Privacy Policy

LAST UPDATED: 28 Sept 2021

1. INTRODUCTION
Welcome to the Brioche Pasquier UK website. The website is located at https://www.pasquier.fr/en_uk/ (Site) and the personal information collected from this Site is processed by Pasquier SA and Brioche Pasquier U.K. Limited.

Pasquier SA and Brioche Pasquier U.K. Limited are companies in the same group and joint controllers of the processing of your personal information described in this policy. This means that these companies have decided between them how and why your personal information will be processed and are both responsible to you for that processing. Unless expressly stated otherwise, references to “we”, “us” and “our” in this policy are a reference to both companies. If you have any queries, please contact Brioche Pasquier U.K. Limited in the first instance using the contact details at the end of this policy.

This Privacy Policy explains:
• why and how we may use the personal information that we obtain from you when you visit and use our Site, when you contact us or when we contact you;
• with whom we share your personal information; and
• the rights you have in connection with the information we use.

Please read the following carefully.

Please note that a separate privacy notice applies to any personal information you provide to us through the Site when :
• applying for a job vacancy. Please see our Recruitment Privacy Policy for further information.
• entering into a competition or other prize promotion. Please see the privacy policy that accompanies the terms and conditions of the particular prize promotion for further information. Links to privacy policies relating to past promotions are provided at the end of this Privacy Policy.

Some of our service providers may use the personal information they receive from this Site’s cookies for purposes that benefit both our businesses. Where this is the case, we are jointly responsible with them for the processing of that information (and are “joint controllers” for the purposes of data protection laws). Please see our Cookies Policy for further information.

This Privacy Policy may change from time to time so please check this Privacy Policy occasionally to ensure that you are happy with any changes. For more information on changes to our Privacy Policy, please see paragraph 11 (Changes to this Privacy Policy).

This Privacy Policy was last updated on the date set out at the top of this Privacy Policy.

2. PERSONAL INFORMATION WE COLLECT ABOUT YOU
We collect personal information from you in the following ways:
Personal information you give to us:

This is personal information you give to us when you:

• register with us to receive marketing communications;
• make a complaint about one of our products; and
• contact or correspond with us for any other reason (e.g. to ask a question or to make a suggestion),
using a form available on the Site, by email, or in another way.

This information includes your contact details (e.g. name and email address), your marketing preferences (e.g. whether you have agreed or declined to receive marketing emails from us), details of the products you have purchased from us and your feedback and experiences regarding those products and any personal information contained in the messages or files you send to us.

This personal information is provided by you entirely voluntarily. However, certain information (in most cases marked with an asterisk on our web forms) must be provided to us to process your complaint or query. If you do not provide this information it will not be possible to process your complaint or query. The information you provide must be truthful and accurate.

Personal information we collect about you:

We automatically collect information technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform as well as cookie information, including tracking pixel and beacon identification information (Technical Information). Please see our Cookies Policy for further information.

3. HOW AND WHY WE USE YOUR PERSONAL INFORMATION
In relation to your personal information that we process as a controller, data protection law requires us to have a valid reason to process it for each of the different purposes for which we use that information. The law refers to each reason as a ‘lawful basis’.

The purposes for which we use Technical Information where it is also your personal information and the lawful basis on which we rely to process it for each purpose is set out in our Cookies Policy.

The purposes for which we use all other personal information we collect about you and the lawful basis on which we rely to process it for each purpose is as follows:

Where you have provided CONSENT

We may use and process your personal information where you have consented for us to do so for the following purposes:

• contact you via email with marketing information about us, our events and products and about our third party partners; and
• when you refresh your marketing preferences when responding to a request from us to do so.

You may withdraw your consent for us to use your information in any of these ways at any time. Please see paragraph 10 (Your Rights) for further details.

Where necessary to comply with our LEGAL OBLIGATIONS

We will use your personal information to comply with our legal obligations:

• to comply with our legal obligations regarding product and customer safety and other applicable laws and regulations;
• to keep a record relating to the exercise of any of your rights relating to our processing of your personal information;
• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
• to anonymise or delete your personal information when it is no longer required for the purposes described in this Privacy Policy or our Cookies Policy;
• to comply with court orders or other notices where failure to do so would result in us breaking the law; and
• to handle and resolve any complaints we receive relating to our processing of your personal information as described in this Privacy Policy.

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

Processing necessary for us to promote our business and measure the reach and effectiveness of our campaigns

• to identify and record when you have received, opened, forwarded or engaged with the Site or our electronic communications (please see our Cookies Policy for more information);

Processing necessary for us to respond to changing market conditions and the needs of our users

• to analyse, evaluate and improve our products or the Site so that your use of the Site or our products are more useful and enjoyable (we will generally use data amalgamated from many people so that it does not identify you personally);

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

• to administer the Site and for internal operations, including troubleshooting, testing, statistical purposes;
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
• for the purposes of analysis and investigation in connection with the production and quality assurance of our products;
• for other general administration including managing any reports you make, your queries, complaints, or claims, and to send service messages to you.

