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Privacy Policy

Last Updated: 17.09.2024 

Flora Food Group is a global leader in plant-based foods, at the forefront of driving positive change for both people and the planet through our established power brands and our investment in cutting-edge food research and technology. Our six iconic “Power Brands” Flora, Becel + ProActiv, Rama, Country Crock, BlueBand and Violife, and many local brand jewels such as Stork, Tulipan and Lätta (together our “Brands”) are at the heart of families, kitchens and communities the world over. 

When you interact with us and our Brands, websites, products, mobile applications, social media channels, branded pages on third-party platforms (for example Facebook or Instagram), applications accessed or used through third-party platforms, our recruitment or job application channels or other sites that display this Privacy Notice (collectively, our “Sites”) we may process your Personal Data. Whilst doing so, be assured we take your rights to privacy very seriously. Respecting your privacy is at the core of how we interact with you, so you can enjoy your interaction with Flora Food Group, our Brands and our Sites whilst knowing your Personal Data is always processed lawfully and in accordance with the principles of transparency, respect, trust and fairness.  

This Privacy Notice applies to Flora Food Group B.V. and all subsidiary Flora Food Group companies (“we” or “us”). We are a “Controller” for the purposes of the (EU) General Data Protection Regulation 2016/679 (the "GDPR") and the UK General Data Protection regulation incorporated by the UK's Data Protection Act 2018 (collectively referred to as the "Data Protection Laws"). 

Flora Food Global Principal B.V. is the Controller of the Personal Data which we collect on the www.florafoodgroup.com website. Flora Food Global Principal B.V. or the local Flora Food Group entity will be the Controller of the Personal Data which we collect on our Sites for all our Brands (for example, https://www.flora.com/ or https://www.rama.com/). 

In this Privacy Notice you will find an overview of what Personal Data we collect in connection with our products and the use of our Sites, how we process your Personal Data, the purposes for which we process it, how you benefit, what your rights are and how you can contact us.  

  • What Personal Data we collect and what we use it for 

    Personal Data means any information that relates to an identified or identifiable individual. This definition includes data collected offline, when you meet us in person, online through our Sites or via our authorised parties such as our consumer “Careline” which is our support helpline where you can raise questions, queries and concerns directly to us

    Therefore, we may collect your Personal Data from a variety of sources. This includes:

    1. Personal Data you provide to us directly.

    We collect Personal Data you provide us with when you sign up for a marketing newsletter, complete a survey, enter a competition or communicate with us through our Sites. In so doing, you may provide Personal Data, for example:

    Categories of Personal Data

    Description 

    Personal Information

    Your name, gender, home address, social media profiles, email, telephone number and date of birth.

    Communication Information

    Your feedback, recipe information or suggestions about our products where you decide to provide us with such information.

    User Generated Content

    Your comments, photos, videos, personal stories, or other similar media or any content that you create and then share with us on third party social networks or by uploading it to one of our Sites. Where permitted, we collect and publish user-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement, and third-party social networking.

    As part of our recruitment activities, we collect Personal Data that you provide to us in the course of applying for a role with us. For example:

    Categories of Personal Data

    Description 

    Personal Information

    Your name, gender, home address, social media profiles, email, telephone number and date of birth.

    Identity Information

    Your residency and work permit status, nationality and passport information

    Financial Information

    Your salary information and benefit information. 

    Employment and Qualification(s) Information 

    Your date of hire, date(s) of promotions(s), work history, technical skills, educational background, professional certifications and registrations, language capabilities, and training records (taken from a CV, cover letter or application form).

    Communication Information

    Your information from interviews and phone-screenings you may have had, if any. Voicemails, e-mails, correspondence, documents and communications created, stored or transmitted using our networks, applications, devices, computers or communications equipment. Letters of offer and acceptance of employment.

    During certain sections of our recruitment activities we may collect "Special Categories of Personal Data" about you (with your explicit consent) such as health status (for example, if you have a disability, we need to be aware of). 

    For more information on the Special Categories of Personal Data we collect and how we use it, please refer to the relevant section below.

