Privacy Policy

1. Introduction

This Privacy Policy governs the processing of any personal information collected in relation to customers of K.T.C. (Edibles) Ltd [and its Subsidiaries] and users of its website www.ktcfoodgroup.co.uk (the Site).
We are K.T.C. (Edibles) Ltd a company registered in England and Wales (Company No. 01433723) with its registered office at JS House Moorcroft Drive, Moorcroft Park, Wednesbury, West Midlands, WS10 7DE (KTC, we, our, us).

We are a data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 whilst undertaking our business services.

KTC is owned by Endless LLP, who shall also act as a data controller of any KTCs data that is provided in connection with their investment and ongoing relationship with KTC. Personal data will be processed by Endless LLP in accordance with the Endless Portfolio Privacy statement, accessible here: https://www.endlessllp.com/portfolio-privacy-statement. Endless LLP is a company incorporated in England and Wales with Company Reg. No. OC316569.

We are committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully as it contains important information on our practices regarding your personal information and how we, as a data controller, will treat personal information you provide to us through our Site, including the information we collect, what we do with the information you provide to us and who we may share your information with.

Our Site also use cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For more information on how our Site uses cookies, please see our cookie policy.

2. Data Protection Principles

We will comply with data protection law and principles, which means that your information will be:

• Used lawfully, fairly and in a transparent way;
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• Relevant to the purposes we have told you about and limited only to those purposes;
• Accurate and kept up to date;
• Kept only as long as necessary for the purposes we have told you about; and
• Kept securely.

3. The type of information we collect about you

If you purchase services from us, communicate with us, or do business with us, this will result in us collecting personal data about you. We will collect, store, and use the following types of personal information about you:

• Contact data such as the name, address, email, fax and telephone number of business contacts.
• Bank and transaction data such as details about payments to and from you and other details of products and services you have purchased from us.
• Technical data such as includes 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 which includes information about our service to you including your username and password, purchases or orders made by you, your preferences and any feedback you give us. Records of your correspondence with us if you contact us.
• Usage data which includes information about how you use our website, products and services.
• CCTV footage in the event you appear on CCTV installed by us.
• Marketing and communications data, including your preferences in receiving marketing from and our third parties and your communication preferences.

We do not normally collect special categories of sensitive personal data from our customers or users of our website (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. In the event you provide us with any special category data, we will take extra care to ensure your rights are protected.

4. How is your personal information collected?

We collect your personal information through different methods including:

• Direct interactions with you by telephone, e-mail, phone or otherwise.
• Through the service we provide to you.
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

5. How we will use your personal information

We will only use your personal information 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.

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to such marketing at any time by contacting us.

6. Purposes for which we use your personal information

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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7. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your 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 and you have not opted out of receiving that marketing.

8. Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

9. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

10. If you fail to provide personal information

If you fail to provide certain information when requested either by law, or under the terms of a contract we have with you and you fail to provide that information 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 service you have with us but we will notify you if this is the case at the time.

11. Change of purpose

We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

12. Sharing your personal information

Where we are acting in our capacity as data controller we will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

We may share your personal information with:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. Analytics and search engine providers that assist us in the improvement and optimisation of the Site;
• Our group companies;
• Auditors, accountants and financial organisations;
• Insurers, solicitors, professional advisers and consultants;
• Survey and research organisations;
• Police forces, courts, tribunals; and
• Professional bodies.

We may be required to share your information with third-party service providers (including contractors, suppliers and designated agents). The activities carried out by third-party service providers include, but are not limited to: IT support, website design and payment merchants.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or the police or to otherwise comply with the law.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.

In the event we transfer your personal data outside of the UK, where the recipient is based in a jurisdiction that has not been deemed to provide adequate protection of your data, we will put in place specific contractual protections approved for use by the UK Information Commissioner’s Office (ICO) in order to ensure that your data is adequately protected.

13. Data security

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

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

14. Data Retention

We will only retain your personal information 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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal information are available in our Retention

Policy which you can request by contacting us.

15. What rights do you have?

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your business relationship with us.

Under certain circumstances, by law you have the right to:

1. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
4. Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
6. Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our HR Department via hr@ktc-edibles.co.uk or K.T.C. (Edibles) Limited, Moorcroft Drive, Wednesbury, West Midlands, WS10 7DE. Please note, there are some specific circumstances where these rights do not apply and we can refuse to deal with your request.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our HR department via email hr@ktc-edibles.co.uk or write to us at K.T.C. (Edibles) Ltd, JS House Moorcroft Drive, Moorcroft Park, Wednesbury, West Midlands, WS10 7DE. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Complaints:

We take any complaints we receive about the collection and use of personal information very seriously. We would encourage you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. You can make a complaint at any time by contacting us (see contact details section below).

If you think our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at the following address:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Contact us:

You can e-mail us at hr@ktc-edibles.co.uk or write to us at the following address: K.T.C. (Edibles) Limited, JS House, Moorcroft Drive, Wednesbury, WS10 7DE

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16. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this Privacy Policy, please contact our HR Department via email – hr@ktc-edibles.co.uk

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