Henderson Wholesale Ltd., 9 Hightown Ave., Mallusk, Newtownabbey, Co. Antrim. BT36 4RT (we, our, or us) are committed to protecting and respecting your privacy.

This policy (together with our terms of use 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.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.spar-ni.co.uk (our website) you are accepting and consenting to the practices described in this policy.

At Henderson Wholesale Limited, we understand your concerns about what happens to information which you provide to us and we are dedicated to protecting your privacy.

 

Henderson Wholesale Limited provides this Privacy Policy in its role as data controller in order to explain how your information is collected and used. The Privacy Policy also explains the use of certain features on the websites and social media channels.

How do we collect information?

We collect information on you through [any of our websites (www.spar-ni.co.uk/, www.eurospar-ni.co.uk/, www.henderson-group.com/ and www.tellusfirst.com/ (Websites)), social media channels (under any of the names of “SPAR NI”, “EUROSPAR NI”, “VIVO NI” or “VIVOXTRA NI”), competition paper entry forms, conversations in-store or over the phone with you, through CCTV systems in use at our stores or sites, video or image recording by us at various events or in-store or in connection with a contract with you or your employer] 

 

What information do we collect from you?

As appropriate for the intended use of the information (described below), we collect certain personal data regarding you including (among other things) your [name, address details, contact details including phone numbers and email addresses, image and voice recordings, location data, online identifiers and any other information required to perform a contract that you have entered into. We also collect information relating to the options you select on the Websites and other websites which are accessible through links from the Websites.

 

How will we use this information?

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

* to enter you into competitions that we run and administer those competitions;

* where we need to perform the contract we are about to enter into or have entered into with you;

* 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. Those legitimate interests can include: necessity to keep our records updated and study how our services are used; to develop our services and grow our business; for running our business and administering ancillary services such as IT provision and network security; and to inform our marketing strategy)

* to deliver relevant content of the Websites and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;

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

* where we need to comply with a legal or regulatory obligation.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time, as described below.

 

We may use your personal data for some or all of the following purposes:

* dealing with queries/concerns that you have brought to our attention;

* to enter you into competitions that we run and administer those competitions;

* for administration of a contract with you or your employer;

* to run promotional campaigns;

* to comply with our legal obligations and responsibilities and establishment and defence of legal claims;

* to deliver relevant marketing information to you from time to time;

* to deliver relevant content of the Websites and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;

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

* for good governance, accounting and managing our business operations.

 

How long do we hold your information for?

Subject to your rights set out in relevant data protection laws and explained in this Privacy Policy, we will retain your information in accordance with our standard retention policy. Unless that retention policy defines a shorter time, we will keep your information for as long as necessary for the purposes it was collected for, for as long as you (or someone else) would be permitted to take a legal claim against us in a matter which involves your information or as for as long as we are otherwise legally required to retain the information.

 

Your right to opt out

You may opt out of receiving marketing communications from us. Details of how to unsubscribe from emails will be included with each marketing email we send you. Alternatively, you can email us at brandteam@henderson-group.com to change your contact preferences. Please be aware that there may be times when it is necessary for us to contact you even if you have opted out of receiving other communications from us, such as for administrative or operational reasons.

 

To whom will we provide your information?

From time to time we may need to disclose your information to:

* other companies within our group and their employees;

* to market research companies to carry out market research about the Henderson Wholesale Limited brands;

* to professional advisors (including lawyers, bankers, accountants, insurers and insurance brokers);

*and to third party data processing service providers (such as marketing automation platform and marketing service providers, IT hosting providers, data security providers and FMCG suppliers to Henderson Wholesale Ltd.) who process your information on our behalf in accordance with our instructions to enable us to provide services to you and facilitate the purposes described above.

 

We will only ever do so as permitted by and in accordance with applicable data protection law.

 

Some of the recipients of the information may be located outside of the European Union. Whenever we transfer information outside of the European Union, we make sure that similar levels of protection are applied.

 

Whenever any providers are located in the US, we only transfer information to them if they are part of the “Privacy Shield”, which requires them to provide similar protection (more information is available here: Privacy Shield). In particular, we do business with The Rocket Science

Group LLC (trading as MailChimp), who (as at the date shown at the top of this Privacy Policy) are certified under the Privacy Shield (which can be viewed here: MailChimp).

