Manna Pro UK’s Privacy Statement
In these unprecedented times, data privacy and the protection of Personal Data are of paramount concern to our animal care and nutrition customers, vendors, and business partners around the globe.
Whether you are interacting with our Vet’s Best, Simple Solution, Bags on Board, or OUT! Pet Care divisions or are engaging us through our website, mannaprouk.com, Manna Pro UK Ltd (“Manna Pro”) respects and is committed to your privacy in connection with the processing of your Personal Data. This is why we want you to have a clear picture of how we intend to treat your Personal Data and how it will be processed and managed by us.
This privacy statement (“Privacy Statement”) contains important information regarding our privacy practices and the choices we offer you with respect to your Personal Data. If you choose to provide us with your Personal Data, you are telling us that you have read, understand, and accept the privacy practices summarized in this Privacy Statement. We strongly encourage you to read this Privacy Statement in its entirety before submitting any Personal Data to us.
You will always be able to locate this Privacy Statement whenever necessary, as it is prominently displayed on our website at mannaprouk.com. Further, we are always here to address any questions regarding this Privacy Statement or any of our related privacy policies, procedures, and practices. Should you do have any additional questions, please do not hesitate to contact our Privacy Manager at +44 (0) 1733 404390 or at email@example.com.
Effective Date: 15/10/2020
Tony Tickner, Vice President International Division
Click on one of the links below to jump to a specific section:
- Scope of this Privacy Statement
- Purposes for Which We Process Your Personal Data
- Personal Data We Collect by Automated Means
- Who Has Access to Your Personal Data
- Links to Other Sites
- International Transfers of Your Personal Data
- Legal Ground(s) for Processing Your Personal Data
- Your Rights with Respect to Your Personal Data
- How We Protect Your Personal Data
- Retention of Your Personal Data
- Revisions to this Privacy Statement
- Our Privacy Concern Handling Process
- Our Contact Information
Scope of this Privacy Statement
This Privacy Statement applies to our processing of the Personal Data of all the animal care and nutrition customers, vendors, and business partners of Manna Pro and all visitors to mannaprouk.com, when the General Data Protection Regulation (EU 2016/679) applies to such Personal Data. In this Privacy Statement, we use the word “you” to refer to anyone within the scope of this Privacy Statement.
When we use the term “Personal Data” in this Privacy Statement, we mean any information that relates to an identified or identifiable natural person and is sufficient to enable such person to be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, or an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This can be, for example, a name, street address, an e-mail address, or a telephone number.
Manna Pro has operationalized compliance in connection with the EU General Data Protection Regulation (GDPR). The GDPR replaced the Data Protection Directive 95/46/EC and similar domestic legislation in the various EU Member States with respect to most (but not all) areas of data privacy and protection. Significant changes include, but are not limited to:
- Increased fines (up to €20 million or 4% of global annual turnover);
- Enhanced rights for individual data subjects;
- Increased accountability;
- Changes in the ways that personal data should be obtained and held, including a requirement to document personal data processing activities; and
- Changes in the rules for responding to data breaches, requiring most data breaches to be reported to the relevant data protection authority (“DPA”) within seventy-two (72) hours of discovery.
Purposes for Which We Process Your Personal Data
We may collect Personal Data from you through our website or by other means (such as via email, mail, and phone). We may also on rare occasions receive Personal Data about you from other sources, such as public databases, verification services, and permission-based marketing lists. The principal ways you may provide the Personal Data, the types of Personal Data you may submit, as well as the ways we may process the Personal Data, are listed below.
Business Purposes – On our website you may share your Personal Data in connection with your business relationship with us or the products we offer. We use these details to facilitate your use of our website or mobile application. You may also choose to provide, or we may obtain, your Personal Data at trade shows or from our business partners. It is in our legitimate business interests to use this Personal Data so that we can manage our business relationships and carry out our marketing and sales activities.
Contact – You may contact us with questions, requests, or comments through the “Contact Us” link on our website or via the contact information provided in the “Our Contact Information” section of this Privacy Statement. When you do so, we may ask you for your Personal Data to verify your identity or to track the inquiry internally to ensure we appropriately respond to your questions, requests, or comments.
Contractual Obligations – If you are a customer, vendor, or business partner, we may ask you to provide Personal Data such as your name, contact details, or business and financial details to establish and administer your account, process payments, and for compliance with internal and legal requirements. We use your Personal Data for this purpose so that we can comply with our contractual obligations to you. It is in our legitimate business interests to meet our contractual obligations to you.
