Fair Processing of Data

NOTICE FOR CUSTOMERS AND CONSUMERS OF OSU ON THE FAIR PROCESSING OF PERSONAL DATA

INTRODUCTION
Mizkan Euro (“Mizkan”)[1] is primarily a UK based group of companies that manufactures, markets and distributes food products. The company operates under different brands such as but not limited to Sarsons, Branston, Haywards, Mizkan, Dufrais and OSU.
Mizkan operates a corporate website called www.Mizkan.co.uk and a number of product brand websites. The branded product websites that Mizkan operates are those such as;
You will find this notice (“Notice”) for consumers and customers on the fair processing of personal data and a notice on cookies on each of these websites. This Notice is to inform consumers and customers[2] (i.e. “you”) of how we at Mizkan (“we” or “us”) process your personal data and the measures and processes we have put in place to ensure its adequate protection.

In addition, this Notice may be provided to you in digital or paper format, or we may refer to its location on our intranet site, if and when you visit any of our locations or if you share your personal data anywhere else with us.

We provide you with this information as required by the EU General Data Protection Regulation 2016/679 (“EU GDPR”) and pursuant to amendments made by The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (“DP Brexit Regulations”) (the “UK GDPR”) (collectively, "GDPR").
THE SCOPE OF THE FAIR PROCESSING NOTICE
This Notice applies to all personal data of Mizkan Consumers and Customers processed by Mizkan in any way or form and/or via any medium.
LAWFUL PROCESSING
We will only process your personal data:
1. where you have given your consent;
2. where the processing is necessary to provide our products or services to you;
3. where the processing is necessary to respond to a request from you;
4. where the processing is necessary to maintain our relationship with you;
5. where the processing is necessary for compliance with our legal and regulatory obligations; or
6. where the processing is necessary in order to protect the vital interest of the data subject.
In case of (a) above, you may withdraw your consent at any time, by making a request as set out in section 14 below.
What personal data we collect about you
1. We may process the following types of personal data about you:
  - Your name, email address, twitter and/or Instagram (or other social media) handle and other contact details;
  - Details of your preferences for types of marketing events or materials;
  - Your messages, feedback or contributions to customer surveys and questionnaires;
  - Digital still images and videos that you provide (for which consent will be sought at the time of provision);
  - Other communications you send to us; and
  - Details of your access to our websites (including IP address).
2. It may be mandatory for you to provide us with your personal data, to enable us to manage our business and operations, to maintain our relationship with you, to provide our products or services to you or to comply with our legal and regulatory obligations. If you fail to provide your personal data, we might be unable to maintain our relationship with you or to provide our products or services to you.
3. We make every effort to maintain the accuracy and completeness of your personal data which we store and to ensure all your personal data is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal data or if you become aware that we have inaccurate personal data relating to you (see section 11 below). We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
How we Collect Personal Data
We usually collect your personal data from the information you submit during the course of your relationship with us. This will typically be through:
- You sending us emails and other correspondence;
- The forms and documents used when you sign up to our marketing or market data newsletters;
- The sign-up information you use to access any of our products or services;
- The information you as a customer provide to us as supplier so we can ship to you and bill you and can contact you on orders and/or issues;
- The forms we would ask you to complete when you visit one of our manufacturing sites and or offices; and/or
- Through online platforms such as social media.

how we Use Personal Data
We will process your personal data in connection with the management of our relationship with you and the provision of our products and services to you for the following purposes:

to provide you with requested products or services;
to provide you with promotional and marketing materials about our products and services that we think you may be interested in;
for monitoring and assessing compliance with various laws and our policies and standards;
to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
to carry out money laundering, financial and credit checks and for fraud and crime prevention and detection purposes;
for administrative purposes in relation to the security and access of our websites and applications;
to comply with court orders and exercise and/or defend our legal rights;
to deal with your complaint or any concerns about your health and/or wellbeing;
for any other legitimate business purpose;
as otherwise permitted or required by any applicable law or regulation; and/or
for your security and safety whilst you are at our offices and/or manufacturing locations.

PROPERTIES OF A COMPUTER FILE
Each picture file that you submit to us may contain additional information in its “PROPERTIES”. Pictures taken with a mobile phone may indicate in its “PROPERTIES” the GPS coordinates of the location where the picture was taken. As a matter of caution, we recommend that you remove all additional data in “PROPERTIES” before submitting a picture to us.

In some cases, such as for instance a competition or prize draw, you may provide us with specific information, such as a photo or video, which could contain personal data. In those specific cases, we will always inform you for what objective we gather the information and for how long we intend to keep such data.

Where you wish to share personal data on specific matters like health with us, to enable us to handle a question and/or complaint we may ask you for your consent before we process such data. If you submit your request online we may ask for your consent online before you can submit your question. If you submit your correspondence by postal mail we may first have to contact you and ask you for your written consent. If you call us we may ask you for your consent in the telephone call and will record you answer before we can process your personal data. In all three incidences, we would maintain a record of your consent for us to process such specific data.

