Caterlyst Limited (“Caterlyst”), “Us”, “We”, “Our”] registered in England and Wales under company number 05962192 and is the Data Controller of your Information for the purposes of the Data Protection Act 1998 (the “Act”), and from May 25th, 2018 for the purposes of The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/6, (the “Regulation”).
We respect your privacy and we are committed to protecting your personal Information as defined in both the “Act” and in the “Regulation”.
We aim to maintain consistently high levels of best practice in our processing of your information.
By using our website and services you consent to our collection and use of your Information as described in this Policy. If we change our Policy and/or procedures, we will update this Policy to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.
2 WHAT INFORMATION DO WE COLLECT?
All your Information will be held and used in accordance with the “Act” and the “Regulation” where applicable. If you want to know what Information we collect and hold about you, please email us at: firstname.lastname@example.org, or write to us at the address given at the end of this Policy. When you visit and use our websites or request our services you may provide us with or we may collect your Information such as your postal address, email address and other personal information.
2.1 Information you voluntarily provide to us
We collect and maintain Information that you voluntarily submit to us during your use of our website or services. For example:
· When you register on our website or for a product or service, you may provide us with certain Information including your name, email address, user name, password and demographic Information
· If you sign up to our service via a social network we may use the profile Information you enable us to access regarding your interests.
· If you sign up to receive a newsletter or participate in social networking activities, you may provide us with contact Information (e.g. email, telephone and/or physical address)
· You may provide us with Information in the course of email, customer support interactions and surveys.
Different services operated by us may ask for different pieces of Information. You can choose not to provide us with certain Information, but this may stop you from gaining access to a service or limit the features that you can use on our websites. For more Information, please see the “How We Use Your Information” section of the Policy below.
2.2 Information we collect through your use of our Website & Services
2.3 Information we receive from third parties
We may also combine online and/or offline Information received from third parties with your Information. The third-party Information is used for a variety of purposes including to verify other Information about you (e.g., verify your mailing address to send you requested products or services) and to enhance the content and relevance of the services we provide.
3 HOW WE USE YOUR INFORMATION
We may process your personal information for our legitimate business interests.
“Legitimate Interests” means the interests of our company in conducting and managing our business. For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under the “Act” and the “Regulation”. Our legitimate business interests do not automatically override your interests - we will 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).
Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights.
You have the right to object to this processing if you wish, and if you wish to do so please click here. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.
3.1 To Provide the Services
In general, we use your Information as necessary or appropriate for our legitimate business purposes including to:
· Administer your account where you have opened an account with us
· Register you and provide you access to the website or services requested by you
· Respond to inquiries or requests that you direct to us
· Fulfil your requests for products or services
· Send communications and administrative emails about the website or our services
· Personalise and better tailor the features, performance and support of the website and our services for your use; analyse, benchmark and conduct research on user data and user interactions with the website and our services
· Deliver customer services
· Other purposes related to any of the above
Where you have provided us with the appropriate consents, or where the “Act” or the “Regulation” entitles us to do so, we may send you marketing materials about other products or services offered by Caterlyst Ltd and our clients, as part of carrying out our legitimate business interests.
In addition, we may also host messages on behalf of selected third parties in the Foodservice and Convenience sector where the Information they provide will be relevant to you.
However, be assured that we understand the irritations of unsolicited communications and we are fully committed to ensuring the rights and obligations are respected as set out in the “Act”, in the “Regulation” and the Privacy and Electronic Communications Regulations 2003, updated 2004 and 2011.
4 HOW CAN I FIND OUT WHAT PERSONAL INFORMATION CATERLYST HOLDS ON ME?
Under the “Act” and the “Regulation” you have the right to request a copy of the Information that we hold about you. We will require two pieces of identification to prove your identity. Please make a written application to the Data Controller,
If any of the Information that we hold about you is incorrect and you’d like it amended, please email the email@example.com and we’ll review your request.
5 HOW WE DISCLOSE YOUR INFORMATION TO THIRD PARTIES
We may share your Information with third parties under the circumstances described below and in this Policy.
5.1 Disclosure for legal reasons
We may disclose your Information if we are under a duty to disclose or share your Information to comply with any legal obligation or in order to enforce or apply or fulfil our terms and conditions and other agreements or protect the rights, property, or safety of our customers or others.
We use carefully selected third party organisations to help provide a professional service to our customers. These organisations act as data processors and are strictly contractually controlled under the “Act” and in the “Regulation” in how they process your Information.
5.2 Changes to our Company
In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
6 UPDATING AND CONTROL OF YOUR INFORMATION
There are a number of ways in which you can control the collection, use, and sharing of your Information and update your Information and preferences.