 

By opting in to receive marketing information via SMS, email or post, you acknowledge and accept that we may need to disclose your information in those limited circumstances and for the purposes described.

 

At Henderson Wholesale Limited, we understand your concerns about what happens to information which you provide to us and we are dedicated to protecting your privacy.

 

Henderson Wholesale Limited provides this Privacy Policy in its role as data controller in order to explain how your information is collected and used. The Privacy Policy also explains the use of certain features on the websites and social media channels.

 

 

How do we collect information? 

We collect information on you through [any of our websites (www.spar-ni.co.uk/, www.eurospar-ni.co.uk/, and www.henderson-group.com/ (Websites)), social media channels (under any of the names of “SPAR NI”, “EUROSPAR NI”, “VIVO NI” or “VIVOXTRA NI”), competition paper entry forms, conversations in-store or over the phone with you, through CCTV systems in use at our stores or sites, video or image recording by us at various events or in-store or in connection with a contract with you or your employer] [DN: please confirm that this represents all data-capture scenarios]

 

What information do we collect from you?

As appropriate for the intended use of the information (described below), we collect certain personal data regarding you including (among other things) your [name, address details, contact details including phone numbers and email addresses, image and voice recordings, location data and online identifiers] [DN: please confirm this represents all categories of data captured]. We also collect information relating to the options you select on the Websites and other websites which are accessible through links from the Websites.

 

How will we use this information?

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

* to enter you into competitions that we run and administer those competitions;

* where we need to perform the contract we are about to enter into or have entered into with you;

* 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. Those legitimate interests can include: necessity to keep our records updated and study how our services are used; to develop our services and grow our business; for running our business and administering ancillary services such as IT provision and network security; and to inform our marketing strategy)

* to deliver relevant content of the Websites and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;

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

* where we need to comply with a legal or regulatory obligation.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time, as described below.

 

We may use your personal data for some or all of the following purposes:

* dealing with queries/concerns that you have brought to our attention;

* to enter you into competitions that we run and administer those competitions;

* for administration of a contract with you or your employer;

* to run promotional campaigns;

* to comply with our legal obligations and responsibilities and establishment and defence of legal claims;

* to deliver relevant marketing information to you from time to time;

* to deliver relevant content of the Websites and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;

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

* for good governance, accounting and managing our business operations.

 

How long do we hold your information for?

Subject to your rights set out in relevant data protection laws and explained in this Privacy Policy, we will retain your information in accordance with our standard retention policy. Unless that retention policy defines a shorter time, we will keep your information for as long as necessary for the purposes it was collected for, for as long as you (or someone else) would be permitted to take a legal claim against us in a matter which involves your information or as for as long as we are otherwise legally required to retain the information.

 

Your right to opt out

You may opt out of receiving marketing communications from us. Details of how to unsubscribe from emails will be included with each marketing email we send you. Alternatively, you can email us at customerservices@henderson-group.com to change your contact preferences. Please be aware that there may be times when it is necessary for us to contact you even if you have opted out of receiving other communications from us, such as for administrative or operational reasons.

 

To whom will we provide your information?

From time to time we may need to disclose your information to:

* other companies within our group and their employees;

* to market research companies to carry out market research about the Henderson Wholesale Limited brands;

* to professional advisors (including lawyers, bankers, accountants, insurers and insurance brokers);

* and to third party data processing service providers (such as marketing automation platform and marketing service providers, IT hosting providers and data security providers) [DN: this has been drafted in a general sense for now but to meet the obligation of transparency, these companies should be identified here. The returned information audits may be used to identify all processors] who process your information on our behalf in accordance with our instructions to enable us to provide services to you and facilitate the purposes described above.

 

We will only ever do so as permitted by and in accordance with applicable data protection law.

 

Some of the recipients of the information may be located outside of the European Union. Whenever we transfer information outside of the European Union, we make sure that similar levels of protection are applied.

 

Whenever any providers are located in the US, we only transfer information to them if they are part of the “Privacy Shield”, which requires them to provide similar protection (more information is available here: Privacy Shield). In particular, we do business with The Rocket Science

Group LLC (trading as MailChimp), who (as at the date shown at the top of this Privacy Policy) are certified under the Privacy Shield (which can be viewed here: MailChimp).

 

By opting in to receive marketing information via SMS, email or post, you acknowledge and accept that we may need to disclose your information in those limited circumstances and for the purposes described.