Cookies
On our websites, we use two different categories of cookies; strictly necessary cookies and performance cookies. The first category of cookies is used to store a unique identifier which allows us to manage and to uniquely identify you as a user so we can provide you with consistent and accurate services. The second category of cookies collects information about your use of our website and may be used by us to provide you with more similar information. For more information about how we use cookies, please read our cookie policy on our corporate website; http://www.mizkan.co.uk/cookies/
International Transfers of Personal Data
Your personal data may be transferred to (including accessed in or stored in) a country or territory outside the European Economic Area ("EEA") or the UK, including to countries whose laws may not offer the same level of protection of personal data as are enjoyed within the EEA and/or the UK. Where we share your personal data with our group companies in Japan, we will rely on the decision by the European Commission and the UK Secretary of State in accordance with Article 45 of GDPR that the laws in Japan offer an adequate level of data protection as are enjoyed within the EEA and/or the UK.

We may also share your personal data with other group companies and other third parties (set out in section 9 below) located in countries in which laws do not offer the same level of protection of personal data as are enjoyed in countries inside the EEA and/or the UK. In such cases, we will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the GDPR. You can obtain copies of the relevant safeguard documents by making a request as set out in section 14 below.
When we may disclose your personal data
We do not and will not sell, rent out or trade your personal data. We will only disclose your personal data to the following recipients:
1. to our group companies;
2. to third parties who process your personal data on our behalf such as;
  1. Providers of consumer and customer communications in areas such as;
    1. Digital and social media communications
    2. Customer care
    3. Advertising
    4. Market Research
  2. Providers of logistical services
  3. Providers of legal services
  4. Providers of IT support services in areas such as;
    1. Website development and website management
    2. Web site hosting
    3. Providers of generic IT services
    4. Application development
  5. Providers of assurance in areas such as;
    1. External and Internal Audits
    2. Health, safety, hygiene and technical matters
3. to any third party to whom we assign or novate any of our rights or obligations;
4. to any prospective buyer in the event we sell any part of our business or assets; and/or
5. to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.
How we protect your personal data
We are committed to safeguarding and protecting your personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect your personal data from accidental or unauthorised destruction, loss, alteration, disclosure or access.
Your rights in relation to the personal data we collect
1. If you would like us to stop sending you emails, please make use of the option at the end of our email to you where you can request that we remove you from our mailing list.
2. If you wish to:
  1. update, modify, delete your personal data or obtain a copy of your personal data that we hold; or
  2. restrict or stop us from using any of your personal data which we hold;
  you can request this by contacting us as set out in section 14 below.
3. In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.
How long we will hold your PERSONAL data for
We will only retain your personal data as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
How we update or change this Fair Processing Notice
This Notice does not form any contractual relationship between you and us, and we may change or update parts of this Notice to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating this Notice on our UK corporate website www.mizkan.co.uk and all our product brand websites that are linked to this UK corporate Website.

You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Notice so you are fully aware of any changes or updates.
How you can contact us
If you have any queries about the contents of this Notice or your personal data, or wish to make a request in relation to your personal data, please contact us using the details set out below:

Email: gdpr.coordinator@mizkan.co.uk

Post: The GDPR Coordinator, Mizkan Euro, Building 10, Chiswick Park, 566 Chiswick High Road, London W4 5XS

When you make your request, please indicate the following;
1. Your name
2. Your email address (or postal address if you previously submitted your postal address to us)
3. The date of your request
4. The date at which you submitted your personal data to us or a description of the specific situation[3] when you provided us with your personal data
5. The nature of your request (i.e. do you want us to correct your data, for us to delete your data, to provide you with a copy etc.)
HOW TO LODGE A Complaint TO THE REGULATOR
The protection of your personal data and of our relationship with you is important to us. If you have any questions or you think we have breached your data protection rights please contact our GDPR Coordinator at gdpr.coordinator@mizkan.co.uk.

However, if you are unable to come to a solution with our GDPR coordinator or want to contact the UK Data Protection Regulator to lodge a complaint, please contact the Information Commissioner's Office, at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

[1] Mizkan Euro consists of Mizkan Euro Ltd., Mizkan Euro Partners Limited, Mizkan Euro Holdings Limited and Mizkan AMS B.V.

[2] A consumer is the end user of Mizkan’s Products. A customer is the retailer and/or distributor to whom Mizkan directly sells its products.

[3] A specific situation could be a specific campaign, an event during which we handed out samples, a competition etc.

NOTICE FOR CUSTOMERS AND CONSUMERS OF OSU ON THE FAIR PROCESSING OF PERSONAL DATA

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