Privacy Policy

Privacy Policy

This website (https://www.crugabiltong.com/) is owned and operated by New World Foods (Europe) Limited (“NWF,” “we,” “us,” or “our”). At NWF, we are committed to protecting your privacy. We take the issue of security of your personal information very seriously.

This Privacy Policy (this “Policy”) together with our website Terms & Conditions explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure. Personal information is any information about you from which you can be identified (such as your name or your email address).

This Policy tells you about:

Our details

What information do we gather from you and how is it collected?

How is your personal information used and on what legal bases?

How is your personal information shared?

Transferring your information outside of the UK

Data breach

Children

Cookies

Protection of your personal information and retention

Your rights

Changes to our privacy policy

Links

Questions or complaints

Our details

We are New World Foods (Europe) Limited (company number 07843083) a manufacturer of meat snacks in the UK and represents the meat snacks division of Valeo Snackfoods. Our registered office address is at 38 Barnard Road, Bowthorpe, Norwich, Norfolk NR5 9JP, UK. We are the data controller for the purposes of data protection laws, in respect of your personal information collected and used through your use of the website. We dictate the purpose for which your personal information is used and how we use your personal information. See “Questions or complaints” section below for more information on how to contact us.

As described in the section below entitled “How is your personal information shared?” we may share your personal information with other organisations, such as other entities in the NWF Family, that may receive and process your personal information as a controller in their own right and with our service providers.

What personal information do we gather from you and how is it collected?

We gather personal information from you, such as first and last names, telephone numbers, credit or debit card/bank details and email addresses, that you may provide voluntarily when you fill in appropriate sections of our website or when we directly message with you via our social media channels or when you make a purchase direct from us. For example, if you make a purchase direct from us, we will collect your name and contact details as well as your debit or credit card information in order to facilitate the payment due and to fulfil your order. When you contact us, you may provide us with personal information which we hold and use for the purposes set out in the next section. We may also obtain information about you when you contact us about products (e.g., nutrition/ingredient queries, product availability) or when you enter one of our competitions via our website, on pack promotions or through social media. We may collect your postal and/or email address in order to send you information you have requested or to send you a competition prize.

We also collect technical information (to the extent such information constitutes personal information) through your activity and use of the website. For example, we collect information about the devices you have used (such as the IP address you use to connect your device to the internet and the browser type and version you use on your device); and information about your use of the website and any services we offer (such as the pages you have viewed). We may receive information from other sources, such as information from any of the other websites we operate or the services we provide, if you use any of them. We make use of Google Analytics and Facebook pixels which are subject to separate terms and conditions issued by the relevant companies https://policies.google.com/privacy/update and https://www.facebook.com/about/privacy/update.

If you provide us with personal information about another person, you must ensure that before you provide us with their personal information, you have their agreement to do so and that they are aware of the ways in which we use personal information as set out in this Privacy Policy.

How is your personal information used and on what legal bases?

Our main aim in gathering your personal information is to provide you with a customised service. In particular, your personal information may be used by us, our employees and service providers and disclosed to third parties for the following purposes. For each of these purposes, we have set out the legal basis on which we use your personal information.

Purpose	Legal Basis
To provide the website to you.	This is in our legitimate interest (i.e., the provision of the website to you).
To provide you with the services we offer (including sales of goods and any promotions, sweepstakes or contests).	This is in our legitimate interest (i.e., the provision of the services to you), and depending on the circumstances, to perform a contract between you and us.
To communicate with you and other individuals and to carry out your requests and respond to your communications.	This is in our legitimate interest (i.e., the provision and support of the website and service)
To carry out our obligations arising from any contracts entered into between you and us.	This is to perform a contract between you and us.
To notify you about changes to the website.	This is in our legitimate interest (i.e., the provision of the website and service).
To audit and monitor the use of the website and to improve the quality of the website.	This is in our legitimate interest (i.e., the provision of the website and service, as well as to improve and ensure the security of the website and those services). We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law (e.g., in relation to our use of certain cookies).
To manage complaints, feedback and queries and provide customer support.	This is in our legitimate interests (i.e., the provision and support of the website and service and improvements and development of our business operations).
To comply with any legal or regulatory obligations	This is in our legitimate interests (i.e., protection of our business, employees and customers) and for compliance with legal obligations to which we are subject.
To facilitate the purchase of products direct from us	Processing is necessary to fulfil a contract (a contract is created between you and NWF when you purchase products direct from us) your name, postal address, email address and credit/debit card details are required for this purpose.
To periodically send promotional emails about new products, special offers or other direct marketing information which we think you may find useful or interesting using the email address which you have provided.	Where you have provided your consent for us to send you such communications.

