Bel UK Consumer Personal Data Protection Policy

The entity responsible for processing personal data for this website is BEL UK, as part of FROMAGERIES BEL SA. Before communicating your personal data to us and to give us a consent for their processing, we recommend you read this Policy on the protection of our consumers’ privacy carefully. 1. THE BEL GROUP’S COMMITMENT TO PROTECTING CONSUMERS’ PRIVACY AND PERSONAL DATA “Personal data” (hereinafter “PD”) means any information collected about our consumers who are natural persons that enables us to identify them directly or indirectly. To better meet the requirements of all our consumers and to forge a close relationship with you, the Group collects personal data in various ways. You need to be confident that the information you communicate to us and our brands is not disclosed. Our Group gives an undertaking that it will not contravene your privacy and that your personal data will be collected and retained in a totally transparent and secure way. As part of our commitment to meet your requirements, we have implemented a privacy protection policy for our customers. This Policy describes the conditions in which BEL uses your personal data. The entity responsible for processing personal data for this website is BEL UK, as part of FROMAGERIES BEL SA. 2. PERSONAL DATA PROTECTION OF CONSUMERS: THE PRINCIPLES Legitimacy: the data will be collected only for particular, explicit and legitimate purposes. Processing will not concern sensitive data (racial or ethnic origins, political, philosophical or religious views, trade union membership, health, sex life, offences, criminal convictions or security measures). Relevance and Accuracy: we ensure that the data collected are appropriate, relevant and not excessive given the purposes for which they are collected, and that they are accurate, complete, and, if necessary, updated. Transparency: when collecting your PD, you will be informed of any information regarding the collection and processing of data about you, in particular about why the data are collected. Retention limit: the PD will be retained for a period which does not exceed the period required for the purposes for which the data are collected and processed; Consent: your consent will be required before any collection of PD for purposes which will be described at the time of its collection; Access, correction, objection: at any time, you may access and request the correction or deletion of your PD. You may also object to the use of your PD. To exercise these rights, please refer to Article 11 of the Policy. Privacy & Security: The BEL Group undertakes to process your PD in a way that guarantees the privacy and security of the PD by implementing appropriate technical and organisational measures. 3. SCOPE This policy applies to all processing of the www.thelaughingcow.co.uk website and the UK websites belonging to the entities of the Bel group to which you could be redirected during your navigation: 4. PERSONAL DATA COLLECTED Depending on the type of relationship we have with you, we may need to ask you for information about yourself and/or your family members, such as: Contact information (last name, first name, telephone No, email, address etc.) Location / city Any other information necessary for us to provide the requested service (e.g. to resolve a customer service query or to enable your participation in a marketing / promotional initiative). 5. TIME OF COLLECTION Depending on the purposes for which your “PD” will be processed, the collection may take place at different times including: When your contact the consumer service (Questions, Complaints, etc.) When you take part in marketing programmes or initiatives (contests, games, subscription to newsletters, etc.) When you visit the BEL group’s websites 6. DATA COLLECTION PURPOSES Meet all your requests as regards the consumer service Improve our products, in particular, thanks to improved knowledge of your needs and wishes To provide coupons Send you newsletters, promotions or offers from partners, when you have authorised us to do so. At any time, you may unsubscribe from these newsletters by clicking on the link provided at the bottom of these e-mails; Participate in a competition, prize draw or other specific marketing initiative. Reach you with relevant advertising content on partner or publisher websites Secure and enhance your use of the BEL group’s websites (navigation, data security, etc.). To build “lookalike audiences” for media targeting with 3rd parties including Facebook and Google. See point 6.1 below for more information. 6.1 LOOKALIKE AUDIENCES Building lookalike audiences involves passing our email data to the aforementioned third parties, who build a profile of traits common to those signed up to our email marketing lists. The purpose is to enable us to target our advertising at people more likely to respond positively, to minimise wasted ad spend. Data passed to third parties in this way may only be used for this specific purpose and not for any other, by any other party There is no impact on your privacy or on the advertising you would see from any other organisation. You will not see additional advertising from us as a result of lookalike audiences as the source data used to build lookalike audiences is excluded from the targeting. We are relying on having a legitimate interest, as laid down in the GDPR, for processing your data in this way, but you may object to this usage at any time by contacting us via any of the channels mentioned in clause 11 below. 7. SHARING YOUR PERSONAL DATA As part of management of our relationship, we will transmit, or give access to your “PD” to internal and external recipients for the following purposes. Internally, to authorised staff in our entities, for the purpose of maintenance / management of the data: IT services Marketing services Externally, to the following types of company, for the following purposes: Technology providers providing a service to Bel and / or yourself – e,g, a provider of coupons like Shopmium, or an emailing marketing tool like Mailchimp Externally sourced Customer service and social media community management teams (typically the first point of contact when you contact us) Marketing agencies / suppliers managing our email marketing communications Marketing / PR agencies managing promotions/ competitions for your benefit Media owners (including e.g. Facebook and Google) , and by extension media agencies for the sake of building lookalike audiences (as per clause 6.1 above). Marketing / Consultancy suppliers for the purposes of analysing marketing performance All third parties who receive (access to) your data do so under contractual obligations not to share or otherwise abuse access to the data. They may use it for no other purpose as that directed by Bel More specific information regarding current suppliers who currently or previously have had access to your data can be provided on request We cannot provide more specific information within this privacy policy as suppliers vary over time, and the exact journey your data has taken depends on how and when you provided it to us for what purpose). We may also need to forward your information to local authorities due to a legal obligation or at the request of an administrative authority empowered to make this type of request. 