal data when interacting with us including when you visit
our website and tell you about your privacy rights and how the law protects you. Please note that by
providing data relating to any third parties (e.g. your family members) you confirm that you have
permission from that third party to the provision of their data to us. We process third party data in
accordance with this privacy policy.

Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how R&R collects and processes your personal data
when you interact with us as a customer, supplier or other person including any data you may provide
through this website when you sign up to our newsletter, purchase a product or service or take part in a
competition.

It is important that you read this privacy policy together with any other privacy policy or fair processing
notice we may provide on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data. This privacy policy supplements
the other notices and is not intended to override them.

Controller

R&R is the controller and responsible for your personal data (referred to as R&R, “we”, “us” or “our” in
this privacy policy). If you have any questions about this privacy policy, including any requests to exercise
your legal rights, please contact us using the details set out below.

Contact details

  • Full name of legal entity: R&R Ice Cream (UK) Ltd
  • privacy@froneri.com
  • Postal address: Leeming Bar Industrial Estate, Leeming Bar, Northallerton, North Yorkshire, DL7 9UL
  • Telephone number: (01677) 423397

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the
UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on the date above and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed
if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links
or enabling those connections may allow third parties to collect or share data about you. We do not
control these third-party websites and are not responsible for their privacy statements. When you leave
our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data in law as
this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage
Data to calculate the percentage of users accessing a specific website feature. However, if we combine or
connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat
the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health and genetic and biometric data). Nor do we collect
any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and
you fail to provide that data when requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with goods or services). In this case, we may
have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • become a customer, supplier or enter into other business relationships with us;
    • contact us with an enquiry or complaint;
    • interact with us using social media;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
    We collect this personal data by using cookies, and other similar technologies. We may also
    receive Technical Data about you if you visit other websites employing our cookies.

  • Third parties or publicly available sources. We may receive personal data about you fromvarious third parties and public sources as set out below

    • Technical Data from the following parties: (a) analytics providers such as Google based outside the EU; (b) advertising networks based inside or outside the EU; and (c) search information providers based inside or outside the EU.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services inside or outside EU.
  • Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the
  • Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We may from time to time also rely on your consent as a legal basis for processing your personal data,
although we generally only do this when sending direct marketing communications to you via email or
text message or sharing your data with third parties where you have a relationship with that third party
and you have consented to us sending information (for example social media sites). You have the right
to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data,
and which of the legal bases we rely on to do so (this does not include those scenarios where we rely on
your consent). We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific
purpose for which we are using your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in
the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer / supplier (a) Identity (b) Contact Performance of a contract with you
To address your enquiry or complaint (a) Identity (b) Contact (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (in some circumstances) (c) Necessary for our legitimate interests (to monitor our business and operational performance, to study how our customers use our products / services, to make decisions on how to improve our products / services)
To process and deliver your order /receive your goods / services (asapplicable) including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us / make payments due from us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legalobligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To detect, prevent, investigate or remediate crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies) (a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to protect our business and our legal rights)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and other crime and in the context of a business sale or reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing
and advertising. We will ask you to set your preferences with respect to the marketing that you receive
from us and from others and you will be able to change these preferences at any time by contacting us.

Promotional offers from us.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think
you may want or need, or what may be of interest to you. This is how we decide which products, services
and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or
purchased goods or services from us or if you provided us with your details when you entered a
competition or registered for a promotion and, in each case, you have not opted out of receiving that
marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside
the Froneri group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the optout links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies and similar technologies

These are small files that are widely used in order to make websites work more efficiently. Most web
browsers allow some control of cookies through browser settings. To find out more about cookies,
including how to see what cookies have been set and how to manage or delete them from your computer,
visit www.allaboutcookies.org.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
access cookies. If you disable or refuse cookies, please note that some parts of this website may become
inaccessible or not function properly.

