Privacy and cookies policy

Last Updated: 2 June 2020

 

What this policy covers

The data controller (who determines the purpose and manner in which your personal data is used) is Kedar DTC UK Limited trading as Home Delivery Grocery  (referred to in this policy as “we” or “us”).

We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That’s why we’ve developed this privacy and cookies policy (“Policy”), which:

  • Sets out the different ways you interact with us and the types of personal data that we collect
  • explains the reasons why we use the data we collect
  • explains when and why we will share personal data within the group of companies owned by Kedar DTC UK Limited and with other third party organisations; and
  • explains the rights and choices you have when it comes to your personal data


Third Party service providers refers to customer care, delivery, warehouse, logistics, payment and hosting service providers that are essential to providing you with the service or information, or fulfilment of our contract with you

We offer a wide range of products and services, so we want you to be clear about what this Policy covers. This Policy applies to you if you use our services (referred to in this Policy as “our Services”) and buy goods from us.

Using our Services means:

  • Shopping with us over the phone or online or;
  • otherwise using any of the websites (“our Websites”) or mobile applications (“our Mobile Apps”)1 or third party service providers2 where this Policy is posted
  • This Policy also applies if you contact us or we contact you about our Services


Some affiliated  companies (where control or ownership is similar to us)  and other group companies (owned by Kedar DTC UK Limited) and third party service providers may need to collect and use the personal data you provide in order to provide you with the products and services and for certain other purposes. They have their own privacy policies that explain how they use your personal data.

Our Websites or Mobile Apps may contain links to other websites operated by other organisations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal data on a website as we do not accept any responsibility or liability for websites of other organisations.

1 Where our Mobile Apps process additional data, you will see a separate “just in time” notification in the Mobile App

2Online media channels include websites, social media sites, Youtube channels,  and any other channels that become available to us

 

Personal data we collect when we interact with you

  • This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.

Types of data

Aggregated data

We try and remove personal data we do not need. If we remove enough personal data it becomes anonymous. This means that you cannot be identified.

We might also take data we hold and remove certain information and replace it with other non-identifying information such as ID number or reference number. This is an extra technique we use to protect data. We normally use these techniques to look at large amounts of individuals. This includes information that is statistical or demographic data.

Identity data

This is information that helps us identify who you are, so your name, title or account number or userID.

Contact data

This is information that details how we can contact you i.e your address, email or telephone number.

Financial data

This is information about your bank account and payment card details.

Location data

In some cases our apps might ask for your location information to help better serve you information about your local store, you will be made aware at the time if we would collect this data.

Special category data

This is special information that the law says is more sensitive (sometimes it is referred to as sensitive personal data) and it needs more protection. If we collect sensitive personal data in our interactions with you (for example you are making a complaint to us), this will be done with your consent and its use made clear to you.

Transaction data

This is information about your purchase of a product or service from us. This includes when, where, what and how you purchased that item or service. It will also include where we sent that product or service, any offer or promotional schemes applied or other benefits awarded or collected as part of the transaction.

Technical data

This is information about your device used to access our sites and apps. This could be information that identifies your device, its operating system, internet address, your login data; browser and plug-ins; location; where you came to our site from and where you leave to as well as how often you visit. This is done via the use of cookies which is covered elsewhere in this notice.

User data

This is information collected about you as a user of our stores, products and services more generally (compared to other types of data that relate to you directly for us to deliver our specific service to you). This may include where you engage with us in a survey, provide feedback on your shopping experience or engage with us via our social sites.

We will also collect information about you that allows us to create an analysis of you as a consumer to better judge what products and services to offer in our stores.

Interaction data

This is information about how you interact with our products and services, namely what you click on and interact with on our sites and apps or products in stores.

Marketing and communications data

This is your marketing preferences and also your interaction with online marketing to be able to judge its effectiveness.

