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Privacy Policy

Introduction

This privacy notices explains how we use 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.

The Glossary (section 9 of this page) sets out the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website.

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

It is important that you read this privacy notice together with any other privacy notice 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. This privacy notice supplements other notices and privacy policies and is not intended to override them.

1.2 Controller

Mowi Consumer Products UK Limited is the controller and responsible for your personal data (collectively referred to as “Mowi“, “we“, “us” or “our” in this privacy notice). Mowi Consumer Products UK Limited is one legal entity among several forming a group of entities (referred to as “Mowi Group“).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the DPO via the Contact details below.

1.3 Contact details

If you have any questions about this privacy notice or our privacy practices, please contact our DPO:

Email address:
mowi.uk@mowi.com

Postal address:
FAO Mrs J Whittem
Mowi CP UK
Admiralty Park
Rosyth
Scotland
KY11 2YW

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.

1.4 Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. 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.

1.5 Third-party links

This 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 notice of every website you visit.

2. The data we collect about you

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 First name, last name, username or similar identifier
Contact Data Email address and telephone number
Technical Data Internet protocol (IP) address, 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.
Usage Data Information about how you use our website, products and services
Marketing and Communications Data Your preferences in receiving marketing from us and our third parties and your communication preferences

 

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 personal data as it will not directly or indirectly reveal your identity.

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.

2.1 If you fail to provide personal data.

Where we need to collect personal data by law, or under the terms of a contract we have 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. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

3. 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 and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • subscribe to our service or publications;
    • 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 (such as Google);
      • advertising networks (such as Google Display Network); and
      • search information providers (such as Google).

4. How we use your personal data

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.
  • 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.
  • Where we need to comply with a legal obligation.

Visit section 9 of this page to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.1 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 manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) 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 (a) Identity

(b) Contact

(c) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) 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) (a) Identity

(b) Contact

(c) Technical

(a) 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)

(b) 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 (a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) 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 (a) Technical

(b) 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 (a) Identity

(b) Contact

(c) Technical

(d) Usage

(f) Marketing and Communications

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

4.2 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

4.2.1 Promotional offers from us. We may use your Identity, Contact, Technical and Usage 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 and you have not opted out of receiving that marketing.

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

4.2.3 Opting out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

4.2.4 Cookies. You can use the cookie control on our website to decide which cookies you wish to accept. For more information about the cookies we use, please see our Cookie Policy.

4.2.5 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.

4.3 Matomo Analytics

Matomo Analytics is an open source web analytics platform used by Mowi in order to measure, collect, analyse and report visitors data for purposes of understanding and optimizing the website.

  1. Purpose of the processing

Matomo is used to analyse the behaviour of the website visitors to identify potential pitfalls; not found pages, search engine indexing issues, which contents are the most appreciated. Once the data is processed (number of visitors reaching a not found pages, viewing only one page…), Matomo is generating reports for website owners to take action, for example changing the layout of the pages, publishing some fresh content… etc.

Matomo is processing the following personal data:

  • Cookies
  • IP address
  • User ID
  • Location of the user

And also:

  • Date and time
  • Title of the page being viewed
  • URL of the page being viewed
  • URL of the page that was viewed prior to the current page
  • Screen resolution
  • Time in local timezone
  • Files that were clicked and downloaded
  • Link clicks to an outside domain
  • Pages generation time
  • Country, region, city
  • Main Language of the browser
  • User Agent of the browser

The processing of personal data with Matomo is based on explicit consent. Your privacy is our highest concern. That’s why we will not process any personal data with Matomo unless you give us clear explicit consent by clicking on the ‘Accept cookies’ button.

  1. Recipient of the personal data

The personal data received through Matomo are sent to our service provider: InnoCraft, 7 Waterloo Quay PO625, 6140 Wellington, New Zealand (link to Matomo cloud privacy policy.)

Matomo data is hosted in Germany.

  1. Retention period or criteria used to determine the retention period

Data retention for data stored in Matomo:

  • all visits and actions raw data are deleted after 24 months 14 days.
  • aggregated reports are never deleted.
  1. The existence of each of the data subject’s rights

As Matomo is processing personal data on explicit consent, you can exercise the following rights:

  • Right of access: you can ask us at any time to access your personal data.
  • Right to erasure: you can ask us at any time to delete all the personal data we are processing about you.
  • Right to portability: you can ask us at any time for a copy of all the personal data we are processing about you in Matomo.
  • Right to withdraw consent: you can withdraw your consent at any time by clicking on the ‘Managing consent’ button.

 

  1. The right to lodge a complaint with a supervisory authority

If you think that the way we process your personal data with Matomo analytics is infringing the law, you have the right to lodge a complaint with a supervisory authority.

  1. Whether the provision of personal data is part of a statutory or contractual requirement; or obligation and possible consequences of failing to provide the personal data

If you wish us to not process any personal data with Matomo, you can opt-out from it at any time. There will be no consequences at all regarding the use of our website.

4.4 Google Analytics

To better understand how visitors interact with our website and to offer a more personalized experience, we use Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. The information gathered may include, but is not limited to, IP addresses, browser types, pages visited, duration of visit, and referral sources. This data is used to analyze user interactions with our website, allowing us to improve functionality and user experience. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. Google Analytics deploys cookies on your computer to identify how you engage with our site. However, no personally identifiable information is collected. Your IP address is anonymized before being sent to Google servers, ensuring your anonymity.

For more information on Google Analytics and how it uses your data, please refer to Google’s privacy policy: https://policies.google.com/privacy

If you prefer, you may opt out of Google Analytics by withdrawing consent for Google to use cookies in the Cookie Settings or by installing the Google Analytics Opt-out Browser Add-on.

5. 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 Purposes for which we will use your personal data (section 4.1 above).

  • Internal Third Parties as set out in the Glossary (section 9 of this page)
  • External Third Parties as set out in the Glossary (section 9 of this page)
  • 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 notice.

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.

6. Place of processing and transfers to third countries outside the UK/EU/EEA

Mowi processes personal data at our operating offices and in any other locations where the parties involved in the processing are located. Depending on your location, data transfers may involve transferring your personal data to a country other than your own. If any such transfers take place, you may find out more by contacting Mowi using the information provided below.

Mowi will restrict the transfer of personal data to third countries outside the EU/EEA as to what is necessary to provide a user friendly and satisfactory website, send newsletters to our subscribers as well as to receive and respond to inquiries sent to us through the appropriate channels, i.e. the online form on our website and emails addressed to the contact information provided below.

7. Data retention

7.1 How long will you use my personal data for?

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. In some circumstances you can ask us to delete your data, see paragraph 8.

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.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. In certain circumstances you can ask us to delete or remove your personal data.
  • Object to processing of your personal data in certain circumstances, you can ask us to stop processing your personal data.
  • Request restriction of processing of your personal data. In certain circumstances you can ask us to suspend the processing of your personal data.
  • Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us.

8.1 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.

8.2 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.

8.3 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.

9. Glossary

9.1 LAWFUL BASIS

Legitimate Interest 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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data 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.

Performance of Contract 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 such a contract.

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.

9.2 THIRD PARTIES

Internal Third Parties

Other companies in the Mowi Group [acting as joint controllers or processors] and who are based in Norway and Poland provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors based in the UK, Poland, USA, France and Norway who provide IT, system administration services, digital marketing services, hosting, email marketing and data storage.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK, Norway and Poland who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.