Last updated: 07/06/2019
Food Drop Limited, registered number: 10781956 (“us”, “our”, “we” “Food Drop”) is the controller of your personal data collected through our Applications. Food Drop is committed to protecting and respecting your privacy.

1.         Introduction

This privacy policy (the “Privacy Policy”) sets out the types of personal data we collect and how we may manage that data when you use:
 (i)        our mobile application called “Food Drop” or related applications (the “Food Drop App”);
(ii)        our platform offered to our trusted partners via our Website, or any other products or services provided via our Website (the “Platform”); and/or
(iii)       our website www.fooddrop.co.uk (“Website”).

(together, (i), (ii) and (iii) are henceforth known as the “Applications”).

For ease of reading, we have divided this Privacy Policy into several sections:

1.         Introduction
2.         What information can we collect?
3.         How is your personal data collected?
4.         How and why do we use and/or share your personal data?
5.         For how long do we keep your personal data?
6.         Security
7.         International Data Transfers
8.         Your Rights
9.         Contact Details

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notices that we may provide or display on any of the Applications at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.

This Privacy Policy supplements other notices on our Applications and is not intended to override or replace them.  

By visiting or otherwise using our Applications, you agree to their respective terms (as amended from time to time) and this Privacy Policy.  If, for any reason, you do not agree to the terms of this Privacy Policy, please stop using our Applications.

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavour to let users of our Applications know. However, it is your responsibility to check this Privacy Policy before you use any of our Applications.

Our Applications are not intended for children and we do not knowingly collect personal data relating to children.  

2.         What information can we collect?

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

What types of data we collect from you when you use the Applications?

The personal data we collect from you depends upon the Applications you are using.

Where you are a visitor of our Website, we may collect the following types of data:

•           Technical Data which includes your IP address and browser type and version.
•           Usage Data which includes information about how you use the Website.
•           Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties.

Where you are a user of our Platform, we may collect the following types of data:

•           Identity Data which includes your full name, your place of work and your position at work.
•           Contact Data which includes your e-mail address and work phone number.
•           Financial Data which includes your bank account and payment card details.
•           Transaction Data which includes details about payments to and from you.
•           Usage Data which includes information about how you use the Platform.
•           Profile Data which includes your username and password and your feedback.
•           Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties.

Where you are a user of the Food Drop App, we may collect the following types of data:

•           Identity Data which includes your full name and date of birth.
•           Contact Data which includes your email address and mobile number.
•           Device Data which includes the type of mobile device you use, a unique device identifier mobile network information and your mobile operating system.
•           Food Drop App Data which includes information about your compliance with Food Drop App’s code of conduct or any other feedback we receive concerning your use of the Food Drop App.
•           Profile Data which includes your username and password.
•           Usage Data which includes information about how you use the Food Drop App.
•           Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties.
•           Location Data which includes your current location disclosed by GPS technology.

What happens if you fail to provide personal data?

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, provide you with our Platform where you are a partner retailer and you remove your Financial Data). In this case, you may not be able to access the Food Drop App, or we may not be able to provide you with a Product, or we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.

3.         How is your personal data collected?

Information you give to us

When you: register an account with us, purchase our services made available to you via the Platform, complete a form, request marketing be sent to you, participate in social media functions, interact with us or other users of the Applications via a function enabled by any of the Applications, contact us by email or by post or report a problem with any of the Applications, we may collect, store and use the personal data that you disclose to us.

It is important that the personal data we hold about you is accurate and current. If you want to update the information you have previously given to us, please contact us.

Automated technologies or interactions

Each time you use our Applications we will automatically collect your personal data including Device Data, Technical Data and Usage Data.  We collect this data using technologies such as cookies or other similar tracking technologies.

We use this data for several different reasons. Firstly, we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and audience participation across our Applications. We undertake both of these activities because we have a legitimate interest in doing so.

Please refer to our Cookies Policy for further details.

Location Data

Where you are a user of the Food Drop App, we also use GPS technology to determine your current location. The Food Drop App requires your Location Data in order to provide you with its essential features. You can withdraw your consent at any time by disabling your Location Data in your settings.

Third parties or publicly available sources

We may also receive personal data about you from various third parties, and public sources, such as: analytics providers, advertising networks and search information providers.

4.         How and why do we use and/or share your personal data?

Lawful basis for processing your information

We will only use your personal data when the law allows us to.  Most commonly we will use your personal data in the following circumstances:
•          Where you have asked us to do so, or consented to us doing so;
•          Where we need to do so in order to perform a contract we have entered into with you;
•          Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
•          Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.

