Last updated: 22nd October 2024
Fresh Teched Limited (also referred to in the policy as “we“, “us“, “our”) are committed to protecting and respecting your privacy. We are the data controller for Personal Data that we collect about you.
This policy explains how we use any Personal Data (as defined below) we collect from you or that you provide to us when you visit our platform accessible on our website, www.FreshDirectory.co.uk, buy products on our platform, use services related to the platform (such as delivery services), contact us or otherwise engage with us (together the “Services“).
Please read this policy carefully. You should also review our [Website Terms of Use] and [Consumer Terms] to understand other aspects of our relationship with you.
This policy covers:
- Personal Data we collect about you
- Personal Data you give us
- Personal Data we receive about your use of the Services
- Personal Data we may receive from other sources
- How we use your Personal Data
- Lawful basis for processing Personal Data
- Cookies and other technologies
- Links to other websites
- Who we share your Personal Data with
- Processing your Personal Data outside the UK and the EEA
- How we protect your Personal Data
- How long we keep your Personal Data
- Your rights
- Changes to this policy
- Contact us
Personal Data we collect about you
When you use our Services, engage with us through social media channels or online adverts, or otherwise engage with us, we collect information from you including Personal Data. Personal Data means information from which you may be identified both directly (from that information alone) and indirectly (when different pieces of information are combined).
We may collect and process the following Personal Data from you in the following ways:
Personal Data you give us
- Identity information: We collect your first name, last name, marital status, title, date of birth. We use this to identify who is using our Services, ensure the relevant order is delivered to the correct person and verify your age when purchasing age restricted items.
- Contact information: We collect your delivery address (including your approximate longitudinal and latitudinal coordinates when you use our pin-drop functionality), billing address, email address and telephone numbers. We use this information to identify your delivery location, correspond with you, including providing updates about your order, responding to complaints and enquiries, and to send you marketing emails, or where you otherwise correspond with us.
- Account information: If you register for a customer account with us, we will collect your name, contact information, chosen username/login, your chosen password, security question response and other registration information such as your date of birth, your interests, preferences. Certain login information may also be generated by us, such as a unique customer number which we assign to your account.
- Marketing and communication information: We collect your preferences in receiving marketing from us and our third parties and your communication preferences.
- Feedback information: We collect personal information you provide to us when you fill-out a customer survey, provide your feedback, leave a review, make a complaint, or otherwise correspond with us – this may include the categories of Personal Data mentioned above.
- Retailer information: If you are a business customer representing a retailer, we will collect your ‘Identity information’, ‘Contact information’, details of which retailer you represent, any ‘Feedback information’ you provide to us, and other information required to provide our services to you and to fulfil our contractual obligations to you.
If you reach out to us via a third party, for example, if you send us a direct message on a social media platform, we may also collect your name and information related to your social media profile which is visible in the message. We will only be able to see the information which you have selected can be displayed to us. Please consult your social media profile settings for more details.
When we take a payment from you, we don’t process your financial information. This is handled by a third party, but we may be provided with some parts of your financial information related to the transaction such as the last four digits of you card and your billing address. We will not be able to fulfil your order unless you provide certain payment related information.
We will indicate whether information including Personal Data is required by the Services.
Personal Data we receive about your use of the Services
- Technical information: such as the Internet Protocol (IP) address used to connect your device to the Internet, browser type and version, browser plug-in types and versions, operating system, your device make and model. As well as the content of a request we also receive information associated with the request such as time zone setting, date and time and http status code associated with your device.
- Usage information: information about your use of the Services including the full Uniform Resource Locators (URL), clickstream to, through and from our Services (including date and time), products and content you viewed or searched for, content response times, download errors, length of visits to certain content, interaction information (such as scrolling, clicks, and hover-overs), time and date of orders and methods used to browse away from content.
- Location data: We may derive your approximate regional location from your IP address. We do this in order to localise our Services to you, and make sure the products and services displayed to you are accurate for your location as some products and services may not be available in all locations.
- Order information: We collect details of the items you have ordered in order to process your order and to run internal analysis against these, such as identifying customer trends. We will generate a unique order ID associated with your purchase.
For more information about how we process this information, please see our Cookies and other technologies section.
