Welcome to our App privacy policy. In this document we explain what data we collect from you and how we use it.

Registering your details

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our End-user Licence Agreement (EULA) and it is important that you read that information.

By registering your details on this App, you are providing your consent to our processing of your personal data (including your name and contact details)

How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us via https://www.simmonsbakers.com/contact but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Location Data

This app does not track or record your location.

Introduction

This policy (together with our end-user licence agreement as set out in the EULA and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

• Simmons (Bakers) Mobile application software (App) once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) that are available on the App Site. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.

Important information and who we are

Simmons (Bakers) Limited of 2 The Parade, St Albans Road East, Hatfield, Hertfordshire, AL10 0EY, a company registered in England and Wales under number 00421255 is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: Simmons (Bakers) Limited
• Name or title of data privacy manager: Neal Tuson
• Postal address: 2 The Parade, Hatfield, Hertfordshire, AL10 0EY
• Contact: https://www.simmonsbakers.com/contact

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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated in January 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services. 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 our relationship with you.

Third party links

Our Sites do not have links to other websites or apps other than those run and maintained by the Company.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.
• Contact Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.

We do not collect Financial Data about you. This App does not currently allow for in-app purchases, although it may be updated to do so in future. This Privacy Policy will be updated accordingly at that time. We do not currently 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 considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by installing this app, filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase or redeem an in-App offer or incentives, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you use our App we will automatically collect personal data including , Content and Usage Data. We use JWT Token technology to verify login and user sessions and to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. We do not collect information about your device..

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered 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 or regulatory obligation.

We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will not share your personal data with any third party for marketing purposes

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below:

• Internal Third Parties as set out in the glossary below.
• External Third Parties as set out in the glossary below.
• Specific third parties retained by us to develop and maintain this App and our website
• 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 policy.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

All information you provide to us is stored on our secure servers and is encrypted via SSL technology. We do not handle any of your Financial Data when we carry out any payment transactions. Where you have chosen a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. The password is encrypted and not accessible by us.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see 'your legal rights' below for further information.

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.

In the event that you do not use the App for a period of two years then we may treat the account as expired and your personal data will be deleted.

Your legal rights

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

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer or your personal data.
• Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at https://www.simmonsbakers.com/contact

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

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.

Third parties

Internal third parties

Other companies in the Simmons (Bakers) Group and who are based in the UK and provide IT and system administration services and undertake leadership reporting.

External third parties

Service providers acting as processors based in the UK who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

Your legal rights

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:
  • (a) if you want us to establish the data's accuracy;
  • (b) where our use of the data is unlawful but you do not want us to erase it;
  • (c) 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; or
  • (d) 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.

Description of categories of personal data

• Identity Data: first name, last name, username or similar identifier, date of birth.
• Contact Data: email address
• Financial Data: Although the app may allow you to purchase our products through the app, we do not store or record your financial data such as credit/debit card or bank account details
• Transaction Data: includes details about payments to and from you and details of in-App purchases, transaction history and loyalty points.
• Device Data: includes the type of mobile device you use, a unique device identifier [(for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device),[mobile network information, your mobile operating system, the type of mobile browser you use,[time zone setting,
• Content Data: includes information stored on your Device, such as login information,
• Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.