Privacy Policy

  1. Important information about this privacy policy

Welcome to the privacy policy of The Very Good Food Company Inc. and its brands The Very Good Butchers Inc. and The Very Good Cheese Co.

This privacy policy was last updated on 4 August 2021.

About this policy

In this privacy policy, we aim to give you information on how The Very Good Food Company collects and processes your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This website is not intended for children and we do not knowingly collect data relating to children.

It is really important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Who we are

The Very Good Food Company (“VERY GOOD” or “we”, “us” or “our”) is the controller and responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Changes to the privacy policy and your duty to inform us of changes

We reserve the right to modify this privacy policy at any time. If we make changes to this privacy policy, the updated privacy policy will be posted online via https://uk.verygoodbutchers.com/pages/privacy-policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  1. Information we collect and why

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, marital status, title and date of birth.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes payment card details.
  • Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
  • Usage Data includes [information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or newsletter;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
    • Technical Data from the following parties:
      • analytics providers;
      • advertising networks; and
      • search information providers.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  1. How we use your personal data

We need to collect your information so that we can continue to provide services to you, improve these services and manage the accounts of all our customers.  This includes creating statistics and carrying out data analysis.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

If we use your personal information for performance of a contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

If we use your personal information for our legitimate interests this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. Whenever we use legitimate interests, we give careful consideration to and balance any potential impact on you (both position and negative) and your rights. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

  • Where we need to comply with a legal obligation.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

  • Where you have provided your consent for us to use your personal data.

If you would like to receive direct marketing from us, we will always ask for your consent. You can withdraw your consent at any time by contacting us or using the unsubscribe link included in our communications.

  1. Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

·                Identity

·                Contact

Performance of a contract with you

To process and deliver your order including:

·                Manage payments, fees and charges

·                Collect and recover money owed to us

·                Identity

·                Contact

·                Financial

·                Transaction

·                Marketing and Communications

·                Performance of a contract with you

·                Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

·                Notifying you about changes to our terms or privacy policy

·                Asking you to leave a review or take a survey

·                Identity

·                Contact

·                Profile

·                Marketing and Communications

·                Performance of a contract with you

·                Necessary to comply with a legal obligation

·                Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

·                Identity

·                Contact

·                Profile

·                Usage

·                Marketing and Communications

·                Performance of a contract with you

·                Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

·                Identity

·                Contact

·                Technical

·                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 or group restructuring exercise)

·                Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

·                Identity

·                Contact

·                Profile

·                Usage

·                Marketing and Communications

·                Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

·                Technical

·                Usage

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 make suggestions and recommendations to you about goods or services that may be of interest to you

·                Identity

·                Contact

·                Technical

·                Usage

·                Profile

·                Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will therefore only ever send directing marketing communications to you where you have provided your consent, for example, when you tick a box to receive email newsletters. You have the right to withdraw consent to marketing at any time by contacting us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time using the details below.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy https://uk.verygoodbutchers.com/pages/cookie-policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties – companies in VERY GOOD Group who are based in Canada and undertake leadership reporting.
  • External Third Parties – these include:
    • Sales agencies to whom you have consented to contact you in relation to the purchase of a product or service.
    • Government agencies, regulators and other authorities who require reporting of processing activities in certain circumstances.
    • Service providers acting as processors that perform services on our behalf.
  • Professional advisers including lawyers, bankers, auditors and insurers based in Canada who provide consultancy, banking, legal, insurance and accounting services.
  • National regulators and other authorities based in Canada who require reporting of processing activities in certain circumstances.
  • Other companies and brands owned or controlled by VERY GOOD such as our subsidiaries. These companies will use your personal information in the same way as we can under this Privacy Policy.
  • Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Website Terms of Use https://uk.verygoodbutchers.com/pages/website-terms-of-use or to protect the security or integrity of our website; and/or (c) to exercise or protect the rights, property, or personal safety of VERY GOOD, our visitors, or others.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International transfers

We transfer and process your personal data outside of the UK including in countries that have data protection laws that are different to the UK.  However, we take appropriate safeguards to ensure a similar degree of protection is afforded to it and that your personal data will remain protected in accordance with this Privacy Policy.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

Data protection laws give you certain rights in relation to your personal data which you can exercise under certain circumstances. To help you understand your rights, we’ve included information which you can access by clicking on the links below. [If you’d like more information on your rights, please visit the ‘Your Data Matters’ campaign on the ICO’s website at https://ico.org.uk/your-data-matters

  • Request access to your Personal Information

You have the right to request access the personal information that we have collected about you and to confirmation that your personal information is being processed by us. This is often referred to as a “data subject access request”. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  • Request correction of your Personal Information

This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

  • Request erasure of your Personal Information

This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Request restriction of processing your Personal Information

You can ask us to suspend the processing of your personal information in the following circumstances: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

  • Request to transfer your Personal Information

You have the right to obtain and reuse your personal information. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Object to processing of your Personal Information

You have the right to object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Right to withdraw consent

Where you have consent to our processing of your personal information (for example, where we ask you to consent to us sending you marketing materials) you have the right to withdraw your consent at any time.

Please note the following:

  • You may correct, update, restrict or limit your account information at any time by adjusting that information via your account settings.
  • You may request that your account, together with the personal information within your account, is deleted by contacting us (please see below).
  • You can object to our processing of your personal information and we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Contacting us

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: The Very Good Food Company Inc.

Email address: hello@verygoodbutchers.com

Postal address: 2748 Rupert Street, Vancouver, British Columbia, Canada V5M 3T7

  1. Your right to make a complaint

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.