Personal Data we may receive from other sources
- Social media information: If you interact with us through third party sites, such as social media platforms (e.g. Facebook, Instagram, TikTok, Pinterest, X), we may collect Personal Data from you. For example, if you tag us in a social media post or otherwise interact with our social media adverts, accounts and posts (for example, by liking or providing a comment on our post on a social media platform), we may collect Personal Data such as your social media profile name and picture, as well as the pictures or content you post (including likes and reactions to your posts). We will only be able to see the content you post to your social media account if your profile is set to “public” or if we are “following” you. The Services may also allow you to share via social media channels and other tools, for example, social media “Like” or “Share” buttons. This allows you to share how you interact with our Services and allows us to understand your engagement with our us, for example, which features of our content, and products, are most popular.
- Third-party log-in information: You may choose to register an account with us using a third-party login, such as Facebook or Google. You don’t have to do this if you want to register with us but if you do, we will collect details from the third party account, including your profile name, name associated with that account, and profile picture. We use this information to create and administer your account with us.
We may also receive your Personal Data from third party providers and partners which we work with, including our advertising partners and networks. For more information about how we process this Personal Data, please see our Cookies and other technologies section.
How we use your Personal Data
Lawful basis for processing Personal Data
We process your Personal Data where we have a lawful basis under UK and European data protection law for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interests of others.
Where we need your Personal Data to fulfil a contract with you (or take steps to fulfil that contract) if you do not provide some Personal Data we may not be able to progress or fulfil that contract with you.
“Legitimate interests” is a legal term used in UK and European data protection law. When we rely on legitimate interests, we mean in pursuing our own interests we have considered your rights and interests at the same time and concluded that these are not overridden by your rights.
If we rely on your consent to process your Personal Data, we will ask for this before processing.
Below we set out in a table format, a description of all the ways we plan to use the various categories of your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interest are where appropriate.
Purposes for which we will use your Personal Data
| Purpose/Use | Type of data | Legal basis |
| To register you as a new customer |
|
Performance of a contract with you for the provision of the Services. |
| To process and deliver your order including payments |
|
Performance of a contract with you to provide the Services to you and products you have ordered. |
| To register and offer services to a retailer |
|
Performance of a contract with you to offer your products for sale on our platform. |
To manage our relationship with you which will include:
|
|
Performance of a contract with you for the provision of the Services.
Necessary to comply with a legal obligation, for example our obligation to notify you about changes to this Policy.
Necessary for our legitimate interests (to keep our records updated and manage and maintain our relationship with you and resolve queries you may have). |
| To send you relevant marketing communications (including emails about offers, new products and services), and make personalised suggestions and recommendations to you about goods or services that may be of interest to you. |
|
Necessary for our legitimate interests (to carry out direct marketing, develop our Services and grow our business).
Consent, having obtained your prior consent to receiving direct marketing communications. |
| To administer and protect our business, platform and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation exercise).
Necessary to comply with a legal obligation concerning security of the website and platform and the Personal data processed in offering the Services. |
| To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you. |
|
Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy). |
| To use data analytics to improve our website, products/services, customer and retailer relationships and experiences and to measure the effectiveness of our communications and marketing. |
|
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
| To carry out market research through your voluntary participation in surveys. |
|
Necessary for our legitimate interests (to study how customers use our Services and to help us improve and develop our Services). |
Cookies and other technologies
We use cookies and other similar technologies to collect and store certain information about you which includes Personal Data. These technologies include cookies, pixels, web beacons and JavaScript (together “Cookies“), typically involve storing pieces of information or code transferred to or accessed from your device to store and, sometimes, record information about your interaction with online services from your device.
Cookies and similar technologies enable you to be remembered when using that device to interact with online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content. They allow us to distinguish you from other users of our Services which helps us to provide you with a good experience and also allows us to improve our Services and see how they are performing. Cookies also allow us to secure areas of our Services, remember items in your shopping basket, deliver your preferences and personalised content and deliver ads to you online.
A number of Cookies and similar technologies we use last only for the duration of your online session and expire when you close your browser. Others are used to remember you when you return to our Services and will last for longer. Some Cookies will also record where you came to our Services from and where you visit once you have left. We use Cookies and/or other similar technologies, either alone or in combination with each other, to create a unique ID which corresponds to you.
When you first interact with our Services, you will be notified that we use Cookies, and we will ask for your consent to use non-essential Cookies. This banner will also allow you to decide which non-essential Cookies you want to accept. We also give you information about how to disable Cookies below. Where you change your browser settings to generally disable all Cookies, you may not be able to take full advantage of our Services; some aspects may not work without some Cookies being used.
