DATA PROTECTION
PRIVACY NOTICE (GENERAL)

Version as at 26th February, 2024

We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Key terms

It would be helpful to start by explaining some key terms used in this privacy notice:

We, us, our

Zensho Foods UK Limited, trading as Ichikokudo , a limited company (company number: 14006099) registered in England and Wales, whose registered office is at Hudson House, 8 Tavistock Street, London, England, WC2E 7PP, and our affiliated entities and group companies within the Zensho Group (Corporate Profile | About Us | ZENSHO HOLDINGS) (‘the Zensho Group’ or ‘our group companies’)

Personal data

Any information relating to an identified or identifiable individual

Special category personal data

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic data

Biometric data (where used for identification purposes)

Data concerning health, sex life or sexual orientation

Data subject

The individual who the personal data relates to

Personal data we collect about you

The personal data we collect about you depends on the particular products and services we provide to you. We will collect and use the following personal data about you:

  • your name and contact information, including email address and telephone number and (where applicable) company details
  • information to check and verify your identity, eg your date of birth
  • your gender, if you choose to give this to us
  • location data, if you choose to give this to us
  • any delivery addresses specified for your order
  • your billing information, transaction and payment card information
  • bank account and payment details
  • your account details, such as customer reference, username and login details
  • your tax information (where necessary)
  • information on your gift card or other loyalty card that can be used to enjoy products and/or services at Ichikokudo
  • details of any information, feedback or other matters you give to us by phone, email, post or via social media
  • your activities on, and use of, our website
  • information about how you use our apps, IT, communication and other systems
  • information about the services we provide to you
  • your personal interests
  • your professional online presence, eg LinkedIn profile
  • your contact history, purchase history and saved items
  • information from accounts you link to us, eg Facebook
  • information to enable us to undertake credit or other financial checks on you
  • your responses to surveys, competitions and promotions
  • your images on CCTV

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.

How your personal data is collected

We collect most of this personal data directly from you – in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:

  • from publicly accessible sources, eg Companies House or HM Land Registry;
  • directly from a third party, eg:
    • sanctions screening providers;
    • credit reference agencies;
    • customer due diligence providers;
  • from a third party with your consent, eg your bank or building society
  • from cookies on our website – for more information on our use of cookies, please see our cookie policy
  • via our IT systems, eg:
    • from door entry systems; and
    • through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

  • where you have given consent;
  • to comply with our legal and regulatory obligations;
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Providing products and services to you

To perform our contract with you or to take steps at your request before entering into a contract

Preventing and detecting fraud against you or us

For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us

Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by relevant regulator(s)

Depending on the circumstances:

  • to comply with our legal and regulatory obligations
  • for our legitimate interests

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

  • to comply with our legal and regulatory obligations;
  • in other cases, for our legitimate interests, ie to protect our business, interests and rights

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, eg policies covering security and internet use

For our legitimate interests, ie to make sure we are following our own internal procedures

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

Ensuring the confidentiality of commercially sensitive information

Depending on the circumstances:

  • for our legitimate interests, ie to protect trade secrets and other commercially valuable information;
  • to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, eg in relation to our customer base, product range or other efficiency measures

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

Preventing unauthorised access and modifications to systems

Depending on the circumstances:

  • for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us;
  • to comply with our legal and regulatory obligations

Protecting the security of systems and data used to provide the goods and services

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Updating and enhancing customer records

Depending on the circumstances:

  • to perform our contract with you or to take steps at your request before entering into a contract;
  • to comply with our legal and regulatory obligations;
  • for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

Depending on the circumstances:

  • to comply with our legal and regulatory obligations;
  • for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:

  • existing and former customers;
  • third parties who have previously expressed an interest in our services;
  • third parties with whom we have had no previous dealings.

For our legitimate interests, ie to promote our business to existing and former customers

Credit reference checks via external credit reference agencies

For our legitimate interests, ie to ensure our customers are likely to be able to pay for our products and services

External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts

Depending on the circumstances:

  • for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards;
  • to comply with our legal and regulatory obligations

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

  • to comply with our legal and regulatory obligations;
  • in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

How and why we use your personal data – Special category personal data

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. Such data include:-

  • personal data revealing racial or ethnic origin, religious beliefs, or philosophical beliefs;
  • genetic data; and/or
  • data concerning health, and/or food allergy.

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:

  • we have your explicit consent;
  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
  • the processing is necessary to establish, exercise or defend legal claims.

