1. Who Are We

Our Privacy Policy covers the activities of World of Sweets Limited and its subsidiary companies and all trading companies within the group. The data controller is the relevant company whose services are being used (collectively referred to in this notice as “World of Sweets” or “we” “our” or “us”). This policy refers to anyone trading with a group company, referred to as ‘customer’ within this policy.

As a group, we are committed to doing the right thing when it comes to how we collect and use customer data which includes how we store personal data. This privacy policy sets out:

• The types of personal data that we collect
• How and why we collect and use personal data
• When and why we will share personal data within our group or outside of our group of companies
• The rights and choices you have when it comes to personal data

World of Sweets companies serve a variety of customers in different ways, this notice applies to all customers or individuals that trade or work with any of the World of Sweets Companies.

Individuals or organisations may shop with us in a variety of ways: cash and carry branches of Hancocks, online or otherwise using any of the websites (“our websites”) where this Notice is posted; or face to face with one of our sales representatives.

2. What Personal Data Do We Collect

As a customer of the group, you may be asked to provide:

• Personal details, including the name of the proposed account holder, the business address, email addresses, data of birth, photo ID (in some cases) phone numbers and title
• The names and telephone numbers of any additional card holders You will be given an account number which identifies the customer account and used by us
• Information about purchases (for example, what a customer has bought, when and where you bought it and how you paid for it)
• Trading names, including proof of trading address and sales information will also be captured
• CCTV images of you may be captured at our premises

In addition to the above, if you shop with us online via our websites we may collect:

Account Password

Google analytics information regarding URL, Java and flash enabling, and other browser information. Information about online browsing behaviour on our Websites and information about when you click on one of our adverts (including those shown on other organisations’ websites) Information about any devices you have used to access our services (including the make, model and operating system, IP address, browser type and mobile device identifiers) Location information is based on IP address and language.

If you apply for a credit account with us we may also require the following:

• Bank account details
• Credit history and other financial information either via credit searches that we have been authorised as part of an application or that have been provided as part of an application, including information provided from the land registry, Companies House or other relevant organisations.

Whenever an account is used we will collect transactional information regarding the goods purchased, payment method, date and time of purchase.

When a customer contacts us or we contact them or a customer takes part in our promotions, competitions, or questionnaires, we may collect:

• Personal data they provide about themselves, information about our services or products including by phone, email or post or when they speak with us through social media
• Details of the emails and other digital communications we send to customers that are opened, including any links in them that are clicked
• Feedback and contributions to customer surveys and questionnaires

3. Non-Customers or Members of The Public

From time to time we may be contacted by individuals who are not a registered customer or account holder with us. In those circumstances, we will gather sufficient information to address the query or issue (such as name, address and contact details). In some cases, we may need to pass that information on to a third party, such as a supplier (in the event of a product-related query) or a third party advisor in order to address the matter in question. Any information obtained will be processed purely for the purpose of the single issue or query raised and will be deleted in line with our retention policy once the matter has been closed.

4. Why and How do We Use Personal Data

We collect data to ensure we can deliver the service or products to you. We hold and manage this data to allow us to:

• Manage your customer account with us
• Process orders and/or refunds
• Administer loyalty schemes we may have in place
• Deliver goods that have been ordered
• Communicate with customers about their account
• Produce invoices and statements
• Consider any application for credit
• Maintain a credit account
• Communicate with a customer in emergencies for example for a product recall
• As evidence of identity for high cash transactions and for the granting of credit
• Review purchase history to enhance the online or instore shopping experience via tools for example reviewing previous purchases
• To market applicable products or services
• CCTV images are obtained to ensure the security and safety of our customers and colleagues

We need to process personal data so that we can trade with our customers, providing the goods and/or services requested to fulfil our obligations as a supplier. We use this data to continually review our product offering as well as review how our stores physically or online interact with customers to improve our performance.

We also have an obligation to ensure that our services are safe and consequently, if required data may be processed to detect and prevent fraud, other crimes and the misuse of our services.