We use these Cookies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), or where you have consented to their use.
We use the following types of Cookies:
| Types of Cookies | Purpose of these Cookies |
| Essential Cookies | These are Cookies that are required for the operation of our Services and under our terms with you. They include, for example, Cookies that enable you to log into secure areas of our Services, use a shopping basket, and to take steps to deliver our products and services to you. If you disable these Cookies, certain features of the Services may not work. |
| Functionality Cookies | These are used to recognise you when you return to our Services. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region). |
| Analytical/performance Cookies | These allow us to recognise and count the number of visitors and to see how they engage with our online Services, including specific content and features. This helps us for our legitimate interests of improving the way our website works (for example, by ensuring that users are finding what they are looking for easily). |
| Targeting/advertising Cookies | We may work with advertising networks that gather information about the content you have accessed on our Service you visit and on other websites and services you visit. We may also share this Personal Data with third parties for this purpose. This may result in you seeing advertisements on our Services and/or our advertisements when you visit other websites and services of third parties. |
| Social media Cookies |
These are Cookies managed by third party social media companies. They help us manage our social media, including enabling you to share content and enabling us to understand how you interact with us. We will use this Personal Data subject to your choices and preferences to improve and support our Services. We may also share this Personal Data with third parties for this purpose. These Cookies may also inform our advertising campaigns on social media and on other sites (for example, by providing you ads with products and services which we think may be of interest to you). |
We work with the below third-party providers to deliver Cookies:
- [Google Analytics, DoubleClick and AdWords] – we use Google Analytics to distinguish visitors to our Services, to measure traffic on Services, deliver a secure service and ensure that we can deliver our content to you. We also use Google Cookies to deliver our ads to you. This also helps us understand the high-level demographics of visitors to our Services and helps us understand how many users click on our ads, go on to buy our products, etc. Your Google preferences may also be stored by these Cookies, for example, preferred language and number of search results you see per page. We also use Google to help determine how ads perform within certain market segments. You can learn more here including about how to opt-out at the below links:
- [Segment.com] – we use Segment.com to serve Cookies to improve our understanding of how users interact with the Services– more information can be found at https://segment.com/docs/legal/privacy/.
- [Count.ly] – we use Count.ly to understand how users interact with our Services. We use this information to compile reports to understand how the Services is used so that we can make improvements https://count.ly/legal/privacy-policy.
- [Facebook] – we use Facebook Cookies and pixels to help deliver our advertising on Facebook. This means you may see our ads when you use Facebook because you have visited our site and then visited Facebook. These Cookies also tell us if you come to our site after having clicked on an advert on Facebook. We also work with Facebook to deliver our ads to Facebook users who match against certain criteria which Facebook identifies. We use other Facebook advertising services as set out below. Please visit your Facebook privacy settings to learn more and see here https://www.facebook.com/policy.php.
- [HotJar] – we use HotJar to help create market segments of customers which we think may be interested in our products. We use this information along with our advertising partners to show online advertisements to you and users who may share similar characteristics with you on other websites and apps. To learn more, please visit the “End Users” section of HotJar’s privacy policy and to opt-out visit here ]https://www.hotjar.com/legal/compliance/opt-out.
- [X] – we use X Cookies to deliver our ads on the X platform to you and to those other X users who might be interested in our Services based on their online activities including on the X platform. Please visit your own X privacy settings to configure how ads are displayed to you and also see here https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.
You may choose to disable some Cookies. The effect of disabling Cookies depends on which Cookies you disable. As set out above, if you disable all Cookies, certain features of our Services may not work, and you may be unable to complete a purchase on our Services. You will have already had the opportunity to reject Cookies when you first arrived at the Services but if you want to update your choices at any time, you can access and update your existing cookie preferences via our consent management tool at [INSERT HYPERLINK TO TOOL].
Links to other websites
Our Services may, from time to time, contain links to external websites, plug-ins and applications including social media platforms such as Facebook and Google. This policy does not apply to such third-party services, and we are not responsible for the privacy policies or practices or the content of any third party. Please review third-party privacy policies and, where applicable, your privacy settings of such third parties. We provide more information about Personal Data we may collect through third parties above including information we may receive as a result of your engagement with social media channels.
