Froneri International Limited Privacy Notice – Nuii WildArk Competition

(June 2021)

Froneri International Limited (company number: 05777981), a company registered in England with its address at Richmond House, Leeming Bar, Northallerton, DL7 9UL, United Kingdom (“Froneri”), is committed to protecting the privacy and security of your personal data.

This Privacy Notice describes how we collect and process your personal data if you participate in the Nuii WildArk Competition (the “Competition”).  When you share personal data with Froneri when entering the Competition, Froneri will be the Data Controller in respect of your personal data and will process your personal data in accordance with this Privacy Notice.

Your personal data will be used by Froneri only as necessary to manage your participation in the Competition: selection of winner, subsequent contact as well as publication of the winner’s identity. In the event that you win the first prize volunteering trip, after confirmation of your details, these will be communicated to the specific NGOs (WildArk Inc. and EHRA (Elephant Human Relations Aid) who will administer the prize. Froneri’s legal bases for processing your data are as follows (i) necessary for the performance of a contract – the processing is necessary for the purpose of managing and administering the competition; and (ii) legitimate interests – the processing is necessary to allow Froneri to administer the competition, to ensure that the competition is run fairly and to contact the competition winners.

Froneri will process data related to your Instagram account and your images submitted in connection with the Competition. In the event that you win any of the prizes in the Competition, Froneri will contact you to request the following details: name, email address, postal address, contact telephone number and age.  You may also be asked to provide verification of your identity as well as passport details and any dietary requirements in order to arrange your travel and food in the event that you win the first prize volunteering trip. Your data will be kept for the duration of the Competition and until all prizes have been administered. Thereafter your data will be kept in accordance with Froneri’s data retention guidelines for the purposes of satisfying any legal, accounting or reporting requirements and subsequently erased.

If you awarded a prize in the Competition, your identification data, together with your winning image, may be published on Froneri’s official Instagram pages, as well as on Froneri’s website: https://nuiiicecream.com, provided that the publication is directly related to the Competition. In the event that you are awarded the first prize volunteering trip, we may communicate your personal data to WildArk Inc. and EHRA provided it is necessary to perform the contract with you. In addition, we may disclose your personal data to any applicable legal or regulatory body, in the event that we are legally required to do so.

We will share details of your Instagram account and your images submitted in connection with the Competition with our independent judging panel for the purpose of selecting the winner. We may also share your data with processors who provide a service on behalf of, such as advertising agencies. Our advertising agency B The Communications Agency Limited have responsibility for administering the Competition on behalf of Froneri and your personal data will be shared with them for that purpose.

Protecting your data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable Regulator of a suspected breach where we are legally required to do so.

Your data will only be reviewed and used by those individuals who need access to manage the Competition, and only to the extent necessary to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

Transfers of data outside the EU

Froneri is located in and will process your data in the UK. For the purposes of administering the Competition we may share your personal data with our Group companies in the EU. We will transfer your personal data to countries outside of the EU & UK in the following circumstances:

  • When we use an IT system or service, such as email, which is hosted (uses servers located) outside of the UK or EU; or where we use IT service providers located outside the UK or EU e.g. for IT support purposes;
  • In the case of the winner of the first prize, we will provide your information to WildArk Inc. and any airline with which we book flights as part of the first prize;
  • Where any of our independent judging panel are located outside of the UK or EU.

To ensure that your personal data receives an adequate level of protection we put in place the appropriate measures to ensure that your personal data is treated in a way that is consistent with and which respects the EU and UK laws on data protection.

In most cases, these measures are: (i) ensuring the country to which the data is being transferred has an adequacy decision by the European Commission which means the country is deemed an adequate country to transfer data to; or (ii) using the European Commission Standard Contractual Clauses which are standard contract clauses which set out minimum requirements to ensure the data is adequately protected. If you require further information about the protective measures, we use when transferring personal data outside the EU you can request it from us.

Your rights

Under certain circumstances, by law you have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us (see below).

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

Contact

If you have any queries or concerns in relation to this Privacy Notice, please contact:

Froneri International Limited

Leeming Bar Industrial Estate

Leeming Bar

Northallerton

North Yorkshire

DL7 9UL

 

Email address: [email protected]

Telephone number: (01677) 423397

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority, for data protection issues.