    2. Personal Data we collect automatically

    Some automatically collected information may not directly identify you by name, however it may do so indirectly (for example your internet protocol (IP) address may point uniquely to you). For this reason, some automatically collected information is Personal Data under Data Protection Laws.  This information is automatically collected using cookies, pixel, web beacons and similar data collection technology (collectively known as “Data Collection Technology”) when your web browser accesses our Sites or advertisements and other content served by or on behalf of us on other websites.

    To find out more about what Data Collection Technology we use, see our Cookie Notice.

    We may automatically collect certain information from your computers and mobile devices or via other means where required. For example:

    Categories of Personal Data

    Description 

    Location Information 

    IP address, device ID, broad location data and time zone. 

    Device Information

    Information about your computer or mobile device, such as device type and identification number, browser type, internet service provider, mobile network and operating system.

    Traffic and Usage Information

    How many times you have visited our brand websites, your page response times, your download errors, the length of your visits to certain pages, your page interaction information, and methods you use to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.

    We also collect, use and share aggregated data such as statistical or demographic data which is not Personal Data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' usage data to calculate the percentage of users accessing a specific Site in order to analyse general trends in how users are interacting with our Site to help improve the Site and our product offerings. 

    If we meet you in person, we may also collect your Personal Data:

    Categories of Personal Data

    Description 

    Visitor Information

    Your name, company, email and/or telephone number.

    Images and/or Video Recording Information

    Your image, photos or video recordings of you.

     

    3. Personal Data we collect from other sources

    We may collect Personal Data from other sources including:

  • Collection of "Special Categories of Personal Data"

     

    Certain categories of Personal Data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as "Special Categories of Personal Data" and benefit from additional protection under Data Protection Laws. 

    We limit the circumstances where we collect and process these Special Categories of Personal Data. However, we may collect such data in the following circumstances:

    We only collect and use this Personal Data where you have provided us with your explicit consent for us to do so or where we are legally required to process such data.  

    In some instances, you may voluntarily provide us with information which does not directly involve the collection of any Special Categories of Personal Data but may imply or suggest your religion, health or other Special Categories of Personal Data.  

  • Lawful basis for processing your Personal Data 

    Data Protection Laws require us to have a legal basis for collecting and using your Personal Data. 

    We rely on one or more of the following legal bases: 

    Performance of a contract with you (GDPR Article 6(1)(b))

    Where we need to perform a contract, we are about to enter into or have entered into with you, for example when you agree to enter an Flora Food Group Brand competition or promotion or when we send you samples that you have requested. 

    Legitimate interests (GDPR Article 6(1)(f))

    We may use your Personal Data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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). Our legitimate interests could exist for example, when you sign up to receive information about one of our Brands or enter a competition and we use the Personal Data collected to better understand your needs.

    Legal obligation (GDPR Article 6(1)(c))

    We may use your Personal Data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation to you when we rely on this legal basis. For example, a court order or a subpoena may require us to process Personal Data for a particular purpose.

    Consent (GDPR Article 6(1)(a))

    We rely on consent only where we have obtained your active agreement to use your Personal Data for a specified purpose, for example if you subscribe to an email newsletter. You can withdraw this consent at any time.

    You can object to processing that we carry out on the grounds of legitimate interests.  See the section headed "Your Rights" to find out how.

    How we use your Personal Data and the lawful basis for processing it

    Activity

    Type of Personal Data

    Lawful Basis for Processing

    To process and respond to your inquiries, suggestions or registration requests, via our Sites, e-mail, social media or our consumer “Careline”.

    This processing is necessary to meet our and your legitimate interests in dealing with complaints and consumer issues, our legal obligations as a manufacturer of food products and in relation to certain registration requests, we will request your consent. 

     

    If we want to use your User Generated Content, we will request your consent. 

     

    1. Personal Information
    1. Communication Information
    1. User Generated Content
    1. Legitimate Interests
    1. Consent
    1. Legal Obligation

     

     

    To develop and improve our products, communication methods and the functionality of our Sites and online channels.

    This processing is necessary for our legitimate interests to study how consumers use our products and/or services, to develop them, to grow our business and to inform our marketing strategy.

    1. Communication Information
    1. User Generated Content
    1. Location Information
    1. Device Information
    1. Traffic and Usage Information
    1. Legitimate Interests

     

    For the purposes of competitions or promotions that you have entered.