On this website, we use:

Cookie / Technology Purpose Information
ASP.Net Necessary cookie The standard cookies in ASP.Net are used to remember your web browser and allow you to access and use the website.
Google Analytics Third party performance cookie / analytics technology Google Analytics uses “cookies”, to help the website analyse how users use the websites, applications or services. The information generated by the cookie about your use of the websites, applications or services (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the websites, applications or services compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser or within the application, however please note that if you do this you may not be able to use the full functionality of this website. By using our websites, applications or services you consent to the processing of data about you by Google in the manner and for the purposes set out above. To find out more, see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time). To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.
ASP.Net Necessary cookie The standard cookies in ASP.Net are used to remember your web browser and allow you to access and use the website.

R&R may, from time to time, engage in re-marketing, which means third-party vendors, including Google,
may display R&R adverts on the internet, based on your prior interaction with the R&R website. To find
out more about how Google uses any data it collects please visit http://www.google.com/privacy_ads.html.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the
table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary (below).
  • External Third Parties as set out in the Glossary (below).
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with
the law. We do not allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes and in accordance
with our instructions.

6. International transfers

We may share your personal data within the Froneri Group. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an ‘adequate’ level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who have a
business need to know. They will only process your personal data on our instructions and they are subject
to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
puroses through other means, and the applicable legal requirements.

By law we must keep basic information about our customers including Contact, Identity, Financial and
Transaction Data for six years after they cease being customers for tax purposes. We set our data
retention policies considering legal requirements and the factors identified above.

In some circumstances you can ask us to delete your data: see ‘Your Legal Rights’ below for further
information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with
you) for research or statistical purposes in which case we may use this information indefinitely without
further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

These rights are explained at the end of this notice. If you wish to exercise any of the rights set out at the end of this notice, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable
us to give you the best service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative) and your rights before we
process your personal data for our legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we have your consent or are otherwise
required or permitted to by law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary
for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES
Internal Third Parties

Other companies in the Froneri Group acting as joint controllers or processors and who are based in the
United Kingdom, EU and outside the EU and provide IT and system administration services, centralised
Group services (such as customer support or marketing), any products or services you have requested
and undertake leadership reporting.

External Third parties

  • Service providers acting as processors based in the UK, EU and outside the EU (typically in the US) who provide IT and system administration services;
  • Third party brand owners who own the intellectual property rights in the brands of the products we manufacture and sell in the UK, EU and outside the EU acting as processors or joint controllers who require reporting of processing activities in certain circumstances or who may need access to data to provide products, services or marketing information;
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, EU and outside the EU who provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
  • Customers of ours (and their audit providers) acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances (for example relating to the products we manufacture and supply to them for onward sale);
  • Third parties acting as processors or joint controllers based in the United Kingdom, EU and outside the EU used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
  • Third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites);
  • Third parties for marketing purposes where you have consented to this;
  • Credit reference and fraud prevention agencies, crime prevention and law enforcement agencies and regulators acting as processors or joint controllers based in the United Kingdom who require reporting to prevent fraud or other criminal offences in certain circumstances;
  • Service providers and agents (including their sub-contractors) acting as processors in the UK, EU and outside the EU who provide market research, marketing and advertising services to us or for and on our behalf;
  • Any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
  • Another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;
  • Another organisation to whom we may transfer our agreement with you; and
  • Government departments where reporting is mandatory under applicable law.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables
you to receive a copy of the personal data we hold about you and to check that we are lawfully processing
it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete
or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new
data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also have the right to ask us to delete
or remove your personal data where you have successfully exercised your right to object to processing
(see below), where we may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may not always be able to
comply with your request of erasure for specific legal reasons which will be notified to you, if applicable,
at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a
third party) and there is something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have
the right to object where we are processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process your information
which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us to establish the data’s
accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need
us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal
claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third
party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However,
this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you
withdraw your consent, we may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.

©R&R Ice Cream (UK) Ltd 2018. All rights reserved.