Please read this notice carefully. It contains important information about how we process your personal information.

Who we are and how we approach data privacy

We are KP Snacks Limited (Company Registration No. 08314505, Registered Office: Fifth Floor, The Urban Building, 3-9 Albert Street, Slough, SL1 2BE).

We are the Data Controller for the purposes of the Data Protection Act 1998 and, from 25 May 2018, we will be the Controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679).

As a company we are committed to protecting and respecting the privacy of your personal information. We want you to be confident that your information will be properly protected whilst in our possession.

This notice explains how we, and carefully selected third parties we work with, will collect and use the personal information of our consumers, users of our websites, job applicants and, where relevant, customers and suppliers. If this describes you, please read this notice carefully and make sure you're comfortable with the content.

Our representative for the purpose of data protection compliance can be contacted at: data@kpsnacks.com.

If you have any questions about our use of your personal information, or you wish to exercise one of your rights under data protection legislation, please contact us. A summary of your rights is detailed in this notice.

Our websites

This notice details how we use information you provide to us, including through the "Contact Us" function which we have on some of our websites:

• www.kpsnacks.com
• www.mccoys.co.uk
• www.hulahoops.com
• www.kpnuts.com
• www.butterkist.co.uk
• www.pom-bear.co.uk
• www.tyrrellscrisps.co.uk – Collectively referred to in this notice as our Websites.

Any other external websites that may be linked to our Websites will be subject to their own data protection statements/privacy policies which may be different to this notice. You should check carefully the content of those third party notices before you submit any personal information to them.

Unfortunately, the transmission of information through the internet is never completely secure. Although we do our best to protect your personal data at all times, we cannot guarantee the security of the data you send to us through our Websites. Any transmission made is therefore at your own risk. Once we have received your information we use strict procedures and state of the art security features to protect against unauthorised access.

Information we collect from you and how we use it

We hope the following table helps you to understand what information we may collect, in what circumstances and how we use that information (including how long we retain it for).

(A) Information you give to us ("Voluntary Information")

This is information you give to us about you by:

1. Contacting us with an enquiry or to report a problem with our products or our Websites

What is collected and how we use that information

In order to process your enquiry and/or investigate a problem we may ask you to provide contact information (which may include some/all of the following: name, address, telephone number and email address). We may make up a file of the enquiry/problem which will contain any personal information you have given us.

We will only use your personal information to investigate and respond to you with the outcome of your enquiry/our investigation.

You do not have to provide this information to us; it is entirely voluntary. However, we may be limited in our ability to respond to you if contact information is not provided. We will only correspond with you in the way you have asked us to.

It is in our legitimate interests to process this information in order to deal with your enquiry/investigate the problem you've raised.

If your enquiry relates to an issue with one of our products we may request additional personal data from you in order to fully investigate. If medical information is required we will contact you separately about this using the contact information you have provided. Medical information is a special category of data and we will need your express consent to handle it.

How long we will keep it for

Up to 3 years. Access to this information will be restricted on a "need to know" basis.

2. Entering a promotion on our Websites or through a telephone number referenced on our product

What is collected and how we use that information

If you decide to enter a competition through any of our Websites/by phone, you may be asked to provide some basic contact information (e.g. name, email address and telephone number) so that we may contact you if you are a winner in that competition. As part of entering into the competition you will be asked to consent to us processing your data in line with this notice. If you do not agree with the content of this notice you should not enter the competition.

Dependent on the type of competition you may also be asked to provide other personal information as part of the entry criteria (e.g. a photograph of yourself with one of our products). You must not submit any photos that contain images of other people unless you have that person's express consent. You will need to inform them of how that image will be used as set out in this notice and the terms and conditions of the promotion.

In entering the competition, you confirm that you meet the eligibility requirements of the competition (including any age restrictions). We may require you to provide proof of your eligibility. We reserve our right to disqualify you are found to be in breach of the competition terms and conditions.

How long we will keep it for

3 months from the end of the competition period.

