Tre, Pol & Pen Privacy Policy

Last Updated 23rd May 2018

Your information is your information and we understand that, which is why we are committed to respecting the privacy of anyone who visits our farm shops or restaurants (our “Services”) or our website (the “Site”).

Just to let you know the Site is not intended for children, specifically anyone under the age of 16, so if you are under this age please do not use our Site.

This privacy policy (“Privacy Policy”) explains our approach to any personal information we might collect from you (or where a third party has collected it on our behalf) because we want to ensure that you understand this. It also explains what our purpose is when we process this information and your rights surrounding this.

1. WHO ARE WE AND WHAT DO WE DO?

The Site and our Services are operated by DJ Watkins Farming Enterprise trading as Tre, Pol & pen (“we”, “us” or “our”).

2. HOW TO CONTACT US?

If you have any questions about this Privacy Policy or wish to exercise your rights set out in this Privacy Policy, please contact our friendly Data Privacy Team

• sending an e-mail to contactus@trepolandpen.com; or
• writing to us at Tre Pol & Pen Data Team, Highfield House, Holsworthy Beacon, Devon, EX22 7NF

3. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

We collect and use your personal information in a variety of ways, for example, to provide you with the Services that you have requested from us such as ordering a delivery or to send you marketing.

We have set out below the ways in which we collect your personal information and the reasons why we use it.

Fulfilment of Services: We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services. For example, when you request for us to make an order, sign up for a loyalty card, download a voucher, log on to our Wi-Fi, order a food collection, or pay for your shopping through trepolandpen.com.

In providing the Services, we may collect the following types of personal information:

• Title, first name and surname
• Email address
• Contact telephone number
• Number of children aged under 12
• Address or geographic location
• Payment information
• Gender
• Device used and basic Facebook profile (where logging onto Wi-Fi)
• Birthday

What is our legal basis?

It is in our legitimate interest to use your personal information to provide the services you have requested from us and where it is necessary for the performance of any contract that we have with you.

Customer services: Our Site allows you to request information about our products and Services or make a complaint about any of the Services. Your name and contact information may be requested in each case, together with details of other personal information that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your request or complaint.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.

Your feedback about our products and services:From time to time we will ask you to provide feedback about our products and services in the form of a survey. We collect the following types of personal information:

• First name and surname
• Email address
• Telephone number
• Address

We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and services.

What is our legal basis?

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

Customer insight and analysis: We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services in our restaurants, such as the products and services you have purchased or viewed, or from your use of our restaurant Wi-Fi.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

• An IP address to monitor Site traffic and volume
• A session ID to track usage statistics on our Site
• Information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences

Our web pages and e-mails contain certain Tags such as “cookies” "web beacons" or “pixel tags” (“Tags”). Tags allow us to track receipt of an e-mail to you, and/or to view your web page and email interactions. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Please see our cookie policy for further information,

We also use this information for marketing purposes (see the Marketing section below for further details).

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

We will only use your location data for customer insight purposes where we have your consent to do so.

MARKETING

We carry out the following marketing activities using your personal information:

Email marketing: We use your personal information (including details of our offers, newsletters and events), where you have consented to receive such marketing communications or where we have another lawful basis to do so.

Our email marketing will include personalised and non-personalised email marketing. Personalised email marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature our products and services that we think are most likely to appeal to you. Non-personalised marketing is marketing about our products and services generally and is not tailored to any particular individual.

Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our Site, and our email communications to you and/or with our products and services in our restaurants.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have an alternative lawful right to do so.

Online and social media advertising: We use your email address to serve you with online advertising (including on social media channels) operated by Facebook, Instagram and Google where you are a registered user of such services.

Our online and social advertising will include personalised and non-personalised remarketing. Personalised advertising is marketing which has been specifically tailored to you. For example, our personalised remarketing will feature our products and services that we think are most likely to appeal to you. Non-personalised advertising is marketing about our products and services generally and is not tailored to any particular individual.

Where we are undertaking personalised online advertising, we will also use information that we observe about you from your interactions with our Site, and our email communications to you and/or with our products and services in our restaurants (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected).

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

Recruitment.

We use your personal information (e.g. name, job title, contact information including email address, curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us and any other information relevant to potential recruitment) for the following recruitment purposes:

• We use your personal information (e.g. name, job title, contact information including email address, curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us and any other information relevant to potential recruitment) for the following recruitment purposes:
• To review our equal opportunity profile in accordance with applicable legislation, and we do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit.

What is our legal basis?

Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for Azzurri Restaurants. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent which shall be obtained at the time we collect your personal information following the instructions provided

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

4. HOW DO WE SHARE YOUR PERSONAL INFORMATION?

We do not sell any of your personal information to any third parties. Your privacy is important to us. However, we will share your personal information with a variety of companies, where it is necessary to do so, in order to enable us to provide the services to you as set out in this Privacy Policy.

We may share your personal information with the following types of companies:

 

6. HOW DO WE OBTAIN YOUR CONSENT?

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or
• by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

7. THIRD PARTY LINKS AND SERVICES

Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Policy no longer applies.

9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

Regarding personal information we have processed in connection with the supply of our products and services to any customer, we will retain personal information relevant to that supply of products or services for six years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal information we have processed, we will retain relevant personal information for a period of five years from the date of our last interaction with you.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely so we do not send you marketing communications again.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it at the end of that period.

10. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

1. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

You have the following rights in relation to the personal information we hold about you:

Your right of access: If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification: If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure: You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing: You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability: With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object: You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing;
• processing your personal information for non-personalised direct marketing.

Your rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

Your right to withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

12. CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.