    This processing is necessary to meet our and your legitimate interests in handling your participation in competitions and events and the performance of our “contract” with you when you enter the competition and/or the event (e.g., the terms and conditions) and having obtained your prior consent to receive direct marketing communications.

    If we want to use your User Generated Content, we will request your consent. 

    1. Personal Information
    1. Communication Information
    1. User Generated Content

     

    1. Legitimate Interests
    1. Consent
    1. Contract

    To authenticate the identity of individuals contacting us by telephone, electronic means, visiting us in person on our business premises or otherwise.

    This processing is necessary to meet our and your legitimate interests in complying with our legal responsibilities as a business (e.g. in relation to health and safety and the prevention of crime). 

     

    1. Personal Information
    1. Identity Information
    1. Location Information
    1. Visitor Information
    1. Images and/or Video Recording Information

     

    1. Legitimate Interests
    1. Legal Obligation

     

    For internal training and quality assurance purposes.

    The processing is necessary to meet our and your legitimate interests in providing a reliable and responsible service to you. 

    For any job application Personal Data, this processing is necessary for our legal obligations as a responsible employer.

    1. Personal Information
    1. Identity Information
    1. Financial Information
    1. Employment and Qualification(s) Information
    1. Communication Information

     

    1. Legitimate Interests
    1. Legal Obligation

     

    To provide personalised communications and targeted advertising as well as product recommendations.

    This processing is necessary for our legitimate interests (to carry out direct marketing, develop our products and/or services and grow our business and having obtained your prior consent to receive direct marketing communications.

    If we want to use your User Generated Content, we will request your consent. 

     

    1. Personal Information
    1. Communication Information
    1. User Generated Content
    1. Legitimate Interests
    1. Consent

     

    To process and manage job applications.

    The processing is necessary to meet our and your legitimate interests in handling recruitment applications in addition to our legal obligations as a responsible employer. 

    There are circumstances also, for example when your application has been unsuccessful, when we will request your consent to retain your Personal Data in the event of any relevant positions becoming available in the future.

    1. Personal Information
    1. Identity Information
    1. Financial Information
    1. Employment and Qualification(s) Information
    1. Communication Information
    1. Legitimate Interests
    1. Legal Obligation
    1. Consent

    To communicate with you as a recipient of press releases or investor information from us.

    The processing is necessary to meet our and your legitimate interests in the mailing of press releases and investor information from us and having obtained your prior consent to receive direct marketing communications.

    1. Personal Information

     

    1. Legitimate Interests
    1. Consent

     

    To handle the necessary contact information regarding our customers and suppliers.

    This processing is necessary for our legitimate interests to keep our records updated and manage our relationship with customers and suppliers.

    1. Personal Information

     

    1. Legitimate Interests

     

    For any direct marketing from us, during the registration process on our Sites when your Personal Data is collected, you will be asked to indicate your preferences for receiving direct marketing communications and we will request your explicit consent to send them. You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at privacy@florafg.com. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations after your participation in competitions.

    When we collect and use your Personal Data for any other purposes, we will inform you before or at the time of collection.

    We also create profiles by analysing the information about your online surfing, searching behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your Personal Data in one or more segments. For more information on this, see "Profiling" below.

  • Profiling 

     

    Like most organisations with an online presence, we use your Personal Data to build profiles. We create profiles by analysing information about your online surfing, searching behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your Personal Data in one or more segments. These segments are used by us to personalise the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you) and to display relevant offers and advertisements from our Brands on our Sites, and via third-party websites. The segments can also be used for third-party campaigns on our Sites or third-party websites.  

    We profile your Personal Data using cookies where you have provided consent for us to do so; for example, accepting the setting of cookies on your browser online. For more information, see our Cookie Notice.

    If you have asked to receive emails or SMS communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy. 

    We use this data to profile your likes and dislikes. For instance, if we see that you are regularly viewing recipes on our website, and you have opted in to receiving emails from us, we might give you an update on the new recipes that have just hit the site for your interest, or we may tailor our web content when you visit towards things we think you'll be most interested in. 

