Privacy

WEBSITE PRIVACY POLICY
This Privacy Policy (this “Privacy Policy”) explains how we collect, protect, use, and disclose the Personal Information (defined below) when you use our website located at https://pallasfoods.com or any other website we operate (collectively the “Sites”). We understand that you care about how your Personal Information is used and shared, and we take your privacy seriously. Please read the following to learn more about this Privacy Policy.

GENERAL
“We”, “us” and “our” refer to Sysco UC and its operating subsidiaries and affiliates that adopt this Privacy Policy. “You” and “your” refer to the individuals visiting our sites, as well as to the organizations or businesses that they represent. We are the controller of your personal data via our Website pursuant to General Data Protection Regulation (GDPR).
By visiting one of the Sites, you are accepting the practices outlined in this Privacy Policy, which is subject to modification as described below. It is your responsibility to review this Privacy Policy frequently and remain informed about any changes to it, so we encourage you to visit this page often.

WHAT IS PERSONAL INFORMATION?
“Personal Information” means any information about an individual from which that person can be identified. Personal information may include, for example: first and last name; birth dates; e-mail addresses; credit information; home and mobile phone numbers or addresses.

Personal Information does not include, without limitation, aggregated information (i.e. information presented in summary or statistical form which does not contain data that would permit the identification of a specific individual without significant effort).

HOW WE GATHER PERSONAL INFORMATION
We may collect Personal Information from our customers, suppliers and other Site users in several ways:
We may gather account information through the Sites.
When you visit the Sites, we may ask you for Personal Information so that we can provide you with the products, services, or information that you have requested, including credit and financial information required in order to open a business account with us. When you maintain a business account with us and transact business through the Sites, we will ask you for information necessary to process and complete transactions with us, including your name, delivery and billing addresses, e-mail address, and credit card or other payment-related information.
We may maintain historical account information of our customers and suppliers.
We may maintain historical account information relating to present and former customers and suppliers. Often this historical information predates such customers’ and suppliers’ use of the Sites for transacting business with us. We maintain this information so that we may better serve and effectively interact with our customers and suppliers. Historical account information constituting Personal Information maintained by us is subject to this Privacy Policy.
Communications via our Site.

We collect personal information when you provide it to us through communications via our Site. This includes where you have contacted us through the channels listed on the “Contact Us” page on our Site and similar situations in which you have chosen to provide the information to us, including for customer services support.

Goods or Services You Request.

Where you request goods or services from us, we will collect your personal information in order to process your request and otherwise contact you following a purchase. The type of information we may collect from you may include contact details (including name, address, email address, mobile/cell and telephone number) and employment details (including job title).
We may gather information from the Sites by cookies and Internet monitoring technologies.
As you interact with our Site, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy https://pallasfoods.com/cookies for further details.

We may gather information provided by you in one or more other features of the Sites.
We may from time to time offer interactive or social aspects on the Sites. For example, if you choose to express an opinion in an online forum, respond to user polls, or enter any contests, we may ask you for Personal Information. If you request to sign up for newsletters or other promotional materials, or if you send an inquiry to one of our customer service representatives, we may store a record of your request along with any Personal Information allowing us to respond to your inquiry.

HOW WE USE PERSONAL INFORMATION
We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at via the “Contact Us” section on our Site.
We have set out below a description of the ways we plan to use your personal information:
• to register as a new customer;
• to enable us to carry out our obligations arising from any contracts and to provide you with the information, products and services that you request from us;
• to process and deliver your order, including (a) manage payments, fees and charges; and (b) collect and recover money owed to us;
• to enable us to respond to an enquiry or other request you make when you contact us via our Site, including for customer services support;
• to notify you about changes to our service;
• to enable us to issue a notice or corrective action to you in relation to any of our products or services, if required;
• to better understand how you interact with our Site, including its functionality and features, and ensure that content is presented in the most effective manner;
• to manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) asking you to leave a review or take a survey;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about and we feel may interest you, as described in the “Marketing” section below;
• to enable you to partake in a prize draw, competition or complete a survey;
• to deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
• to use data analytics to improve our Sites, products/services, marketing, customer relationships and experiences.