3. Entering a promotion we run through our pages on various social media platforms (e.g. Facebook, Twitter)

What is collected and how we use that information

If you decide to enter a competition through our page(s) on a social media platform you will, in entering the competition, provide your personal information in the form of your online profile and this notice will apply.

A link to this notice is contained on all our corporate social media pages.

Your act of entering the competition will show your consent to us (including any agency we appoint to administer the competition on our behalf) processing your online profile for the purpose of administering the competition.

If you are selected as a winner we will contact you through your online profile via direct personal messaging. At this stage, we may ask you for additional personal information so that we can administer your prize (e.g. contact name, address and email address). You are free to choose whether or not to give us this information. Any information you provide will show your consent to us processing that information for the purpose of administering your prize. If you do not provide this information we may be unable to distribute your prize. We will discuss this with you at the time.

If the competition involves the submission of a photograph containing your image, this is your personal information and will be processed in accordance with this notice. You must not submit any photos that contain images of other people unless you have that person's express consent. You will need to inform them of how that image will be used as set out in this notice and the terms and conditions of the competition.

Before entering a competition through a social media platform you should check the privacy notice of the platform to ensure you're comfortable with how they may also use your personal information.

In entering the competition, you confirm that you meet the eligibility requirements of the competition (including any age restrictions). We may require you to provide proof of your eligibility. We reserve our right to disqualify you if you are found to be in breach of the competition terms and conditions.

How long we will keep it for

3 months from the end of the competition period.

4. Filling in our online job application and the subsequent application process

What is collected and how we use that information

If you apply for a job through our Websites you will be asked to complete our online application form. This will ask for personal information about you (including your name, address (past and present), telephone number, email address, job history and qualifications). During the application process, through the online portal, you are able freely to delete your own profile and therefore the personal data you have submitted to us.

All of the information you provide during the application process will only be used for the purpose of processing your application (prior to possibly entering into an employment contract), or to fulfil legal requirements. This includes any information collected during the interview process, assessment days and personality testing.

We will not share any of this personal information for marketing purposes. The information you provide will be stored securely by us and our data processors. This captures data in both electronic and paper form.

We will use the contact information you provide to keep you up to date on the progress of your application. We will use the other information you provide to assess your suitability for the role you have applied for.

If we make a conditional offer of employment to you we may ask you to provide additional information so that we can carry out pre-employment checks (such as proof of ID, proof of qualifications and referee and health information).

Information about your health is a special category of data; we will only ask for it after a job offer has been made and we will need your express consent to process it.

If you're asked to provide referee contact information please ensure you firstly have the express consent of that individual to provide his/her contact information to us.

You may also be asked to provide evidence of your right to work in the UK and/or complete a Disclosure and Barring Service check.

How long we will keep it for

Your personal information will be held for the duration of the application process.

If successful, your personal information will be retained and held in line with our Transparency Statement for employees. You will receive a copy of this in your induction pack.

If unsuccessful but you consent to us keeping your data on file (in case any other opportunities arise which we feel may be of interest), it will be held for renewable periods of 12 months. Otherwise we will delete your data within 6 months of you being informed you have not been successful.

If successful, any of your special category data will be retained and held in line with our Transparency Statement for employees. You will receive a copy of this in your induction pack.

5. Corresponding with us (for example by email, phone or letter)

What is collected and how we use that information

When you contact us, any personal information you provide will be protected and kept confidential in the same way as we treat our own commercial information.

We will monitor any emails we receive (plus attachments) for any viruses or malicious software. We will promptly delete any email which is illegal or presents harm to us.

How long we will keep it for

We will keep a record of this correspondence for audit purposes for a period of up to 3 years.

6. Business contact information

What is collected and how we use that information

We will keep:

1. A record of business contacts of our customers, suppliers, advisers and agents and their contact information in order to manage our commercial relationship with that third party and perform contractual obligations (i.e. it is necessary for us to perform a contract ); and
2. A record of contacts from competent authorities and regulators linked to our industry, together with their contact information, in order to comply with a legal obligation.