When you register for our Services

You may provide us with:

  • Your personal details, including your postal and billing addresses, email addresses, phone numbers and date of birth and title
  • Information relating to your membership of promotional schemes
  • Your interest in promotional offers or schemes
  • Your account login details, such as your username and the password that you have chosen

 

We may collect:

  • Identity data
  • Contact data
  • Financial data
  • Technical data
  • User data
  • Marketing and communications data

 

When you shop with us online or browse our Websites or use our Mobile Apps

We may collect:

  • Information about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it)
  • Information about your online browsing behaviour on our Websites and Mobile Apps and information about when you click on one of our adverts (including those shown on other organisations’ websites)
  • Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)

 

What type of data might be collected:

  • Identity data
  • Contact data
  • Financial data
  • Transaction data
  • Technical data
  • User data
  • Interaction data
  • Marketing and communications data

 

When you contact us or we contact you or you take part in content contribution, promotions, competitions, surveys or reviews about our Services

We may collect:

  • Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email or post or when you speak with us through social media
  • Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
  • Your feedback, content, comment and contributions to customer surveys or reviews

 

What type of data might be collected:

    • Identity data
    • Contact data
    • User data
    • Interaction data
    • Marketing

 

Other sources of personal data

We may also use personal data from other sources, such as specialist companies that supply information, online media channels1, third party service providers, our retail partners and public registers (such as the electoral register). For example, this other personal data helps us to:

    • Manage your customer account
    • Review and improve the accuracy of the data we hold
    • Improve and measure the effectiveness of our marketing communications, including online advertising2.

 

1 Online media channels include websites, social media sites, Youtube and any other channels that become available to us

2 Marketing messages that you may see on the internet

 

Why we collect the data we collect and why we are allowed to use that personal data

This section explains in detail how and why we use personal data. In summary, we use personal data to:

  • Manage the accounts you hold with us
  • Process your orders and refunds
  • Provide content or information to you
  • Promote products and services that we think will appeal to you and are relevant to your needs
  • Improve our Services including our website experience and our business methodologies
  • Deal with claims

Detailed explanation of why we use personal data

We need to process your personal data so that we can manage your customer accounts, provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for.

We need to promote our Services and improve our Services in order to remain competitive and relevant in the market place.

We use cookies and similar technologies on our Websites and Mobile Apps to improve your customer experience. Some cookies are necessary to make the site function, so you should not disable these if you want to be able to use all the features of our Websites and Mobile Apps. You can disable other cookies but this may affect your customer experience. For more information about cookies and how you can disable them, see below.

We rely on the use of personal data to carry out market research and internal research and development, and to improve our information technology systems (including security) and our product range, services and stores. This allows us to serve you better as a customer.

It is important for us to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of services. This helps us to make sure that you can safely use our Services.

We use your online browsing behaviour as well as your online purchases (including offer and promotional transactions) to help us better understand you as a customer and provide you with personalised offers and services. Looking at your browsing behaviour and purchases allows us to personalise our offers and services for you. This helps us meet your needs as a customer. We use personal data to provide you with relevant marketing communications by email, post or online advertising, relating to our products and services.  We use personal data to provide you will relevant marketing communications of our suppliers, retail partners and other group companies owned by Kedar DTC UK Limited, by  post. Online advertising may be displayed on websites across group companies owned by us and on other organisations’ websites and online media channels. We may also measure the effectiveness of our marketing communications and those of our suppliers and Retail Partners.

You can change your marketing choices,  both when you register with us, and at any time after that.

You also have choices when it comes to online advertising. We set out below your choices when it comes to cookies, and how you can control your online behavioural advertising preferences.

We use personal data to contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us.

We use personal data to manage promotions and competitions you take part in, including those we run with our suppliers and Retail Partners. We may Invite you to take part in and customer surveys, reviews and other market research activities carried out by us and group companies and by other organisations on our behalf. If you tell us that you do not want us to contact you for market research, we will respect this choice. This will not affect your ability to use our Services or offers.

We use personal data In order to resolve legal claims or disputes involving you or us.

