Thatchers Cider Company Ltd, Thatchers Holdings Ltd, Thatchers Myrtle Farm Ltd, John Thatcher Farming, Thatchers Foundation, The Railway, (“We”) are committed to protecting and respecting your privacy.
For the purpose of the General Data Protection Regulations (GDPR), the Data Protection Lead is Head of IT, Thatchers Cider Company Ltd of Myrtle Farm, Sandford, Somerset BS25 5RA who can be contacted using the following contact details email@example.com or 01934 822862.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on our site www.thatcherscider.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
- Information we collect about you. With regards to each of your visits to our site we will automatically collect the following information (this list is not exhaustive):
- technical information, including [the Internet protocol (IP) address used to connect your computer to the Internet], [your login information], [browser type and version], [time zone setting], [browser plug-in types and versions], [operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
- Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have specifically consented to this;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. The legitimate interests that we will rely upon to process this information are:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
If we are not able to process your personal data whether because you do not consent, you withdraw or limit consent, or for any other reason then we will not be able to achieve the purposes listed above.
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- we do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1).
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
We will disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
- if Thatchers Cider Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted [using SSL technology]. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
RETENTION OF DATA
We will only retain your data for as long as we deem reasonable and for the purposes outlined above.
We will only process your data for marketing purposes where you have given express consent to us to do so or where there is a legitimate interest for us to do so. The legitimate interests that we will rely on are as listed above under “Uses made of the Information – Information we collect about you”. In any event, we will only rely on legitimate interest as grounds for processing your data where we have completed a Legitimate Interest Assessment and where such assessment supports the use of such data processing.
We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
At any time, even if you have previously consented, you have the right to ask us not to process your personal data for marketing purposes and/or not to disclose it to third parties for marketing purposes. You can do this by contacting us using the following email address: firstname.lastname@example.org You can also use this email address to notify us of any preferences you have in relation to the processing of your data, for example, the frequency of communications that you receive from us, or the manner or the subject matter of such communications.
GDPR also gives you the following rights:
- to access information held about you;
- to request the deletion or correction of information held about you;
- to object to or restrict the processing of information about you;
- to request that information about you be transferred to another person;
- to complain to the relevant supervisory authority. In the UK this is the Information Commissioner’s Office (ICO) https://ico.org.uk/ , whose contact details are as follows:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
You can exercise these rights by contacting us using the following contact details email@example.com
THIRD PARTY SITES
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
If you have any complaints in relation to how our business has processed your data or in relation to the exercise of your rights as detailed above you can in the first instance raise your concerns by contacting us as follows: Head of IT, Data Protection Lead at Thatchers Cider Company Ltd, Myrtle Farm, Sandford, Somerset BS25 5RA, email; firstname.lastname@example.org or telephone 01934 822862.
You may also contact the Information Commissioner’s Office in relation to any such complaints https://ico.org.uk/
Information Commissioner’s Office, Wycliffe House, Water Lanem, Wilmslow, Cheshire, SK9 5AF
MODERN SLAVERY STATEMENT
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps being taken by Thatchers Holdings Limited and its relevant group companies namely Thatchers Cider Company Limited and Thatchers Myrtle Farm Limited (“Thatchers Cider”) during financial year ending 31August 2017 to prevent modern slavery and human trafficking in its business and supply chains.
Thatchers Cider is very much aware that modern slavery in all its forms, forced and child labour, servitude, slavery, human trafficking and human exploitation is a growing problem in the world. Thatchers Cider has a zero-tolerance approach to all and any aspect of modern slavery and is in the process of introducing and enforcing both practical steps and administrative policies and procedures with the intention of ensuring that both our own business and that of our suppliers both comply with but also embrace the spirit of the Modern Slavery Act 2015.
We have identified that potential areas for modern slavery exist in
– the growing and supply of apples for our juice requirement.
– the growth and supply our requirements for sugar
– the manufacture or supply to us of point of sale materials which includes clothing
– Capital construction projects.
Thatchers Cider is seeking from each of our suppliers of goods and materials in those sectors written undertakings of compliance with the principles of the Modern Slavery Act 2015, and the gathering of and following up of responses is ongoing.
We are seeking to establish through terms of business with our suppliers, express rights to audit their working practices for compliance, including the working and employment conditions of their workers, and oblige them to step down compliance obligations to their own supply chain.
Within the Thatchers Cider Group itself
A total of approximately 1500 acres of fruit tree orchards in the United Kingdom are owned or farmed under contract by Thatchers Farm Limited. Despite the advent and use of modern mechanical harvesting it is acknowledged that within agriculture as a sector the risk of worker exploitation exists especially through the engagement of seasonal manual workers potentially from overseas.
We have reviewed the sources of farm labour, their working conditions and terms of employment and find no areas of concern which are suggestive of modern slavery or other exploitation in any form.
More widely, Thatchers Cider operates a group wide “whistle blowing” policy which although principally aimed at internal issues has recently been opened to our suppliers with the objective of encouraging the disclosure and resolution of modern slavery practices. The outcomes from this policy will be investigated and appropriate action taken.
Our standard terms of business and long-term contractual agreements are under review with the intention of introducing into them appropriate and relevant terms and conditions to flow down modern slavery compliance, backed up by rights to audit for compliance and require rectification.
In the absence of a dedicated Corporate Governance / Compliance Officer or HR Director, the terms of reference of the Managing Director have been extended to include modern slavery compliance issues. The Managing Director will report to the Board regularly on areas of concern and recommend appropriate action.
At Thatchers Cider we are continually looking for ways and means of improving our product offerings and we intend to bring this drive for perfection to our efforts to eliminate modern slavery practices from our business.
We recognise that we cannot be complacent and that there is more that can be done and as stated above we have a number of ongoing initiatives to complete which we look forward to reporting on in our next statement.
This statement was approved by the boards of directors of Thatchers Holdings Limited and Thatchers Cider Company Limited
Martin Thatcher – Managing Director