1. INTRODUCTION
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 data. This privacy policy will inform you as to how we look after your personal data whether you are: (a) a customer of Natures Menu, or (b) a visitor to Natures Menu’s website at https://www.naturesmenu.co.uk (‘website’) (regardless of where you visit it from). This policy tells you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
2. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy policy
This privacy policy aims to give you information on how Natures Menu collects and processes your personal data through your interactions with us as a customer or through your use of our website.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.
Controller
Natures Menu Limited is the controller and is responsible for our website.
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 will share your personal data with Affinity Petcare, who will act as an independent controller and will be independently responsible for your personal data. You can find Affinity Petcare’s privacy policy here: https://www.affinity-petcare.com/en/legal-notice.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
We have appointed a privacy committee who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the privacy committee using the details set out below.
Contact Details
If you have any questions about this privacy policy 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) as well as the Spanish Data Protection Agency (AEPD), the Spanish regulator for data protection issues (https://www.aepd.es). We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the AEPD so please contact us in the first instance.
Our principles
- We'll only collect and use your information where we have lawful grounds and legitimate business reasons to do so
- We'll be transparent in our dealings with you and tell you how we’ll collect and use your information
- If we collect your information for a particular purpose we'll only use it for that purpose, unless you’ve been otherwise informed and given your permission where relevant
- We won’t ask for more information than we need for the purposes for which we’re collecting it
- We'll update our records when you tell us that your details have changed
- We'll periodically review your personal information to ensure we don’t keep it for longer than is necessary
- We'll ensure that your information is securely disposed of at the end of the appropriate retention period
- We'll observe your rights under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are dealt with promptly and transparently
- We'll train our staff on their privacy obligations
- We'll ensure we have appropriate physical and technological security measures to protect your information regardless of where it’s held
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 10 August 2022
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.
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 policy of every website you visit.
3. THE DATA WE COLLECT ABOUT YOU
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 policy of every website you visit.
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, gender and CCTV footage.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- 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.
- 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, 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.
Please read the relevant section under Sections 10-11 that describes your relationship with us as it will set out which categories of personal data are relevant for that particular relationship.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data, Contact Data, Profile Data, and Financial Data and any other information you may choose to supply us by filling in our contact form on our website or by corresponding with us by post, phone, email or otherwise. 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 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/cookie-policy 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; and
· Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services.
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 perform the contract we are about to enter into or have entered into 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 get your consent before sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 10-11 that applies to our relationship with you. We have also identified what our legitimate interests are where appropriate.
Marketing and Opting Out
We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and/or services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested to do so.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can specify your contact preferences when registering online to receive communications from us or by subsequently advising us of your contact preferences by emailing us at info@naturesmenu.co.uk. If you’re an online Natures Menu member, you can do this by logging into your account and changing your preferences.
You can ask us or third parties to stop sending you marketing messages at any time following the opt-out links on any arketing message sent to you or by responding to the relevant email and requesting to opt out of receiving such messages or by contacting us using the contact details referred to above.
Where you opt out of receiving these marketing messages, such marketing messages will no longer be sent but this will not apply to personal data provided to us as a result of your product/service purchase.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.naturesmenu.co.uk/cookie-policy.
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.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURES OF YOUR PERSONAL DATA
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.
Internal Third Parties
- 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 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.
External Third Parties
- Service providers who provide services in: IT/software, media and analytics, system administration, customer care and relationship management, courier service for order delivery, marketing and email communications, acquisition of customer reviews, credit checking and fraud prevention.
- 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 policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
Where Natures Menu is the controller of your personal data
Your personal data may be 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 (for which see below) ❲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 seven conditions set out under UK data protection law which permits such a transfer.
Currently all countries in the European Economic Area (EEA), which is comprised of all European Union member states plus Norway, Iceland and Liechtenstein, have been found to provide an adequate level of data protection as well as Andorra, Argentina, Canada (only data that is subject to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)), Faroe Islands, Gibraltar, Guernsey, Isle of Man, Israel, Japan (only private sector organisations), Jersey, New Zealand, Switzerland, and Uruguay.
We may also share your personal data with Affinity Petcare. This will involve transferring your data outside the UK.
Please contact us using the contact details referred to above if you want further information on how we protect your personal data when transferring your personal data outside of the UK.
