Privacy & Security

We are Forthglade Foods Ltd, a company registered in England & Wales with company number 07781711. Our registered office is at Woodwater House, Pynes Hill, Exeter, Devon, United Kingdom, EX2 5WR.

The Forthglade Group is made up of different legal entities. This privacy policy is issued on behalf of the Forthglade Group of companies, so when we mention the Forthglade Group ("we", "us", or "our") in this privacy policy, we are referring to the relevant company in the Forthglade Group responsible for processing your data.

For the purposes of the Data Protection Laws (as defined below), we are the "data controller" of your personal data. That means that we are responsible for deciding how your personal data is used.

We are committed to being transparent about how we handle your personal data, to protect the privacy and security of your personal data and to ensure that we meet our obligations as a data controller under the UK General Data Protection Regulation, the Data Protection Act 2018, the EU General Data Protection Legislation (to the extent applicable), and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (together, the "Data Protection Laws"). This privacy notice describes the ways that we will process your personal data and also describes some of the ways that we protect your personal data and how we ensure compliance with the Data Protection Laws. This privacy policy also provides you with the necessary information regarding your rights and our obligations, and so it is important that you read and understand it.

This privacy policy explains how we use any personal information we collect about you when you use this website.

If there is anything in this privacy notice that you do not understand or you have any questions about this privacy notice or about how we handle your personal data, please contact Jim Hancock, Data Protection Officer (Jim.Hancock@forthglade.com).

We"Personal data" means any information about an individual from which that person can be directly or indirectly identified. Personal data excludes anonymous or de-identified data that is not associated with a particular individual.

We may collect, use, store and transfer different kinds of personal data about you. This includes, but is not limited to:

• Identity Data: which may include your first name, last name, previous names (if applicable), usernames, marital status, title, date of birth and gender;
• Contact Data: which may include billing address, delivery address, email address and telephone numbers;
• Financial Data: which may include payment details;
• Transaction Data: which may include details about payments to and from you and other details of products and services you have purchased from us;
• Technical Data: which may include 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, device ID and other technology on the devices you use to access this website;
• Profile Data: which may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
• Usage Data: which may include information about how you interact with and use our website, products and services; and
• Marketing and Communications Data: which many include 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 which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We collect information from and about you in different ways, including:

When you directly give it to us (“directly provided data”)

When you visit our website, create an account on our website, register with us, subscribe to our services or publications, place an order for products or services with use, request marketing to be sent to you, complete customer surveys, enter competitions/promotions, give us feedback, or contact us.

All of this information requires a direct action by you.

When you give us permission to obtain it from other businesses (“user authorised data”)

Depending on your settings or the privacy policies for other online services, you may give us permission to obtain information from your account with those other services. For example, if another website jointly runs a competition with us, they will send us a list of the entrants who opted to receive our email newsletter as part of their entry. The information we obtain from such third parties does depend on your settings for that service or their privacy policies, so you should always regularly check what those are. However, we will only arrange such joint-promotions if it is made clear how the data will shared with us.

When our systems, or those of companies we engage with, collect information or data as you use our website or other services (“system collected data”)

Whenever you use a website, or read email, data is created and recorded automatically by the IT systems behind the website or email service. For example:

(a) When accessing Forthglade.com, we use “cookies” (a small text file sent by your computer each time you visit our website, unique to your Forthglade account or your browser) to make it easier for you to use Forthglade.com, improve your shopping experience with us or so we can log data relating to the pages you viewed and activities you carried out during your visit. These cookies may be “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you or your browser deletes them). Some of the cookies we use are directly associated with your Forthglade account (relating to things like the email address you gave us), and other cookies are not. There are more details on our cookie usage below

(b) In addition, the type of device you’re using to access Forthglade and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. What information we can be provided with depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or an Android phone. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.

We will only use your personal data when the law allows us to. Whenever we process your personal data, we are required to identify and maintain a valid "lawful basis" (i.e. a legally compliant justification) for the processing. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you (i.e. to process your orders and manage your account).
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose (i.e. if you subscribe to an email newsletter).

Digital marketing

During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us and/or Epsilon International UK Limited ("Epsilon") via post and/or email. Additionally, you may 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 the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

What if you fail to provide personal data?

Please make sure you provide us with information when requested. If you do not provide the required information, we may not be able to perform the contract we have entered into with you (such as providing you with the goods/services you order).

Change of purpose

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain our legal justification for doing so and we will provide you with any relevant further information. We may also issue a new privacy notice to you.

How and when we will share your personal data

We may disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the contract / relationship with you, including third-party service providers who provide services to us or on our behalf.

We partner with Epsilon to provide you with personalised advertising and content. Epsilon may use first- and third-party cookies and other techniques (including cookies and pixels from Epsilon's advertising partners, a current list of which is available here: https://legal.epsilon.com/eu/publisher-partners) to recognise your browser and collect information about your web browsing activity when visiting this website. [You may read more about Epsilon’s use of cookies and other similar technologies by visiting: https://www.epsilon.com/emea/cookie-list] Such cookies and techniques collect personal data (e.g., information about the browser or device you are using, including browser type, browsing activity, cookie ids, IP-addresses and transactions made). [We also provide Epsilon with other information about you, such as name, address and email for the same purpose. Please contact us if you no longer want us to share such information.] Detailed information about Epsilon’s processing can be found in Epsilon’s privacy policy: https://emea.epsilon.com/privacy-policy. You may visit the European Interactive Digital Advertising Alliance at http://youronlinechoices.eu/to learn more about personalised interest-based advertising, and to opt-out of receiving the same from their respective members. You can also visit Epsilon’s data subject request tool available here: https://legal.epsilon.com/dsr/.

