At Krispy Kreme Ireland Limited (referred to as "we", “us", “our") we take privacy seriously and we are committed to protecting it. This policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure. Krispy Kreme Ireland Limited (company number 607454) the data controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed.
This policy may change from time to time so please check this page occasionally to ensure that you're happy with any changes. Please see Changes to this policy for more information.
This policy was last updated on18 May 2020 by Adrian Mosley.
PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
When you use this website, our mobile app, our products or services, the categories of information that we may collect about you and the way in which we collect it are as follows:
Personal information you give to us: This is information about you that you voluntarily give to us by entering information via our website (www.krispykreme.ie), our mobile app and/or corresponding with us by phone, email or otherwise. This includes information provided at the time of registering to join Krispy Kreme Rewards through our website or mobile app, purchasing products or requesting further products on our website or mobile app, or managing your Krispy Kreme Rewards account online (including engaging in correspondence with us by phone, email or otherwise). This consists of the following categories of information:
- Email address
- Contact telephone number
- Date of birth
- Cardholder and payment details
- Details of orders you place and transactions
- Legal information relating to claims made by you or against you or the claims process
- Information relating to the sale of products
- Information contained in our correspondence or other communications with you about our products or business
- Your marketing preferences
We may also ask you for information when you report a problem with our website or mobile app. If you complete any surveys that we ask you to participate in, or you give any feedback, we will collect your information in these circumstances as well. The information we collect from surveys will generally be on an anonymous basis, however you may be asked to leave your contact details if you would like us to respond to you.
Personal information we collect about you: We may automatically collect information about you, such as details of transactions you carry out through our website or our mobile app, and your visits to our website or our mobile app, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, your device IMEI and other technical information about your device. This information may be collected by cookies placed on our website – please see Cookies for more information.
Personal information we may receive from other sources: We obtain certain personal information about you from our third party partners. We offer some of our services on or through other websites and the personal information that you provide to those websites may be sent to us in order to deliver the service. We use Zendesk as our help desk support technology platform, so when you submit an enquiry via the 'Contact Us' section on our website or mobile app, Zendesk will pass your information and query us or our Customer Service support partners. The categories of information we may receive from Zendesk includes email address, name, enquiry details, and any other information contained in the enquiry correspondence with you.
HOW WE USE YOUR PERSONAL INFORMATION
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
Performance of the contract with you or to take steps to enter into it. We may use and process your personal information where we have supplied you (or continue to supply you) with any Krispy Kreme products, where you are in discussions with us about any new product and where you have an account with us. We will use this information in connection with the contract for the supply of products when it is needed to carry out that contract with you or for you to enter into it, and to manage your account with us and administer our reward and loyalty schemes in accordance with our terms and conditions for those services.
Legitimate interests or that of a third party for the following purposes:
- for marketing activities (other than where we rely on your consent to do this);
- for analysis to inform our marketing strategy, help us understand how our website and mobile app is used, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website and/or mobile app);
- to correspond or communicate with you;
- to administer and manage the reward and loyalty scheme with customers;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for prevention of fraud and other criminal activities;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for assessing the quality of the our service and to provide staff training within the business;
- for the management of queries, complaints, or claims; and
- for the establishment and defence of our legal rights.
- Compliance with a legal obligation. We will use your personal information to comply with our legal obligations: (i) to assist any public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.
- Vital interests. Where we have supplied you with any products, we may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
- Consent. We will ask for your consent to send you direct marketing communications. Please see Marketing below for more information, including how to withdraw your consent.
DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION
Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
This information may be collected by cookies placed on our website and app – please see our Cookies Policy for more information.
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
We may disclose your information to the following third parties:
- Our suppliers and service providers: We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), IT providers, advertising and marketing agencies, communication fulfilment services and administrative service providers. This includes Zendesk and Ventrica, our help desk support technology platform and customer service partner respectively. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
- Third parties who provide Krispy Kreme Rewards: We work closely with HTK (HTK Limited, a company registered in England and Wales with registered company number 03191677 whose registered office is at Chapmans Warehouse, Wherry Quay, Ipswich, Suffolk IP4 1AS) to bring you our rewards and loyalty scheme “Kreme Rewards". In particular, we may offer free gifts, rewards and special offers in relation to our own Krispy Kreme products through the scheme. When you sign up for Krispy Kreme Rewards or download the Krispy Kreme Rewards mobile app, HTK may use your details to provide you with information and carry out their obligations arising from the scheme on our behalf. HTK will share your information with us, which we will use in accordance with this policy. HTK will be processing your information on our behalf and will not be acting as a controller of your information in this instance.
