Privacy Policy
1.INTRODUCTION
- 1.INTRODUCTION
- 2. WHO WE ARE
- 3. THE PERSONAL DATA WE COLLECT ABOUT YOU
- 4. HOW IS YOUR PERSONAL DATA COLLECTED?
- 5. HOW WE USE YOUR PERSONAL DATA
- 6. WHO WE SHARE YOUR PERSONAL DATA WITH
- 7. INTERNATIONAL TRANSFERS
- 8. DATA SECURITY
- 9. DATA RETENTION
- 10. YOUR DATA PROTECTION RIGHTS
- 11. VISITORS TO OUR WEBSITE
- 12. OUR CUSTOMERS
- 13. CHANGES
- 14. THIRD PARTY LINKS
- 15. HOW TO CONTACT US
1. INTRODUCTION
LAST UPDATED: 01/03/2024
Welcome to the privacy policy of Natures Menu Limited (collectively
referred to as ‘Natures Menu’, ‘we’, ‘us’, ‘our’
in this privacy policy).
Natures Menu respects your privacy and is committed to protecting your
personal information. This privacy notice will inform you as to how we collect, share and use
your personal data whether you are: (a) a customer, or potential customer, of Natures Menu, or
(b) a visitor to Natures Menu’s website at https://www.naturesmenu.co.uk (regardless
of where you visit it from) or caller to our customer helpline. This notice tells you about your
privacy rights and how the law protects you.
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 other notices and privacy policies and is not intended to override
them.
If you have any questions or concerns about our use of your personal
data, please contact us using the contact details under "how to contact us" heading below.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
2. WHO WE ARE
Natures Menu Limited is the controller in respect of the processing
covered by this privacy notice and is responsible for the website and customer helpline.
Natures Menu belongs to the same group of companies as Affinity
Petcare S.A. (‘Affinity Petcare’) whose registered office address is Placa Europa, 54-56,
L’Hospitalet de Llobregat, 08902, Barcelona, Spain.
We may share your personal data with Affinity Petcare from time to time, who will act as an
independent controller and will be independently responsible for your personal data. You can
find Affinity Petcare’s privacy notice here:
https://www.affinity-petcare.com/en/legal-notice.
3. THE PERSONAL DATA WE COLLECT ABOUT YOU
As a website visitor, caller to our helpline and/or customer or potential
customer of Natures Menu, we may collect, use, store and transfer different kinds of personal data
about you which we have grouped together as follows:
- Identity Data includes title, first name, last name, username or similar identifier and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Call recordings are the recordings of your conversation where you contact our customer helpline.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Transaction History Data is information of transactions with third parties.
- Preference Data is your preferences or inferred preferences, provided by third parties or derived from data they supply.
- 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 the website.
- Profile Data includes your username and password, details about your pets (such as date of birth, name, breed, and dietary requirements), your interests, preferences (such as language), feedback and survey responses.
- Usage Data includes information about how you use our website and our products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences (such as via email, SMS or post).
- Enquiries and Complaints Data includes the content of any queries or complaints you submit to us.
- Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data can be derived from your personal data. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature or we may combine responses by way of feedback or a survey but will only ever publish such information as anonymous data (which means you cannot be identified from the data).
Please read the relevant section under Sections 11-12 that describes your relationship with us as it
will set out which categories of personal data are relevant for that particular relationship.
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.
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.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a
contract we have with you (or as part of entering into a contract 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). We will make it clear where such
information is required to enter into a contract with you or perform the contract with you. If you do
not provide such information, 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.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect personal data from and about you including
through:
- Direct interactions. You may give us your personal data when you
fill in our contact form on our website, correspond with us by post, phone, email or otherwise or by
purchasing a product from us. This includes personal data you provide when you:
- purchase our products and services;
- create an account on our website;
- subscribe to our newsletter, services, and/or other publications;
- participate in interactive features of our service;
- request a feeding plan for your pet(s);
- request marketing or other information 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 and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy https://www.naturesmenu.co.uk/terms-and-privacy/natures-cookie-policy.html for further details.