8. SECURITY BEL makes every effort, by taking appropriate technical measures, to protect you against the destruction, accidental or otherwise and the accidental loss or alteration or unauthorised disclosure of or access to your “PD”. 9. COOKIES 9.1 What is a cookie? Cookies are data placed in your browsers or mobile devices. They can be distinguished by their unique identifiers, associated with your browser or device. Common uses include: Enabling anonymised website analytics Remembering your login information and other preferences (e.g. location or language) Personalising content for you based on previous visits Reaching you with advertising on other websites / platforms These “cookies” are stored in RAM in your computer. They do not allow us to identify you as an individual, they only allow the anonymous association of your device or browser with a visit (or visits) to our website(s) (date, time, pages visited etc) pages and with certain preferences (logins etc ). Cookies are non-permanent – but how long they last varies based on the type of cookie and its use.  Some might be 24 hours, others might be up to 540 days. 9.2 What do we use cookies for on this website? Analytics Cookies These cookies allow us to assess the website traffic, We use this information to: Identifying problems with the site Make improvements to the site and content Understand how digital media driving traffic to the site is performing All data gathered by analytics cookies is used anonymously : we do not know what “you” have done The specific cookies currently in use are: Google Analytics – primary analytics tool Facebook Pixel – being used ONLY for analysis of traffic driven by Facebook & optimisation of Facebook Ads. Facebook Pixel does enable retargeting of visitors to our website on Facebook, but we will not be using data collected for this purpose until we have an explicit “opt in” on site for that purpose. If you have not ticked such an option – you will not be retargeted in such a way We are relying on having a legitimate interest, as laid down in the GDPR, for automatically delivering these cookies when you land on the site, however you are still able to delete them using the instructions below. 9.3 Deleting & managing cookies You can delete or block cookies in your browser / device in the following ways: Internet explorer: http://support.microsoft.com/en-gb/help/278835/how-to-delete-cookie-files-in-internet-explorer Chrome & Android devices: http://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en Firefox: http://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored Safari or Apple devices: http://support.apple.com/en-gb/ht201265 For any other browsers or devices please refer to the appropriate support websites. 10. DATA RETAINED BY BEL In compliance with the laws in force, the PD will be retained only for the period required for the purpose for which the data have been collected and processed. We will retain your data for the following periods dependent on the type of data: Data gathered as a result of contacting customer services: Up to 2 years after last contact between us, or until you ask us to delete your information if earlier Email data & other data gathered for marketing purposes : Up to 2 years after last contact from us, or until you choose to unsubscribe if earlier. Cookies: The duration varies but the maximum duration of any cookie is 540 days, or when you choose to delete cookies from your browser / device if earlier. 11. YOUR RIGHTS REGARDING YOUR PERSONAL DATA You enjoy all the rights under the applicable legislation as regards personal data protection. In this regard, you may, in particular, at any time, request access to your “PD” collected by BEL and make a request to change them, by contacting our Customer Service using the contact details below BEL Consumer Service Address: Bel UK, 160 London Road, Sevenoaks, London, TN13 2JA Phone: 0800 030 4596 (Open Mon-Fri, 9-5) Email: BelConsumercare@uk.cpm-int.com More contact information including available social channels: https://www.thelaughingcow.co.uk/faqs-and-contact/ Similarly, if your “PD” are not accurate, complete or up-to-date, you can communicate any changes to be made to them to the above address. You can also assert your right of opposition by contacting the Consumer Service at the above address. In particular, where processing of the PD is based on your consent, you have the right to withdraw your consent at any time in order to object to any subsequent processing. All requests will be processed as soon as possible and in accordance with the applicable law. 12. PROTECTION OF PERSONAL DATA OF CHILDREN BEL considers that parents must be informed of the relationship that the company and its brands establish with their children. Therefore, the BEL group undertakes to request the electronic address of parents/guardians of web users who are under 15, when Bel is aware of that fact, in order to send them a copy of the registration email sent to their children. At any time, on simple request by contacting the consumer service, parents/guardians may have access to the personal data stored about their child and, if they wish, request that they are deleted from our databases. Similarly, parents/guardians may exercise all the rights which their child has in accordance with the rules applicable regarding personal data rights by contacting the consumer service according to the terms set out in Article 11 of this Policy. 13. UPDATES TO THIS POLICY This Policy may change periodically. If we hold contact information on you and there are relevant changes then we will inform you.