The Legal Basis for using your personal data are as follows:

  • Legitimate interests – browsing the site before a purchase
      • Technical data
      • Interaction data
      • Aggregated data
  • Contractual Necessity – at the time we collect it:
      • Purchase & transaction data;
      • Contact details;
      • Profile details;
      • Delivery/collection details.

(We will not be able to provide you with your products or services if you do not provide us with this data.)

  • To fulfil a legal obligation – following fulfilment of your order
      • Purchase & transaction data;
      • Contact details;
      • Profile details;
      • Delivery/collection details.
  • Legitimate Interests - following fulfilment of your order:
      •  Technical data
      • Interaction data
      • Aggregated data
      • Purchase & transaction data;
      • Contact details;
      • Profile details;
      • Delivery/collection details

 

Our Legitimate Interests in using your personal data            

Where we have mentioned above our use of your personal data is based on our “legitimate interests”, these are:

    • to service our customers’ needs, including delivering our products and services;
    • to promote and market our products and services;
    • to promote offers and promotional schemes,
    • to understand our customers including their patterns, behaviours as well as their likes and dislikes;
    • to grow, protect and support our business, suppliers, Retail partners, colleagues, customers
    • to prevent and detect anti-social behaviour, fraud and other crime;
    • to test and develop new products and services as well as improve existing ones.

We may share the personal data we collect with other group companies owned by Kedar DTC UK Limited.

We have considered the balance of our legitimate interests and the risks to the rights and freedoms of the data subjects and consider that it is acceptable to use your personal data in this way.

 

Sharing personal data within the Group and with  Retail Partners and Service Providers

This section explains how and why we share personal data within the Group and with Retail Partners and Service Providers.

We share data within the Group because it is in our legitimate interests to do so. We have considered the balance of our legitimate interests and the risks to the rights and freedoms of the data subjects and consider that it is acceptable to use your personal data in this way.

When we share personal data with these companies, we require them to keep it safe, and they must not use your personal data for their own marketing purposes.

 

Retail partners

We work with a number of Retail Partners who:

  • sell products through our services; or
  • offer products, services and/or offers/promotional schemes

 

We only share personal data that enable our Retail Partners to provide their services.

 

Service Providers

We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing, combining and analysing data, processing payments, provide us with legal or other professional services as well as delivering orders. We only share personal data that enable our Service Providers to provide their services.

Some of the Service Providers we work with operate online media channels1, and they place relevant online advertising for our products and services, as well as those of our suppliers and our Retail Partners, on those online media channels on our behalf. For example, you may see an advert for our products and services as you use a particular social media site or watch television through your pay TV account.

When we introduce a customer to a product or service this is referred to as onboarding. We use partners to help us ‘onboard’ you as a customer to any marketing you receive from us.

Examples of our Service Providers include Facebook, Twitter,  Instagram, Youtube, Adobe, Shopify, Shopify payments, Mailchimp, Pinnacle Supplies Limited trading as Parade Brand Support, Parcel Force, DPD 

Sharing personal data with other organisations

This section explains how and why we share personal data with other organisations.

We may share personal data with other organisations in the following circumstances:

  • if the law or a public authority says we must share the personal data or for the administration of justice;
  • if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud);
  • where we restructure, sell or transfer our business (or a part of it). For example, in connection with a takeover or merger.

 

How we protect your personal data

We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.

  • We apply physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data;
  • We protect the security of your information while it is being transmitted by encrypting it;
  • We use computer safeguards such as firewalls and data encryption to keep this data safe;
  • We only authorise access to employees and trusted partners who need it to carry out their responsibilities;
  • We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security;
  • We will ask for proof of identity before we share your personal data with you; and
  • We will reveal only the last four digits of your payment card number when confirming an order.

 

Whilst we take appropriate technical and organisational measures to safeguard your personal data, it is important that you keep your login details and devices protected from unauthorised access.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. If we do this we ensure that your privacy rights are respected in line with this Policy.