 

What about Cookies and other tracking tools?

As part of our dedication to high standards we use cookies and other tracking tools on the Websites. Cookies are small packets of data that your web browser stores on your computer when you visit websites, which enable the server to collect information. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies. To get the most out of your experience when using the Website / Social media channels you will need to use cookies. However, should you want to turn off the cookie function, please see the help section on your web browser.

To read our cookies policy click here: Cookie Policy.

 

What happens if you follow a link to another website?

If you use other links on the Websites that lead to external websites we will no longer have control over the way in which any information is collected from you through those websites. Other websites may handle your information in a different way and should have their own privacy policies.

 

How can you find out what information we hold about you?

If at any time you wish to know what information we hold about you, please contact Henderson Wholesale Limited Marketing at:

Henderson Wholesale Ltd, PO Box 49, Hightown Ave Newtownabbey BT36 4RT

Telephone: (028) 90343316

E-mail: brandteam@henderson-group.com  

 

Your other rights over the information

Depending on the information we are using and under certain circumstances, you have rights under data protection laws in relation to some of the information you provide that can identify you (which is known as personal data under data protection laws).

 

You have the right to:

* Request access to your personal data;

* Request correction of your personal data;

* Request erasure of your personal data;

* Object to processing of your personal data;

* Request restriction of processing your personal data;

* Request transfer of your personal data; and

* Right to withdraw consent.

 

If you want to exercise any of the above rights, please contact us at the address or email address above and let us know.

 

Your right to lodge a complaint

If you are not happy with how your information has been handled you have the right to lodge a complaint with a supervisory authority. The UK supervisory authority for data protection issues is the Information Commissioner's Office (www.ico.org.uk) (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.

 

Full company details for Henderson Wholesale Limited:

Henderson Wholesale Limited, PO Box 49, Hightown Ave Newtownabbey BT36 4RT

Company No: NI000068

 

What if there are changes to this Privacy Policy?

Occasionally, to better protect you and in accordance with the law, we may need to update our Privacy Policy. We reserve the right to amend, update or replace this Privacy Policy at any time and your continued use of our website will constitute your acceptance of any such changes we may make. Any changes we make will be shown here, so please make sure you check this page from time to time.

As part of our dedication to high standards we use cookies and other tracking tools on the Websites. Cookies are small packets of data that your web browser stores on your computer when you visit websites, which enable the server to collect information. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies. To get the most out of your experience when using the Website / Social media channels you will need to use cookies. However, should you want to turn off the cookie function, please see the help section on your web browser.

To read our cookies policy click here: Cookie Policy.

 

What happens if you follow a link to another website?

If you use other links on the Websites that lead to external websites we will no longer have control over the way in which any information is collected from you through those websites. Other websites may handle your information in a different way and should have their own privacy policies.

 

How can you find out what information we hold about you?

If at any time you wish to know what information we hold about you, please contact Henderson Wholesale Limited Customer Services at:

Henderson Wholesale Ltd, PO Box 49, Hightown Ave Newtownabbey BT36 4RT

Telephone: (028) 90343316 E-mail: customerservices@henderson-group.com

 

Your other rights over the information

Depending on the information we are using and under certain circumstances, you have rights under data protection laws in relation to some of the information you provide that can identify you (which is known as personal data under data protection laws).

 

You have the right to:

* Request access to your personal data;

* Request correction of your personal data;

* Request erasure of your personal data;

* Object to processing of your personal data;

* Request restriction of processing your personal data;

* Request transfer of your personal data; and

* Right to withdraw consent.

 

If you want to exercise any of the above rights, please contact us at the address or email address above and let us know.

 

Your right to lodge a complaint

If you are not happy with how your information has been handled you have the right to lodge a complaint with a supervisory authority. The UK supervisory authority for data protection issues is the Information Commissioner's Office (www.ico.org.uk) (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.

 

Full company details for Henderson Wholesale Limited:

Henderson Wholesale Limited, PO Box 49, Hightown Ave Newtownabbey BT36 4RT

Company No: NI000068

 

What if there are changes to this Privacy Policy?

Occasionally, to better protect you and in accordance with the law, we may need to update our Privacy Policy. We reserve the right to amend, update or replace this Privacy Policy at any time and your continued use of our website will constitute your acceptance of any such changes we may make. Any changes we make will be shown here, so please make sure you check this page from time to time.