    Based on this profile information, we may also give you advertising that we think you will like and want to see as you view content from us or from our network of publishers that we advertise with. Sometimes we may use your current location to serve advertising to you that is to do with promotions or events that are happening nearby that we think you might be interested in. 

    We may also use information you have provided to selected third parties and consented to be shared, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.

  • Automated decision-making 

     

    We will not process your Personal Data and make decisions based solely on automated decision making that has a significant impact on you.  

    If we do so, we will notify you in advance and provide you with clear information about our decision to rely on automated processing and to request your explicit consent. 

  • Who your Personal Data is shared with 

    We do not sell or trade your Personal Data to third parties, but we may disclose your Personal Data to other companies or third parties (who process the Personal Data on our behalf and in accordance with our strict instructions, known as “Data Processors”) when it is necessary for us to conduct our business or fulfil our commitments to you. When we engage with a Data Processor, we will ensure there is a written agreement that guarantees the security and privacy of your Personal Data. 

    We share your Personal Data internally and with selected third parties in the following circumstances:

    Third-party service providers

    In order to carry out your requests, respond to your inquiries, provide you with samples, enable you to participate in competitions, make features or materials available to you through our Sites, we may share your Personal Data with third-party service providers that perform functions on our behalf, such as companies that: i) host or operate our Sites, ii) analyse data, iii) provide customer service, iv) postal or delivery services, and v) other third-parties that participate in or administer our promotions or sponsorships. They have access to Personal Data needed to perform their functions but may not use it for other purposes. You can contact us if you want a full list of our service providers that are relevant to you.

    Other third parties

    Your Personal Data will also be used by us or shared with our sponsors, supply chain partners, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third parties in connection with marketing, promotion or distribution of our products.

    Business transfers

    Your Personal Data will be used by us or shared with the our group of companies for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets, subsidiaries or business units. In such transactions, your Personal Data generally is one of the transferred business assets but remains subject to this Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to our websites, your Personal Data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets.

    Legal disclosure

    Your Personal Data may also be disclosed by us if it is necessary to comply with applicable legal or governmental requirements, to safeguard our legal interests or to detect, prevent or be attentive to crime, fraud and other security or technical issues. For example: 

  • International data transfers 

     

    Your Personal Data is transferred and processed outside of the UK and EEA.   

    Any transfer of your Personal Data outside the UK and the EEA will be carried out in accordance with the Data Protection Laws to safeguard your privacy rights and to provide you with remedies in the unlikely event of a security breach. This level of protection to your Personal Data is guaranteed either by a decision of the EU Commission that the country concerned ensures an adequate level of protection or through the use of so-called appropriate safeguards. Examples of appropriate safeguards are: approved code of conduct in the destination country, Standard Contractual Clauses (“SCCs”) or Binding Corporate Rules (“BCRs”). 

    You can contact us if you want more information about the appropriate safeguards that we use and countries where your Personal Data is processed.

  • How we protect your Personal Data 

     

    We take the security of your Personal Data very seriously. We take every effort to protect your Personal Data from misuse, interference, loss, unauthorised access, modification or disclosure. Our measures include implementing appropriate access controls, investing in the latest information security capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise or anonymise Personal Data wherever possible. 

    Access to your Personal Data is only permitted among our employees, partners and agents on a need-to-know basis and subject to strict contractual obligations regarding both confidentiality and data privacy when processed by Data Processors. 

  • How long we keep your Personal Data for 

    We only retain your Personal Data for as long as we need it for the purpose for which it was collected or as otherwise required by Data Protection Laws. Your Personal Data will be securely destroyed after the expiry of the applicable retention period. To determine the appropriate retention period for your Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Furthermore, we may retain your Personal Data for a longer period than indicated below in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    Please refer to the specific retention period for each category of Personal Data:

    Category of Personal Data

    Retention Period

    Personal Information

    Personal Data relating to users who have signed up for and consented to receive information on our Brands, i) until such consent is withdrawn or ii) in the event such user has not interacted with us for a period of two years then such Personal Data is deleted after this two-year period has elapsed. 

    Personal Data relating to complaints and consumer issues is stored for no longer than seven years.

    Personal Data relating to rejected job applicants is stored for no longer than two years.

    User Generated Content

    Personal Data relating to consumer queries and responses is stored for no longer than two years.

