What is the purpose of this document?
Matthew Clark Bibendum is committed to protecting the privacy and security of the personal information of its employees, workers, contractors, customers, suppliers and other third parties.
This data protection policy describes how we collect and use personal information about you during and after your trading relationship with us, in accordance with the General Data Protection Regulation (GDPR).
It applies to all customers, suppliers and other third parties that trade or otherwise deal with our business. This statement does not apply to candidates, workers or employees and more information.
Matthew Clark Bibendum Limited (“we”, “us”, “our”) is a "data controller" (registration number: Z5208550). This means that we are responsible for deciding how we hold and use personal information.
This Privacy Statement applies to all customers, suppliers and other third parties that trade or otherwise deal with our business ("you", "your").
It is important that you read this statement, together with any other information we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
HOW WE PROCESS YOUR PERSONAL INFORMATION
The kind of information we hold 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).
There are "special categories" of more sensitive personal data which require a higher level of protection.
We may collect, store, and use the following categories of personal information about you:
• Identity data (including name, title, job title, nationality and gender).
• Contact data (including email addresses, telephone numbers and postal address).
• Technical usage data (including usernames, passwords, IP addresses, information about how you use our websites, browser type and version, and other technical information about the devices you use when you access our website).
• Communications data (including emails, telephone calls and post which you receive from us or send to us, and your preferences in receiving information and being contacted by us).
• CCTV footage (where you visit our premises or come into close proximity with one of our vehicles).
Where you trade with us as a sole trader, partnership or a club/association, we may also collect, store, and use the following categories of personal information about you:
• Financial data (including bank account, payment card details, credit rating, assets and liabilities, trade references and other information about your business).
• Transaction data (including details about orders made by you, payments to and from you and other details of goods and services you have purchased from us).
How is your personal information collected?
We primarily collect personal information when you apply for a trading account with us, when you communicate with your account manager, buyer or our contact centre or otherwise through our customer and supplier on-boarding process, either directly from you or sometimes from a credit reference agency or other trade reference.
We will also collect personal information about you if you visit our premises or websites, if you contact us via email, telephone or post, if you subscribe to our publications or request information to be sent to you, if you enter a competition, promotion or survey, if you attend one of our events or where you have indicated that you would be interested in trading with or otherwise dealing with our business.
We may collect additional personal information in the course of trade-related activities throughout the period of you trading or otherwise dealing with us.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. 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.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else's interests).
2. Where it is needed in the public interest or for official purposes.
Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing communications at any time by contacting us.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information are listed below.
• Registering you as a new customer or supplier.
• Administering the contract we have entered into with you.
• Order fulfilment, including managing payments and collecting money owed to us.
• Managing our relationship with you, responding to your queries and providing you with information about our goods and services.
• Making a decision about your credit worthiness, payment terms, credit limit and security.
• Business management and planning, including accounting and auditing.
• Making arrangements for the commencement or termination of our trading relationship.
• Education, training and development requirements.
• Dealing with service issues or legal disputes involving you, or other customers and suppliers, or our own employees, workers and contractors.
• Complying with health and safety obligations.
• Administration of competitions, promotions, surveys and events.
• Prevention of crime and fraud.
• Monitoring your use of our information and communication systems to ensure compliance with our IT policies.
• Monitoring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• Data analytics studies to review and improve our websites, goods and services, and customer and supplier relationship and experiences.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or delivering goods to you), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
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 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.
We may have to share your data with third parties, including third-party service providers and other entities in our group of companies.
We require third parties to respect the security of your data and to treat it in accordance with the law.
Why might you share my personal information with third parties?
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.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group 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 data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group 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.
What about other third parties?
We may share your personal information with other third parties as required to administer your contract with us, to ensure our compliance with legal obligations and to protect our legitimate interests, which may include (without limitation) HM Revenue & Customs, accountants and auditors, lawyers and debt collection agencies.
We may also share your personal information with other third parties in the context of the possible sale or restructuring of the business.
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
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.
How long will you use my information for?
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 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 purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain your personal information in accordance with our Data Protection Policy and all applicable laws and regulations.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
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.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
• 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.
• 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.
• 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).
• 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.
• 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.
• 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 email@example.com.
No fee usually required
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.
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 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 firstname.lastname@example.org. 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.
Facial Recognition and Target Tracking
Bibendum Apps use can use Augmented Reality Technology which use APIs (Application Programming Interface) for in-app facial recognition and target acquirement, such as the TrueDepth API. Below is a summary of how APIs such as TrueDepth are used:
- Used for facial recognition in order to overlay animation over the face accurately
- Data is used internally in the app for efficient and effective facial recognition
- User facial data is not shared by any third parties
- Facial data is used for internal app operation for Augmented Reality.
Because Plonk is all about sharing your Augmented Reality experience with friends, with photos and videos taken on the app, the app asks - with your permission - to allow access to contacts for this purpose.
Camera and photos
Our services require us to collect images and other information from your device's camera and photos. For example, you won't be able to send videos or upload photos from your camera roll unless we can access your camera or photos.
What are cookies and why do we use them?
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
Cookies make the interaction between users and websites faster and easier, and help to improve websites. Without cookies, a web site could not remember a user's preferences or registration details for a future visit.
The types of cookies we use
We have classified our cookies according to the categories proposed by the International Chamber of Commerce.
None of the cookies used on our websites gather personal information about you.
We use the following types of cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping basket or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
|Name of Cookie||What it does||Where you can find more information|
|“Performance Cookie” used by Google Universal Analytics and limits the collection of data on high traffic sites.||
|“Performance Cookie” used by Google Universal Analytics and distinguishes unique users in order to calculate visitor, session and campaign data for the site’s analytics reports.||
|“Targeting Cookie” used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers||https://www.facebook.com/business/
Cookies used by third parties
Blocking or opting out of cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice 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.