Privacy Policy

1. Who are we?

Winterbotham Darby & Co Limited (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms of use Terms and conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, whether via our website or otherwise, will be processed by us. This applies to consumers, our customers, our suppliers, delegates on our courses, candidates who apply for a job with us and persons who make enquiries to us, sign up for our newsletters or take part in our market research. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of UK and European data protection and e-privacy legislation (Data Protection Legislation), the data controller is Winterbotham Darby & Co Limited of Granville House, Granville Park Business Centre, Wells Place, Redhill, Surrey RH1 3AS.

2. Information we collect from you

We will collect and process the following data about you:

  • Information you give us. This is information about you that you give us by filling in forms on our website http://www.winterbothamdarby.com (our website) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our website, make an enquiry, search for a product, place an order with us, sign up for one of our newsletters or other updates, participate in social media functions on our website, enter a competition, promotion or survey and when you report a problem with our website. The information you give us may include your name, position, company, contact details (such as address, e-mail address and phone number), date of birth, your personal preferences, choices and requirements specific to particular requests or services, personal description or videos of consumers trying out products.
  • Information we collect about you.  With regard to each of your visits to our website we will automatically collect the following information:
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
    • If you visit our premises, we operate CCTV at our premises and may collect CCTV footage of you.
  • Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide or from third parties. We may receive your details from a colleague of yours. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

3. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

4. Legal grounds for collection and use of your personal information

We will only collect, use and otherwise handle your personal information when:

  • We have your consent for specified, explicit and legitimate purposes. Where you have signed up to receive our newsletter, we have your consent to send you the newsletter; and/or
  • it is necessary for our legitimate interests in connection with operating the website and our business, in particular:
    • responding to your queries;
    • carrying out direct marketing;
    • providing services and/or information to you;
    • transmitting personal information between our group companies for internal administrative purposes;
    • hosting and maintaining our website;
    • providing technical support to you;
    • preventing and detecting fraud and other criminal offences; and/or
    • ensuring network and information security,
  • as long as, in each case, these interests are in line with applicable law and your legal rights and freedoms; and/or
  • where this is necessary for legal obligations which apply to us; and/or
  • where this is necessary for the performance of a contract we have with you (for example to provide goods and/or services to you) or that you have with a third party; and/or
  • where this is necessary to take steps at your request prior to entering into a contract.

5. Uses made of the information

We use information held about you in the following ways:

  • Information you give to us. We will use this information:
    • to carry out our obligations arising from any contracts entered into between you and us, respond to your queries and to provide you with the information, products and services that you request from us, including issuing a certificate if you attend our training events;
    • if you register for one of our business-focused events, we will share your name, professional title and your professional address with other people that are attending the same event;
    • to deal with any complaints you make about our products or services;
    • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
    • where you have provided us with your contact details, to provide you with information about goods or services we feel may interest you. This may be by post, telephone or electronic means (e-mail or SMS). A communication could be from Winterbotham Darby & Co Limited or any of the Compleat Food Group companies. If you are an existing customer, have enquired about our products or have signed up to receive our newsletter, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data (the subscription or enquiry form). If you provide your details to one group company, another group company will contact you by electronic means only if you have consented to this. If you opt out of marketing communication, your visit to and use of the website will not be affected;

Marketing Opt-Out – you are entitled to opt-out of marketing communication at any time and free of charge by using the contact details; dataofficer@winterbothamdarby.com provided in this Privacy Policy or by using the “unsubscribe” option included in any marketing e-mail or other marketing material received from us.

  • to notify you about changes to our service:
    • to ensure that content from our website is presented in the most effective manner for you and for your computer.
      We may also use any personal information that you provide to us:
    • where legally permitted for specific purposes made clear at the point of collection on particular pages of our website; and/or
    • where we otherwise have legal grounds for collection and use of your personal information as explained in more detail

If you choose not to provide personal information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the personal information. Aside from this, your visit to the website will remain unaffected.

  • Information we collect about you. We will use this information:
    • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
    • to allow you to participate in interactive features of our service, when you choose to do so;
    • as part of our efforts to keep our website safe and secure;
    • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
    • to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them;
    • to help to maintain a safe and secure environment for all our staff and visitors.
  • CCTV footage. We currently use CCTV around our premises. We believe that such use is necessary for legitimate business purposes, including:
    (a) to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
    (b) for the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime;
    (c) to support law enforcement bodies in the prevention, detection and prosecution of crime;
    (d) to assist in day-to-day management, including ensuring the health and safety of staff and others;
    (e) to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings;
    (f) to assist in the defence of any civil litigation, including employment tribunal proceedings.
  • Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive), where those purposes are compatible.

6. Disclosure of your information

Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your personal information is adequately protected.

You agree that we have the right to share your personal information with the following third parties:
i). Google Analytics
Our website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics works using cookies.
Google Analytics cookies collect your IP address, however because IP anonymisation is used on this website, your IP address will be shortened (and therefore anonymised) as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics.

The anonymisation process takes place within the European Union or the European Economic Area, except in exceptional cases, where your full IP address may be sent to a Google server in the USA and shortened there.

We use the information collected by Google Analytics cookies to find out about how visitors use our website.

The IP address sent by your browser in connection with Google Analytics will not be combined by Google, with other data.