1. Bel UK’s Commitment for Privacy

1.1  To best meet our consumers’ expectations and forge with them the strongest links possible, Bel UK Ltd (“We”, “Our” or “Us”) are often led to collect personal data. Consumers must be assured that we take the best care to guarantee the confidentiality of personal information exchanged between our group companies.

1.2 We are committed to protecting and respecting your privacy. We undertake not to violate your privacy and ensure full transparency and security while collecting and storing your personal data. As a part of this commitment, we have implemented a policy on processing our consumer’s personal data.

1.3  For the purpose of the Data Protection Act 1998 (the Act), the data controller is Bel UK Ltd of 160 London Road, Floor 2 Suite 1, Sevenoaks, Kent TN13 2JA.

2.  Consent

2.1  The term “personal data” must be understood as any collected information relating to an individual that enables us to identify our consumers directly or indirectly.

2.2  This policy (together with our terms of use https://www.thelaughingcow.co.uk/terms-conditions/  and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

2.3  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://www.thelaughingcow.co.uk/  (our site) you are accepting and consenting to the practices described in this policy.

3.  Principles for protection of personal data

3.1 Legitimacy: the data will be collected for specific, explicit and legitimate purposes. Processing will not involve sensitive data (e.g. racial or ethnic origin, political, philosophical or religious opinion, union membership of persons, health or sex life, offences, sentences and security measures).

3.2 Relevance: collected data will be suitable, relevant and non-excessive with regard to the purposes for which it is collected.

3.3 Accuracy: the data will be accurate, complete and, if necessary, up to date.

3.4 Transparency: when collecting your personal data, you will be informed about every relevant information and notice relating to this collection and process of their data and notably concerning the purpose and recipients of such information.

3.5 Storage: the data will be kept for a time period that does not exceed the period required for the purposes for which they are collected and processed.