How and why we use your personal data – sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You do, however, have the right to opt out of receiving marketing communications at any time by:

  • contacting us at privacy.uk@zensho.com or
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share it with other organisations outside the Zensho Group for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

  • companies within the Zensho Group;
  • third parties we use to help deliver our products and services to you, eg payment service providers, warehouses and delivery companies;
  • other third parties we use to help us run our business, eg marketing agencies or website hosts;
  • third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
  • credit reference agencies; and
  • our banks.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

  • our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

We will not share your personal data with any other third party.

Who we share your personal data with – further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. For example:

  • if you have any contractual relationship with us: whilst that relationship is active and after the end of the contract, for at least six years;
  • If you no longer have an account with us or we are no longer providing goods or services to you, we will usually delete or anonymise your account data after seven years;
  • those who do not have any contractual relationship with us: usually less than six years; and
  • Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Different retention periods apply for different types of personal data. For example, we may have to retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

Transferring your personal data out of the UK

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

  • our service providers located outside the UK in the EEA; and
  • our group companies located in the EEA; and
  • our group companies (private sector) located in Japan

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

  • the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries: Japan (only the private sector) and the EEA
  • in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. We do not currently plan to transfer any personal data from the EEA to outside the EEA.
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
  • a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR and/or EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this privacy notice.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy notice’ below.

Transferring your personal data out of the UK – further information

If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal data

Rectification

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data – in certain situations

Restriction of processing

The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations

To object

The right to object:

  • at any time to your personal data being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to automated individual decision making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

The right to withdraw consent

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

You may withdraw consent by contacting us (see ‘How to contact us’ below)

Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO).

If you would like to exercise any of those rights, please:

  • email, call or write to us—see below: ‘How to contact us’; and
  • provide enough information to identify yourself (eg your full name, address, and reference) and any additional identity information we may reasonably request from you; and
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems.

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

If you want detailed information on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator).

Changes to this privacy notice

This privacy notice was published on 26th February, 2024.

We may change this privacy notice from time to time – when we do we will inform you via our website on Ichikokuido’s HP.

Updating your personal data

We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed (eg your surname or address) – see below ‘How to contact us’.

How to contact us

Individuals in the UK

You can contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

Zensho Foods UK Limited

Hudson House, 8 Tavistock Street London WC2E 7PP

privacy.uk@zensho.com

+4474 6233 7965

DATA PROTECTION
PRIVACY NOTICE (RECRUITMENT)

This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share data about you during the application process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal data about you.

Who collects the data

Zensho Foods UK Limited, trading as Ichikokudo (‘Company’) is a ‘controller’ of personal data and gathers and uses certain data about you. This data is also used by our affiliated entities and group companies within The Zensho Group (Corporate Profile | About Us | ZENSHO HOLDINGS) and so, in this notice, references to ‘we’ or ‘us’ mean the Company and our group companies.

Data protection principles

We will comply with the data protection principles when gathering and using personal data, as set out in our Data Protection and Privacy Notice (general) and our data protection policy.

About the data we collect and hold

The table set out in Part A of the schedule below summarises the data we collect and hold up to and including the shortlisting stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared.

The table in Part B of the schedule below summarises the additional data we collect before making a final decision to recruit, ie before making an offer of employment unconditional, how and why we do so, how we use it and with whom it may be shared.

We seek to ensure that our data collection and processing is always proportionate. We will notify you of any changes to data we collect or to the purposes for which we collect and process it.

Where data may be held

Data may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents as described above.

How long we keep your data

We keep the personal data that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your data will depend on whether your application is successful and you become employed by us, the nature of the data concerned and the purposes for which it is processed.

We will keep recruitment data (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed . If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.

If your application is successful, we will keep only the recruitment data that is necessary in relation to your employment.

Your right to object to us processing your data

Where our processing of your data is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your data unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Please contact our Data protection section, shogo.hamano@zensho.com, +4474 6233 7965 if you wish to object in this way.

Your rights to correct and access your data and to ask for it to be erased

Please contact our Data protection section, shogo.hamano@zensho.com, +4474 6233 7965 if (in accordance with applicable law) you would like to correct or request access to data that we hold relating to you or if you have any questions about this notice. You also have the right to ask us for some but not all of the data we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Our Data protection section, shogo.hamano@zensho.com, +4474 6233 7965 will provide you with further information about the right to be forgotten, if you ask for it.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your data will do so only in an authorised manner and are subject to a duty of confidentiality.

