WHO ARE WE AND IMPORTANT INFORMATION
Mastergen Ltd is incorporated in England, company registration number 09051527. We are registered at Unit 5, Monument View, Sunmmerfield Avenue, Chelston Business Park, Somerset, TA21 9ND.
Mastergen Ltd (‘we’ or ‘us’ or ‘our’) collects and processes your personal data in accordance with this privacy notice and in compliance with data protection laws. This privacy notice provides you with the necessary information regarding your privacy rights and how the law protects you.
This privacy notice aims to explain how we collect and process your personal data including, through your use of this website from telephone conversations, emails, text messages, farm visits, surveys, agricultural shows, through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a promotion or competition.
Neither our products and/or services, nor this website is intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
OUR ROLE AS A DATA CONTROLLER
Mastergen Ltd is the controller and responsible for your personal data.
We have appointed data privacy managers who are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice including any requests to exercise your legal rights, please contact the data privacy manager via email on firstname.lastname@example.org or via post at Goodridge Court, Goodridge Avenue, Gloucester GL2 5EN
Changes to the privacy notice and your duty to inform us of changes
We do update this Policy from time to time so please do review this Policy regularly. This version was last updated on 18/04/2014 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THE PERSONAL DATA WE COLLECT
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers (landline and mobile).
- Financial Data includes bank account and payment card details for payment purposes only.
- Transaction Data includes details about payments to and from you, farm and breeding information provided by you and other details of products and services you have purchased from us.
- Technical Data includes 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 and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences and records of conversations had by telephone, text, email and face to face meetings.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We take your privacy seriously. We control and process your personal data to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than already specified in this privacy notice. We will never provide or sell your personal data to a third party for their marketing purposes. We only retain your data for as long as is necessary and for the purposes specified in this privacy notice.
CONSEQUENCES OF NOT PROVIDING YOUR PERSONAL DATA
You are not obligated to provide your personal information to us, however, where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide this data , we may not be able to perform the contract we have or offer some/all of our services to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED AND USED
We collect information in the following ways: –
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, in face to face meetings or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- request our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
AUTOMATED TECHNOLOGIES OR INTERACTIONS
THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- social media platforms such as Facebook, Twitter and LinkedIn based outside the EU; and
- search information providers such as yell.com, Thomson business directories and 192.com which are all based inside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Barclays Bank based inside the EU.
- Identity and Contact Data from publicly availably sources such as business directories and agricultural publications based inside the EU.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data 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 data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
PROMOTIONS AND OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what specific products, offers, services, newsletters and promotions we think you may want, need or may be of interest to you.
You will receive marketing communications from us if you have requested information from us or purchase goods or services from us or if you provide your details when you entered a competition or registered for an offer or promotion and, in each case you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.
If you consent to us sharing your personal data with a third party for marketing purposes, you can ask us or third parties to stop sending you marketing messages at any time by using the opt-out/subscribe options or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
CHANGE OF PURPOSE
We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
SHARING AND DISCLOSING YOUR PERSONAL INFORMATION
We may have to share your personal data with the parties set out below for the purposes specified in this notice, including to facilitate the processing of orders, requesting quotations and arranging deliveries or where there is a legal or contractual requirement. We use third-parties to provide the below services and business functions. All EU processors acting on our behalf only process your data in accordance with direct instructions from us and comply fully with this privacy notice, the relevant data protection laws and any other appropriate confidentiality and security measures. Please be assured that processing contracts are in place, where appropriate, to provide you with more confidence that we are committed to protecting your personal data.
EXTERNAL THIRD PARTIES
- Service providers acting as processors based in the UK and USA who provide IT, system administration and customer relationship management services.
- Service providers acting as processors based in the UK who provide goods/product delivery services.
- Service providers acting as processors based in the UK and USA who provide electronic marketing, text marketing and postal marketing services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
We do not transfer your personal data outside the European Economic Area (EEA).
HOW WE PROTECT YOUR PERSONAL DATA
We take your privacy seriously and we have put in place appropriate security measures to prevent your personal data from being accidently lost, used or accessed in an unauthorised way, alteration, disclosure or destruction. We have several layers of security measures in place including, regular cyber security reviews as part of our wider IT Governance Policy (a copy of which is available upon request by contacting us), firewalls, anti-virus software, encryption of data in transit, password protection and role based access.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WE KEEP YOUR DATA
We only retain your personal data for as long as is necessary for the purposes set out in this policy and to comply with our legal obligations. We have strict review and retention policy in place to meet these obligations. 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.
We are required under UK tax law to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a minimum of 6 years after they cease being customers, after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Details of retention periods for different aspects of your personal data are available, by contracting us.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a “data 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 correction of the 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 us.
Request erasure of your personal data. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
If we receive a request from you to exercise any of the above rights, we may need to request specific information from you to help us verify your identity before acting on the relevant request; this is to ensure your right to access your personal data (or exercise any of your other rights.) This is a security measure to ensure that personal data is protected and 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 will try to respond to all legitimate requests within 1 month of the request being made. Occasionally it may 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.
LODGING A COMPLAINT
We only process your personal data in compliance with this privacy notice and in accordance with the relevant data protection laws. You have the right to make a complaint at any time to the Information commissioner’s Office (ICO), the UK supervisory authority for data protection issues, including where you are unsatisfied with how we have handled or processed your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance via email at email email@example.com .
INFORMATION COMMISSIONERS OFFICE
0303 1231113 (local rate)
01625 545745 (national rate)
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Updated 25th May 2018
Chelston Business Park,