What is this policy?
Who are we?
We are MEDFRESH. Our contact and other details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).
Whose personal data do we process?
We may process personal data relating to you if:
You are a customer or a supplier of ours.
You use our products or services.
You work for a customer or a supplier of ours, or for someone who uses our products or services.
You are someone (or you work for someone) to whom we want to advertise or market our goods or services. In this case, we may have obtained your details direct from you (for example, via our website or at a trade show or exhibition) or from another source.
What personal data do we process?
We may process personal data relating to you that we have either obtained from you, or obtained from somewhere else. The personal data relating to you that we process may include the information set out below.
Your personal details
We may process your personal details, including:
Who you work for, and your job function or department
Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the person that you work for).
Information we obtain from communications with us
We may process information that we obtain from communicating with you, including:
Information about you that you give us by communicating with us by phone, by e-mail, via our website, via social media or otherwise.
Information you give us or that we obtain when you use our website, obtain or subscribe to our goods or services, supply us with goods or services, enquire about a product, place an order, enter a competition, promotion or survey, or contact us to report a problem, or do any of these things on behalf of the person that you work for.
Information relating to our dealings with you or the person you work for
We may process information relating to our dealings with you or the person that you work for, including:
Information relating to transactions with us involving you or the person that you work for (for example, details of goods or services that we have supplied to, or obtained from, you or the person you work for).
Other information relating to you which it is necessary for us to process in order to enter into or perform a contract with you or the person that you work for (for example, right to work information and information obtained from credit references agencies where this is necessary to enable us to carry out appropriate checks in relation to contracts with you or someone else that you work for or are otherwise related to).
Information about events to which you or those related to you are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events (for example, your dietary requirements).
Information relating to you that you give us or we otherwise obtain when you visit us (for example, if you sign in or are recorded on CCTV while visiting us, or you give us the registration details of your vehicle).
What personal data do we process when you use our website?
Information that we obtain from you when you use our website includes:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
What do we do with your personal data?
We may process your personal data for the following purposes:
To enter into, and to perform, contracts with you or the person that you work for.
provide goods and services to customers or other users of those goods and services;
obtain goods and services from suppliers;
manage and administer our relationships with customers, suppliers or other users of our goods and services;
where you or the person that you work for may be the relevant customer, user or supplier of goods or services for these purposes.
To advertise and market, and provide information about, our goods and services. This may be via direct marketing communications (such as emails) or telephone calls. This may included making suggestions and recommendations about goods or services that may interest you or the person that you work for, and it will be subject to your stated preferences where relevant.
To administer our website under our terms and for internal operations, including troubleshooting, and data analysis, testing, research, statistical and survey purposes.
To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
To keep our website and other systems safe and secure.
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising.
Who do we disclose your personal data to?
We may share your personal data with:
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Appropriate third parties including:
our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
our auditors, legal advisors and other professional advisors or service providers;
credit reference agencies for the purpose of assessing your credit score where this is in the context of us entering into a contract with you or the person that you work for.
In relation to information obtained via our website:
our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy;
analytics and search engine providers (including A/B testing tools) that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.
Other disclosures we may make
We may disclose your personal data to third parties:
If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of M-Elite, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
What are the legal grounds for our processing of your personal data?
The legal basis on which we process your personal data is as follows:
Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned (see below for how to withdraw your consent at any time).
Otherwise, we will process your personal data where the processing is necessary:
for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
for compliance with a legal obligation to which we are a subject; or
for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data (most circumstances in which we process your personal data in relation to a relationship that we have with the person that you work for will fall into this category).
Where do we process personal data?
The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of orders, the processing of payment details and the provision of support services.
All personal data processed by is stored securely. Any payment transactions will be encrypted using appropriate technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or systems, 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 website and 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.
How long do we process personal data for?
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.
What are your rights?
You have the following rights in relation to personal data relating to you that we process:
You may request access to the personal data concerned (please see the section on obtaining access to your personal data, below).
You may request that incorrect personal data that we are processing be rectified.
In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time, after which we shall stop the processing concerned.
If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal compliant with the Information Commissioner.
How to withdraw your consent to processing
You can withdraw your consent to any relevant processing of personal data:
By emailing us at [firstname.lastname@example.org]
How to exercise your right of access to your personal data
You can exercise your right of access to your personal data:
By emailing us at [email@example.com] By writing to us at the address below.
Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.
Our details – contacting us
Changes to this policy
Date of this policy
This policy was last updated on 24.05.2018