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

How to complain

We hope that our Data protection section, shogo.hamano@zensho.com, +4474 6233 7965 can resolve any query or concern you raise about our use of your data. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

THE SCHEDULE ABOUT THE DATA WE COLLECT AND HOLD

Part A
Up to and including the shortlisting stage

The data we collect

How we collect the data

Why we collect the data (purpose)

Legal basis for processing

How we may share the data

Your name and contact details (ie address, home and personal mobile phone numbers, personal email address)

From you

So that we can contact you by letter, email, or phone where necessary to progress your application, arrange interviews and inform you of the outcome at all stages

To inform the relevant manager or department of your application

Legitimate interest: to carry out a fair recruitment process

Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages

With HR personnel to enable them to contact you

With the relevant manager or department

Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests

From you, in the completed application form and interview notes (if relevant)

So that we can make an informed decision about which candidates to shortlist for interview and ultimately recruit

Legitimate interest: to carry out a fair recruitment process

Legitimate interest: to make an informed decision to shortlist for interview and (if relevant) to recruit

The person making the shortlisting decision will receive pseudonymised or anonymised details only; if you are invited for interview, the interviewer will receive non-anonymised details

Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs

From you, in a completed anonymised equal opportunities monitoring form

To comply with our equal opportunities monitoring obligations and to follow our policies

To comply with our legal obligations and for reasons of substantial public interest (equality of opportunity or treatment)

For further information, see *note 1* below

Details of your referees

From your completed application form

To obtain a reference about you, so that we can make an informed decision about your recruitment

Legitimate interest: to carry out a fair recruitment process

Data shared with relevant managers, HR personnel and the referee

*note 1*

If your application is unsuccessful at this stage, we will keep your data, in pseudonymised form, for the purpose of establishing, exercising and/or defending any legal claims, in accordance with our legitimate interests.

Part B
Before making a final decision to recruit

The data we collect

How we collect the data

Why we collect the data (purpose)

Legal basis for processing

How we may share the data

Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers **

From your referees (details of whom you will have provided)

So that we can make an informed decision about your recruitment

Legitimate interest: to make an informed decision to recruit

To comply with our legal obligations

Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice

Information shared with relevant managers and HR personnel

Information regarding your academic qualifications **

From you, from your education provider

To make an informed recruitment decision

Legitimate interest: to verify the qualifications information provided by you

Information shared with relevant managers and HR personnel

Data regarding your criminal record, in a criminal records certificate (CRC) or enhanced criminal records certificates (ECRC) as appropriate **

From you and from the Disclosure and Barring Service (DBS)

To make an informed recruitment decision

To perform the employment contract

To carry out statutory checks in accordance with our legal obligations

Legitimate interest: to verify the criminal records data provided by you

Information shared with DBS and other regulatory authorities as required

For further information, see *note 1* below

Your nationality and immigration status and data from related documents, such as your passport or other identification and immigration information **

From you and, where necessary, the Home Office

To enter into/perform the employment contract

To carry out right to work checks in accordance with our legal obligations

Legitimate interest: to maintain employment records

To carry out obligations and exercise rights in employment law

For reasons of substantial public interest (preventing or detecting unlawful acts)

Information may be shared with the Home Office

A copy of your driving licence **

From you

To make an informed recruitment decision

To ensure that you have a clean driving licence

To enter into/perform the employment contract

To comply with our legal obligations

To comply with the terms of our insurance

Legitimate interest: to ensure you can legally drive

Legitimate interests: to ensure you are fit to perform the duties

To carry out obligations and exercise rights in employment law

For reasons of substantial public interest (preventing or detecting unlawful acts)

Information may be shared with our insurer

Data relating to your health **

From you and/or your GP and/or medical practitioner

To make an informed recruitment decision

To enter into/perform the employment contract

To comply with our legal obligations

Legitimate interests: to ensure you are fit to perform the duties

For the purposes of obligations and rights in employment and social security law

Information may be shared with our insurer

*note 1*

If your application is unsuccessful at this stage, we will keep your data, in pseudonymised form, for the purpose of establishing, exercising and/or defending any legal claims, in accordance with our legitimate interests.

*note 2*

You are required (by law or in order to enter into your contract of employment) to provide the categories of data marked ‘**’ above to us to enable us to verify your right to work and suitability for the position.

*note 3*

Further details on how we handle special category data and data relating to criminal convictions and offences are set out in our data protection policy, the relevant contents of which are available from the HR department upon request.

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