4. DISCLOSURE OF YOUR PERSONAL INFORMATION BY US
We may disclosure your personal information to companies in our corporate group for administration and audit purposes, to escalate complaints/queries, to consider or implement any suggestions or feedback you provide or to evaluate your application for a job vacancy.

In particular, we may forward your personal information to our departments responsible for consumer relations.

We also may disclose your personal information to our third party service providers, agents and subcontractors (Suppliers) for the purposes set out above. Our Suppliers can be categorised as follows:

When sending your information to Suppliers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

When we share your personal information with any third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.

We may disclose your personal information to other third parties if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, tribunals, regulators, the government or related agencies.

5. WHERE WE STORE YOUR PERSONAL INFORMATION
The information you provide to us may be transferred to countries outside the United Kingdom (UK) and European Economic Area (EEA).

By way of example, this may happen where any of our servers or those of our third party service providers are from time to time located in a country outside of the UK and EEA. These countries may not have similar data protection laws to the UK/EEA and so may not protect the use of your personal information to the same standard.

If we transfer your information outside of the UK and EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy. These steps include:

• ensuring the non-UK/EEA countries to which transfers are made have been deemed adequately protective of your personal information for the purposes of data protection law by the relevant bodies;
• imposing contractual obligations on the recipient of your personal information using provisions formally issued by relevant bodies for this purpose. We use these provisions to ensure that your information is protected when transferred your personal information to our Suppliers outside the UK and EEA; or
• ensuring that the recipients are subscribed to valid ‘international frameworks’ that aim to ensure adequate protection.

Your personal information will be transferred from the UK to the EEA. These jurisdictions have similar data protection laws and practices which means your personal information is protected to a very similar high standard when transferred to the UK.

Please contact us using the details at the end of this Privacy Policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

If you use our services whilst you are outside the UK and EEA, your information may be transferred outside those territories in order to receive those services.

6. THE PERIOD FOR WHICH WE KEEP YOUR PERSONAL INFORMATION
If we collect your personal information, the length of time for which we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 6 years after the date it is no longer needed by us for any of the purposes listed under paragraph 3 (How and why we use your personal information) above. The only exceptions to this are where:

• we will retain any personal information contained in your job application for 6 months from the date of receipt;
• we receive personal information from you in connection with a complaint or query in which case we will retain that information for 5 years following the year in which the complaint or query was resolved;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see paragraph 10 (Your Rights) below);
• you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see paragraph 10 (Your Rights) below);
• we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
• in limited cases our legal obligations or a court or regulator requires us to keep your personal information for a longer or shorter period.

7. SECURITY AND LINKS TO OTHER SITES
We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.

The Site may contain links to other websites run by other organisations which we do not control. This Privacy Policy does not apply to those other websites‚ so we encourage you to read their privacy policies. We are not responsible for the privacy policies and practices of other websites (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

In addition, if you linked to the Site from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

8. COOKIES
'Cookies' and similar technologies are small pieces of information sent to your computer or device and stored on its hard drive to allow our Site to recognise you when you visit.

Please visit our Cookies Policy to find out more about how we use cookies.

9. AUTOMATED DECISION MAKING
We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this Privacy Policy and inform you if this position changes.

10. YOUR RIGHTS
You have a number of rights in relation to your personal information under data protection law. Please see our Privacy Principles for further information regarding your data protection rights. You may exercise these rights in a number of ways but to help us to handle your requests most efficiently, please use our GDPR webform.

You have the right to complain to a supervisory body if you are concerned about the way we have processed your personal data. In France this is the CNIL – www.cnil.fr, and in the UK this is the ICO – www.ico.org.uk.

Although you have the right to complain to the supervisory body, we encourage you to contact us first with a view to letting us help in resolving any queries or questions.

11. CHANGES TO THIS PRIVACY POLICY
We may review this Privacy Policy from time to time by posting a copy of them on the website. Any changes will take effect on the date on which we post the modified terms on the Site. We recommend you regularly check for changes and review this Privacy Policy whenever you visit or use the Site. If you do not agree with any aspect of the updated Privacy Policy you should immediately notify us and cease using the Site.

12. CONTACT US
If you have any questions or concerns about this Privacy Policy, please contact us as follows:

If you wish to write to us, please write to:

Brioche Pasquier U.K. Limited
8 Garamonde Drive
Wymbush
Milton Keynes
MK8 8DF

Our email address for data protection queries is contact-uk@pasquier.fr.

If you would prefer to speak to us by phone, please call 01908 266 700.

The company details of Brioche Pasquier U.K. Limited are located at https://www.pasquier.fr/en_uk/page/legal-requirements

The company details of Pasquier SA are located at https://www.pasquier.fr/fr/page/mentions-legales

13. PRIVACY POLICIES FOR PAST PROMOTIONS
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