Data protection

This notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us in connection with your use of our website. It covers information that could identify you and which relates to you (“personal data”). In the context of the law and this notice, “process” means any use of personal data, including to collect, store, transfer, use or otherwise act on information. This notice tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal data. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal data.

We undertake to preserve the confidentiality of all information you provide to us.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Please note that our website is not intended for users under the age of eighteen (18) years old.

Our 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 or Website, we encourage you to read the privacy policy of every website/application you visit.

1. Our contact details

We are Agri-EPI Centre Limited, a company registered in England and Wales (Company Number 09922991) with registered office at Midlands Agri-Tech Innovation Hub Poultry Lane, Edgmond, Newport, England, TF10 8JZ. In this notice we refer to Agri-EPI Centre Limited as ‘The Agri-EPI Centre Ltd’, ‘Agri-EPI’, ‘Agri-EPI Centre’, ‘AEC’, ‘us’ or ‘we’.

Agri-EPI Centre is the controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this notice.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data privacy manager in the following ways:

• Full name of legal entity: Agri-EPI Centre Limited
• Email address: dataprotection@agri-epicentre.com
• Postal address: Agri-EPI Centre Northern Agri-Tech Innovation Hub, Easter Bush, Roslin EH25 9RG
• Telephone number: 0131 239 7100

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.

2. Data we process

We may collect, use, store and transfer different kinds of personal data relating to you. We have collated these into groups as follows:

• Identity Data includes information such as first name, last name, title, which you provide to us, details of your role within the company/organisation you work for and other identifiers that you may have provided at some time.
• Technical Data includes your 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 our websites and/or Website.
• Marketing Data includes your preferences in receiving marketing from us, communication preferences, responses and actions in relation to your use of our services.

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal data in law because it does not reveal your identity. For example, we may aggregate profile data to assess interest in a product or service or suitability for a project.

However, if we combine or connect aggregated data with your personal data so that it can identify you in any way, we treat the combined data as personal data and it will be used in accordance with this privacy notice.

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.

3. How we collect your personal data

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Marketing Data by filling in forms or by corresponding with us by post, phone, e-mail, through our Website or otherwise. This includes personal data you provide when you:
  • 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 https://agri-epicentre.com/cookies-notice/ for further details.

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 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.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

The next part of this notice tells you how we use your personal data in relation to our different processing activities.

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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service we are providing to you but we will notify you if this is the case at the time.

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.

5. Information we process for the purpose of legitimate interests

We may process information on the basis there is a legitimate interest, to you or to us of doing so.

For example, we may process your Identity, Contact, Technical, Marketing and Profile Data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our business (our legitimate interests in keeping our records updated and to study how Members use our products/services);
• responding to unsolicited communication from you to which we believe you would expect a response (our legitimate interests in communicating with our Members);
• insuring against or obtaining professional advice that is required to manage business risk (our legitimate interests in protecting our business and managing risk);
• administering and protecting our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (our legitimate interests in running our business, provision of administration and IT services, network security, preventing fraud and in the context of a business reorganisation or group restructuring exercise);
• using data analytics to improve our Website, other products/services, marketing, Member relationships and experiences (our legitimate interests in assessing types of customers for our products and services, to keep our website and the Website updated and relevant, to develop our business and to inform our marketing strategy);
• making suggestions and recommendations to you about goods or services that may be of interest to you (our legitimate interests in developing our products/services and growing our business); and
• protecting your interests where we believe we have a duty to do so.

6. Information we process in order to comply with a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

We also need to retain financial records (which may include your Identity, Contact and Profile Data) in order to comply with accountancy and tax rules.

7. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above in this notice.

• Service providers acting as processors who provide IT and system administration services, including:
  • Jellyhound Ltd providing application support based in the UK;
  • Network ROI Ltd providing application support based in the UK; and
  • Kinsta Ltd providing hosting based in the UK.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK 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 UK who require reporting of processing activities in certain circumstances.
• 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 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.

8. Communicating with us

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply.

We record your request and our reply in order to increase the efficiency of our business and we do so on the basis of our legitimate interests in managing our business and communications.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you and provide our services.

9. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our Website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our Website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our Website.

We use cookies in the following ways:

• to track how you use our website
• to record whether you have seen specific messages we display on our website

We provide more information about the cookies we use in our cookie policy: https://agri-epicentre.com/cookies-notice/.

10. Data processing

Our Website is hosted in the United Kingdom and your data will not be transferred out of the EEA.

11. Changes to this notice and your duty to inform us of any changes

We keep our privacy policy under regular review. This version was last updated on 28^th April 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes either by email or by updating your details within our Website.

12. Your legal rights in relation to your personal data

At any time you may review or update personally identifiable information that we hold about you, by contacting us by email dataprotection@agri-epicentre.com.

In certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights set out below, please contact us

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.

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.

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.

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. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios.
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

13. Removal of your information

If you wish us to remove personally identifiable information from our Website, you should adjust your details using the settings options, or email us at the following address: dataprotection@agri-epicentre.com.

14. Personal data retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

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.