Privacy Statement

The Refill Larder Privacy Statement (also known as a Fair Processing Notice –FPN)

Introduction
As a business we hold individuals privacy and data protection in high regard. We have never and will not sell information to third parties for marketing purposes.

This Privacy Statement sets out how we ensure information received by us is processed lawfully, appropriately and in line with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

Terms used in this statement
We receive and process data from a range of data subjects, including: customers, suppliers, job applicants and general enquiries.

Personal Data is Information from which a living individual can be directly or indirectly identified.

Processing is considered to be any activity that involves the use of personal data. It includes: obtaining, recording or holding data. Also carrying out any operations on the data including: organizing, amending, retrieving, using, disclosing, erasing or destroying it.

We ensure that data processing is…

In line with the Data Protection Principles
We will ensure that the data we store is:
1. Processed fairly, lawfully and in a transparent manner
2. Collected for specified, explicit and legitimate purposes and any further processing is completed for a compatible purpose.
3. Adequate, relevant and limited to what is necessary for the intended purposes.
4. Accurate and where necessary kept up to date.
5. Kept in a form that permits identification for no longer than necessary for the intended purposes.
6. Processed in line with the individual’s rights and in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage using appropriate technical or organisational measures.
7. Not transferred to people or organisations situated in countries without adequate protection and without firstly having advised the individual.

Fair and lawful
In accordance with the Data Protection Act 2018 and the GDPR we will only process personal data where it is required for the following lawful purposes:
· When it is necessary for performing a contract for the individual
· For compliance with a legal obligation
· In the legitimate interest of the business
· When the individual has given their consent

In line with Data Subject’s Rights
As a data subject you have the rights to:
1. Confirmation as to whether or not personal data concerning the individual is being processed
2. Request access to any data held about them
3. Request rectification, erasure or restriction on processing of their personal data
4. Lodge a complaint with a supervisory authority
5. Data portability
6. Object to processing, including direct marketing
7. Not be subject to automated decision-making including profiling


Changes to this statement
Our Privacy Statement may change from time to time. The amended version will be published on our website and any significant changes will be communicated to you either on the website or directly. This will replace any previous privacy statement.

Data Controller
The Refill Larder Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy statement).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this statement, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.

CONTACT DETAILS
Our full details are:

The Refill Larder
contact@refill-larder.co.uk
Full name of legal entity: The Refill Larder Limited

Name or title of Data Protection Officer: Kate Chesshyre

Postal address: 122 High Street, Teddington, TW11 8JB

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.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.