    Identity Information

    Personal Data relating to rejected job applicants is stored for no longer than two years.

    Financial Information

    Personal Data relating to rejected job applicants is stored for no longer than two years.

    Employment and Qualification(s) Information

    Personal Data relating to rejected job applicants is stored for no longer than two years.

    Communication Information

    Personal Data relating to rejected job applicants is stored for no longer than two years.

    Personal Data relating to consumer queries and responses is stored for no longer than two years.

    Location Information 

    COOKIES NOTICE

    Device Information

    COOKIES NOTICE

    Traffic and Usage Information

    COOKIES NOTICE

    Visitor Information

    Personal Data relating to visitors to our business premises is stored for no longer than three months from creation.

    Images and/or Video Recording Information

    CCTV recordings are stored for no longer than three months from creation. 

    Personal Data relating to photography or filming in connection with our participation in events, festivals, trade fairs, etc. is stored for no longer than two years.

    Special Category Personal Data

    Special Category Personal Data is stored for no longer than two years. 

  • Your rights over your Personal Data 

     

    You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you.  

    You can exercise your rights by sending an email or submitting a request through the “Contact Us” form on our websites. 

    You have the following rights in relation to your Personal Data: 

    • Information, Rectification and Access: You have the right to access, correct or update your Personal Data at any time. For rectification, 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. If you request access, where feasible and permitted by Data Protection Laws, we will provide a copy of the Personal Data we are processing. The Personal Data shall be provided in electronic form. 

    • Deletion: The right to request deletion of your Personal Data, however this right may not apply if we are permitted to retain your Personal Data in accordance with Data Protection Laws for the purposes of i) exercising the right of freedom of expression and information ii) compliance with a legal obligation which requires processing by a law to which we are subject iii) the performance of a task carried out in the public interest iv) reasons of public interest in the area of public health v) archiving purposes in the public interest, scientific or historical research purposes or statistical purposes and vi) the establishment, exercise or defence of our legal rights. 

    • Portability: The right to data portability. The Personal Data you have provided us with is portable. This means it can be moved, copied or transmitted electronically under certain circumstances. However, if the lawful basis that we rely upon for the processing of your Personal Data is to pursue our legitimate interests or if your Personal Data has been anonymised or pseudonymised then the right to data portability does not apply. 

    • Restriction & Objection: Under certain circumstances, you have the right to restrict or object to certain types of processing, including processing for direct marketing (i.e., receiving marketing emails from us or being contacted about potential opportunities, events and promotions). If you have given your consent to anything we do with your Personal Data (i.e., we rely on consent as a legal basis for processing your Special Category Personal Data) you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your Personal Data at any time by contacting us with the details provided below. 

    • Automated Decision Making and Profiling: The right not to be subject to a decision which is based solely on automated processing or profiling, and which produces legal or other significant effects on you.  

    • Complain: You have the right to lodge a complaint directly with any local Supervisory Authority about how we process your Personal Data. 



    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. 

    Please be aware that there are exceptions and exemptions that apply to some of these rights, which we will apply in accordance with the Data Protection Laws. 

    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 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. 

  • Contact us 

     

    If you have any questions or concerns about our use of your Personal Data, please contact us by emailing privacy@florafg.com or submitting a request through the “Contact Us” form on our websites.

  • Notice updates 

     

    We will update this Privacy Notice when necessary to reflect feedback, changes in our products or changes in Data Protection Laws. When we post changes to this Privacy Notice, we will revise the "last updated" date.  

    If the changes are significant, we will provide a more prominent notice (including, potentially email notification of Privacy Notice changes). 


  • Complaints 

     

    It is important that you ensure you have read this Privacy Notice. If you do not think that we have processed your Personal Data in accordance with this Privacy Notice, you should let us know as soon as possible. 

    You also have the right to complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or any other relevant Supervisory Authority. Further information about how to complain to the Dutch Data Protection Authority is available on its website at https://www.autoriteitpersoonsgegevens.nl/en/contact

  • Additional terms or notices 

     

    In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional terms or notices. We encourage you to read these before participating in any such campaigns or promotions.

Additional information relevant to residents of the United States and Canada can be found in our USA and Canada Privacy Notice Addendum.