This Privacy Statement gives you information about how First Milk collects and uses your personal data including through your use of this website, including any data you may provide when you join First Milk as a member, register with us, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

First Milk is made up of First Milk Limited (Registered under the Co-operative and Community Benefit Societies Act 2014, Number 29199R) and its subsidiaries and associated companies (together the Group). This Privacy Statement is issued on behalf of the Group so when we mention First Milk, “we”, “us” or “our” in this privacy Statement, we are referring to the relevant company in the Group responsible for processing your data. Unless stated otherwise First Milk Limited will be the Controller.

If you have any questions about this Privacy Statement, including any requests to exercise your legal rights (paragraph 8), please contact us using the information set out in the contact details section (paragraph 9).

The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Farm Data includes details of your farm address, details relating to herd and milk production, your participation in programmes and schemes run or co-ordinated by us and financial, environmental, employment and veterinary information relating to your farm, premises or business;
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you interact with and use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us feedback or contact us;
- you apply for membership;
- complete questionnaires; or
- submit reports in respect of accreditations or upload information to your account on our website relating to your business, herd(s) and related veterinary, environmental and scientific information (this includes where third parties do so on your behalf).
- Cookies. As you interact with our website, we will automatically collect a certain minimal amount of Technical Data about your equipment, browsing actions and patterns using only essential cookies (or similar technology).
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below :
- Technical Data is collected from the following parties:
- analytics providers;
- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services;

3. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you this includes the contract between us and our members.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure member or customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Recognised Legitimate interests: We may use your personal data where it is necessary for
- crime prevention;
- public security;
- national security or defence;
- safeguarding;
- emergencies; or
- sharing personal information to help other organisations perform their public tasks or official functions.
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. Where you have provided your consent you may withdraw it at any time by contacting us at Secretary@firstmilk.co.uk.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
To register you as a member or a new customer	(a) Identity (b) Contact(c) Farm	Performance of a contract with you; to enter your details in the register of members or customer list to allow us to identify you
(a)To provide membership services including targeted advice and notify you of dairy schemes and other projects and initiatives relevant to your business or the aims of First Milk and administering your involvement therein. (b)To process your order including: Manage payments, fees and charges administering your account with us Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications(f) Farm	(a) Performance of a contract with you (b) Necessary for our legitimate interests
To manage our relationship with you as a customer or member which will include:(a) Notifying you about changes to our membership rules or terms of business or to our Privacy Statement(b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications(e) Farm	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical(d) Farm	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications. You may withdraw your consent at any time.
To carry out market research through your voluntary participation in surveys		Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

Special Category and Criminal Offence Data

We will not process Criminal Offence Data other than in very exceptional cases or where relevant in the employment context and in accordance with our Privacy Policy and Employee Privacy Statement.

We do not envisage that we will process your Special Category Data but if we do we will only do so if we have an appropriate legal basis to do so and meet the necessary special conditions specified in the Data Protection Legislation and in accordance with our Privacy Policy.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Automated Decision Making

We do not envisage that any decisions will be taken about you using automated means. However, we will notify you if this position changes.

4. Disclosures of your personal data

We may share your personal data where necessary with:-

third parties who assist us in providing our services to you or who provide services to us as an organisation or who provide services to our members in respect of which you have agreed to participate;
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

We require all third parties to whom we transfer personal data to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

The First Milk website (First4milk) and First Milk App are provided on our behalf by Kingshay who act as our data processor. The personal data which you upload to the website or App is shared with Kingshay for certain specific purposes related to the services which Kingshay provide to us or to you directly. Certain third parties have access to your personal data that has been uploaded to the First4Milk website or app in their capacity as providers of services and are only permitted to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers or any other third party, we ensure a similar degree of protection is afforded to it as afforded by the law in the UK[ by ensuring that either the transfer of your personal data is to a country that has been deemed by the UK to provide an adequate level of protection for personal data or that appropriate contractual safeguards are put in place in accordance with data protection legislation and ICO guidance.

Request access to your personal data (commonly known as a “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, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
Object any time to the processing of your personal data for direct marketing purposes.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Complain to us about how we handle your personal data.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.