Privacy Policy

This Privacy Policy will detail the following:

1. Our Privacy Promise
2. What personal data we may collect from you and how we use the personal data about you
3. Providing your personal data to others
4. Website Cookies
5. How you can access, update and remove your personal data from our system
6. Retaining personal data
7. Other websites
8. Keeping your data secure
9. Changes to our Privacy Policy
10. How to contact us

We are committed to safeguarding the privacy of our customers, suppliers and all of those who use the Sharpham Cheese website.

We take the collection, use and storage of your personal data very seriously and we promise to do our utmost to handle your personal data in a way that you would reasonably expect and ensure that it’s stored in a highly secure environment.

For the purposes of applicable data laws, the data controller is Sharpham Partnership Ltd, company number 02702613 and our registered offices are The Cheese Dairy, Sharpham Estate, Ashprington, Totnes, Devon, United Kingdom, TQ9 7UT

Policy key definitions:

• "I", "our", "us", or "we" refer to the business, Sharpham Partnership Ltd
• "you", "the user" refer to the person(s) using this website
• GDPR means General Data Protection Act
• Cookies mean small files stored on a user's computer or device

Key principles of GDPR:

Our privacy policy embodies the following key principles; (a) Lawfulness, fairness and transparency, (b) Purpose limitation, (c) Data minimisation, (d) Accuracy, (e) Storage limitation, (f) Integrity and confidence, (g) Accountability.

On the basis that it is necessary for the performance of a contract with you we use your information for the following purposes:

-  To allow us to handle your orders, deliver products and process your payments and refunds

-  To let you know about your orders The following provides a more detailed explanation of when we process personal data for contractual purposes:

a) Tour Bookings made via phone or on-site at Sharpham Estate – when booking a tour over the phone or on-site at Sharpham Estate, we will take a purchasers name, email address, telephone number and payment information (such as credit or debit card details). This data is inputted onto our online booking system and may also be written into our physical diary. This data is processed for the purposes of recording tour bookings, fulfilling a required service and enabling us to contact purchasers regarding their booking if necessary i.e. such as in the event of needing to organise a cancellation.

The legal basis for the processing of this data is contractual as it’s required for us to fulfill the requested service.

For all purchases made over the phone, receipts are either mailed to the purchaser or kept on-site in a secure safe to which only authorised employees have access to. All receipts kept on-site are confidentially destroyed after a period of 2 years.

All purchase data is kept for no longer than 7 years, after which it will be confidentially destroyed. Our physical diary is confidentially destroyed annually.

b) Purchases made via Sharpham Cheese website – when purchasing a product or service on the Sharpham Cheese website, we’ll process the following personal data supplied by customers at the point of purchase:

• Full name (first name and surname)
• Company name (if applicable)
• Delivery Address
• Billing Address
• Email Address
• Phone Number
• Payment Information (either credit card or debit card)

The legal basis for the processing of this data is contractual as it’s required for fulfilling a requested service for the supply of products/services, referencing sales and enabling us to contact purchasers when necessary, such as in the event of resolving complaints and issuing refunds.

Purchase data is kept for no longer than 7 years for the purpose of record keeping. After 7 years, purchase data is confidentially destroyed.

c) Product Purchases made on Sharpham Estate – for all products which are purchased on-site we only require the processing of payment information, if paying electronically. This will include credit or debit card information which is recorded by our card reader.

The legal basis for the processing of this data is contractual.

The following details other activity where we process personal data:

d) Website Usage – when using the Sharpham Cheese website, we may process personal data such as:

• Your IP address
• Your geographical location
• Your browser type and version
• Your operating system
• Referral source
• Length of visit (i.e. how long you’re on our website)
• Page views
• Website navigation paths
• Information about the timing, frequency and pattern of your website use when visiting the Sharpham Cheese website.

The source of the data detailed above is collected via Google Analytics which use Cookies to collect this data. We use this data for the purposes of obtaining information to help us analyse website traffic which will help us determine strategies to improve our website’s functionality and ultimately your user experience. For more information on Cookies, please refer to section 4 of this policy.

The legal basis for the use of Cookies for the purpose of tracking website visitor activity as previously detailed is consent, when you first visit the Sharpham Cheese website, we will ask you to consent to our use of our tracking cookies in accordance with the terms of this policy via our cookies banner/pop-up.

Some of the cookies used on our website are needed for operational purposes and are absolutely necessary for our website to function, and therefore the legal process for the use of these operational cookies is legitimate interests. We will not use these operational cookies to process any personal data.

e) Customer Website Accounts – our website provides the option to create a shopping account using a unique username and password generated by customers themselves.

To register for an account, the following personal data is required:

• Email Address
• User Generated Password

The legal processing of this data is consent as it’s the responsibility of the customer to create an account and is not required for contractual purposes.

