Privacy policy

1. About this policy

  1. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about our customers and we recognise the need to treat it in an appropriate and lawful manner, in accordance with the General Data Protection Regulation (GDPR). The purpose of this policy is to make you aware of how we will handle your personal data.
  2. However data technology and rules change regularly, so we reserve the right to amend it at any time.

2. Data protection principles

  1. We will comply with the seven data protection principles in the GDPR, which say that personal data must be:
    1. Processed fairly and lawfully.
    2. Processed for limited purposes and in an appropriate way.
    3. Adequate, relevant and not excessive for the purpose.
    4. Accurate.
    5. Not kept longer than necessary for the purpose.
    6. Processed in line with individuals’ rights.
    7. Be kept secure.
  2. “Personal data” means recorded information we hold about you from which you can be identified. It may include your contact details, other personal information, photographs, expressions of opinion about you or indications as to our intentions about you. “Processing” means doing anything with the data, such as accessing, disclosing, destroying or using the data in any way.

3. Introduction

  1. We are committed to safeguarding the privacy of our website visitors; in this policy, we explain how we will treat your personal information.

4. Collecting personal information

  1. We may collect, store and use the following kinds of personal information:
    1. information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
    2. information that you provide to us when registering with our website (including your email address);
    3. information that you provide when completing your profile on our website (including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details);
    4. information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
    5. information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including [the timing, frequency and pattern of service use);
    6. information relating to any purchases you make of our [goods / services / goods and/or services] or any other transactions that you enter into through our website (including your name, address, telephone number, email address and card details);
    7. information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);
    8. information contained in or relating to any communications that you send to us or send through our website (including [the communication content and metadata associated with the communication);
    9. any other personal information that you choose to send to us; and
    10. provide details of other personal information collected.
  2. Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

5. Using your personal information

  1. Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
  2. We may use your personal information to:
    1. administer our website and business;
    2. personalise our website for you;
    3. enable your use of the services available on our website;
    4. send you goods purchased through our website;
    5. supply to you services purchased through our website;
    6. send statements, invoices and payment reminders to you, and collect payments from you;
    7. send you non-marketing commercial communications;
    8. send you email notifications that you have specifically requested;
    9. send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
    10. send you marketing communications relating to our business [or the businesses of carefully-selected third parties] which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
    11. provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
    12. deal with enquiries and complaints made by or about you relating to our website;
    13. keep our website secure and prevent fraud;
    14. verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service); and
    15. other uses.
  3. If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
  4. Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
  5. We will usually only process your personal data where you have given us your explicit consent, for example, to register for access to our website, or for entry into a prize promotion, or where the processing is necessary to comply with our legal obligations. In other cases, processing may be necessary for the protection of your vital interests, for our legitimate interests or the legitimate interests of others. The full list of conditions is set out in the GDPR.
    1. We will only process your personal data for the specific purpose or purposes notified to you or for any other purposes specifically permitted by the GDPR.
    2. Your personal data will only be processed to the extent that it is necessary for the specific purposes notified to you.
    3. We will seek to keep the personal data we store about you accurate and up to date. Data that is inaccurate or out of date will be deleted. However, it is your obligation to keep us informed of any changes to your personal data, eg if you move house, or if you become aware of any inaccuracies in the personal data we hold about you. You may do this by sending an email as indicated in section thirteen.
    4. We will not keep your personal data for longer than is necessary for the purpose. This means that data will be destroyed or erased from our systems when it is no longer required, which is typically two years from your last interaction with us, by email, website or other means.
    5. We will only process your data in line with your data rights.
  6. You have the right to:
    1. Request access to any personal data we hold about you.
    2. Prevent the processing of your data for direct marketing purposes.
    3. Ask to have inaccurate data held about you amended.
    4. Prevent processing that is likely to cause unwarranted substantial damage or distress to you or anyone else.
    5. Object to any decision that significantly affects you being taken solely by a computer or other automated process.
  7. To exercise any of these rights, please send us an email to the contact in section thirteen with your full name and details and we will do our best to make the amendments as soon as possible. But do please understand that changes may not be immediate.
  8. We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
  9. We will ensure that we have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of deletion.

6. Providing information to third parties

  1. Unless we have obtained your specific consent, we will never transfer your data to third parties for them to communicate directly with you. The only exception is where it is necessary to fulfil our obligations to you, for example, to give a fulfilment company your address to send you a prize. But we will only transfer personal data if the other company agrees to comply with our data procedures and policies, and if they put in place adequate data security measures.

7. Disclosing personal information

  1. We may disclose your personal information to [any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors] insofar as reasonably necessary for the purposes set out in this policy.
  2. [We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.]
  3. We may disclose your personal information:
    1. to the extent that we are required to do so by law;
    2. in connection with any ongoing or prospective legal proceedings;
    3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
    4. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
    5. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
  4. Except as provided in this policy, we will not provide your personal information to third parties.

8. International data transfers

  1. Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
  2. Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: [the United States of America, Russia, Japan, China and India].
  3. Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
  4. You expressly agree to the transfers of personal information described in this Section 8.

9. Retaining personal information

  1. This Section 9 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
  2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  3. Notwithstanding the other provisions of this Section 9, we will retain documents (including electronic documents) containing personal data:
    1. to the extent that we are required to do so by law;
    2. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
    3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

10. Security of your personal information

  1. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
  2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
  3. All electronic financial transactions entered into through our website will be protected by encryption technology.
  4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
  5. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

11. Amendments

  1. We may update this policy from time to time by publishing a new version on our website.
  2. You should check this page occasionally to ensure you are happy with any changes to this policy.
  3. We may notify you of changes to this policy [by email or through the private messaging system on our website].

12. Your rights

  1. We may withhold personal information that you request to the extent permitted by law.
  2. You may instruct us at any time not to process your personal information for marketing purposes.
  3. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

13. Subject access requests

  1. If you wish to know what personal data we hold about you, you may make a request in writing. Send all such requests to the address in section thirteen.

14. Data Contacts

  • For email requests: leap@neseafood.com
  • For written requests: 48 Cox Lane, Chessington, Surrey KT9 1TW
  • Full Address of the Data Controller: Saffrey Champness, Sovereign House, 6 Windsor Court, Harrogate HG1 2PE

15. Third party websites

  1. Our website includes hyperlinks to, and details of, third party websites.
  2. We have no control over, and are not responsible for, the privacy policies practices of third parties.

16. Updating information

  1. Please let us know if the personal information that we hold about you needs to be corrected or updated.

17. Data protection registration

  1. We are registered as a data controller with the UK Information Commissioner’s Office.
  2. Our data protection registration number is 00010095952.

18. Our details

  1. This website is owned and operated by New England Seafood International Limited.
  2. We are registered in England and Wales under registration number 2565953, and our registered office is at Saffrey Champness, Sovereign House, 6 Windsor Court, Harrogate, HG1 2PE
  3. Our principal place of business is at 48 Cox Lane, Chessington, Surrey KT9 1TW
  4. You can contact us by writing to the business address given above, by using our website contact form, by email to leap@neseafood.com or by telephone on +44 (0)20 8391 9777

This policy was written and approved on 2nd May 2018. Any amendments will be available on this page.