- Third parties.We will receive personal data about you from various
third parties as set out below:
- Technical Data and Usage Data from analytics providers such as Google;
- Identity Data, Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services;
- Identity Data, Contact Data, Transaction History Data and Preference Data from members of the Abacus Alliance (which consists of retailers and charities who share information about their customers and supporters and what they buy or donate, enabling them to better understand customer or supporter behaviours and preferences, or identify new potential customers and supporters, and send these individuals suitable offers and appeals that should be of interest to them); and
- Preference Data from CACI Limited, the Data & Marketing Association (in the form of suppression lists), Experian Limited and Epsilon International UK Limited.
5. 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 under these lawful bases:
- Where we need to process your personal data to perform a contract we have entered into with you or to enter into a contract 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal
data although we will usually get your consent before sending marketing communications to you and we will
always get consent before we share your information with members of the Abacus Alliance. You have the right
to withdraw consent at any time by contacting us on the details set out in this privacy notice.
We describe the lawful basis/bases relied on for specific processing activities
and the purposes for which we will use your personal data in the relevant section below under Sections 11-12
that applies to our relationship with you. We have also identified what our legitimate interests are where
applicable.
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.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
We may share your personal data with the third parties as set below for the purposes
set out in the relevant section that applies to our relationship with you.
Our group companies:
- Affinity Petcare S.A. who provide customer care services, internal support services and other business services (such as IT and system administration services) to Natures Menu and whose business is related to food, products and services for pets.
- Affinity Foundation / Fundacion Affinity, a charitable foundation set up by Affinity Petcare S.A. whose mission is to promote the role of pets in society.
Third Parties
- Service providers who provide services to us in: IT/software, media and analytics, system administration, referral schemes, customer care and relationship management, courier service for order delivery, marketing and email communications, acquisition of customer reviews, credit checking and fraud prevention.
- Our professional advisers including lawyers, bankers, accountants, auditors and insurers who provide legal, banking, accounting and insurance services.
- HM Revenue & Customs, regulators and government and other public authorities who require reporting of processing activities in certain circumstances under applicable law or regulation.
- 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 notice, to the extent permitted.
- Experian, and other providers for the purposes of gaining insights into customer preferences.
- Epsilon Abacus (registered as Epsilon International UK Ltd), the company that manages the Abacus Alliance.
- Members of the Abacus Alliance (where you have provided consent for us to do so).
- Any other person with your consent to the disclosure.
We require all third parties to respect the security of your personal data and to treat it in accordance with
the law.
7. INTERNATIONAL TRANSFERS
Your personal data is transferred for processing by our external third parties, some
of whom are based outside of the UK.
We will only transfer your personal data outside of the UK ❲a❳ to countries that provide an adequate level of protection for personal data ❲b❳ if the transfer is subject to appropriate safeguards (as required under UK data protection law) or ❲c❳ in the absence of an adequate level of protection or appropriate safeguards being provided, if the transfer meets one of eight exceptions set out under UK data protection law which permits such a transfer.
Currently we only share personal data with entities based in countries in the European Economic Area (EEA) or the US. The EEA is comprised of all European Union member states plus Norway, Iceland and Liechtenstein.
Countries in the EEA have been deemed adequate by the UK (which means they provide an essentially equivalent level of data protection to that which exists within the UK). This is the basis upon which we send your personal data to the EEA.
The US has been deemed adequate by the UK in certain limited circumstances. Where this is applicable, we will transfer your data to US entities on this basis. In cases where the transfer does not meet the conditions for being adequate, we will rely on standard data protection clauses between ourselves and the entity to which we are transferring your personal data, to safeguard your data. If the data is sent overseas on our behalf, these clauses will be between the entity sending the data on our behalf and the receiving entity. These standard data protection clauses impose obligations on the transferring entity and the receiving organisation. They also give you rights in respect of your data. Wherever we use standard data protection clauses we will also do a transfer risk assessment in respect of the transfer to ensure that, in the circumstances of the transfer and with the standard data protection clauses in place, the relevant protections for your data under the UK data protection regime will not be undermined.
Please contact us using the contact details in this privacy notice if you want further information on how we protect your personal data when transferring your personal data outside of the UK, including if you would like a copy of the applicable adequacy determination or a copy of the applicable standard data protection clauses.
We will only transfer your personal data outside of the UK ❲a❳ to countries that provide an adequate level of protection for personal data ❲b❳ if the transfer is subject to appropriate safeguards (as required under UK data protection law) or ❲c❳ in the absence of an adequate level of protection or appropriate safeguards being provided, if the transfer meets one of eight exceptions set out under UK data protection law which permits such a transfer.
