2 SISTERS FOOD GROUP – PRIVACY NOTICES

Boparan Holdings Limited (trading as the 2 Sisters Food Group) is the parent company for a number of subsidiaries (the Group).

These notices (together with any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by the Group. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The position is different depending on who you are – so please read the relevant section to you. The notices are split out into:


ACCESS TO INFORMATION
The Data Protection Act gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act, and further information is provided in the section relevant to you.

SECURITY
2 Sisters takes precautions to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have taken appropriate technical and organizational measures to protect the information systems on which your personal information is stored and we require our suppliers to protect your personal information by contractual means.


Retention
Your personal information will be retained as long as necessary to achieve the purpose for which it was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Collecting personal data from children under the age of 16

We do not collect personal data from children under the age of 16.

Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Group Legal at legal@2sfg.com  or the Group’s Data Protection Officer at dataprotection@2sfg.com

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Applicants, employees and pension scheme members


1. SCOPE
This notice explains how we handle the personal information of employees, applicants, former employees, dependents, beneficiaries, and temporary agency workers in the course of our human resources activities. We may amend this notice from time to time, should it become necessary to do so. This notice may also be supplemented by other statements as needed to comply with local site requirements, or where employees’ representation agreements exist.


2. Information we may collect from you
We may process your personal information for legitimate business purposes to administer our employment or contractual relationship with you and to run our businesses.

We may collect, use and transfer your personal information through automated, electronic and/or paper-based data processing systems. We have established routine processing functions (such as processing for regular payroll and benefits administration).

We also process personal information on an occasional or ad hoc basis (such as when an employee is being considered for a particular new position or in the context of changes to their marital status for example).

In the normal course of human resources activities, we can collect the following types of personal information:

(a) Personal identification information, such as your name, home address, date of birth, gender, work- related photographs, and home phone number;
(b) Government-issued identification numbers, such as your national insurance number or national ID for payroll purposes;
(c) Immigration, right-to-work and residence status;
(d) Familyandemergencycontactdetails;
(e) Job-related information, such as years of service, work location, employment ID, work record, vacation
absences, and contract data;
(f) Educational and training information, such as your educational awards, certificates and licenses, vocational
records and in-house training attendance;
(g) Recruitment and performance-related data, such as objectives, ratings, comments, feedback results, career
history, work equipment, career and succession planning, skills and competencies and other work-related
qualifications;
(h) Information related to your usage of 2Sisters’ assets;
(i) Information needed for compliance and risk management, such as disciplinary records, background check
reports and security data;
(j) Payroll- and payment or benefits-related information, such as salary and insurance information, dependents, government identifier or tax numbers, bank accountdetails,andemploymentrelated benefits information; and
(k) Medical and occupational health records, such as surveillance records, case notes and GP / specialist reports.

We take reasonable steps to ensure that personal information is accurate, complete, and current. Please note that you have shared responsibility with regard to the accuracy of your personal information. Please notify dataprotection@2sfg.com of any changes to your personal information or that of your beneficiaries or dependents.


3. Uses made of your Personal Information

We process personal information for the following purposes:
(a) work force planning, recruitment and staffing;
(b) work force administration, payroll, compensation and benefit programs;
(c) performance management, learning and development;
(d) advancement and succession planning;
(e) legal compliance, including compliance with government authority requests for information;
(f) workplace management, such as travel and expense programs and internal health and safety programs,
(g) internal reporting,
(h) audit;
(i) to protect 2 Sisters, its workforce, and the public against injury, theft, legal liability, fraud or abuse;
(j) other legal and customary business-related purposes; and
(k) to advise and support in accordance with occupational health needs and fitness to work.


In addition, we may process sensitive personal information if it is needed for legitimate business objectives or if it is required to comply with applicable law. Sensitive personal information will not be collected, processed or transferred, except where adequate privacy protection mechanisms are in place.


4. Disclosure of your Personal Information

You agree that we have the right to share your personal information with:

(a) Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
(b) We may disclose your personal information to any prospective seller or buyer of our business.
(c) We may disclose your personal information to any third party if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or for the performance of any contract we enter into with them or you, or to protect the rights, property or safety of 2 Sisters Food Group, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
(d) Third parties for employment verification purposes.
(e) Third parties when reasonably necessary such as in the event of a life-threatening emergency.

