Fresh Start Policy Privacy & Cookie Policy

Fresh Start Catering Limited, Oxford Court, St James Road, Brackley NN13 7XY

1. Introduction

Fresh Start (“we,” “us,” or “our”) is committed to protecting and respecting your privacy. This Privacy & Cookie Policy explains the types of personal data we may collect about you when you interact with us and how we store, handle, and keep it safe.

We hope this policy answers any questions you have. If not, please get in touch with us.

This Privacy & Cookie Policy may be updated from time to time, so please check back periodically.

2. Who is Fresh Start?

Fresh Start is a trading name of Fresh Start Catering Limited (company number 06198481), a contract catering business. Our website, www.freshstartcatering.uk, provides information about our business and access to Meal Manager, which allows parents and guardians to order and pay for school meals.

This policy, along with our Terms and Conditions and any other referenced documents, sets out how we process any personal data we collect from you or that you provide to us. Please read it carefully to understand our views and practices regarding your personal data.  

3. Data Controller

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is Fresh Start Catering Limited. Our registered office address is: Oxford Court, St James Road, Brackley NN13 7XY. Our Data Protection registration number is ZA310926.  

4. Legal Bases for Processing

We collect and process your personal data based on the following lawful grounds:

• Consent: In specific situations, we may collect and process your data with your explicit consent (e.g., when you tick a box to receive marketing communications). We will always make it clear what data is necessary and why.
• Contractual Obligations: We may need your personal data to fulfil our contractual obligations to you (e.g., to process your meal orders and payments).
• Legitimate Interest: We may use your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests (e.g., to send you service updates or reminders about order deadlines).  

5. When We Collect Your Personal Data

We may collect your personal data when you:

• Visit our website and use our services, including Meal Manager.
• Register for an account with us.
• Place an order for school meals.
• Contact us by phone, email, or through our website.
• Complete surveys or provide feedback.
• Interact with our social media pages.

6. Types of Personal Data We Collect

We may collect the following types of personal data:

• Identity Data: Your name, email address, postal address, telephone number.
• Financial Data: Payment card details (processed securely by our third-party payment processor).
• Technical Data: IP address, browser type and version, operating system, device type, and other technical information.
• Usage Data: Information about how you use our website and services, including the pages you visit, the links you click, and the meals you order.
• Marketing and Communications Data: Your preferences for receiving marketing communications from us.
• Pupil Data: Pupil names, classes, and free school meal eligibility (provided by schools).

7. Children’s Data

We understand the importance of protecting children’s privacy. We collect and process children’s data (e.g., names, classes, free school meal eligibility) only as provided by schools to fulfil our contractual obligations and provide our services.

8. IP Addresses and Cookies

We may collect your computer’s IP address, operating system, and browser type for system administration, fraud prevention, and aggregate reporting. This is statistical data and does not identify you individually.

Our website uses cookies to distinguish you from other users, enhance your experience, and improve our site. Cookies are small files stored on your computer (with your consent) that contain information.

We use Google Analytics, which uses cookies to track visitor interactions and provide anonymous information about website trends. This helps us understand how visitors use our website and improve its functionality.

You can block cookies in your browser settings, but this may limit your access to our website.

9. How We Use Your Personal Data

We use your personal data for the following purposes:

• To provide and improve our services: To process your orders, manage your account, and provide customer support.  
• To communicate with you: To respond to your inquiries, send you service updates, and provide information about our services.
• To personalise your experience: To tailor the content and information we show you.
• To analyse website usage: To understand how our website is used and improve its functionality.
• To prevent fraud and ensure security: To protect our website and services from unauthorised access and fraudulent activity.
• To comply with legal obligations: To comply with applicable laws and regulations.

10. Data Security

We have implemented appropriate technical and organizational security measures to protect your personal data from unauthorised access, use, disclosure, alteration, or destruction.  

These measures include:  

• Secure Socket Layer (SSL) encryption: To protect data transmitted over the internet.
• Password protection: To restrict access to your account.
• Access controls: To limit access to your personal data to authorised personnel.
• Regular security assessments: To identify and address potential vulnerabilities.

11. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.  

12. Data Sharing

We may share your personal data with the following third parties:

• Service providers: We may share your data with third-party service providers who assist us in providing our services, such as payment processors, IT service providers, and marketing agencies.  
• Schools: We share relevant pupil data with schools to facilitate meal ordering and provision.
• Legal and regulatory authorities: We may disclose your data to comply with applicable laws and regulations, or to respond to lawful requests from public authorities.

13. International Data Transfers

Your data may be transferred to and stored in countries outside the European Economic Area (EEA). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and applicable data protection laws.  

14. Your Data Rights

Under the UK GDPR, you have the following rights:

• Right of access: You have the right to request access to your personal data.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.  
• Right to erasure: You have the right to request deletion of your personal data, under certain conditions.  
• Right to restriction of processing: You have the right to request restriction of processing of your personal data, under certain conditions.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, under certain conditions.  
• Right to object: You have the right to object to processing of your personal data, under certain conditions.

You can exercise your rights by contacting our Data Protection Officer at the contact details below.

15. Contact Us

If you have any questions about this Privacy & Cookie Policy or your data rights, please contact our Data Protection Officer:

• Email: [email protected]
• Mail: Data Protection Officer, Fresh Start Catering Limited, Oxford Court, St James Road, Brackley NN13 7XY

16. Updates to this Policy

We may update this Privacy & Cookie Policy from time to time. Any changes will be posted on our website.

This notice was last updated on 26^th October 2024.