Currently we only share personal data with entities based in countries in the European Economic Area (EEA) or the US. The EEA is comprised of all European Union member states plus Norway, Iceland and Liechtenstein.
Countries in the EEA have been deemed adequate by the UK (which means they provide an essentially equivalent level of data protection to that which exists within the UK). This is the basis upon which we send your personal data to the EEA.
The US has been deemed adequate by the UK in certain limited circumstances. Where this is applicable, we will transfer your data to US entities on this basis. In cases where the transfer does not meet the conditions for being adequate, we will rely on standard data protection clauses between ourselves and the entity to which we are transferring your personal data, to safeguard your data. If the data is sent overseas on our behalf, these clauses will be between the entity sending the data on our behalf and the receiving entity. These standard data protection clauses impose obligations on the transferring entity and the receiving organisation. They also give you rights in respect of your data. Wherever we use standard data protection clauses we will also do a transfer risk assessment in respect of the transfer to ensure that, in the circumstances of the transfer and with the standard data protection clauses in place, the relevant protections for your data under the UK data protection regime will not be undermined.
Please contact us using the contact details in this privacy notice if you want further information on how we protect your personal data when transferring your personal data outside of the UK, including if you would like a copy of the applicable adequacy determination or a copy of the applicable standard data protection clauses.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from
being accidentally destroyed, 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.
Unfortunately, the transmission of information via the internet isn’t completely secure. Although we endeavour to protect your personal data, we can't guarantee the security of data transmitted over the internet. Any transmission of data is at your own risk.
Where you have created an account with us that uses a unique password to enable you to access your account, it is your responsibility to keep this password secure and confidential.
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.
Unfortunately, the transmission of information via the internet isn’t completely secure. Although we endeavour to protect your personal data, we can't guarantee the security of data transmitted over the internet. Any transmission of data is at your own risk.
Where you have created an account with us that uses a unique password to enable you to access your account, it is your responsibility to keep this password secure and confidential.
9. HOW LONG WE KEEP YOUR PERSONAL DATA FOR
We will only retain your personal data for as long as reasonably necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax,
accounting or reporting requirements. We may retain your personal data for a longer period in the event of a
complaint or if we reasonably believe there is a prospect of litigation.
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.
Website visitors: The only personal data of our website visitors (i.e. those who do not create an account or become a customer) that we retain is related to cookies, queries you submit to us, or information relating to you when you respond to a survey, take a quiz or take part in a competition or prize draw. Our general retention period for cookies is 6 months. For more information about the cookies we use, please see https://www.naturesmenu.co.uk/terms-and-privacy/natures-cookie-policy.html. Our retention period for information we collect in relation to queries, surveys, quizzes, competitions or prize draws is 6 years.
Customers: Our retention period for personal data related to our customers is 6 years.
Potential customers: Where we receive your details from the Abacus Alliance and market our products to you, we will retain your data for 6 months, unless you become a customer, in which case we will hold your data in accordance with the above provision.
When we have no ongoing legitimate business need or legal reason to process your personal information, we will delete it. When we delete your data we delete all of the identifiers (so that it can no longer be associated with you). This anonymised information is then used to ensure data integrity.
In some cases it may not be possible to delete your data (for example, because your personal information has been stored in backup archives). In these instances, we will securely store your personal information and isolate it from any further processing until deletion is possible.
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.
Website visitors: The only personal data of our website visitors (i.e. those who do not create an account or become a customer) that we retain is related to cookies, queries you submit to us, or information relating to you when you respond to a survey, take a quiz or take part in a competition or prize draw. Our general retention period for cookies is 6 months. For more information about the cookies we use, please see https://www.naturesmenu.co.uk/terms-and-privacy/natures-cookie-policy.html. Our retention period for information we collect in relation to queries, surveys, quizzes, competitions or prize draws is 6 years.
Customers: Our retention period for personal data related to our customers is 6 years.
Potential customers: Where we receive your details from the Abacus Alliance and market our products to you, we will retain your data for 6 months, unless you become a customer, in which case we will hold your data in accordance with the above provision.
When we have no ongoing legitimate business need or legal reason to process your personal information, we will delete it. When we delete your data we delete all of the identifiers (so that it can no longer be associated with you). This anonymised information is then used to ensure data integrity.