Personal data and sensitive personal data collated and processed in accordance with your occupational health needs is strictly medically confidential to our HR and Occupational Health function. All Occupational Health staff adhere to a strict code of ethics in relation to the confidentiality of all consultations, telephone contact and the maintenance of medical records. No personal information is disclosed to any third party outside of Occupational Health (including your manager, HR or your general practitioner, without consent). However, where withholding this information could impact on your health and safety and the health and safety of others, information on your fitness to work will be provided to management and to HR without your consent. In cases where we are unable to gain your consent, or where your consent is withheld, and we need to share information anyway, you will always be informed. Reports to management concerning your fitness for work will always be discussed and agreed with you prior to sending the report.
Anonymised statistical data is shared with senior members of 2 Sisters Food Group to help us to plan the service and monitor health trends in the workplace.


5. Where we store your Personal Information

(a) Please note the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, administration of benefits arrangements, and provision of support services. However, we will not transfer personal data outside of the European Economic Area unless there are appropriate safeguards in accordance with applicable data protection law.

(b)  Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

6. Your Rights
You have the right to ask us not to process your personal data for the above purposes where such processing is not required by law, necessary for the fulfilment of a contractual obligation, or required to meet a legitimate need of 2 Sisters as an employer. If you do object, please contact Group Legal on legal@2sfg.com, and we will work with you to find a reasonable accommodation.

7. Access to Information
You may reasonably access and update the personal information pertaining to you that is on file with 2 Sisters. You can exercise this right by contacting dataprotection@2sfg.com. Please note that your right to access your personal information may have some restrictions. For example, access may be denied (i) in the case of recurrent access requests within a short time interval, or (ii) where providing such access or correction could compromise the privacy of another person or unreasonably expose sensitive company information.

If you believe that any information we are holding on you is incorrect, incomplete or out of date, please contact dataprotection@2sfg.com. We will promptly correct any information found to be incorrect.

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Consumers

1. SCOPE
This notice explains how we handle the personal information of consumers in the course of our consumer engagement, promotional and marketing activities. We may amend this notice from time to time, should it become necessary to do so. This notice may also be supplemented by other statements as needed in relation to standalone competitions, promotions or marketing.


Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.


2. Information we may collect from you

We may process your personal information for legitimate business purposes to manage our consumer engagement with you, including marketing, competitions and complaints. We may process your personal information for direct marketing purposes with you consent.

In the normal course of our consumer engagement activities, we can collect the following types of personal information:

(a) Information that you provide by filling in forms on our site (http://www.2sfg.com/) or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and phone number.

(b) We may also ask you for information when you enter a competition or promotion sponsored by the Group and when you report a problem with one of our sites. The information you give us may include your name, address, e-mail address and phone number, personal description and a photograph.

(c) If you contact us, we may keep a record of that correspondence, including details of any complaint or feedback relating to our products.

(d) Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide.

In addition, we may process sensitive personal information if it is needed for legitimate business objectives or if it is required to comply with applicable law. Sensitive personal information will not be collected, processed or transferred except where adequate privacy protection mechanisms are in place.

COOKIES: In addition, our website uses cookies to distinguish you from other users of our website. A cookie is a small piece of data that is sent from our web server to your browser, which is saved on the hard drive of your computer. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can change your browser settings to refuse cookies or alert you when a cookie is being sent at any time.

Session cookies are used to keep track of information needed by a user and their browser on their journey through a website. Session cookies are necessary for your use of the website. If we use cookies, we generally only use session cookies.

However, we may also use permanent cookies which enable basic web traffic analysis using Google Analytics or similar analytical tools. These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information about google analytics please visit Privacy Overview. You can identify these cookies as _utma _utmb _utmc _utmz. You can reject or delete this cookie by visiting http://tools.google.com/dlpage/gaoptout


3. Uses made of your Personal Information

We process personal information for the following purposes:

(a) to provide you with the information, products and services that you request from us;
(b) to administer competitions and promotions that we run;
(c) to allow you to participate in interactive features of our websites, when you choose to do so;
(d) to provide you with information about other goods and services we offer that are similar to those that
you have already purchased or enquired about;
(e) to provide you, or permit selected third parties to provide you, with information about goods or services
we feel may interest you. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes please email the Data Protection Officer on dataprotection@2sfg.com;
(f) to notify you about changes to our service to ensure that content from our site is presented in the most effective manner for you and for your computer;
(g) to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(h) as part of our efforts to keep our site safe and secure;
(i) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver
relevant advertising to you; and
(j) to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.