5. Marketing, Promotions, Competitions and Research – Customer Preferences

We communicate with customers to promote our offers, promotions or competitions along with gaining feedback. We may do this via email, text, phone, post or via social media.

When registering with us customers are asked about their marketing preferences, whether in-store or online. They may change this by contacting us via email, phone or in-store.

It is also important we improve our services and offerings by gaining feedback from our customers, we will from time to time communicate to give the opportunity to feedback to us.

We may at times supply details to our selected third-party partners so they can share details of information or products/services that we think could be of interest to customers.

6. Sharing of Data

We may share the personal data we collect with other companies in World of Sweets. Eg. Customer details from our online websites to our cash & carry stores for click & collect orders to enable us to fulfil orders.

We also share data with some third-party organisations, some of this data is anonymised (pseudonymised or anonymised where possible) but in some instances, we must share personal data, some of these have already been set out within this policy but for clarity, we may do this:

• To fulfil orders by passing details onto our transport partners to deliver orders
• To process payments from customers through our third-party partners e.g. to process credit card payments
• To provide improved service of our websites or stores working with third parties to improve, or with suppliers to improve our product offering
• To allow for investigations or audits to take place for example HMRC or when we need to further investigate a complaint or product recall
• To market products or services that may be of interest to you from third parties.
• To provide symbol groups with details of their members
• To allow us to market our services or products to customers

We work with various service providers to carry out certain functions on our behalf, these may be companies that provide technology solutions to us, the processing of payments, credit checking or provide us with market research data. We only share personal data necessary to enable these partners to provide their services.

We may also share data for legal reasons in certain circumstances such as:

If a public authority states we must share data with them or by law we have to do so
For legal proceedings in which we need to defend, establish or exercise our legal rights, this may also be for the purposes of fraud or fraud detection
To any organisation in which we sell or transfer (or enter into negotiations to do so with) any of our subsidiary businesses then they may use personal data in the same way as set out by us

7. Protecting Personal Data

We take the security of personal data seriously and have implemented measures to protect and manage the personal data of our customers. As a group we:

• Use measures we have deemed necessary and appropriate to protect data both electronically and physically
• Have implemented measures from a digital infrastructure perspective with the goal of increased network and data security
• Have implemented measures from a physical security point of view in instances of data being stored on-site
• Use appropriate security protocols when sharing data with Third Parties Suppliers and Service Providers.

Whilst we take technical, organisational, and physical measures to try and ensure data is kept secure, we cannot guarantee the security of any data that a customer may transfer or send to us.

8. Cookies and Similar Technologies

We use cookies and similar technologies, such as tags and pixels (“Cookies”), to personalise and improve customers’ experience as you use our websites to provide you with relevant online advertising. This section provides more information about Cookies, including how we use them and how you can exercise your choices about our use of Cookies. Cookies are small data files used for a variety of reasons including security e.g. to enable you to sign in, collate and manage site errors, store information e.g. customers’ shopping baskets online or to remember individuals’ preferences, to track and monitor analytics from the sites e.g. to monitor promotions and offers to understand their success and to enable payments. Cookies also allow us to ensure the performance of our website is at its best and monitor issues and downtime.

If you choose to disable some or all Cookies, you may not be able to make full use of our websites. For example, you may not be able to add items to a shopping basket or proceed to checkout.

9. Your Rights

Under the General Data Protection Regulation, you have the right to see the personal data we hold about you. This is called a Subject Access Request.

If you would like a copy of the personal data we hold about you, please write to: Zach Towers, Data Protection Officer, World of Sweets Limited, 25 Jubilee Drive, Loughborough, LE11 5TX or by emailing: hr@worldofsweets.co.uk We want to make sure that the personal data we hold about you is accurate and up to date. If any of the details are incorrect, please let us know and we will amend them.

10. Changes to This Privacy Notice

We reserve the right to make changes to this Privacy Notice from time to time, so please take the time to review it periodically.