We are committed to protecting your privacy. This policy explains how we collect, use, store and share your personal data.
2. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?
Great Western Malting Co (“GWM”) (registered number 2184031) is responsible for your personal data.
GWM’s registered office is at 2711 Centerville Road, Suite 400, Wilmington, New Castle County, Delaware 19808 USA (“we”, “us”, “our”). GWM forms part of the United Malt Group of Companies, whose ultimate parent is United Malt Group Limited (company number 140 174 189), whose registered office is Citigroup Centre, Level 18, Suite C, 2 Park Street, Sydney NSW 2000, Australia.
Your data will be controlled by GWM.
If you have any questions in relation to this policy or generally how your personal data is processed by us please contact the Privacy Delegate by letter addressed to: Privacy Delegate, Great Western Malting Co, 1705 NW Harborside Drive, Vancouver, Washington 98660, USA; or by email at [email protected].
3. WHICH PERSONAL DATA DO WE COLLECT?
The personal data we collect may include:
- General information, such as your name and contact details (including your postal address, business address, telephone number, fax number, mobile phone number and e-mail address)
- Payment and identity verification information, such as bank account details to facilitate payments, date of birth, passport details, drivers licence details, credit card details if you use that as a payment method, and related billing information.
- Publicly available information, such as company and personal searches, and credit agency reports.
- General business information processed in a contractual relationship with GWM, which is voluntarily provided by you.
- Details of when you visit any of our premises, such as your vehicle registration details, and select biometric data such as CCTV footage and on-site security imaging.
Each time you visit our websites we may also automatically collect information and personal data about your computer for system administration including, where available, Internet Protocol (IP) address used to connect your computer to the internet, MAC addresses, traffic data, location data, your login information, time-zone setting browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access. We do this to help us analyse how users use the websites (including behaviour patterns and the tracking of visits across multiple devices), to establish more insights about our website users and to assist us in managing your account and improving your online experience. Please see our cookies policy for further information about what information may be automatically collected when you visit our websites http://www.greatwesternmalting.com/gwm/cookie-policy.
Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.
4. HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect some of your information directly from you, either through information that you give to us, or information that we collect during your visits to our website or premises, or through your communications with us. We also obtain some information from other third parties, including reference checks.
|Information that you give us||
You may share personal data about yourself and your circumstances by:
You are not obliged to provide your personal data to us. However, if you do not provide your personal data to us, we may not be able to provide goods or services to you, receive goods or services from you, respond to your queries, or allow you onto our premises.
|Information that we collect about you||
We collect personal data about you:
|Information that we receive from other sources||
We may receive personal data about you from other third parties, including:
5. FOR WHICH PURPOSES WILL WE USE YOUR PERSONAL DATA?
We may use your personal data for the following purposes:
Necessary for the entry into or performance of a contract
When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place an order for goods or services, or for you to supply goods or services to us), we will need to collect, process and share (as further detailed below) your personal information. Failure to provide the requisite personal information when placing your order and financial information on entering into the transaction or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our goods or services to you, or you supply goods or services to us.
Legitimate business interests
We use your personal data for the legitimate interests of our business to enable us to:
- accept goods and services from you, or provide you with goods and services as requested by you;
- manage and administer you or your organisation’s business relationship with Bairds Entities, including the processing of payments, accounting, auditing, billing and collection and support services;
- comply with our legal obligations, compliance screening or recording obligations, which may include automated checks on your contact data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for compliance purposes;
- carry out research to understand our customers and suppliers and how they use our products and services;
- develop and improve our services to you and to our other customers and suppliers;
- to administer and improve our website to ensure that content is presented in the most effective manner;
- to provide customer support;
- as part of our efforts to keep our premises safe and secure (for example through the use of CCTV on our premises);
- manage insurance requirements;
- monitor and assess compliance with our policies and procedures;
We may also process your personal data for the following purposes when you have given us your consent:
- communicating with you through means which you have approved, to keep you up to date on our products and services, company announcements, events and news;
- customer surveys, marketing campaigns, market analysis, competitions, and promotional activities or events;
- collecting information about your preferences so we can personalise the quality of our communications and interactions with you.
- With regard to direct marketing communications, we will, where legally required, only engage in such communications where you have consented to receive it. You will have the opportunity to “opt out” at any time if you no longer wish to receive direct marketing communications from us. You have the right to withdraw your consent to processing of this nature at any time by emailing us at [email protected].
We have a legitimate interest in processing your information as:
- we will both benefit from the provision of goods and services;
- we have a legitimate interest in recording telephone calls for quality and training purposes;
- we will both benefit from the ability to enforce or apply rights under any contract between us;
- we are required to ensure health and safety of our premises and have a legitimate interest in ensuring any processes are effective;
- we have a legitimate interest in ensuring the security of our premises, and in assisting with the prevention and detection of crime;
- we would be unable to provide our goods and services without processing your information.