- Credit/debit card payment processors: When you purchase any products online or through our mobile app, your credit/debit card payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.
- Customer satisfaction surveys: As customer satisfaction is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services. The information collected will generally be on an anonymous basis, however you may be asked to leave your contact details if you would like us to respond to you.
- Business restructure or reorganisation: We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation.
- Legal obligation: We may transfer your personal information if we're under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. When disclosing your personal information to third parties, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).
If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA.
If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
We will not keep your information for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it.
If you have registered a Krispy Kreme Rewards account with us we will store your personal information for as long as your account is open. We regularly review inactive accounts and actively initiate reactivation of your account by sending you reminders. If your account is dormant for more than 2 years we'll close your account and delete your account information data.
Where you have placed an order with us we will store your personal information for 1 year from the date of delivery of your order.
If you have signed up to receive email marketing from us we will store your personal information for as long as you are subscribed to our email marketing list. If you unsubscribe or your Krispy Kreme Rewards account is closed, we will keep your email address on our suppression list to ensure that we do not send you marketing emails.
If you have contacted us with a complaint or query we will store your personal information for as long as is reasonably required to resolve your complaint or query.
We retain technical information from Google Analytics for 18 months from the date it is collected.
The exceptions to the above are where:
we need your personal information to establish, bring or defend legal claims or to comply with a legal or regulatory requirement;
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law or you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Right to restrict processing below);; or
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems. After that time, we may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
SECURITY AND LINKS TO OTHER SITES
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website / mobile app and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we have given (or where you have chosen) a password which enables you to access your account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Our website / mobile app may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
We may collect your preferences to receive marketing information about Krispy Kreme directly from us by email in the following ways:
when you register for a Krispy Kreme Rewards account with us online and through the mobile app and indicate that you would like to receive such marketing from us (including rewards and exclusive offers);
- if you place an order and indicate (by opting in) that you would like to receive marketing information; or
- when you refresh your marketing preferences when responding to a request from us to do so.
You have the right to withdraw your consent (opt out) at any time to our use of your personal information for marketing purposes. Please see Withdrawing your consent and Objecting to our use of your personal information below for further details on how you can do this.
We may make automated decisions about you based on your personal information. We do this so that we can provide you with personalised offers, discounts or recommendations based on your shopping history, website browsing history, and other information you provide to us (none of these will have a legal or other significant effect on you).
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
- Accessing your personal information: You have the right to ask for a copy of the information that we hold about you. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Correcting and updating your personal information: The accuracy of your information is important to us. If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know. You can also update your by logging into your online account.
- Withdrawing your consent: Where we rely on your consent as the legal basis for processing your personal information you may withdraw your consent at any time. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool in the relevant communication. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
- Objecting to our use of your personal information: Where we rely on our legitimate interests as the legal basis for processing your personal information you may object to us using your information for these purposes. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
- Automated decisions: In certain circumstances, you may contest a decision made about you based on automated processing.
- Erasing your personal information or restricting its processing: In certain circumstances, you may ask for your personal information to be removed from our systems. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
- Transferring your personal information in a structured data file (“data portability"): Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file. You can also ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Complaining to the Irish data protection regulator: You have the right to complain to the Irish Office of the Information Commisioner if you are concerned about the way we have processed your personal information. Please visit the Office of the Information Commissioner website (www.oic.ie) for further details. If you have concerns about the way we have handled your personal information, we encourage you to contact us and we will seek to resolve any issues or concerns you may have.
CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and app and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website and app, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website or use the app. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.
Email: firstname.lastname@example.org with the email subject heading 'Data protection'
Phone: +44(0)1276 601170 quoting 'Data protection'
Post: Krispy Kreme U.K Limited, Unit 4 Albany Park, Frimley Road, Camberley, Surrey, GU16 7PQ with the heading 'Data protection'