We may also share your information in the following circumstances:

• To business partners, suppliers, subcontractors and other third parties as necessary for the performance of any contract we enter with you, such as the delivery of an order or processing of a credit card payment
• To business partners, suppliers and subcontractors and other third parties as necessary for the performance of any contract we have with them, for example we use a third-party supplier to send marketing emails
• In the event of a competition or promotion where we give you the opportunity to opt-in to news and offers from a third party. If you do opt-in, we will pass the relevant details, typically just your name and email address, to the third party
• To analytics and search engine providers that assist us in the improvement and optimisation of our website
• If we sell or acquire a business or assets, or otherwise reorganise our business, we may disclose your personal data to the prospective buyer, seller or other relevant party involved in the transaction. Any such disclosure will be subject to appropriate confidentiality protections, including a non-disclosure agreement where appropriate.If Forthglade Foods Ltd, or substantially all of its assets, are acquired by the third party, personal information held by it about its customers will be one of the transferred assets
• To protect our website from fraud and theft we may pass on personal information that is required to make identity checks and personal information that we obtain from making identity checks (including information relating to your age, name and location), together with account information to organisations, including law enforcement agencies, involved in fraud prevention and detection and credit risk reduction. Please note that these third parties may retain a record of the information that we provide to them for this purpose.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation
• In order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of Forthglade Foods Limited, our customers or others.
• We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. These retailers and charities share information about their customers and supporters and what they buy or donate. Epsilon Abacus processes this information as a processor on behalf of these companies to help them understand individuals’ behaviour and preferences. Epsilon combines information provided by participating retailers and charities with third party data. From this combined information, these companies can tailor their communications, sending individuals suitable offers and appeals that should be of interest to them. You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here.

We will always make sure that these trusted suppliers meet agreed standards for the protection of your personal data and that they will only ever be allowed to use your personal data in order to provide us with services (and not for their own purposes). We require all third parties to take appropriate technical and organisational security measures to protect your personal data and to treat it subject to a duty of confidentiality and in accordance with Data Protection Laws.

Sharing your personal data with other entities in our group and our investors

We will share your personal data with other entities in our group as part of the administration of our business. For example, we may share personal data as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely EEA countries and the United States of America; or
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact Jim Hancock, Data Protection Officer (Jim.Hancock@forthglade.com).

Additionally, we may share your personal data within the Forthglade Group. This will involve transferring your data outside the UK to our overseas offices in the United States of America.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented. We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact Jim Hancock, Data Protection Officer (Jim.Hancock@forthglade.com).

We take the security of your personal data very seriously and have put in place physical, technical, operational and administrative strategies, controls and measures to help protect your personal data from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice. We will always keep these under review to make sure that the measures we have implemented remain appropriate. You can obtain further information about these measures from Jim Hancock, Data Protection Officer (Jim.Hancock@forthglade.com)

In addition, we limit access to your personal data to those employees, workers, agents, contractors and other third parties who have a need to know in order to perform their job duties and responsibilities. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Forthglade will not share your information with other companies for their marketing purposes, and will not sell, or seek to make financial gain from, your information, aside from our own marketing activities.

We do not store or retain your financial information, such as credit card numbers. All website payments are taken by third parties who give us details of you, your order number and status of the payment, but not your credit card numbers.

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

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data (see below for further information).

We would like to send you
information about products and services via email. We will only do this if you
opt to receive such information. 

Every email newsletter that we
send out includes an unsubscribe link. You can also unsubscribe by contacting
customer services. You can ask to us to stop sending you marketing
communications at any time.

We do not send marketing text
messages or social media direct messages, and will not do so in the future
without your explicit permission.

If you opt out of receiving
marketing communications, you will still receive service-related communications
that are essential for administrative or customer service purposes (i.e. order
confirmations for a product/service warranty, registration, appointment
reminders, updates to our Terms and Conditions, checking that your contact
details are correct).

You have a number of legal rights under Data Protection Laws in relation to your personal data.

You have the right to:

• Request access to your personal data (this is commonly known as a '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 the correction of your 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 use.
• Request erasure of your personal data in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see 'Marketing opt out' section above for details of how to object to receiving direct marketing communications).
• 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  
  o If you want us to establish the data's accuracy;
  
  o Where our use of the data is unlawful but you do not want us to erase it;
  
  o 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
  
  o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact Jim Hancock, Data Protection Officer (Jim.Hancock@forthglade.com).

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

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

For further information visit www.aboutcookies.org or www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.

Our website contains links to
other websites. This privacy policy only applies to the websites operated by
Forthglade Foods Ltd, so when you link to other websites you should read their
own privacy policies. 

We reserve the right to update or amend this privacy notice at any time, including where we intend to further process your personal data for a purpose other than that for which the personal data was collected or where we intend to process new types of personal data. We will issue you with a new privacy notice as soon as practicable when we make significant updates or amendments. We may also notify you about the processing of your personal data in other ways from time to time.

You have the right to complain tot if you have any concerns about the way we handle your data (our contact details are in the section above). We will try to put things right.

However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to the UK's Information Commissioner's Office ("ICO"). You can contact the ICO at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF; 0303 123 1113; or https://ico.org.uk/.