Where Affinity Petcare is the controller of your personal data
Your personal data will be transferred outside of the UK to the EEA for processing by Affinity Petcare and its external third parties, some of whom are based outside of the EEA.
As stated above, currently all countries in the European Economic Area (EEA), which is comprised of all European Union member states plus Norway, Iceland and Liechtenstein, have been found to provide an adequate level of protection for personal data.
Please contact Affinity Petcare using the contact details referred to above if you want further information on how it protects your personal data when transferring your personal data outside of the UK.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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.
9. DATA RETENTION
How long will you use my 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 in respect to our relationship with you.
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.
Details of retention periods for different aspects of your personal data and for specific processing activities are set out in the relevant section under Sections 10-11 that applies to our relationship with you.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. YOUR LEGAL 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 will need to email us at info@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 may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 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 will need to email us at info@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 consent for us to use or where we used the information 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.
If you wish to exercise any of your legal rights, please contact us using the contact details referred to above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. OUR CUSTOMERS
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
To register you as a new customer |
❲a❳ Identity
❲b❳ Contact |
Performance of a contract with you |
To process and deliver your order including: ❲a❳ Manage payments, fees and charges
❲b❳ Respond to your queries
❲c❳ Collect and recover money owed to us |
❲a❳ Identity
❲b❳ Contact
❲c❳ Financial
❲d❳ Transaction
❲e❳ Marketing and Communications |
❲a❳ Performance of 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 communication and updates
❲b❳ Asking you to leave a review or take a survey
❲c❳ Notifying you about changes to our terms or privacy policy |
❲a❳ Identity
❲b❳ Contact
❲c❳ Profile
❲d❳ Marketing and Communications |
❲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 to study how customers use our products/services so we can improve our customer service and make our products and services more valuable to you) |
To enable you to partake in a prize draw, competition or complete a survey |
❲a❳ Identity
❲b❳ Contact
❲c❳ Profile
❲d❳ Usage
❲e❳ Marketing and Communications |
|
❲a❳ Performance of a contract with you
❲b❳ Necessary for our legitimate interests (to study how customers use our products/services, to develop / improve them, and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
❲a❳ Identity
❲b❳ Contact
❲c❳ Technical |
❲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
❲b❳ Contact
❲c❳ Profile
❲d❳ Usage
❲e❳ Marketing and Communications
❲f❳ Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
❲f❳ Technical
❲d❳ Usage |
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) |
To send you details of promotions and offers which we think may be of interest to you and 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) |
❲a❳ Identity
❲b❳ Contact
❲c❳ Technical
❲d❳ Usage
❲e❳ Profile
❲f❳ Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Data retention
The only data stored related to visitors of our website who do not create an account or become a customer is data related to cookies. Our general retention period for such data is 6 months. For more information about the cookies we use, please see https://www.naturesmenu.co.uk/cookie-policy
12. VISITORS TO OUR WEBSITE
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
Responding to your queries about our products and services via our website contact form |
❲a❳ Identity
❲b❳ Contact
❲c❳ Profile
❲d❳ Marketing and Communications |
|
Necessary for our legitimate interests (to develop our website and our products and services and improve our customer service and grow our business) |
To enable you to partake in a prize draw, competition or complete a survey |
❲a❳ Identity
❲b❳ Contact
❲c❳ Profile
❲d❳ Usage
❲e❳ Marketing and Communications |
❲a❳ Performance of a contract with you
❲b❳ Necessary for our legitimate interests (to develop our website and our products and services and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
❲a❳ Identity
❲b❳ Contact
❲c❳ Technical |
❲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
❲b❳ Contact
❲c❳ Profile
❲d❳ Usage
❲e❳ Marketing and Communications
❲f❳ Technical |
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) |
To 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, sales intelligence, marketing effectiveness (such as click and open rates) uptake and progress |
❲a❳ Technical
❲b❳ Usage |
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) |
To make suggestions and recommendations to you about products and services that may be of interest to you |
❲a❳ Identity
❲b❳ Contact
❲c❳ Technical
❲d❳ Usage
❲e❳ Profile
❲e❳ Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Data retention
The only data stored related to visitors of our website who do not create an account or become a customer is data related to cookies. Our general retention period for such data is 6 months. For more information about the cookies we use, please see https://www.naturesmenu.co.uk/cookie-policy