In some cases it may not be possible to delete your data (for example, because your personal information has been stored in backup archives). In these instances, we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. YOUR DATA PROTECTION RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to
your personal data.
You have 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. Please email your request to privacy@naturesmenu.co.uk.
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. If you’re an online Natures Menu member you can find out more about the process to correct the information we hold about you within your account by visiting https://www.naturesmenu.co.uk/portal. If you’re not an online Natures Menu member, you can email us at updatemydetails@naturesmenu.co.uk.
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 are processing 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 where there is a reason, set out under law, which means we do not have to. If this is the case this will be notified to you, if applicable, at the time of your request. If you’re an online Natures Menu member you can find out more about the process to request erasure of the information we hold about you within your account by visiting https://www.naturesmenu.co.uk/portal. If you’re not an online Natures Menu member, you can to email us at updatemydetails@naturesmenu.co.uk.
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:
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 to us and which we are processing on the basis of consent or 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 have 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. Please email your request to privacy@naturesmenu.co.uk.
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. If you’re an online Natures Menu member you can find out more about the process to correct the information we hold about you within your account by visiting https://www.naturesmenu.co.uk/portal. If you’re not an online Natures Menu member, you can email us at updatemydetails@naturesmenu.co.uk.
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 are processing 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 where there is a reason, set out under law, which means we do not have to. If this is the case this will be notified to you, if applicable, at the time of your request. If you’re an online Natures Menu member you can find out more about the process to request erasure of the information we hold about you within your account by visiting https://www.naturesmenu.co.uk/portal. If you’re not an online Natures Menu member, you can to email us at updatemydetails@naturesmenu.co.uk.
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:
- 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.
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 to us and which we are processing on the basis of consent or 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.
Marketing and Opting Out
We may market to you directly, via post, email, SMS and other messaging services
(such as Whatsapp). We may also use cookies and your personal details to direct adverts at you on our
website or third party websites.
You can specify your contact preferences when registering online to receive marketing communications from us or, for the purposes of marketing which uses cookies, when you decide whether to place the cookies on your device.
You can ask us to stop sending you email marketing, SMS marketing or marketing to you via messaging services at any time by following the opt-out links in the message sent to you, by responding to the message and requesting we stop sending you messages or by contacting us using the contact details referred to in this privacy notice. If you’re an online Natures Menu member, you can also do this by logging into your account and changing your preferences. If you no longer wish us to market to you via post, you can contact us on the details referred to in this privacy notice or, if you’re an online Natures Menu member, you can also do this by logging into your account and changing your preferences.
If you no longer wish us to use your personal data for directing adverts at you, you can opt-out of this at any time by contacting us using the contact details referred to in this privacy notice.
Where you opt out of receiving marketing, we will no longer use your personal data to market to you, however this will not affect our processing of your personal data for other purposes.
If you wish to exercise any of your legal rights, please contact us using the contact details referred to in the ‘How to Contact Us’ section, in addition to any contact method stated above.
You can specify your contact preferences when registering online to receive marketing communications from us or, for the purposes of marketing which uses cookies, when you decide whether to place the cookies on your device.
You can ask us to stop sending you email marketing, SMS marketing or marketing to you via messaging services at any time by following the opt-out links in the message sent to you, by responding to the message and requesting we stop sending you messages or by contacting us using the contact details referred to in this privacy notice. If you’re an online Natures Menu member, you can also do this by logging into your account and changing your preferences. If you no longer wish us to market to you via post, you can contact us on the details referred to in this privacy notice or, if you’re an online Natures Menu member, you can also do this by logging into your account and changing your preferences.
If you no longer wish us to use your personal data for directing adverts at you, you can opt-out of this at any time by contacting us using the contact details referred to in this privacy notice.
Where you opt out of receiving marketing, we will no longer use your personal data to market to you, however this will not affect our processing of your personal data for other purposes.
If you wish to exercise any of your legal rights, please contact us using the contact details referred to in the ‘How to Contact Us’ section, in addition to any contact method stated above.
11. VISITORS TO OUR WEBSITE OR CUSTOMER HELPLINE
How we use your personal information (our purposes) and our legal basis for
processing it
We have set out below, in a table format, more details on our purposes for processing
your personal data and the related legal bases. 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.