 

How long we use personal data for

We will not keep your personal data longer than we need to, and will only use your personal data for the purposes set out in this Policy. We will always keep your personal data in accordance with applicable legal and regulatory requirements.

In most circumstances this means we will not keep your personal data for more than 7 years after the end of your relationship with us. However, for certain data sets we have the following retention periods:

  • Customer complaints and feedback will be deleted 4 years after the date of last communication.
  • Information you submit when participating in research panels/market surveys will be deleted 3 years after its creation.
  • Health and safety records (example: incident reports) will be deleted 7 years after their creation.
  • Where your personal data is needed because we are in serious dispute with you (such as litigation), your personal data will be deleted 7 years after closure of the matter.

 

Cookies and similar technologies

We and our partners use cookies and similar technologies, such as tags and pixels (“Cookies”), to personalise and improve your customer experience as you use our Websites and Mobile Apps and to provide you with relevant online advertising. This section provides more information about Cookies, including how we use them and how you can exercise your choices about our use of Cookies.

How we use cookies

Cookies are small text files containing a unique identifier, which are stored on your computer or mobile device so that your device can be recognised when you are using a particular website or mobile app. They can be used only for the duration of your visit or they can be used to measure how you interact with services and content over time. Cookies help to provide important features and functionality on our Websites and Mobile Apps, and to improve your customer experience. Cookies can also be used help us to detect fraudulent activity or to prevent security breaches and so we may record information about your device within the cookie.

When you consent to Cookies on our Services, these may be used to do the following:

 

Improve the way our Websites and Mobile Apps work

Cookies allow us to improve the way our Websites and Mobile Apps work so that we can personalise your experience and allow you to use many of their useful features.

For example, we use Cookies so we can remember your preferences and the contents of your shopping basket when you return to our Websites and Mobile Apps.

 

Improve the performance of our Websites and Mobile Apps

Cookies can help us to understand how our Websites and Mobile Apps are being used, for example, by telling us if you get an error messages as you browse.

These Cookies collect data that is mostly aggregated and anonymous.

 

Deliver relevant online advertising, including via social media

We use Cookies to help us deliver online advertising that we believe is most relevant to you on our Websites and other organisations’ websites and using social media. Cookies used for this purpose are often placed on our Websites by specialist organisations.

Cookies used for this purpose are often placed on our Websites by organisations providing specialist services to us. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.

To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected, for example your use of offers, promotions, information or purchases.

 

Measuring the effectiveness of our marketing communications, including online advertising

Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.

We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent.

 

Third parties operating through our Websites and Mobile Apps

Our key partners are listed below with information about the services they provide to us. This list is not exhaustive but it does include those partners with whom we have an established relationship and whose cookie technologies are most frequently deployed through our Services.

  • customer care service provider: Parade Brand Support Limited
  • delivery service provider: DPD Group UK Limited & Parcel Force
  • Technology service provider: Shopify International Limited
  • Marketing communications provider: Rocket Science Group LLC trading as Mailchimp

More details regarding third parties

 

Measurement & Personalisation

To analyse how our services are used, including to test different content versions. This data may also be used to enable us to personalise our services and the marketing of our services.

 

Product recommendations

To enrich your shopping experience by delivering personalised recommendations to you on some of our websites

  • Shopify
  • Mailchimp

 

Online marketing

To personalise our adverts shown to you via our websites (websites operated by Kedar DTC UK Limited) and associated social pages. For example, by using data about your transactions , what you have in your basket and the pages and products you look at, we may personalise our marketing via our newsletter subscription service operated by Mailchimp.

 

Social media

To market to you via social media platforms and to enable social sharing and engagement on our websites. These companies may use your data for their own purposes, including to profile and target you with other advertising.

  • Facebook
  • Twitter
  • Instagram ((insert orivacy link))
  • Youtube (insert privacy link)

 

Commenting

To power commenting and review  on our websites

  • Shopify

 

Delivering ads for our Retail Partners

To enable us to personalise and deliver online advertising on behalf of our Retail Partners.