Activity
Examples of the types of personal data we may collect
Lawful basis for processing
Users of the Website
To deliver the Website to you
Usage Data and Technical Data
Performance of a contract with you (to provide you with the Website in consideration for your compliance with the Website terms of use and supplemental policies)
To administer and protect the Website (including troubleshooting, data analysis and system testing)
Usage Data and Technical Data
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To use data analytics to improve the Website
Usage Data and Technical Data
Necessary for our legitimate interests (to grow our business)
To deliver personalised content and advertisements to you.
Usage Data, Technical Data and Marketing and Communications Data
Users of the Platform
Necessary for our legitimate interests (to grow our business)
To register you as a new user
Identity Data and Contact Data
Performance of contract with you
To process and deliver your order including managing payments, and collecting money owed to us
Identity Data, Contact Data, Financial Data and Transaction Data
Performance of contract with you
To manage your account as you use the Platform
Identity Data, Contact Data, Profile Data, Usage Data and Marketing and Communications Data
Performance of a contract with you
To administer and protect our business and our Platform (including troubleshooting, data analysis and system testing)
Identity Data, Contact Data and Technical Data
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To use data analytics to improve the Platform
Usage Data and Technical Data
Necessary for our legitimate interests (to develop our Platform and grow our business)
To deliver personalised content and advertisements to you.
Identity Data, Contact Data, Profile Data, Usage Data and Marketing and Communications Data
Necessary for our legitimate interests (to develop our Platform and grow our business)
Users of the Food Drop App
To install the Food Drop App and register you as a new app user
Identity Data, Contact Data and Device Data
Your consent
To manage your account with us and enable the services provided via the Food Drop App
Identity Data, Contact Data, Device Data, Food Drop App Data, Profile Data, Usage Data, Location Data and Marketing and Communications Data
Your consent

Performance of a contract with you
To monitor your behaviour whilst you use the services enabled by the Food Drop App
Food Drop App Data and Location Data
Your consent  Performance of a contract with you
To administer and protect our business and the Food Drop App (including troubleshooting, data analysis and system testing)
Identity Data, Contact Data and Device Data
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To use data analytics to improve the Food Drop App
Usage Data and Device Data
Necessary for our legitimate interests (to develop our Food Drop App and grow our business)
To deliver personalised content and advertisements to you
Identity Data, Contact Data, Device Data, Profile Data, Usage Data, Marketing and Communications and Location Data
Consent

Necessary for our legitimate interests (to develop our Food Drop App and grow our business)

Marketing

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services, products and/or promotional offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have:

• subscribed to receive marketing communications from us; or
• requested information from us or purchased our services via the Platform, or downloaded the Food Drop App, and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we sell your personal data to any third party for its own marketing purposes.

Opting Out of Marketing 

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email, or you can also contact us

Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:

• we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006; 
• with selected third parties who we sub-contract to provide various services and/or aspects of any of the Application’s functionality, such as where third-party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below); and
• with analytics and search engine providers that assist us in the improvement and optimisation of our Applications as described above.

We may also disclose your personal data to third parties in the following events: 

• if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that sale; 
• if Food Drop or some of its assets are acquired by a third party, in which case personal data held by us about our 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 if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or 
• in order to enforce or apply our Applications’ terms of use or terms and conditions; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.  The following is a list of our major service providers:

• Analytics Provides;
• Payment Processors;
• Website or Application Developers; and
• Marketing Communications Providers. 

Links to third-party sites 

Our Applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you enter a third-party website, we encourage you to read their privacy policy.  

5. For how long do we keep your personal data?

We will hold your personal data on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

In some circumstances you can ask us to delete your personal data: see the Your Rights below for further information.

In some circumstances we may 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.

6. Security

Food Drop App takes the protection of your information very seriously. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers and passwords. Where we have given you a password that enables you to access certain parts of our Applications you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. International Data Transfers

Whenever we do transfer your personal data outside of the European Economic Area (“EEA”), we ensure that a similar degree of protection is afforded to it by ensuring that in most cases at least one of the following safeguards is implemented: 

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• we will only transfer data to the US, where the business we are transferring your personal data to is part of the Privacy Shield (which requires them to provide similar protection to personal data shared between Europe and the US); and
• where you we use certain service providers, we will use specific contracts approved by the European Commission which gives personal data the same protection it has in the EEA. 

By submitting your personal data, you agree to the terms of such transfers. If you would like more information about the mechanism via which your personal data is transferred, please contact us.

8. Your Rights

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request"). 

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
 
You can exercise this right at any time by writing to us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request. 

You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the sections of this Privacy Policy which explains how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party, we are happy to consider such requests.

Your Right to object to processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data.  We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to withdraw consent at any time

You may withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you. 

Exercising your rights

When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information (and where this is the case, we will tell you).

9. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing [email protected].  You may also lodge a complaint with our lead supervisory authority, the Information Commissioner, or you may lodge a complaint with your local supervisory authority about any aspect of our handling or processing of your personal data.  We would, however, appreciate the chance to address your concerns before you approach any supervisory authority, so please contact us in the first instance. 

Need more information? Contact us here!