In addition to the purposes set out below we will also retain your data, in accordance with the retention periods set out in Section 8, to comply with our legal obligations and to enable us to respond to any complaints or claims (and in some cases bring claims) (which will be processed on the basis it is in our legitimate interests to respond to queries and defend or bring claims).
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.
In addition to the purposes set out below we will also retain your data, in accordance with the retention periods set out in Section 8, to comply with our legal obligations and to enable us to respond to any complaints or claims (and in some cases bring claims) (which will be processed on the basis it is in our legitimate interests to respond to queries and defend or bring claims).
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register for an account with us | ❲a❳ Identity Data ❲b❳ Contact Data |
Performance of a contract with you (or to enter into a contract with you) |
| To respond to your queries about our products and services via our website contact form or customer helpline This does not apply to customers or potential customers. See section 12 for more detail on queries from customers or potential customers | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Profile Data ❲d❳ Marketing and Communications Data (e) Enquiries and Complaints Data (f) Call recording |
Necessary for our legitimate interests (to reply to queries as part of running our business) |
| To enable you to partake in a prize draw, competition, quiz or complete a survey and manage/administer such surveys, quizzes, prizes and competitions | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Profile Data ❲d❳ Usage Data ❲e❳ Marketing and Communications Data (f) Call recordings (where you correspond with us via the telephone in relation to a survey) (g) Enquiries and Complaints Data (h) Profile Data Where you are a customer we may also use your Transaction Data. |
❲a❳ Performance of a contract with you ❲b❳ Necessary for our legitimate interests (to offer engaging methods to grow our business)) |
| To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Technical Data (d) Usage Data (e) Call recordings (f) Enquiries and Complaints Data (g) Aggregated Data (h) Profile Data Where you are a customer or potential customer we may also use: (a) Financial Data (b) Transaction Data (c) Transaction History Data (d) Preference Data (e) Marketing and Communications Data |
❲a❳ Necessary for our legitimate interests (for running our business, provision of
administration and IT services, network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise) ❲b❳ Necessary to comply with a legal obligation |
| To deliver relevant website content to you and measure or understand the effectiveness of the website content we serve to you | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Profile Data ❲d❳ Usage Data ❲e❳ Marketing and Communications Data ❲f❳ Technical Data (g) Aggregated Data Where you are a customer we may also use your Transaction Data. |
(a) Necessary for our legitimate interests (to study how website visitors use our products
and services, to develop our website and our products and services, to grow our business and
to inform our marketing strategy) (b) Consent (where consent is required under applicable law). |
| To manage our use of tracking technologies and use data analytics to improve our website, products/services, marketing, customer relationships and experiences by monitoring the traffic on the website, recognising and counting the number of visitors and seeing how visitors move around our website when they are using it | ❲a❳ Technical Data ❲b❳ Usage Data (c) Aggregated Data (d) Identity Data (f) Profile Data Where you are a customer we may also use your Transaction Data. |
(a) Necessary for our legitimate interests (to define types of customers for our products
and services, to keep our website updated and relevant, to develop our business and to
inform our marketing strategy) (b) Consent (where required under applicable law). |
| To collect and share your information with third party organisations to direct marketing to you | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Technical Data ❲d❳ Usage Data ❲e❳ Profile Data ❲e❳ Marketing and Communications Data |
(a) Consent (where required under applicable law). |
| To make suggestions and recommendations to you about products and services that may be of interest to you If you are a customer or potential customer, you should see the equivalent rows in section 12 | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Technical Data ❲d❳ Usage Data ❲e❳ Profile Data ❲e❳ Marketing and Communications Data |
(a) Necessary for our legitimate interests (to develop our products/services and grow our
business) (b) Consent (where required under applicable law). |
| To review communications with you for customer support and quality assurance and training purposes, and related recordkeeping | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Profile Data ❲d❳ Usage Data ❲e❳ Technical Data (f) Call recordings Where you are a customer we may also use your Transaction Data. |
Necessary for our legitimate interests (to operate, provide and improve our business; to communicate with you) – where our communications are not necessary to perform or enter into a contract with you. |
| To aggregate your data and to use your data (including aggregated data) to improve our products, services, website and telephone helpline | (a) Identity Data (b) Contact Data (c) Call recordings (d) Profile Data (e) Aggregated Data (f) Technical Data (g) Usage Data (h) Enquiries and Complaints Data We may use any of the data we process about you, other than Financial Data, to create aggregated data. Where you are a customer or potential customer, we may also use the following data to improve our products, services, website and telephone helpline: (a) Transaction Data (b) Transaction History Data (c) Preference Data (d) Marketing and Communications Data |
Necessary for our legitimate interest in improving our goods, services, website or telephone helpline to improve our business. |
In addition to the purposes set out in above, we may be required to:
- a. process personal data we hold about you to comply with legal obligations we are subject to from time to time. Where possible, we will notify you of these obligations and they will include responding to government bodies, where required, and responding to subject access requests;
- b. process your personal data to defend or pursue legal claims. In this case we will rely on our legitimate interests in pursuing a claim or defending ourselves. Whenever we use your data in these instances we shall ensure we have assessed whether your interests outweigh those being pursued in the specific case.
