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Henderson Group Privacy Policy: Updated March 2021

Who we are:

The Henderson Group consists of a group of four companies. Henderson Wholesale Ltd, Henderson Retail Ltd, Henderson Foodservice Ltd and Henderson Group Property Ltd. We also operate Henderson Print, Henderson Technology and Henderson Kitchen which sit within parent company Henderson Wholesale Ltd.

Company Name	Company Number
Henderson Foodservice Limited	NI006894
Henderson Group Property Limited	NI020650
Henderson Retail Limited	R0000035
Henderson Wholesale Limited	NI000068

Our head office address is Henderson Group 9, Hightown Avenue, Newtownabbey BT36 4RT.

Our main customer facing company is Henderson Retail Ltd. This includes Eurospar, Spar, Vivo, Vivo Essentials and VivoXtra, shops you may be familiar with in your own local community.

Our Data Protection Lead is Patricia White, and she has overall responsibility within Henderson Group for data protection. She may be contacted by emailing GDPRTeam@henderson-group.com. You can also write to Patricia White at our Head Office address as listed above.

Scope

This policy relates to all users of the Henderson Group corporate website. It should be read in line with the privacy notices displayed on each of the corporate websites which may identify further purposes for that legal entity.

Our Website is not intended for children and we do not knowingly collect data relating to children. We do not actively solicit information from children, and we do not knowingly collect Personal Information from children without proper parental consent. If you believe that we may have collected Personal Information from someone under the applicable age of consent without parental consent, please write to us at gdprteam@henderson-group.com.

Purpose

This Privacy Policy explains how we collect and use your personal information. All personal information given to us through this site will be held and stored securely in accordance with this policy and the UK General Data Protection Regulations and Data Protection Act 2018, and any amending and replacement legislation in future.

Henderson Group or any of our Companies are the data controller for the purpose of this policy. This means we are responsible for determining when, why and how to process personal data. We will not collect any personal information about you, except where it is specifically and knowingly provided by you.

How do we collect information?

We collect information on you through any of our websites below:

Each of the above companies may have their own privacy policies that explain how they use your personal data. It is important that you read these.

We may also collect your data when you engage with us in public platforms such as social media. Also through competition paper entry forms, conversations in-store, at events, by telephone, email, video or image recording by us at various events or in-store or in connection with a contract with you.

What information do we collect from you?

As appropriate for the intended use of the information (described below), we may collect the following information about you:

your name, age/date of birth and gender;
your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
Your job title.
purchases and orders made by you.
your on-line browsing activities on our Website;
your password(s);
your communication and marketing preferences;
your interests, preferences, feedback and survey responses;
your location;
your correspondence and communications with us; and

other publicly available personal data, including any which you have shared via a public platform.

We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.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.

Information we receive from other sources. This is information we receive about you if you use any of the other Websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

How we use your personal information:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

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 or regulatory obligation
Where we might need to protect your vital interests in the event of an emergency

Examples of the way in which we may use your information is set out below:

To communicate about the fulfilment of contracts between us, if you are a supplier of goods or services and to provide you with the information, products and services that you request from us.
To maintain our database of store locations, if you are a retailer
To communicate about matters of mutual importance, such as to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
To track the progress of your query, or to inform you of progress, if you are a customer
To enter you into competitions that we run and administer
to deliver relevant content of the websites and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
to use data analytics to improve our websites, products/services, marketing, customer relationships and experiences.
to run promotional campaigns and to deliver relevant marketing information to you from time to time.
to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form or registration form).
to verify your identity.
for crime and fraud prevention, detection and related purposes.
To notify you about changes to our service.
to comply with our legal obligations and responsibilities and establishment and defence of legal claims.
for good governance, accounting and managing our business operations.

We collect and use customers’ personal data because it is necessary for the pursuit of our legitimate interests, the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer or complying with our legal obligations.

How long do we hold your information for?

We retain your personal data while you remain a customer and for 7 years thereafter unless you ask us to delete it. We will delete or anonymise your information at your request unless:

There is an unresolved issue, such as a claim or dispute.
We are legally required to; or
There are overriding legitimate business interests, including but not limited to fraud prevention and protecting customers' safety and security.

How we protect your personal data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers or within secure filing systems. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

To whom will we provide your information?

From time to time we may need to disclose your information to:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 and their employees.
credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
to professional advisors (including lawyers, bankers, accountants, insurers and insurance brokers) in the event of a breach of contract or other such legal proceedings.
and to third party data processing service providers (such as marketing automation platform and marketing service providers, IT hosting providers, data security providers and FMCG suppliers to Henderson Wholesale Ltd.) who process your information on our behalf in accordance with our instructions to enable us to provide services to you and facilitate the purposes described above.
In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, refinancing, or acquisition of some or all of our business by another company.

Transfers to Third Countries and International Organisations

We transfer personal data to third countries or international organisations to help deliver our products and services. We are satisfied that the personal data is appropriately secured and protected by the receiving organisations.

Your rights over the information

Depending on the information we are using and under certain circumstances, you have rights under data protection laws in relation to some of the information you provide that can identify you (which is known as personal data under data protection laws). Those rights are as follows:

You have the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data; and the
Right to withdraw consent.

Where we rely on consent as a legal basis for processing your personal data, you have the right to withdraw that consent at any time. Details of how to unsubscribe from emails will be included with each marketing email we send you or emailing MarketingTeam@henderson-group.com to change your contact preferences. You can also withdraw your consent by emailing GDPRTeam@henderson-group.com

We may seek to verify your identity first before responding to any of your individual requests.

Your right to lodge a complaint

If you are not happy with how your information has been handled, you have the right to lodge a complaint with a supervisory authority. The UK supervisory authority for data protection issues is the Information Commissioner’s Office (ICO). (www.ico.org.uk) We would, however, appreciate the chance to deal with your concerns before you approach the ICO.

What if there are changes to this Privacy Policy?

Occasionally, to better protect you and in accordance with the law, we may need to update our privacy policy. We reserve the right to amend, update or replace this privacy policy at any time and your continued use of our website will constitute your acceptance of any such changes we may make. Any changes we make will be shown here, so please make sure you check this page from time to time.