7.1 Opting-Out on Receipt of Marketing Communications
When you receive electronic marketing communications from us you will have the opportunity to "opt-out" by following the unsubscribe instructions provided marketing communication from us.
7.2 Preference Services
The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS) and the Mailing Preference Service (MPS) allow you to choose to opt out of unsolicited marketing contact. However, if you are registered on any of the preference services, which are general opt-out registers, you may still receive marketing communications from us if you have given us your consent previously or if you subsequently give us that consent.
7.3 Contacting Us
If your Information has changed or if you no longer wish to receive marketing communications from us then you can amend your Information or update your preferences if you click here.
Please note that:
· Even if you delete Information, we may retain your Information in conformance with our data retention policy most specifically for legal reasons and to honour your opt-out requests; and
· We do not keep Information longer than required for the purposes of our legitimate business activities.
8 THIRD PARTY LINKS AND SERVICES
Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies. Your browsing and interaction on any other website or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies.
We do not monitor, control, or endorse the Information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This Policy applies solely to Information collected by us through our website or services and does not apply to these third-party websites and third-party service providers.
9 WHERE WE STORE YOUR INFORMATION
The Information that we collect from you will be stored and processed at a destination inside the European Economic Area, (all EU countries plus Norway, Iceland and Liechtenstein). By submitting Information to us, you agree to this transfer, storing or processing. We will take all reasonable steps necessary, including contractual means to ensure that your Information is treated securely and in accordance with this Policy, the “Act” and the “Regulation”.
10 SECURITY OF YOUR INFORMATION
We follow appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal Information to comply with the same. However, unfortunately, the transmission of Information via the Internet is not completely secure. So, we cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the “Act” and the “Regulation”. Act. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.
11 REPORTING OF SECURITY VULNERABILITIES
Caterlyst Ltd is committed to the privacy, safety and security of our customers. If you discover a potential security vulnerability, we would appreciate it if you could report it just to us in a responsible manner. Please email us at firstname.lastname@example.org, who will respond to you as soon as possible. This provides us with an opportunity to work with you and quickly address and resolve any issue. Publicly disclosing a potential vulnerability could put the wider community at risk, and therefore we encourage you to come to us first. We’ll keep you informed as we move forward with our investigations.
12 SOCIAL MEDIA
12.1 Caterlyst Ltd may provide users with the ability to use their social media credentials to sign in to our website(s)
When you create your Caterlyst account, and authenticate via a third-party service like Linked-in, you grant permission to the social network to share your user details with us.
Depending on the network this will include
· Basic account Information included in your public profile such as name and email address required to verify and facilitate your sign in
· Other Information that is publicly available based upon the privacy settings you have with your social media account.
· Any other details you choose to share according to your specific account settings.
We will be clear when we do request more than just basic account Information from you and request that you should also check what permissions we are asking for before you connect with these apps and services. We want to use this Information to better tailor any content we provide to you.
Social sign-in may be provided by Caterlyst or a third party
12.2 Social networking sites, such as Facebook, Linked-In, among others, work with us as trusted third party partners. We also work with application developers who specialise in social media, so that we can connect with your social networks. We provide access to our Websites for third parties and business partners so that we can generate interest in our products and services among members of your social networks and to allow you to share product and service interests with friends in your network.
12.3 We do not control how your personal Information is collected, stored or used by such third party sites or to whom it is disclosed. You should review the privacy policies and settings on any social networking site that you subscribe to so that you understand the Information they may be sharing. If you do not want your networking sites to share Information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such Information. Caterlyst is not responsible for how these third party sites may use Information collected from or about you.
13 ANTI-SPAM POLICY
Caterlyst provides interesting and useful content in our emails and aims to tailor them to the specific needs & interests of our audience. We hope you enjoy receiving and reading them.
13.1 Automated Spam Filtering: We automatically scan all incoming electronic messages and filter out those that appear to be spam. As no system can be 100% accurate in detecting genuine emails from spam, authentic messages may occasionally be filtered. If you believe this may have happened, please contact the recipient by another means.
13.2 Unwanted messages from Caterlyst: Any recipient of email communication from us may request, at any time, to unsubscribe. In the unlikely event you are in receipt of email communication from Caterlyst Ltd which could be considered as spam, we encourage you to report it to us by forwarding a copy to us at: email@example.com
We will fully investigate any reports of abuse.
Updated 19th March 2018
Data Controller, Caterlyst Ltd, Suite 14, 5 Hercules way, Leavesden park, Watford, WD25 7GS