Privacy Policy

Introduction

This policy (together with our Terms of Use) applies to:

• Your use of our website
• Your orders of products through our website
• Our processing of your personal data more generally

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Winters Family Farm is the controller and is responsible for your personal data (we, us, or our).

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 26 June 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email.

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 our relationship with you.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows: 

• Identity Data.
• Contact Data.
• Device Data.
• Content Data.
• Usage Data.
• Profile Data.

We do not collect any financial information from you (e.g. any bank account or debit/credit card details).

We also collect, use and share aggregated data such as statistical 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. 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.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity and Contact data) you provide to us when creating an account with us, or by corresponding with us (for example, by email). It includes information you provide when you register to shop on our website, and when you raise queries or provide feedback. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device.Each time you visit the website we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy below for further details.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the website, to allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to provide you with a good experience when you use the website and also allows us to improve the website for example, by ensuring that users are finding what they are looking for easily.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter or have entered 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.

Purposes for which we will use your personal data

• We will use your Identity, Contact and Device data to register you as a user of the website for the purposes of any order of products that you make.  The lawful basis for processing such data is that it is necessary for our legitimate interests (to verify new users and keep records of orders made by users).
• We will use your Identity, Contact, Device and Profile data to manage our relationship with you including notifying you of changes to the website or on updates on your orders.  The lawful basis for processing such data is: (a) performance of a contract with you; (b) it is necessary for our legitimate interests (to keep records updated and to analyse customer orders of our goods and products) and; (c) necessary to comply with legal obligations (to inform you of any changes to our terms and conditions). 
• We will use your Identity, Contact, Device and Profile data to email you about our products, events, promotions and other activities that may be of interest to you. The lawful basis for processing such data is that it is necessary for our legitimate interests (marketing to existing and past customers). However, at any time you may opt-out of such communications by emailing us, and we will process your request as soon as possible. 
• We will use your Identity, Contact and Device data to administer and protect our business and our website including troubleshooting, data analysis and system testing.  The lawful basis for processing such data is that it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).

Disclosures of your personal data

We may share your personal data with our affiliated businesses and persons, including our business partners and our suppliers. Examples of such suppliers include webhosting companies and IT services providers. Such third parties will be subject to appropriate contractual safeguards.

If we sell or buy any business or assets we may also disclose or transfer personal to the prospective seller or buyer.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to order goods and products from our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Data retention

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

• 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.
• 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.
• 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.
• 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:

1. if you want us to establish the data’s accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3.  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; or
4. 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 where we used the information to perform a contract with you.

You can exercise any of these rights at any time by contacting us at info@blackangusbelgium.be . 

Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Description of categories of personal data

• Identity Data: username or similar identifier.
• Contact Data: name, billing and shipping addresses, email address.
• Device Data:information about how you interact with our website including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the Unique Device ID (UDID), IP address, cookie information, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device settings, and software data.
• Content Data:includes information stored on your Device, including login information, photos, videos or other digital content.
• Profile Data: includes your username and password, comments, feedback and survey responses.
• Usage Data: includes details of your use of our website including, but not limited to the type of content that you view and the frequency of activity.