Who we share your Personal Data with
We may make Personal Data available to:
- Organisations who process your Personal Data on our behalf and in accordance with our instructions. This includes supporting our services, in particular data hosting services, fulfilment services, communications providers, fraud detection services, advertising services, marketing services, facilitating feedback on our Services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your Personal Data to the extent necessary to perform their support functions.
- Analytics and search engine providers that assist us in the improvement and optimisation of our Services and advertising and are subject to our Cookies policy.
- Retailers that offer their items for sale on our platform. We will only share personal data with such retailers to the extent necessary to provide the Services. We may also share aggregated trend data about customers’ use of the site and/or purchases so that retailers can improve their offering on the platform.
- Other third parties such as retailers that offer their items for sale through our platform, professional advisors, including banks, accountants, and lawyers.
- Payment processing providers who provide secure payment processing services. Note, as above, your payment card details are not shared with us by the provider.
- Retailers that we work with on joint campaigns (for example, to run specific promotions).
We will also disclose your Personal Data to third parties in the event that:
We sell our business or assets; in which case we will disclose your Personal Data to the prospective buyer of such business or assets subject to the terms of this privacy policy.
Such disclosure is required in order: to comply with legal requests, where required or legally permitted to establish, exercise or defend legal rights; in order to enforce or apply our terms of supply and other agreements with you; or to protect the rights, property, or safety of Fresh Teched, our customers, our retailers or others. This includes exchanging Personal Data with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
Payment processing
Payments are made through a payment processing provider, for example, we use Stripe. You will be providing credit or debit card information directly to such payment providers which operate a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to these third parties is not within our control and is subject to their own privacy policy and terms and conditions. For more information please see here:
- For Stripe services see here https://stripe.com/gb/privacy-center/legal and here https://stripe.com/privacy/
Processing your Personal Data outside the UK and EEA
The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (“UK“) and European Economic Area (“EEA“) that may not be subject to equivalent Data Protection Law.
Where your Personal Data is transferred to partners, suppliers, our group companies and other third parties who process your Personal Data outside the UK and EEA, including in the U.S., we will take steps to ensure that your Personal Data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, or approved standard contractual clauses for transfers, and that it is treated securely and in accordance with this privacy policy.
How we protect your Personal Data
We use technical and organisational measures to safeguard your Personal Data.
- Personal Data you provide to us in relation to the Services is stored on our secure servers.
- Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- We take steps to limit access to your Personal Data only by those who need access to process your Personal Data in accordance with this privacy policy.
- We take steps to contractually require our service providers to protect any Personal Data they process on our behalf.
How long we keep your Personal Data
We retain Personal Data:
- for as long as we are legally required or otherwise permitted to meet our reason for collection (for example, for as long as we are providing Services to you and as necessary after that to anticipate, resolve or document any issues); and
- relating to any account or transactions with us, in order to meet our contractual obligations to you and / or any purchase of products to identify any issues, resolve any legal proceedings and for tax and accounting purposes.
Child safety
Protecting the safety of children when they use the Internet is important to us. The Services are intended for use only by adults. If you are under the age of 18, you confirm you have received permission from your parent or guardian before using the Services or sending us Personal Data. By using the Services, you confirm to us that you meet this requirement.
Your rights
If you have any questions about our processing of your Personal Data, and/or want to exercise the rights listed below please contact us at any time at [email] and state “Privacy Query” in the subject line.
You have the right under certain circumstances:
- to find out what Personal Data we hold about you;
- to be provided with a copy of your Personal Data;
- to request the correction or deletion of your Personal Data;
- to request that we restrict the processing of your Personal Data (while we verify or investigate your concerns with this Personal Data, for example);
- to object to the further processing of your Personal Data; and
- to request that your provided Personal Data be moved to a third party.
Your right to withdraw consent:
Where the processing of your Personal Data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at [email] and stating “Privacy Query” in the subject line.
You can change your preferences and object to receiving further marketing at any time by checking and updating your contact details within your account if you have chosen to register with us, or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to [email] and state “Privacy Query” in the subject line.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your Personal Data, as well as deal with any complaints that you have about our processing of your Personal Data. If you are based in the EEA, you can find your supervisory authority here https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Changes to this policy
Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on the date mentioned at the beginning of it.
Contact us
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:
The Privacy Team
Fresh Teched Ltd
Spaces
Third Avenue
Marlow
SL7 1EY