We may send business contact information to third parties to nominate their business for an industry award or accreditation and/or to understand how we are performing. In this instance, we will only disclose personal information with the relevant person's prior consent. This is in our **legitimate interests ** and does not undermine your data rights.

How long we will keep it for

Up to 2 years from when we are notified that the contact in question no longer has a relationship with us.

(B) Information we collect about you and your device

Each time you visit our Websites we will automatically collect the following information:

1. Technical information, including your operating system, the browser you use (Device Information); and
2. Details of your use of our Websites including traffic data, the resources you use, where you have clicked through to our website from that of a third party, the domain name of the connecting website (Log Information)

What is collected and how we use that information

Some online identifiers (such as static IP addresses) are your personal information.

We collect Device Information so that we can ensure adequate technical support for our Websites and ensure they are functioning properly on all operating systems/browsers. We want to ensure the content of our Websites are being presented to you in the most appropriate way to ensure they are easy to use/navigate. We also need this information in order to allow you to participate in interactive features on the Websites where you chose to do so.

We collect Log Information so that we can better understand how our Websites are used and improve their functionality/content. We want to provide you with a customised service.

Your Device Information and Log Information will be combined with that of our other users and reported back to our advertisers in statistical form. It will not be possible to identify you from this aggregated information.

These activities are in our legitimate interests (i.e. we have a justifiable reason for processing your information in this way). We use cookies and pixel tags on our Websites:

• A cookie is a small text file sent to your computer or device;
• A pixel tag is an invisible tag placed on certain parts of our Site. It does not leave a footprint on your computer/device.

You can manage this automatic collection of data by adjusting your cookie settings. More information can be found here and at http://www.allaboutcookies.org/.

We use Google Analytics Software Solutions to track and report on general patterns of activity on our website at statistical level. More information about this and how Google Analytics Solutions uses your Device and Log Information can be found at www.google.com/policies/privacy/partners

The Google Analytics cookies we use are:

• __utma
• __utmb
• __utmc
• __utmz

These cookies enable us to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

How long we will keep it for

Default expiration times per Google Analytics:

developers.google.com/analyticsjs/cookie-usage

( C ) Information we receive from third parties ("Third Party Information")

We work with third party service providers including: recruitment agencies, and agencies to run our competitions for us. We will notify you when we receive information about you from these third parties and the purposes for which we intend to use that information.

What is collected and how we use that information

Recruitment Agencies:

Where appropriate, we will notify you when we receive information about you from these third parties and the purposes for which we intend to use that information.

Agencies running our competitions:

We engage selected third party agencies to run competitions on our behalf (each an Agency for this notice). In this case, the Agency is the Data Controller/Controller of the personal data you provide to enter the competition. The Agency will only provide us with the name and contact information of competition winners. Where a competition is run through a social media platform (e.g. Facebook, Twitter, Snapchat or Instagram) you should check the privacy notice of the platform to ensure you're comfortable with how they may use your personal information before entering the competition.

We carefully select the third parties we work with to ensure they handle your personal information in line with our standards and those required by law.

How long we will keep it for

See section (A)4. above

See section (A)2. and (A)3. above

Do I have to provide this information?

In most cases the personal information you provide to us in the table above is entirely voluntary. You are not under a statutory or contractual obligation to provide it to us. The only exceptions to this are:

1. Where you work for a company which has a contract with KP Snacks and you are involved in the performance of that contract/named as the relationship manager for that company. This is a contractual requirement. If you fail to provide your personal information your company may not be able to fulfil its contractual obligations to us; and
2. Where you apply for a job with KP and we have given you a conditional offer. Our offer may be conditional upon you providing evidence of your identity and/or your right to work in the UK. This is a legal requirement. If you fail to provide this personal information we may not be able to offer you employment.

Providing us with personal information of another person

If you need to provide us with personal information about another person you must obtain that individual's express consent to pass us their information. You should share this notice with those individual as it may also apply to them.

Marketing

We will not use your personal information to directly market our products and services to you.

If you send personal information to us indirectly through the third parties we work with (marketing agencies, recruitment agencies) these third parties will be in control of your personal information. You should check their privacy notices to ensure you're comfortable with their marketing activities and the marketing you have consented to.