Once an account is created, the customer is able to decide what personal data they would like their account to store for their convenience when making repeat purchases, such personal data could include:

• Full name (first name and surname)
• Company name (if applicable)
• Delivery Address
• Billing Address
• Phone Number
• Payment Information (either credit card or debit card)

If a customer closes their account, we may retain some of their information for up to 12 months after to deal with any disputes that may arise.

f) Enquiries - We may process personal data contained in any enquiry submitted to us regarding our services and products. This could be through any of the following:

• The contact form on our website
• Phone
• Email
• Social Media
• In person on the Sharpham Estate or whilst at external events

Personal data collected through an enquiry could be either, all or a selection of the following depending on the type of enquiry made:

• Full Name (first and surname)
• Email Address
• Phone Number

This data may be used to contact you to discuss the points contained in your submitted enquiry. Your personal data may then be kept on file for a maximum of 5 years for the purposes of record-keeping.

The legal basis for the processing of this data is legitimate interests for the purposes of being able to effectively respond to your submitted enquiry.
Please be aware that when enquiries are submitted via social media and personal data is shared, the privacy of this data is the responsibility of the social media network concerned. You can find out more information about the Privacy Policies of the social media networks that we have accounts with below:

• Facebook – https://www.facebook.com/about/privacy/update
• Twitter – https://twitter.com/en/privacy
• Instagram – https://help.instagram.com/155833707900388

g) Email Marketing - When subscribing to receive email marketing communications from Sharpham Partnership Ltd, we will collect the following personal data from you:

• Full Name (first and surname)
• Email Address

The legal basis for this data processing is consent. We will never send marketing emails to a recipient who has not positively opted in to receive these email marketing communications. You can opt-out of receiving email marketing communications by following the unsubscribe process which is supplied via a link at the bottom of our marketing emails or by emailing info@sharphamcheese.co.uk or by calling 01803 732 600.

Our email marketing communications are distributed via our chosen email supplier ‘MailChimp’ a leading marketing automation platform. Your personal data (name and email address) will also be stored on the MailChimp platform. MailChimp is situated in the U.S. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to the U.S. will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

MailChimp is a highly secure system and are members of the ANA, ESPC, OTA, and MAAWG. MailChimp also retain a law firm in the UK to consult on EU privacy issues. To find out more information on MailChimp’s security policies, please visit: https://mailchimp.com/about/security/

h) We contact you using any of your personal data identified in this policy in the circumstance that it’s within our customers' best interests, for example, when we need to cancel bookings, recall a product or any information relating to a recent purchase. The legal basis for the processing of this data is legitimate interests.

i) We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

j) We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

k) In addition to the specific purposes for which we may process your personal data provided in this Privacy Policy, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

We do not disclose your personal data to any third parties, except when we are required to do so for contractual purposes or by law for information such as a court order, witness summons, or complaint from governmental authorities.

The below details contractual circumstances when your details may need to be supplied to others outside Sharpham Partnership Ltd:

a) We may disclose your personal data such as your full name, delivery address, email address and phone number to our chosen couriers as reasonably necessary for the purposes of fulfilling a service contract so we can deliver purchases.

Our courier services are supplied by DHL and once we have passed on the personal data required for fulfilling the purchase contact, this personal data is then the responsibility of this organisation.

• DHL Privacy Policy

b) Financial transactions and invoice processes relating to our services are handled by the Sharpham Partnership Ltd team through the accountancy software, ‘Sage’. Sage stores both customer & supplier data in relation to invoicing and processing payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

At the end of each financial year, we share data contained on Sage such as full names, home/business addresses, phone numbers, email addresses and banking information with our accountant, Francis Clark LLP (registered address: Sigma House, Oak View Close, Edginswell Ln, Torquay TQ2 7FF) only to the extent necessary for the purposes of processing our end of year accounts.

You can find information about Sage’s privacy policy and practices at: https://www.sage.com/en-gb/legal/privacy-and-cookies/

c) In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

d) We may disclose your personal data to our insurers and/or professional advisers as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

The below details the legitimate interests circumstances when your details may need to be supplied to others outside Sharpham Partnership Ltd:

a) If the conduct of the wine-making undertaking is transferred to another entity where that entity is based in the UK and intends to continue making and selling award-winning cheeses.

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please contact us via one of the following:

a) Email – info@sharphamcheese.co.uk

b) Phone - 01803 732 600

c) Letter - The Cheese Dairy, Sharpham Estate, Ashprington, Devon TQ9 7UT

Personal data that we process for any purpose shall not be kept for longer than has already been identified in this policy or is necessary for its purpose.

If you are a regular customer or supplier of Sharpham Cheese, we will keep your contact information on file for as long as we are providing a service and/or product to you or if we require a supplier's on-going services. The legal processing of this data is contractual.

If we process your data for marketing purposes, you are able to unsubscribe at any time by following the process provided in the footer of our marketing emails or by calling 01803 732 600 or emailing info@sharphamcheese.co.uk.

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Our website contains links to other websites. This Privacy Policy only applies to this website so when you link to other websites you should read their own Privacy Policies.

We have put in place appropriate physical and electronic measures, security policies and managerial procedures to safeguard and secure all personal data that we have under our control.

Only authorised employees will have access to your personal information. All employees who have access to your personal data are contractually obliged to respect the confidentiality of your personal data.

Please note that we keep our Privacy Policy under regular review and may be required to change this Privacy Policy from time to time, therefore we highly recommend that you review our Privacy Policy on a regular basis to ensure you’re up to date on our latest personal data processing activities.

This Privacy Policy was last updated on 24th September 2020.