Special Categories of Personal Data
Certain personal data falls into ‘special categories of personal data’, such as data regarding your race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying a person, data concerning your health (including mental and physical health), or data concerning your sex life or sexual orientation.
Other than select biometric data collected when you visit one of our premises, we do not collect any other Special Category data of customers, suppliers or advisors whether existing or prospective.
Personal Data of Children
We do not knowingly collect information from children, and we do not use our website to knowingly solicit personal information from or market to children. If we learn that someone under age 18 has provided personally identifiable information through one of our Sites, we will use reasonable efforts to remove that information from our systems.
6. WHO DO WE SHARE YOUR INFORMATION WITH?
We may share your information with other United Malt Group Companies, but only for the purposes specified in this policy.
We may also use a number of carefully selected third parties to supply us with products and services, such as (but not limited to) supply chain operators, credit checks, reference checks and legal advice. We will only share your information with these suppliers where it is necessary for them to provide us with the services we need. We do not share your information with third parties for marketing purposes.
7. PERSONAL DATA ABOUT OTHER PEOPLE WHICH YOU SHARE WITH US
If you provide personal data to us concerning another person, you must ensure that you have the right to disclose that personal data to us and that we may collect, use and disclose that personal data (examples include the personal data of your directors, officers, employees or any other persons with whom you have business dealings or connections). You must ensure that the person concerned is aware of all the matters outlined in this Policy which relate to them.
8. TRANSFERRING YOUR PERSONAL DATA ABROAD
We may transfer your data abroad if required for the purposes as outlined in this Policy. This may include countries which do not provide the same level of protection as the laws of your home country. We will ensure that such transfers are subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other relevant laws.
9. RETENTION OF YOUR PERSONAL DATA
We will only retain your personal data for the period necessary to fulfil the purposes outlined in this Policy, or otherwise legally required or permitted. This may be up to 6 years, unless a longer or shorter retention period is required or permitted by law.
We will also retain your personal data if it is required by GWM to assert or defend legal claims, until such time that the claims have been settled or the relevant retention period has expired.
10. SECURITY OF YOUR PERSONAL DATA
The personal data we hold on you may be stored electronically or in hard copy. We have put in place reasonable physical, technical, and organisational measures to safeguard the information we hold. Such measures include, but are not limited to: system access restrictions and authentication, firewall and virus protection systems, and physical security systems.
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 us; any transmission is at your own risk.
If you have reason to believe that your interaction with us is no longer secure please immediately notify us of the problem by contacting us at [email protected]. In the unlikely event that we believe the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If such a notification is appropriate, we will endeavour to do so as promptly as possible under the circumstances.
You are reminded if you have an account with the GWM website, you are responsible for maintaining the strict confidentiality of your account password, and you are responsible for any activity under your account and password. It is your sole responsibility to control the dissemination and use of your password, control access to and use of your account, and notify us when you wish to cancel your account. We will not be responsible for any loss or damage arising from your failure to comply with this obligation.
11. WHAT RIGHTS DO YOU HAVE?
You have a number of rights concerning the personal data we hold about you.
You have the right to:
- Ask us not to sell your personal information (‘Do Not Sell My Personal Information’ Form HERE)
- Request access to your personal data
- Ask us to rectify any inaccurate personal data
- Ask us to erase your personal data
- Ask us to restrict or block the processing of your personal data
- Port your personal data;
- Object to our processing of your personal data;
- Not be subject to automated decisions;
- Withdraw your consent
If you wish to do any of the above, please send an email to [email protected].
12. WHAT IF YOU HAVE A COMPLAINT?
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request made by you, or would otherwise like to make a complaint, please contact the Privacy Delegate, Great Western Malting Co, 1705 NW Harborside Drive, Vancouver, Washington 98660, USA; or by email at [email protected]greatwesternmalting.com so we can do our very best to sort out the problem. To request your personal information not be sold, you may also call 1-866 I OPT OUT (1-866-467-8688), Enter Service Code 753#.
If you are not satisfied with our response, you may raise your complaint with the relevant privacy regulator.
13. OTHER WEBSITES
Our websites may, from time to time, contain links to and from the websites of third parties. 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 or your use of those websites.
This policy was updated on 21 February 2023. We reserve the right to update this Policy if it is deemed necessary, and we will publish the updated Policy on our website, or in any other form considered appropriate.
15. CCPA COMPLIANCE
For the purpose of complying with the California Consumer Privacy Act of 2018 and any similar laws, (a) you disclose “Personal Information” (as defined therein) to Great Western Malting Co solely for a valid business purpose and for Great Western Malting Co to provide Products and Services, and (c) Great Western Malting Co will not: (i) sell Personal Information; (ii) retain, use, or disclose Personal Information for a commercial purpose other than providing Products and Services; and (iii) retain, use, or disclose Personal Information outside of the business relationship between Great Western Malting Co and you. Great Western Malting Co understands the foregoing restrictions and will comply with them.