We may also use aggregate personal information and statistics for the purposes of monitoring website usage in order to help us develop the website and our services and may provide such aggregate personal information to third parties. These statistics will not include any data that can be used to identify any individual.

How is your personal information shared?

We do not share personal information with third parties unless certain safeguards and contractual arrangements are in place. We may share personal information within the NWF Family and certain selected companies. By “NWF Family”, we mean the companies within the same group as NWF. The NWF Family will process your personal information in accordance with this Policy and all applicable data protection legislation.

The selected companies are those that provide technical assistance and support and perform other functions to support our sales and marketing activities. We use Shopify to power our online consumer store and provide associated payment services. You can read more about how Shopify uses your Personal Information here: Shopify Privacy Policy. Our third-party service providers also include our marketing partners, fulfilment partners and website analytics providers. In some cases, third party providers will be acting as a data controller of your information and therefore we advise you to read their Privacy Policy. If any of our third-party service providers shares your information with us, we will use it in accordance with this Policy.

All selected companies may have access to personal information if needed to perform such functions but will only be permitted by us to use such personal information for the purpose of performing that function (which may include one to which you have expressly given your consent) and not for any other purpose.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

We reserve the right to use or disclose any personal information as needed to satisfy any law, regulation or legal request, to protect the integrity of the site, to fulfil your requests, or to cooperate in any law enforcement or regulatory investigation. Save for this, we do not sell, rent, transfer or disclose personal information we have collected from you in connection with our website activities, to third parties outside the NWF Family.

Transferring your information outside of the UK

As part of the services offered to you through our website or competitions, the information which you provide to us may be transferred to countries outside the UK. Data protection law imposes restrictions on the transfer of personal information outside of the UK but such transfers can be made if the country to which we may transfer the data has an adequate level of protection for your rights, there are appropriate safeguards or a contract is in place allowing the transfer to take place, you have provided your consent or the transfer is necessary for reasons set out in the data protection laws.

Some countries may not have similar data protection laws to the UK. If we transfer your information outside of the UK in this way, we will take reasonable steps and implement relevant measures to make sure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy and in accordance with data protection law. These measures generally include either transferring personal information to countries that have been deemed to provide an adequate level of protection for personal information by the UK or in relation to new contracts entered into by us from September 2022, transferring personal information to a country where the recipient has agreed to the UK’s International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s new Standard Contractual Clauses and any other appropriate safeguards. In addition, a Data Transfer Risk Assessment (“TRA”) or a Data Protection Impact Assessment incorporating a TRA may be carried out.

Data breach

The Data Protection Act 2018 requires us as Data Controller of your personal information to notify any breach of personal information to the applicable regulator and in certain instances to you, the data subject, which we will do as appropriate.

Children

Where individuals under the age of 13 register on any of our websites, we must obtain the consent of a parent or guardian. We also reserve the right to request parental/ guardian consent for anyone between the ages of 12 and 16. Information provided by under 16’s will not be used for marketing purposes but we may from time to time tell you about developments on our site or provide you with information about NWF.

Our direct sales website is only intended for use by UK residents aged 18+.

Cookies

A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website, to track the pages you looked at while visiting our website and therefore to improve our service to you. Cookies may also be used to compile aggregate personal information about the areas of our website which are visited most frequently. This aggregate personal information can be used to enhance the content of our website and make your use of it easier. If you wish to reject our cookie (which you can do at any time), you may configure your browser to do so. However, if you do so, you may not be able to use certain features on our website.