IS PERSONAL INFORMATION EVER SHARED OR DISCLOSED?
Personal Information is used to complete and support your use of the Sites and the services provided thereon and to comply with any requirements of law. We may share Personal Information with third parties as described below:
• Sysco UC is a Sysco Company and Personal Information may be shared with other Sysco entities;
• our selected commercial partners and sponsors where you have chosen to participate in surveys, opinion groups or other marketing-related initiatives relating to your use of our goods and services;
• a prospective seller or buyer in the event of a sale or purchase of any our business or assets so that the buyer can continue to provide you with information and services;
• our service providers that we engage to provide services for us. Where we provide your personal information to third party services providers, they are required to keep your personal information confidential and secure, and must only use your personal information as instructed by us; and
• our distributors, business partners, or other service providers, including for marketing purposes or where you have chosen to share your personal information through various features and functionality provided via our Site.

We may also disclose your personal information where required to respond to authorised requests from government authorities or where required by law, including for national security. Where we are required by law, we may also disclose your personal information where it is necessary to enforce or apply our Site Terms, this Privacy Policy or other agreements, to investigate or protect the rights, property or safety of our business and our group companies, our products and services and our customers, distributors or business partners or to prevent or take action regarding illegal activities or fraud, situations involving potential threats to the safety of any person or as evidence in litigation.

MARKETING
We may contact you to provide you with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. You may be contacted by us, or by one of our selected partners, in each case where you have consented to receive these communications.
You may opt out of receiving our marketing communications at any time by contacting us at marketing@pallasfoods.com or by using the unsubscribe link in any of our communications.
We will continue to contact you for non-marketing related purposes where we need to issue a field corrective or safety notice, or to where we need to send certain information to you under a legal, regulatory, or ethical requirement.

IS PERSONAL INFORMATION SECURE?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please, however, note that the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet and any transmission is at your own risk.

LINKS TO OTHER SITES
You should be aware that this Privacy Policy applies only to the Sites. Importantly, it does not apply to any other websites to which a link may be provided on the Sites. We cannot control and are not responsible for the actions of third parties operating such sites. You should not take the existence of an affiliation with, or a link from, the Sites to any such other website to mean that it has a privacy policy similar to this one. You should review the privacy policy of any such website.

STORING YOUR PERSONAL INFORMATION
Your Personal Information collected via our Site will be stored on servers located in an EU member state. It may also be processed by our staff or by one of our service providers operating in an EU member state. In some circumstances, your personal information may be transferred to the United States. This includes individuals engaged in, among other things, the fulfilment of your order, and administration of an enquiry or request you make via our Site or the provision of support services.
We have implemented appropriate safeguards, to protect your personal information when it is transferred, including the execution of data transfer agreements with recipients of the information.

YOUR RIGHTS
You may inform us of any changes in your Personal Information, and in accordance with our obligations under applicable data protection laws we will update or delete your Personal Information accordingly.
Residents of the EEA: You may have the right to: request (a) access the to your personal information we hold about you; (b) request we correct any inaccurate personal information we hold about you; (c) request we delete any personal information we hold about you; (d) restrict the processing of personal information we hold about you; (e) object to the processing of personal information we hold about you; and/or (f) receive any personal information we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
To exercise any of your rights in connection with your personal information, please contact dataprotection@sysco.com, please note that Sysco UC is a Sysco Company. We will process any request in line with any local laws and our policies and procedures. If you are located in the EEA, you have the right to lodge a complaint about how we process your personal information with the supervisory authority in your country.

MODIFICATIONS TO THIS PRIVACY POLICY; YOUR CONSENT
By using any of the Sites, you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. We may change this Privacy Policy at any time by posting a new version of this Privacy Policy on the Sites. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the Personal Information we collect. Your continued use of a Site constitutes your agreement to this Privacy Statement and any updates.

CONTACTING US
If you have any questions about the processing of personal information via this Site, please contact our Data Protection Officer by email at dataprotection@sysco.com, please note that Sysco UC is a Sysco Company. If you contact us, we will do our utmost best to address any concerns you may have about our processing of your Personal Information.
Version: 1.0
Date Published: 25/05/18