4. Disclosure of your Personal Information

You agree that we have the right to share your personal information with:

(a) Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

(b) We may disclose your personal information to any prospective seller or buyer of our business.
(c) We may disclose your personal information to any third party if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or for the performance of any contract we enter into with them or you, or to protect the rights, property or safety of 2 Sisters Food Group, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5. Where we store your Personal Information

(a) Please note the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. However, we will not transfer personal data outside of the European Economic Area unless there are appropriate safeguards in accordance with applicable data protection law.

(b) Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

6. Your Rights
We need your consent to use your personal data for direct marketing purposes. Whenever you choose to fill in a form on the website, look for the box that you must tick to indicate that you agree to the information being used for these purposes.

Also, if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting Group Legal on legal@2sfg.com.

7. Access to Information
You may reasonably access and update the personal information pertaining to you that is on file with 2 Sisters. You can exercise this right by contacting dataprotection@2sfg.com. Please note that your right to access your personal information may have some restrictions. For example, access may be denied (i) in the case of recurrent access requests within a short time interval, or (ii) where providing such access or correction could compromise the privacy of another person or unreasonably expose sensitive company information.

If you believe that any information we are holding on you is incorrect, incomplete or out of date, please write to us or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.

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Vendors and Business Customers

1. SCOPE
This notice explains how we handle the personal information of vendors and business customers in the course of our trading activities. We may amend this notice from time to time, should it become necessary to do so. This notice may also be supplemented by other statements as needed to comply with local site requirements.


2. Information we may collect from you
We may process your personal information for the legitimate business purposes of trading with our vendors and customers, or for administering our contractual relationship with you and for the running of our businesses.

We may collect, use and transfer your personal information through automated, electronic and/or paper-based data processing systems. We have established routine processing functions (such as processing for regular payment administration and via our vendor and customer set up processes).

We also process personal information on an occasional or ad hoc basis (such as when a vendor or customer requests a change in details).

In the normal course of our trading activities, we can collect the following types of personal information. This is generally only where a vendor or customer operates as a sole trader or partnership:

(a) Personal identification information, such as your name, home address, and home phone number; and
(b) Payment related information, such as your government identifier or tax numbers or bank account details.

We take reasonable steps to ensure that personal information is accurate, complete, and current. Please notethat you have shared responsibility with regard to the accuracy of your personal information. Please notify Centralmasterdata@2sfg.com of any changes to your personal information.


3. Uses made of your Personal Information
We process personal information for the following purposes:

(a) to collect information about your business’ qualifications as a potential supplier or customer;
(b) to contact and identify you throughout the supplier evaluation process,
(c) to allow our businesses to partner and trade with each other; and
(d) other legal and customary business-related purposes.

In addition, we may process sensitive personal information if it is needed for legitimate business objectives or if it is required to comply with applicable law. Sensitive personal information will not be collected, processed or transferred, except where adequate privacy protection mechanisms are in place.


4. Disclosure of your Personal Information
You agree that we have the right to share your personal information with:

(a) Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
(b) We may disclose your personal information to any prospective seller or buyer of our business.
(c) We may disclose your personal information to any third party if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or for the performance of any contract we enter into with them or you, or to protect the rights, property or safety of 2 Sisters Food Group, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
(d) Third parties for credit verification purposes.


5. Where we store your Personal Information

(a) Please note the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, administration of benefits arrangements, and provision of support services. However, we will not transfer personal data outside of the European Economic Area unless there are appropriate safeguards in accordance with applicable data protection law.
(b) Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.


6. Your Rights
You have the right to ask us not to process your personal data for the above purposes where such processing is not required by law, necessary for the fulfilment of a contractual obligation, or required to meet a legitimate need of 2 Sisters as your business partner. If you do object, please contact Group Legal on legal@2sfg.com, and we will work with you to find a reasonable accommodation.

7. Access to Information
You may reasonably access and update the personal information pertaining to you that is on file with 2 Sisters. You can exercise this right by contacting Centralmasterdata@2sfg.com. Please note that your right to access your personal information may have some restrictions. For example, access may be denied (i) in the case of recurrent access requests within a short time interval, or (ii) where providing such access or correction could compromise the privacy of another person or unreasonably expose sensitive company information.

If you believe that any information we are holding on you is incorrect, incomplete or out of date, please contact Centralmasterdata@2sfg.com. We will promptly correct any information found to be incorrect.

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