12. OUR CUSTOMERS AND POTENTIAL CUSTOMERS
Purposes for which we will use your personal data
When you access and use our website or respond to a prize draw, competition,
survey or quiz we will use your personal data as set out in the table in section 10 (we have indicated
where a purpose does not apply to you or where we will use additional data categories, if you are a
customer or potential customer). Additionally, we may use your data, as set out under the table in
section 11, for the purposes of aggregating your data and improving our goods, services, website and
helpline, for reviewing communications with you for customer support and quality assurance and training
purposes and related recordkeeping and to administer and protect our business, even where such
information is not collected via the website.
When you set up an account with us, sign up via a referral and/or purchase from us we will process personal data as part of your customer relationship. We have set out below, in a table format, further details on our purposes for processing your personal data and the related legal basis. We have also identified what our legitimate interests are where appropriate.
In some instances, we may receive data on individuals who are not yet our customers, but whom we think may be interested in receiving marketing from us. Where this is the case, we will only process your personal data for the final four purposes set out in the table below and at the end of this section, unless you subsequently become a customer.
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.
In addition to the purposes set out below we will also retain your data, in accordance with the retention periods set out in Section 8, to comply with our legal obligations and to enable us to respond to any complaints or claims (and in some cases bring claims) (which will be processed on the basis it is in our legitimate interests to respond to queries and defend or bring claims).
When you set up an account with us, sign up via a referral and/or purchase from us we will process personal data as part of your customer relationship. We have set out below, in a table format, further details on our purposes for processing your personal data and the related legal basis. We have also identified what our legitimate interests are where appropriate.
In some instances, we may receive data on individuals who are not yet our customers, but whom we think may be interested in receiving marketing from us. Where this is the case, we will only process your personal data for the final four purposes set out in the table below and at the end of this section, unless you subsequently become a customer.
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.
In addition to the purposes set out below we will also retain your data, in accordance with the retention periods set out in Section 8, to comply with our legal obligations and to enable us to respond to any complaints or claims (and in some cases bring claims) (which will be processed on the basis it is in our legitimate interests to respond to queries and defend or bring claims).