3.6 Consent: the person concerned must have given his consent to the processing of his data.

3.7 Confidentiality & Security: We will assure confidentiality and security of every collected personal data by implementing reasonable technical measures

4. Types of personal data we may collect from you

4.1 We may collect and process the following data about you:

4.1.1  Information you give us. You may give us information about you and/or your family members (including, but not limited to):

(a) contact details (including last name, first name, telephone number, e-mail address, etc.);

(b) personal information  (including date of birth);

(c) information about your family (including number of persons, age, etc.);

(d) consumption habits as regards dairy products / cheeses.

You may give us this about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes (but is not limited to) information you provide when you use our site, participate in market programs or animations (including contests, games and newsletters), search for a product, 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.

4.1.2  We consider that parents should be kept informed of the relationship between us and their young children. We therefore ask for parents/guardians’ e-mail addresses of internet users under 12 in order to provide copies of all e-mails asking their children for personal data. At any time, parents/guardians will be entitled to have access to personal data concerning their child and ask for their modification or deletion from our consumer’s database by contacting our consumer service at beluk@groupe-bel.com.

4.1.3  Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:

(a) 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;

(b) 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), and methods used to browse away from the page and any phone number used to call our customer service number.

4.1.4 Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, advertising networks, analytics providers, search information providers) and may receive information about you from them.

5.  Cookies

5.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

5.2  A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

5.3 We use the following cookies:

(a) Strictly necessary cookies. These are cookies that are required for the operation of our website.

(b) Analytical/performance cookies. They 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 improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

(c) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

5.4  The purpose of the data gathered using the cookies is to identify you when you want to connect to your personal space and to memorise your connection to the Site. When you close your internet browser, they are not saved.

5.5 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

5.6 If you would like to block cookies, change your browser settings as follows:

5.6.1 If you browse on the Internet with Internet Explorer (Microsoft): choose the “Tools” menu, then “Internet Options”, click on the “Privacy” tab. Then “Advanced Privacy Settings”, click on “Override automatic cookie handling” and select “Reject all cookies” (internal and third party). Click on “OK”.

5.6.2  For Firefox: choose “Tools” then “Options”. In the “Privacy” tab, tick “Tell websites I do not want to be tracked”. Click on OK.

5.6.3  For Chrome, click on “Settings” then “Show Advanced Settings”. Then in “Privacy”, click on “Content settings” and make your choice in the Cookies part.

If you use versions of browsers other than those stated: please refer to the help files or to the user manual.

6.  Uses made of the information

6.1  We use information held about you in the following ways:

6.1.1  Information you give to us. We will use this information:

(a) to provide you with the information, products and services that you request from us (including customer service, discount vouchers, newsletters);

(b) to provide you with information about other goods and services we offer that are similar to those that you have already enquired about;

(c) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the contact form);

(d) to notify you about changes to our service;

(e)  to ensure that content from our site is presented in the most effective manner for you and for your computer.

6.1.2 Information we collect about you. We may use this information:

(a) to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

(b) to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

(c)  to allow you to participate in interactive features of our service, when you choose to do so;

(d) as part of our efforts to keep our site safe and secure;

(e)  to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

(f) to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

6.1.3  Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

7. Disclosure of your information

7.1  We may 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.

7.2  We may share your information with selected third parties including:

7.2.1  Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

7.2.2 Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.

7.2.3  Analytics and search engine providers that assist us in the improvement and optimisation of our site.

7.3  We may disclose your personal information to third parties:

7.3.1  In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

7.3.2  If Bel UK Ltd 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.

7.3.3  If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use https://www.thelaughingcow.co.uk/terms-conditions/ and other agreements; or to protect the rights, property, or safety of Bel UK Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

8.  Where we store your personal data

8.1  The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Bel UK Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

8.2  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.

8.3  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.

9. Your rights

9.1  You have the right to ask us not to process your personal data for marketing purposes. 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. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.  You can also exercise the right at any time by contacting us at beluk@groupe-bel.com.

9.2  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.

10. Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

11. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

12. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to beluk@groupe-bel.com.