Privacy Notice for Customers
What is the purpose of this document?
Mink Farm (“the Business”, “we”, “us”) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your membership with us, in accordance with the General Data Protection Regulation (GDPR).
It applies to all customers.
The Business is a "data controller" for the purpose of GDPR and the data protection legislation. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to any existing customers. This notice does not form part of any contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice 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:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.
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).
The information that we hold about you may include the following:
Personal contact details such as name, address, any change of addresses, telephone numbers and email addresses supplied by you;
Credit or debit card details;
Details of contact we have had with you in relation to the provision or proposed provision of our services;
Details of any services that you have received from us;
Our correspondence and communications with you;
Information about any complaints and enquiries that you make to us;
Where you need to provide us with someone else’s personal data, you should take steps to inform them of what you are doing and provide them with a copy of this privacy notice.
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:
Where we need to perform legal duties arising from your entering into the Scheme.
Where we need to comply with a legal obligation.
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:
Where we need to protect your interests (or someone else's interests).
Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
We need all the categories of information in the list above (see paragraph headed “The kind of information we hold about you”) primarily to allow us to perform our duties under the our contract with you in accordance with our 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. Communicating with you in relation to our contract with you.
To comply with our legal obligations and duties.
Dealing with any complaints from you or disputes with you.
For any additional purpose reasonably required to perform our obligations under our contract with you.
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 be prevented from complying with our legal obligations or perform our contract with you.
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.
Data sharing
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
They may transfer your personal information outside the EU.
If that is the case, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law or where it is necessary to perform our contract with you.
Which third-party service providers process my personal information?
"Third parties" includes third-party service providers (including contractors and designated agents). The following third-party service providers process personal information about you:
a) Pet Admin.
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.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business.
If and when we do so, those third-parties will also be required to take appropriate security measures to protect your personal information, i.e. - in line with our policies – for specified purposes - and in accordance with our instructions.
We may also need to share your personal information with a regulator or to otherwise comply with the law.
Data security
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.
Data retention
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, accounting, 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. Once you are no longer a member we will retain and securely destroy your personal information in accordance with 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 working 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 Adam Sutherland at Mink Farm, Littlewick Common, Knaphill, Woking GU21 2JZ in writing.
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.
In some cases, it may be necessary to obtain additional information from you, e.g. in order to carry out your request for a transfer of benefits. We will notify you when information is required for this purpose.
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 us at the address below. 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.
Contact
If you have any questions about this privacy notice or how we handle your personal information, please contact:
Adam Sutherland, Mink Farm, Littlewick Common, Knaphill, Woking GU21 2JZ
Or by email at info@minkfarm.co.uk. 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 (www.ico.org.uk).
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.
If you have any questions about this privacy notice, please contact Adam Sutherland at the address shown above.