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To process and deliver your order including: ❲a❳ Manage payments, fees and charges and receipts ❲b❳ Respond to your queries (including via the customer helpline) ❲c❳ Collect and recover money owed to us (d) Deal with any returns |
❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Financial Data ❲d❳ Transaction Data ❲e❳ Marketing and Communications Data (f) Call recordings (where you communicate with us via telephone) (g) Enquiries and Complaints Data (h) Profile Data |
❲a❳ Performance of a contract with you (or to enter into a contract with you) ❲b❳ Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: ❲a❳ General communications and updates ❲b❳ Notifying you about changes to our terms or privacy notice |
❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Profile Data ❲d❳ Marketing and Communications Data (e) Transaction Data |
❲a❳ Performance of a contract with you ❲b❳ Necessary to comply with a legal obligation ❲c❳ Necessary for our legitimate interests (to keep our records updated and manage our relationship with you) |
| To use any testimonials, results of surveys you provide to improve our products or market our products | ❲a❳ Identity Data ❲b❳ Contact Data (including any photos provided) ❲c❳ Profile Data (d) Transaction Data |
Necessary for our legitimate interests (to market our products and improve our products and surveys). |
| To manage our referral schemes | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Transaction Data |
Necessary for our legitimate interests (to run our referral programme and grow our business) |
| To make and manage insurance claims | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Financial Data ❲d❳ Transaction Data (e) Profile Data (f) Enquiries and Complaints Datal |
Necessary for our legitimate interests (to make claims under our insurance policies) |
| To share your information with Epsilon International UK Limited to enable them to anonymise your data for their own purposes | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Transaction Data |
Necessary for the legitimate interests of Epsilon International UK Limited in improving and providing their services |
| To share your information with the Abacus Alliance | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Transaction Data |
This will only be shared with your consent. |
| To analyse your information to better understand your preferences and ensure we can offer you products and services which you are interested in | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Transaction Data (d) Preference Data (e) Transaction History Data (f) Profile Data |
Necessary for our legitimate interests (to develop our products/services and grow our business) and your legitimate interests (to only receive marketing for products and services you are interested in) |
| To send you marketing including details of promotions and offers which we think may be of interest to you, to ask you to leave a review or provide feedback, to send you surveys, prize draws, quizzes and competitions, to make suggestions and recommendations to you about products or services that may be of interest to you or to provide you with recommended feeding plans for your pet(s). We may also share your personal data with third parties, to enable them to direct marketing at you online. | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Technical Data ❲d❳ Usage Data ❲e❳ Profile Data ❲f❳ Marketing and Communications Data (g) Preference Data (h) Transaction History Data (i) Transaction Data |
Consent Necessary for our legitimate interests (to grow our business)- This will only be used where we have received your details via the Abacus Alliance and you are not already a customer OR, in certain limited circumstances, where we are permitted to rely on legitimate interests |
| To send you service updates, confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages and to respond to your enquiries, requests or complaints. | ❲a❳ Identity Data ❲b❳ Contact Data ❲c❳ Technical Data ❲d❳ Usage Data ❲e❳ Profile Data (f) Enquiries and Complaints Data (g) Transaction Data |
❲a❳ Performance of a contract with you ❲b❳ Necessary for our legitimate interests to operate, provide and improve our business; to communicate with you Where you are a potential customer, we will only use your data to respond to your enquiries, requests and complaints and we will rely on our legitimate interests to do this. However, if your enquiry relates to potentially buying something from us, this processing may be done on the basis of performance of contract. |
| To maintain an opt-out list where you indicate you do not wish to be marketed to. | ❲a❳ Identity Data ❲b❳ Contact Data |
To comply with our legal obligations. |
In addition to the purposes set out in above, we may be required to:
- a. process personal data we hold about you to comply with legal obligations we are subject to from time to time. Where possible, we will notify you of these obligations and they will include responding to government bodies, where required, and responding to subject access requests; and
- b. process your personal data to defend or pursue legal claims. In this case we will rely on our legitimate interests in pursuing a claim or defending ourselves. Whenever we use your data in these instances we shall ensure we have assessed whether your interests outweigh those being pursued in the specific case.
13. CHANGES
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.
We keep our privacy notice under regular review. We may update this privacy notice from time to time in response to changing legal, regulatory, technical or business developments. When we update our privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
You can see when this privacy notice was last updated by checking the “last updated” date displayed at the top of this privacy notice.
We keep our privacy notice under regular review. We may update this privacy notice from time to time in response to changing legal, regulatory, technical or business developments. When we update our privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
You can see when this privacy notice was last updated by checking the “last updated” date displayed at the top of this privacy notice.
14. THIRD PARTY LINKS
This website may include links to third-party websites, plug-ins and
applications, including those of our partner networks and affiliates. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control
these third-party websites and are not responsible for their privacy statements. When you leave our
website, we encourage you to read the privacy notice of every website you visit.
15. HOW TO CONTACT US
If you have any questions about this privacy notice or our privacy practices,
please contact us in the following ways:
Full name of legal entity: Natures Menu Limited
Email address: privacy@naturesmenu.co.uk
Telephone number: 0333 270 7239
Postal address: Privacy, Natures Menu Limited, Falcon Road, Snetterton, Norfolk, NR16 2FB.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (https://ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Full name of legal entity: Natures Menu Limited
Email address: privacy@naturesmenu.co.uk
Telephone number: 0333 270 7239
Postal address: Privacy, Natures Menu Limited, Falcon Road, Snetterton, Norfolk, NR16 2FB.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (https://ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.