You can prevent Google Analytics cookies from being stored by setting your browser software accordingly. See our cookie policy for further information.

However, please note that you may not then be able to make full use of all the website’s functions.

You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

ii) Sharing with our group companies

The personal information you provide on the website is collected by Winterbotham Darby & Co Limited. However where you ask or indicate that we may do so (e.g. in an online form) or where we are otherwise legally permitted to do so in accordance with this privacy policy, we may transfer your personal information between and to our group companies. Group companies are our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. Please click here for a current list of group companies to whom we may transfer your personal information.

When a group company intends to use your personal information for a new purpose, they will let you know about this.

iii) Sharing with our service providers

We may share your personal information with our third party service providers based in the UK or the European Economic Area (“EEA”) who we engage to process the information that we collect from you on the website or otherwise, and/or to host and maintain our website, content or services, on our behalf and in accordance with this privacy policy.
We will let you know if we need to transfer your personal information to any third party service providers located outside of the EEA.
Where we employ third party companies or individuals to process personal information provided by us (and not collected by them), they only use this personal information on our behalf and in line with our instructions and this privacy policy.

iv) Sharing with other selected third parties

We may share your personal information with selected third parties including:

  • business partners for the performance of any contract we enter into with you;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
  • analytics and search engine providers that assist us in the improvement and optimisation of our website;
  • our website offers the possibility to share content on social media channels, e.g., Facebook. The respective social media provider will directly gather personal information only after you click on the corresponding sharing button. Please refer to the privacy policy of the social media providers to learn more about what personal information is collected and used.

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Winterbotham Darby & Co Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • Where Winterbotham Darby & Co Limited will transfer personal data to a third country or internal organisation.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use Terms and conditions| Winterbotham Darby or our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Winterbotham Darby & Co Limited, any of our group companies, our customers, or others. This includes exchanging information with other companies and organisations, regulators and law enforcement agencies for the purposes of preventing and detecting fraud, other criminal offence, credit risk reduction and/or to ensure network and information security.

7. How long do we store personal information?

It is our policy to retain your personal information for the length of time required for the specific purpose or purposes for which it was collected, which are set out in this privacy policy. We keep financial records relating to transactions with you for 7 years and we retain information relating to food safety aspects of transactions with you for 5 years following the supply of food products to a customer or following a purchase of food products by us from a supplier. CCTV footage will generally be kept for 2 months. However, on occasion we may be obliged to store some data for a longer time, for example, where a longer time period is required by applicable laws. In this case, we will ensure that your personal data will continue to be treated in accordance with this privacy policy.

For more information on how long cookies are stored, please refer to our cookie policy below

8. Where we store your personal data

The 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 staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Winterbotham Darby & Co Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9. Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at; dataofficer@winterbothamdarby.com.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

If you wish to:

  • Access, confirm, correct, rectify, update, supplement, anonymise, block, restrict or delete your personal information;
  • Object to our use of your personal information;
  • Withdraw your consent;
  • If you have any questions about our processing of your personal information; or
  • If you would like to transfer your personal information from us to another person or business,

please contact us.

Where you request access to your personal information, the information will be provided in writing. In order to comply with your request, we may ask you to verify your identity. We will fulfil your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you an administrative fee.

We will provide you with all rights in relation to your personal information to which you are entitled under applicable law. If you are unhappy with the way that we have handled your personal information, you can make a complaint to the authority responsible for data protection in the country that you are based. In the UK, the authority is the Information Commissioner’s Office, www.ico.org.uk. Contact details are typically available online, or alternatively you may ask us for assistance.

10. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

11. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to dataofficer@winterbothamdarby.com
Issue date: 25th May 2018


Information about our use of cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

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.

We use the following 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 cart or make use of e-billing services.
  • Analytical/performance cookies. They 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 (for example, your choice of language or region).
  • 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.

You can find more information about the individual cookies we use and the purposes for which we use them and the duration we keep them for below:

Cookie name ID Purpose Source of cookie Expires Further information
Cookie banner WordPress_test_cookie Tests whether or not the browser has cookies enabled WordPress This is a persistent cookie, which remains on your device after your browsing session has ended. This cookie expires 30 days after it was first set. It is not possible to opt out of this cookie as it is strictly necessary
Google Analytics _ga
_gat
_gid
Estimates our audience size and usage pattern Google This is a persistent cookie, which remains on your device after your browsing session has ended. This site uses Google Analytics; a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of this Site and compile reports for us on website activity. This cookie does not collect information that identifies an individual. For how to reject or delete these cookies see https://tools.google.com/dlpage/gaoptout.
Google Retargeting IDE These cookies are set by a third party (DoubleClick) and are used for serving targeted advertisements that are relevant to you across the web. DoubleClick.net on behalf of Google This is a persistent cookie, which remains on your device after your browsing session has ended. For more information, please visit www.google.com/policies/privacy/partners/
Wordfence security Wfjt_ Cookie set by the Wordfence Security WordPress plugin to protect the site against malicious attacks. WordPress After 24 hours It is not possible to opt out of this cookie as it is strictly necessary
Wordfence security Wordfence_verifiedHuman This cookie is used by Wordfence to verify you as a human user, for added security. WordPress After 24 hours It is not possible to opt out of this cookie as it is strictly necessary

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You 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 site.