Children

We appreciate that children may visit our Websites to learn more about our products. We take the protection of children's privacy very seriously.

We do not collect personal information about children. All our competitions are only eligible for individuals aged over 18. Where we establish that personal information relating to an individual under the age of 18 has been collected despite our best efforts we will cease to process that data except (where necessary) to notify the relevant parent or guardian of the processing that has been conducted.

We would encourage all parents and guardians to instruct their children in the safe and responsible use of personal data when using the internet.

Where we send your personal information

(i) Consumers of our products who contact us solely to report an issue with our products or our Websites: your personal information will only be shared with carefully selected IT providers whose systems we utilise for our core business processes and who provide us with IT support, and in very rare circumstances potentially with our insurers. Other than this, we do not share any personal information we receive from you with third parties.

(ii) In all other cases: we may share your personal information with:

1. Carefully selected third parties who provide a service to us to support our core operations, such as: processing our mail, communicating with consumers on our behalf (including via social media), running competitions and promotions, providing IT systems and administrative services and the development and improvement of internal systems and processes;
2. Competent authorities (statutory bodies, regulatory authorities, authorised bodies who have a role laid out by law);
3. Other organisations where we are legally obligated to disclose your personal information (such as requests made in the prevention and detection of crime) or where disclosure is necessary to protect the property, rights and safety of us and our staff;
4. Another company, if our business (or part) is purchased/taken over to ensure our products and services to you can be continually serviced or as part of discussions leading up to a sale/takeover;
5. Another company from whom we are looking to purchase assets, where the personal information is relevant to us assessing if those assets will improve our offering to customers and/or our business processes;
6. Other companies where we are trialling products and services which we consider may improve our offering to customers and/or our business processes; and
7. Other third parties where you have given your express consent or where we reasonably believe a third party is acting on your behalf.

Whenever we share your personal information with third parties we will take all reasonable steps to ensure appropriate safeguards are in place to protect your personal information and your privacy rights.

Where we store your data

The data that you provide to us as set out above may be transferred to, and stored at, a destination outside of the European Economic Area (EEA) by us and/or by the carefully selected third parties we work with.

We and third parties we work with may use cloud platforms to store your personal information. A cloud is a network of remote servers hosted on the internet. We will, and our third parties will, only use cloud platforms which give adequate guarantees that your personal data is secure.

Where your data is held outside of the EEA, on a cloud or otherwise transferred, we will ensure this is only to a country which has been deemed adequate by a competent data protection regulator or where adequate protections have been put in place to safeguard the data (to the same standards as prescribed within the EEA). This includes contractual protections.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this notice. All information you provide to us is also stored on our secure servers.

Your rights

We recognise that the personal information we hold about you belongs to you and it is right that you have control over that personal information. We have detailed below a summary of your legal rights.

You can:

• Ask us to have access to, and for a copy of, the personal information we hold about you;
• Request that we amend or delete your personal information;
• Ask us to stop processing your personal data altogether or in a certain way;
• Change your mind about how you have agreed we can use your personal information. If you have given us consent to use your personal information in a specific way you can withdraw it. This means that we will stop processing your personal data in the way you have objected to from the date that your permission is withdrawn;
• Issue a complaint to the appropriate authority – see www.ico.org.uk for more information; and
• Request that we transfer your personal information to another provider (this is known as data portability).

If you would like to exercise any of these rights, or discuss them in more detail, please contact us using the email address below. We need to make you aware that even where you exercise a right detailed above, we may not be able to comply with that request if an exception in law applies. Where this is the case we will notify you and explain why we're unable to meet your request.

Changes to this notice

We keep this notice under regular review. This notice was last updated on 23 May 2019.

Any changes we make to this notice will be posted on our Websites with a prominent notice and, where appropriate, we will notify you by email.

If, in the future, we wish to use your personal information in a way not set out in this notice we will notify you and seek your permission to do so.

Contact us

If you would like to request further information about this notice or the way in which we handle your personal information, please contact us at:

DATA@KPSNACK.COM