Privacy Policy

INTRODUCTION

Welcome to Farmacy plc’s privacy policy.

We respect your privacy and are committed to protecting your personal data, whether you buy services from Farmacy plc. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. It will also deal with any personal data collected in other ways, such as at events, signing up to newsletters, responses to correspondence or on-site events.

What is the purpose of this notice?

• Your Personal Data
• Why we need it
• How we collect it
• What we do with it
• Who we might share it with
• Where we keep it
• How long we keep it
• What we do to keep it secure
• What are your rights?

Your Personal Data

In this policy, we refer to ourselves as “Farmacy” and this term will cover personal data collected by and processed by Farmacy plc (company reg. no. 05899807).

Farmacy is a controller of the personal data you provide to us or that we collect about you. We only collect the following types of personal data about you:

• Identity Data (first name, last name, business name or similar identifier, title, BASIS & NRoSO membership numbers).
• Contact Data (billing address, delivery address, e-mail address and telephone numbers).
• Financial Data (bank account and payment card details).
• Transaction Data (details about payments to and from you and other details of products and services you have purchased from us).
• Technical Data (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 (your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses).
• Usage Data (information about how you use our website, products and services).
• Marketing and Communications Data (preferences in receiving marketing from us and our third parties and your communication preferences).

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Why we need it

We need to know your basic personal data in order to meet our statutory, legal and contractual obligations, provide goods and services to you, process your orders and provide you with marketing information, if as a customer we have received your consent to tell you about our products and services.

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 that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How we collect it

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 or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for 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 feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will 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 UK;
    • search information providers such as Google based outside the UK.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators such as Map of Agriculture based inside the UK.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, industry articles and journals

What we do with it

We have set out below, in a table format, a description of all the ways we may process 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.

We will only use your information for the purpose or purposes it was collected for (or for closely related purposes).

Whenever we process data for these purposes, we will ensure that we always keep your personal data rights in high regard and take account of these rights at all times. We will also comply with your stated marketing preferences.

When we process your personal data for our legitimate interests, we will make sure that we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will 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 have the right to object to this processing if you wish. Please bear in mind that if you object this may affect our ability to carry out tasks for your benefit.

Who we might share it with?

We may share your personal data with the following classes of third parties as set out below, (for the purposes set out in the table above):

• Internal Third Parties (including our agents and other companies in the Farmacy Group acting as joint controllers, and who are based in the UK and Sri Lanka); and
• External Third Parties such as:
  • Service providers acting as processors based in the UK who provide IT, financial processing and system administration services;
  • Professional advisers acting as processors or joint controllers including agronomists, lawyers, bankers, auditors and insurers based in the United Kingdom 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; and
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

As above, personal data is frequently shared within the Farmacy Group. This will involve transferring your data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented.

Any third parties engaged by us are required to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we keep it

We are based in the UK and the majority of personal data we process is stored within the UK. Some personal data processed by our group companies may be stored in Sri Lanka while it is being processed (please see above section entitled, “Who we might share it with”).

Some organisations which provide services to us may transfer personal data outside of the UK and the EEA, but we will only allow them to do if your data is adequately protected.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

How long we keep it

We will only use and store information for so long as it is required for the purposes it was collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. How long information will be stored for depends on the information in question and what it is being used for. 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. For example, if you ask us not to send you marketing e-mails, we will stop storing your e-mail address for marketing purposes (though we will keep a record of your preference not to be e-mailed)

We continually review what information we hold and delete what is no longer required. We never store payment card information. We will not retain your data for any longer than necessary and the longest time that we will hold your data will be for six years.

What we do to keep it secure

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

What are your rights?

We want to ensure that you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:

• the right to 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;
• the right to 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;
• the right to have inaccurate data rectified. 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;
• the right to 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;
• the right to 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:
  • if you want us to establish the data’s accuracy.
  • where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• the right to 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; and
• the right to withdraw consent for data processing 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.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.

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 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.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.

If you wish to exercise any of the rights set out above or if you wish to raise a complaint on how we have handled your personal data, you can contact Cynthia Oxford, Data Protection Officer, Farmacy plc, Farmacy Services Centre, Sleaford Road, Dorrington, Lincoln, LN4 3PU, who will investigate the matter.