Feedback – You may be able to submit feedback on our website. If you choose to give us your feedback, we may ask you for your Personal Data. We may also ask you about your experience using our website. It is in our legitimate business interests to use the Personal Data you provide to enhance our websites, evaluate the quality of our products, and to communicate with you about our products.
Information Technology Security – We may collect Personal Data when detecting and defending against security threats in accordance with our legitimate business interests and our legal obligations. We use various IT tools to detect and defend against online security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content), to promote business continuity of our information systems and assets, and to maintain optimal performance of our IT systems.
Other Uses of Personal Data – We may use the Personal Data for internal general business purposes in accordance with our legitimate business interests. These purposes include administration of our website, data analytics, fraud prevention, and compliance with our legal obligations, standards, policies, and procedures. We may obtain your explicit consent to collect and use certain types of Personal Data when we are required to do so by law.
Personal Data We Collect by Automated Means
When you visit and interact with our website or application, we may collect certain information that does not inherently reveal your specific identity in order to learn how to best tailor our website for our visitors’ needs.Examples of what other information we may collect and how we and third-party service providers may collect this information include:
Aggregated Information – Aggregated user information does not personally identify you or any other user (for example, we may aggregate user information to calculate the percentage of our users who come from a particular region of the world). Aggregated data is treated strictly in accordance with this Privacy Statement.
Browser and Device Information – Certain information is collected by most browsers or automatically through your device, such as your computer type, operating system, name and version, device manufacturer and model, Internet browser type and version, and the name and version of the online services you are using. We use this information to ensure that our website functions properly.
IP Address – Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP).An IP address may be identified and logged automatically in our server log files whenever a user accesses our website, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We may use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering our online platform. We may also derive your approximate location from your IP address to understand from what regions of the world our website visitors come.
Who Has Access to Your Personal Data
We do not sell or otherwise disclose your Personal Data except as described in this Privacy Statement. Access to Personal Data relating to you is limited. It is our policy that persons within the organization should only have access to Personal Data on a need-to-know basis.
Under certain circumstances, we may share your Personal Data with third parties:
- Because Manna Pro is a global company, we may share your Personal Data with our corporate affiliates, including those in the United States. These affiliates will maintain the privacy of your Personal Data in accordance with this Privacy Statement.
- We may also disclose your Personal Data to our business partners, such as suppliers and service providers, acting on behalf of or for Manna Pro under our instructions for the limited and specific purpose of assisting Manna Pro with its normal business operations. In no event will that limited and specific purpose be inconsistent with this Privacy Statement. In all cases, these business partners may only use this information in connection with providing support to Manna Pro.
- Sometimes a directive, law, regulation, court order, or other judicial, regulatory, or supervisory process requires us to provide Personal Data to a governmental body or party to a private lawsuit.
- Finally, we may disclose certain Personal Data if Manna Pro is involved in a merger, acquisition, or sale of all or a portion of its assets, or we are required to bring or defend against litigation or any regulatory proceeding between, or relating to, you and us, or we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights, our property, our customers, or anyone else who could be harmed by such activities.
We will only transfer your Personal Data to the above mentioned third parties for the purposes stated in this Privacy Statement, and only to the extent that is permitted under the applicable data protection law.
Third parties to whom we transfer your Personal Data are themselves responsible for compliance with applicable data protection law. We are neither responsible nor liable for the processing of your Personal Data where we do not determine the purposes and means of the processing of that Personal Data.
Links to Other Sites
Our website and communications may provide links to other websites, including to social networks or business partners that may use our logo(s) as part of a co-branding agreement. To the extent that any linked products or services are not provided by Manna Pro, we are not responsible for the products or services, or any of the content found on these websites. If you provide information on and use third-party services or websites, the privacy policies and terms of service on those websites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting and of your Personal Data. Also, please be advised that if you disclose Personal Data through public forums or message boards, this information may be collected and used by others. We do not monitor these public spaces and take no responsibility for the content, security, or confidentiality of any information posted thereon.
International Transfers of Personal Data
We take steps to protect your Personal Data no matter what country to which it is transferred. We have procedures and controls in place, as appropriate, to help ensure this is the case. That said, in connection with our business, and for administrative, management, and legal purposes, when processing Personal Data in line with this Privacy Statement, we may transfer your Personal Data outside the European Economic Area (“EEA”), including to the United States. If we transfer your Personal Data outside the EEA, such as to our parent, Manna Pro Products, LLC, in the United States, we do so in accordance with applicable data protection laws, including on the basis of an EU Commission adequacy decision, where the transfer takes place pursuant to recognized appropriate safeguards, and/or where a specific derogation is permissible.
