Privacy and Cookie Policy

1. Introduction
Fresh Start (“We”, “Us”) are committed to protecting and respecting your privacy.

This Privacy and Cookie Policy explains in detail the types of personal data We may collect about you when you interact with Us. It also explains how We’ll store and handle that data and keep it safe.

We hope the following sections will answer any questions you have but if not, please do get in touch with Us.
It’s likely that We’ll need to update this Privacy and Cookie Policy from time to time, therefore please come back and check it whenever you wish.

2. Who is Fresh Start
Fresh Start is a trading name of Fresh Start Catering Limited (company number 06198481). We are a contract catering business. The website www.freshstartcatering.uk provides information about our business and access to Meal Manager which provides a service for parents and guardians to order and pay for school meals for pupils.

This policy (together with our TERMS AND CONDITIONS and any other documents referred to on it) sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the Data Protection Act (the Act), the data controller is Fresh Start Catering Limited our registered office address is: The Shed, Charbridge Lane, Bicester, Oxfordshire, England, OX26 4SS. Our Data Protection reference is ZA310926.

3. Explaining the legal bases We rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent

In specific situations, We can collect and process your data with your consent.

For example, when you click a tick box to say that We can contact you.
When collecting your personal data, We’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, We need your personal data to comply with our contractual obligations.

For example, we may need to contact you if there is a problem with a pupil’s potential meal or packed lunch.

Legitimate interest
In specific situations, We require 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.

For example, we will contact you about when Meal Manager opens, a reminder of the deadline for ordering school meals and if you owe us money.

4. When do We collect your personal data?
When you visit our Website and register to use Meal Manager
When you visit our Website and use the Meal Manager service
When you’ve given a third-party permission to share with Us the information they hold about you.
When We collect information from you over the telephone
When We collect information from you by email

5. What sort of personal data do We collect
When you visit our Website and use our Meal Manager service and provide your name, telephone number and email address
When a school provides us the names and class of a pupil and if that pupil is entitled to Pupil Premium Free School Meals

6. IP addresses
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, fraud prevention purposes and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

7. Other Information We may collect from you
If you contact Us, We may keep a record of that correspondence
We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
Details of your visits to our site including, but not limited to, traffic data, location data, Weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.

8. Information about our use of cookies
Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and allows Us to improve our site.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies We use are “analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the site when they are Using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

We use Google’s Google Analytics, which is a free Web analytics tool to help Us understand how visitors engage with our Website. Google Analytics uses cookies to track visitor interactions. The cookies are used to store information, such as timing of visits, whether the visitor has been to the Website before, and what Website referred the visitor to our Website. Google Analytics collects information anonymously, and reports Website trends without identifying individual visitors. Google Analytics provides Us with a variety of reports about how visitors interact with our Website, so We can improve our Website and access to our Website.

Please note that our advertisers may also use cookies, over which We have no control.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after 2 years.

9. How and why do We use your personal data?
We use information held about you in the following ways:

To ensure that content from our site is presented in the most effective manner for you and for your computer.
To provide you with information, products or services that you request from Us, where you have provided consent to be contacted for such purposes.
To carry out our obligations arising from any contracts entered into between you and Us.
To allow you to participate in interactive features of our service when you choose to do so.
To notify you about changes to our service.

We do not disclose information about identifiable individuals to our advertisers, but We may provide them with aggregate anonymous information about our users (for example, We may inform them that 100 parents at a given school have visited the website on any given day).

We want to give you the best possible customer experience. We use the information you provide Us to provide you with a service to order school meals using our Meal Manager service. We always ask you to provide the Pupil ID and Pupil Password when you register to use our Meal Manager service. The Pupil ID and Pupil Password is provided to you by the school of the pupil.

Where you have provided consent, We may contact you by phone and / or email to provide you information about our Meal Manager service and answer any questions you may have.

When you use our Meal Manager service We need to collect your personal data to enable the service to be provided. We only ask for personal information that is required for us to effectively provide the Meal Manager service.

10. How We protect your personal data
We know how much data security matters to all our customers. With this in mind, We will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our Websites and apps Using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and We may carry out penetration testing to identify ways to further strengthen security.
Email security
Please note that email messages may not be secure and could be intercepted and read by someone else. Please bear this in mind before including personal or sensitive information in any email messages.

11. How long will We keep your personal data?
Whenever We collect or process your personal data, We’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning; such as your age and device type

Some examples of customer data retention periods:
When you register to use Our service, We’ll keep the personal data you given Us for the period that the relevant pupil is at the relevant school , so We can comply with our legal and contractual obligations. We do not keep your payment details.
When you pay for school meals using the Meal Manager service your payment information is processed by our merchant gateway provider which is a separate website to https://mealmanager.freshstartcatering.uk

12. Who do We share your personal data with?
Other than the events described in clause 14 We do not share your data with third parties.

13. Where your personal data may be processed
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
We only operate in the United Kingdom. The reason why your data maybe be transferred to, and stored at, a destination outside the EEA is because We and other organisation use cloud-based storage which may use servers located outside of the United Kingdom or outside of the EEA.
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 our site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

14. Disclosure of your Information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties:
In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets.

If Fresh Start or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our TERMS AND CONDITIONS and other agreements; or to protect the rights, property, or safety of Fresh Start, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

15. What are your rights over your personal data?

An overview of your different rights

You have the right to request:

Access to the personal data We hold about you, free of charge.
The correction of your personal data when incorrect, out of date or incomplete.
That We stop using your personal data for direct marketing, by any means
That We stop any consent-based processing of your personal data after you withdraw that consent.

You can contact Us to request to exercise these rights at any time as follows:

To ask for your information please contact The Data Protection Officer, Fresh Start Catering, The Shed, Charbridge Lane, Bicester, Oxon, OX26 4SS or email [email protected] . To ask for your information to be amended please contact our customer services team.
If We choose not to action your request, We will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given Us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where We rely on our legitimate interest
In cases where We are processing your personal data on the basis of our legitimate interest, you can ask Us to stop for reasons connected to your individual situation.
We must then do so unless We believe We have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, We will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, We will ask them to prove they have your permission to act.

Our site may, from time to time, contain links to and from the Websites of our partner networks, advertisers, affiliates and Websites that may or may not be of interest to you. 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. Please check these policies before you submit any personal data to these Websites.

16. How can you stop the use of your personal data for direct marketing?
We will only contact you by phone and / or email about Our Meal Manager service.

17. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to Us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note We can’t be responsible for the content of external Websites)

18. Any questions?
We hope this Privacy and Cookie Policy has been helpful in setting out the way We handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Email Us on [email protected]

Or write to Us at
Data Protection Officer Fresh Start Catering Limited
The Shed
Charbridge Lane Bicester Oxfordshire OX26 4SS

This notice was last updated on 14th May 2018