Protection of your personal information and retention

The internet is not a secure medium and NWF cannot absolutely guarantee the security of your personal information provided over the internet and any transmission is at your own risk. However, we have put in place various security measures as set out below.

We use appropriate technical, physical, legal and organisational measures, which comply with data protection laws to keep personal information secure. For example, the website and associated databases are protected by certified firewalls in order to protect your personal information from access by unauthorised persons and against unlawful or unauthorised processing, accidental loss, destruction or damage. We also keep your personal information confidential. All outgoing and incoming email is scanned for viruses.

We will retain your personal information for as long as is necessary for purposes for which it was collected. The precise period will depend on the reason why it was collected. For example: for marketing purposes your personal information will be retained until you withdraw your consent; for competitions it will be retained until the competition has been administered and in relation to consumer services until your query has been dealt with and a reasonable period thereafter or as long as the law requires; for purchases made direct from us, your personal information, order and credit/debit card details will be held in accordance with applicable financial regulations, the maximum retention period under these regulations is currently 7 years.

NWF has a strict policy in place relating to the processing of cardholder information which all relevant NWF employees are familiar with and abide by; including but not limited to:-

Any display of cardholder information on a device should be restricted to a minimum of the first 6 and last 4 digits of the cardholder information;
Access to cardholder information such as Personal Account Number’s (PAN’s) is restricted to employees that have a legitimate need to view such information;
All NWF employees processing cardholder information are trained appropriately;
All Point of Sale (POS) and Personal Identification Numbers (PIN) entry devices are appropriately protected and secured; and
Strict control is maintained over the storage and accessibility of any devices containing cardholder information.

Once the retention period for each situation has expired, we will take all reasonable steps to destroy or erase from our systems all personal data that we no longer require in accordance with all our applicable record retention schedules and policies.

Your rights

You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise those rights using the contact details below.

	Summary of your rights
Right of access to your personal information	You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.
Right to rectify your personal information	You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information:	You have the right to ask that your personal information be deleted in certain circumstances. For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.
Right to restrict the use of your personal information	You have the right to suspend our use of your personal information in certain circumstances. For example (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.
Right to object to the use of your personal information	You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes.
Right to data portability	You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e., electronic) means.
Right to withdraw consent	You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Right to complain to the relevant data protection authority	You have the right to complain to the relevant data protection authority where you think we have not used your personal information in accordance with data protection law. You may lodge a complaint with the authority in the Member State of your habitual residence or of an alleged infringement of data protection law. For the contact details for the Information Commissioner’s Office in the UK please see the Questions or Complaints section below.

Controlling your personal information

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by either:

Amending your marketing preferences in your Account;
Using the ‘Unsubscribe’ button attached to any email that we send you; or
Writing to us or emailing us at: privacy@valeosnackfoods.com.

You may request details of any personal information that we hold about you. If you wish to obtain a copy of such personal information, please email: privacy@valeosnackfoods.com.

Changes to our privacy policy

We keep this Policy under regular review and reserve the right to make changes at any time to take account of changes in our business, legal requirements, and the manner in which we process personal information. Any changes we make to this Policy in the future will be posted on this page. The updated Policy will take effect as soon as it has been updated or otherwise communicated to you. This Policy was last updated in February 2023.

Links

The website may contain hypertext links to other sites, which are not under our control. Please note that we are not responsible for the privacy policies of such other websites and we advise you to read the privacy policies of each website you visit which collects personal information.

Questions or complaints:

If you have any questions, concerns, comments or complaints about this Policy and/or our collection or use of personal information, then please contact our Data Protection Officer on privacy@valeosnackfoods.com or telephone +44 (0)1603 744788.

You can also contact the Information Commissioner’s Office (“ICO”) on helpline telephone number 0303 123 1113 or to call in Welsh 0330 414 6421; live chat via the ICO’s website at www.ico.org.uk (the helpline and live chat options are available Monday to Friday 9 a.m. to 5 p.m. (excluding bank holidays) ; post: Wycliffe House, Water Lane, Winslow, Cheshire SK9 5AF; or any other means of contact detailed on the ICO’s website (address above). Our ICO number is ZA668271.

Dated February 2023