Legal Ground(s) for Processing Personal Data
Under applicable data protection law, we are allowed to process Personal Data only if we can rely on one or more of the legal grounds for processing. The legal grounds we are most likely to rely on for processing Personal Data in relation to you are:
- Consent – In exceptional situations we may rely on your consent.
- Contract – The processing is necessary for performance of a contract with you/your company or to take steps at your request to enter a contract.
- Legal Obligation – The processing is necessary to ensure we comply with our legal and regulatory obligations. For example, to comply with our social insurance and tax-related obligations.
- Legitimate interests – The processing is necessary for our or a third party’s legitimate interests. We, or a third party on our behalf, may have legitimate interests in carrying on, managing, and administering our normal business operations and may need to process your Personal Data in connection with the same. Your Personal Data will not be processed on this basis if our or a third party’s legitimate interests are overridden by your own interests, rights, and freedoms.
Your Rights with Respect to Your Personal Data
Under applicable data protection law, you may have the following rights:
- To obtain access to the Personal Data that we hold about you;
- To object on grounds relating to your particular situation to our processing activities where you feel they have a disproportionate impact on your interests, rights, and freedoms;
- To request to review, revise, correct, or update any of the Personal Data we may have about you free of charge, if you believe that your Personal Data that we possess is, or has become, incorrect or is incomplete;
- To request that we restrict the processing activities related to your Personal Data (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- To request that we erase your Personal Data;
- To have Personal Data, which you have voluntarily provided to us, produced in a structured, commonly used, and machine-readable format, including for the purpose of transmitting it to another party;
- To object to the processing of your Personal Data for direct marketing purposes; and
- To lodge a complaint with a DPA with regard to our processing of your Personal Data.
Please note that the above individual rights are not absolute, and we may be entitled to refuse requests where certain exceptions apply. If you have given your consent and you wish to withdraw it, please contact our Privacy Manager at +44 (0) 1733 404390 or at firstname.lastname@example.org.
Please note that where our processing of your Personal Data relies on your consent and where you then withdraw that consent, we may not be able to provide our products to you and/or it may affect the provision of those products. If you have any questions about your rights regarding your Personal Data, please simply write to us at the postal address provided in our Contact Information below or contact our Privacy Manager at +44 (0) 1733 404390 or at email@example.com, where you may initiate a request to access, reject, correct, restrict, or erase your Personal Data, or where you may initiate a request for transfer of your Personal Data or initiate a request that we refrain from sending you marketing information.
How We Protect Personal Information
In proportion to the nature, scope, context, and purposes of processing your Personal Data, as well as the varying degrees of risk associated with processing the same, we maintain appropriate administrative, technical, and/or physical safeguards and security measures to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction and to ensure a level of security appropriate to the risk. However, we cannot absolutely guarantee the security of Personal Data, as no electronic data transmission or processing of Personal Data is completely secure. If an incident is reported affecting your Personal Data, we will investigate and comply with all required reporting obligations.
Retention of Your Personal Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Statement. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (such as, if we are required to retain your information to comply with applicable tax/revenue laws, resolve disputes, and enforce our agreements).
Where we rely on legitimate interests as a reason for retaining your Personal Data, we have carefully considered whether or not those interests are overridden by your rights and freedoms and have concluded that they are not.
Please note that for corporate law and tax purposes, we are required to keep certain data, which might include Personal Data we hold about you (whether directly or indirectly), for a period of six (6) years after the information has lost its relevance. In certain limited cases, local legal requirements may result in the preservation or retention of Personal Data for longer periods of time.
Revisions to this Privacy Statement
Manna Pro reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revise portions of our policies and this Privacy Statement at any time, consistent with the requirements of applicable law. If we change the Privacy Statement in a material way, we will provide appropriate notice to you. The “Effective Date” at the top of this Privacy Statement reflects the date of the most recent revisions.
Our Privacy Concern Handling Process
Manna Pro is committed to resolving concerns about your privacy and our processing of your Personal Data. Individuals with inquiries or concerns regarding this Privacy Statement should first contact our Privacy Manager at +44 (0) 1733 404390 or at firstname.lastname@example.org. In the event that resolution cannot be reached, individuals may also contact their local DPA, which may investigate your concern further.The local DPA in the UK is the Information Commissioner’s Office (ICO), which may be contacted online at https://ico.org.uk/global/contact-us/ or by telephone at (+44) 0303 123 1113.
Our Contact Information
If you have any questions or comments about this Privacy Statement and/or the processing of your Personal Data, please contact Manna Pro at +44 (0) 1733 404390 or at email@example.com. You may also write us at:
Manna Pro UK Ltd