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Privacy Policy

Little & Cull is committed to safeguarding the privacy of our website users.  This privacy notice explains our collection, use, retention and protection of your personal data.

This privacy notice applies to all Little & Cull Limited/Tom’s Pies website users and any application, service or tool where this privacy notice is referred or referenced regardless of how you access or use them, including through mobile or tablet devices.

This policy applies where we are the data controller with respect to your personal data and where we determine the means and purpose of processing your personal data.

We also use cookies on our website which may or may not be strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you visit our website.

Our website uses privacy controls which determine what personal data we collect from you, and how that personal data is processed.  By using our privacy controls, you can decide if you wish to receive to receive forms of direct marketing. If you agree to receive direct marketing from us, you can choose to opt out at any point by emailing marketing@toms-pies.co.uk

Personal data we collect

We collect personal data from you and any devices you use when you register for an account with us, provide us with information on a web form, update or add information to your account or when you correspond with us.

Some of this personal data is necessary for us to keep you informed of our products and services, and is necessary for you to do business with us.

If you are providing data to us on behalf of another individual, you must ensure they have been provided with a copy of our privacy policy.  If you are under the age of 16, please do not provide us with any of your information unless you have the permission of your parent of guardian to do so.

Personal data is information relating to an identifiable person, the following information may be collected about you on our website:

Contact details – Name, address, telephone numbers, email addresses

Website and communications usage – How you use our website, including information collected through cookies and other tracking technology.

Credit and anti-fraud information – Including information about transactions, requests for credit and non-payment of debts with us and third parties and credit ratings from credit reference agencies.

If you opt in to our services or transact with us, we may collect this or other personal data from you.

How we use your personal data

We use your personal data  collected from you for a range of different business purposes and according to different legal basis of processing.  Under EU data protection laws (GDPR), the use of personal data is permitted on the basis of certain legal principles, our main uses of your personal information are as follows:

Marketing and customer servicing

We use your personal information for customer servicing, where necessary with your consent to do so.  In order to ensure you receive relevant information about our products, we will use your personal data to provide you with information about these products and the company in general.

Product sales

When you place an order with us either via the website, through an emailed order or through our contact centre, we will use your personal data in order to process the sale and to notify you of any relevant information in relation to that sale.  We may also collect personal information that is necessary to take payment for an order placed with us.

Customer credit account

When applying for a customer account for either Little & Cull or Tom’s Pies products, we will assess your eligibility for a credit account.  We may use this information with credit agencies to help us decide whether to offer you a credit facility for purchases. Using this information about you is necessary for us to  make a decision, if you fail to provide it, we may not be able to provide you with our products.

If you would like information on how this will be used by us, credit reference agencies and fraud protection agencies, including your rights in relation to that information, or would like to obtain details of the credit reference and fraud prevention agencies, please visit www.experian.co.uk

Compliance with legal requests

We may be legally required to provide your information to law enforcement agencies, regulators and courts and third party litigants in connection with proceedings or investigations anywhere in the world.  Providing this reason is lawful and where permitted to do so, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Legal principles for processing of your personal data

The use of personal data is permitted under EU data protection law (GDPR) on the basis of the following legal principles:

  1. Where you have provided us with your consent to the use your personal information either  by way of a consent form, through a telephone conversation with us, by sending an email or by writing to us at:Little & Cull Limited
    Heathfield Farm
    Oil Mill Lane
    Clyst St Mary
    Devon
    EX5 1AN

You may withdraw your consent at any time by contacting us on 01395 239000 or emailing marketing@toms-pies.co.uk

  1. Where it is necessary to enter into or perform a contract with you.
  2. Where we need to use personal information in order to comply with our legal obligations.
  3. Where Little & Cull/Tom’s Pies use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include promoting the Little & Cull/Tom’s Pies products, offering news details of the company, research and development of our products, assessing your credit performance, and detecting fraud and illegal activities).
  4. Where necessary for us to defend, prosecute or make a claim against you, us or a third party.

There may be uses that are permitted on the basis of other grounds and where this may be the case we aim to identify and communicate it you as soon as possible after becoming aware of the new basis.

Transfer to third parties

Personal data which we collected may be transferred to third parties on your behalf, only with your consent.This will only be shared in a secure manner, using a consistent security protocol.  When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement.

Who we share your personal data with

Little & Cull is based within the EU and your personal data may be accessed by our staff insofar as is reasonably necessary for the purposes, and on the legal basis, set out in this policy.We may disclose your personal data to our insurers and professional advisers insofar as is reasonably necessary for the purposes of maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out of court procedure.

Financial transactions relating to purchases on the website or other means may be handled by our payment services providers (Sage Pay).  We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.  You can find information about the payment services providers’ privacy policies and practices at https://www.sagepay.co.uk/policies/privacy-policy

In addition to the specific disclosures of personal data set out above, we may disclose your personal data where such  disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another individual.  We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out of court procedure.

How long do we keep your personal data for

Personal data will only be kept for as long as is necessary and our retention policies are designed to ensure that we comply with our legal obligations in relation to retention and deletion of your personal data.

We will retain your personal information as follows:

Marketing use – we retain personal data for as long as necessary but only for the purposes that we collected it for.  You retain the right to remove this consent at any point in time.

Contract – In relation to a contractual obligation we may retain that personal information whilst the contract remains in force and for as long as our legal and statutory obligations require.

In some cases it is not possible for us to specify the period for which your personal data will be retained, but this will generally be limited to retention that is necessary to comply with our legal obligations to which we are subject, or in order to protect your vital interests or the vital interests of another individual.

How do we keep your personal data safe

We use a variety of security measures to help maintain and protect the security and integrity of your personal information.  Although data transmitted across the world wide web cannot be guaranteed as secure, once data is captured by us, our internal procedures are robust and we work hard to protect data in accordance with the applicable data protection requirements.

Your rights over personal data

Your principle rights under data protection laws are as follows:

  • The right to access
  • The right to rectification
  • The right to be forgotten
  • The right to restrict processing
  • The right to object to processing
  • The right to data portability
  • The right to complain to a supervisory authority
  • The right to withdraw consent

You have the right to confirm whether or not we process your personal data and where we do, access to that personal data.  You may also access details of the purpose of the processing of your information, the categories of personal data and recipients of your personal data.

Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data, this may incur a reasonable fee and requests should be made in writing to:

Little & Cull Limited
Heathfield Farm
Oil Mill Lane
Clyst St Mary
Devon
EX5 1AN

You have the right for any inaccurate data to be amended and for any incomplete data about you to be completed.

In some circumstances you have the right to erasure of your personal data.  Those circumstances include where personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed, you withdraw consent to consent based processing, you object to processing under certain rules of applicable data law, the process is for direct marketing and the personal data has been unlawfully processed.

There are exclusions to the right to erasure where processing is necessary for exercising the freedom of expression and information, for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Amendments to this policy

We may update this policy from time to time by publishing a new version on our websites.