 

Security of our websites and apps

To enable us to personalise and deliver online advertising on behalf of our Retail Partners.

 

Your choices when it comes to Cookies

Web browser cookies

You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device. You can find more detailed information about how you can manage Cookies through your browser’s help function.

If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

You can also manage advertising related Cookies used on our Services by opting-out through the Service Providers listed in the table above or by visiting the YourOnlineChoices website.

 

Mobile Apps

Cookies work differently on Mobile Apps as they are coded into the App itself and will use a unique identifier created by your mobile device for use for advertising activities. You can turn off or reset this advertising identifier through your mobile device’s privacy settings.

 

Your Rights

Subject access rights

You have the right to see the personal data we hold about you. This is called a Subject Access Request.

To comply with government guidance and enable our office Colleagues to work from home, if you would like a copy of the personal data we hold about you, please email us at dataoffice@kedardtc.co.uk

 

Other data protection rights

In relation to your personal data, you also have the right to:

  1. have inaccurate information corrected:

Summary of the right:

if you believe we hold inaccurate or missing information, please let us know and we will correct it.

  1. object to our use of it:

Summary of the right:

    • general objection - We will then consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it (see section 3 below) or delete it (see section 4 below).
    • objection in relation to direct marketing - If you make such an objection, we will stop using your personal data for direct marketing purposes.
    1. restrict our use of it:

    Summary of the right:

    There are several situations when you can restrict our use of your personal data, this includes (but is not limited to):

      • you have successfully made a general objection (listed in section 2 above).
      • you are challenging the accuracy of the personal data we hold.
      • we have used your personal data unlawfully, but you do not want us to delete it.
      1. have us delete it:

      Summary of the right:

      There are several situations when you can have us delete your personal data, this includes (but is not limited to):

        • we no longer need to keep your personal data;
        • you have successfully made a general objection (listed in section 2 above);
        • you have withdrawn your consent to us using your personal data (and we do not have any other grounds to use it);
        • we have unlawfully processed your personal data.
        1. have us transfer or "port" a copy of it:

        Summary of the right:

          • If you wish  to transfer your data to a third party, such as another retailer, please have their details ready (company name and company email address). Please note, a third party cannot make a request on behalf of a customer.
          • To ensure the security of your data, we require you to verify your account and pass our security test before we will successfully send you your data.
          • We advise you not to share your personal data with people/companies you don’t trust. In addition, do not share your verification code with anybody else.
          • Please be careful of sharing your data with companies outside of the EEA, as they may have different data protection standards.
          • You’ll be sent data from as far back as we hold it. This includes transactional records and online purchases, data you provided us with when you registered with us, plus information your provided for home delivery.
          • We will only process data requests where you’re the primary account holder. We will not process data against any other individual. If you make any changes to your personal information before you make a request, these may not be reflected in your data report as there may be a delay while our systems update.
          • We’ll process your data within 30 days of the request.
          1. complain to the data protection regulator:

          We’d like the chance to resolve any complaints you have, however you also have the right to complain to the UK data protection regulator (the "ICO") about how we have used your personal data. Their website is https://ico.org.uk/your-data-matters/raising-concerns/.

          More Information on your Data Protection Rights

          The ICO website also contains more detail on the data protection rights mentioned above, or if you would like to speak to us about these rights in more detail, see the “how to contact us” section below.

          How to contact us

          If you have any questions about how we collect, store and use personal data please contact us.

          Phone: 03330090944 Mon-Friday  0800-1800

          Mail: customercare@homedeliverygrocery.co.uk

          Post:

          Data Office, Home Delivery Grocery
          PO Box 145
          Birmingham
          B24 8WR

           

          Our Data Protection Office

          Our Data Protection Office can be contacted by email: dataoffice@kedardtc.co.uk

           

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