PRIVACY NOTICE

INTRODUCTION

This privacy notice sets out how the Menzies Distribution Companies safeguard personal data. This notice applies to Menzies’ services, including our services, our websites, our customer portals, surveys, electronic marketing communications and service emails (“Services”).

This notice explains the types of personal data we process, the categories of data subjects to whom data belongs, and how and why we process your personal data. The integrity of your personal data is of paramount importance to our business, and we are committed to keeping it secure.

WHO WE ARE

Menzies Distribution Companies act as Data Controllers, responsible for taking care of the personal data we process for our business purposes, in accordance with data protection laws and regulations. This means we make decisions about how and why we use your data and are responsible for safeguarding your privacy rights and maintaining the integrity of your data. Where a customer is the Data Controller, with Menzies processing personal data on behalf of that controller when delivering a product or service, Menzies will be a Data Processor of the personal data.

Each Menzies entity is registered as a data controller with the Information Commissioner’s Office. Registration numbers can be seen below.

PERSONAL INFORMATION WE COLLECT FROM YOU

Depending on our relationship with you, we may collect various types of personal data from you. For example, we collect specific personal data from our customers so we can deliver our services. Where you are a supplier to Menzies, we may collect personal data that allows us to interact with you about your services. Personal data collected by Menzies can include information that you provide to us directly and information we collect from other sources.

INFORMATION PROVIDED BY YOU:

We may request, collect, and process personal data about you through your use of our website and through service provision, including iMenzies.com and similar customer zones:

• Contact data such as full name of customer (or any other contact name given to us by customer), job title and business name (where applicable), email address, contact number and delivery and invoicing address(es) including postcode;
• Account data where you have an account on our customer zones, such as iMenzies, we will process your username, unique Customer Reference Number, tracking details, delivery preferences or instructions, invoice details, NewstrAid donation status and your communication preferences.
• Customer payment details including bank account number and sort code;
• Marketing data such as your instructions as to whether you would like to receive email marketing and promotional correspondence from Menzies Distribution Companies (opt in/opt-out). This will also extend to any marketing or promotional material sent by Menzies’ trusted partners and third parties. More information below;
• In addition to contact details, any information you provide in any enquiry, comment or request made to Menzies, for example, when you contact our Customer Service Centre;
• Any information included by you when taking part in a customer survey campaign; and
• When you interact with Menzies social media pages, such as leave a comment, we may process personal information from your profile in order to manage your interaction.

INFORMATION PROVIDED BY OTHER MEANS:

• We may be provided with personal information about you by third parties and customers with whom Menzies have a contract for services or are proposing to enter into such a contract. For example, where our customer is data controller and Menzies is acting as their data processor during our provision of services to customer.
• Any personal data necessary to perform customer credit verification checks, such as name and job title.
• From records of delivery, including the name and signature of any person who signs for or accepts delivery from Menzies.

INFORMATION WE COLLECT AUTOMATICALLY:

(Where non-essential Cookies are accepted) Technical Data: information about the device you are using to access our website, including Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system;

• (Where non-essential Cookies are accepted) Analytical Data: information about your website visit, including services you viewed or searched for; page response times, download errors, length and frequency of visits to certain web pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
• Where an individual can be identified from barcodes and reference numbers on items we collect or deliver; and
• Recordings of calls placed to our Customer Service Centre, including contact number used for inbound calls.

HOW WE USE YOUR INFORMATION

We process your personal data for specified, explicit purposes only and only where we have identified an appropriate lawful basis to do so. These lawful bases, set by the UK General Data Protection Regulations (“UK GDPR”) and the Data Protection Act 2018, include but are not limited to:

• Consent: Where you, the data subject, has freely given your consent to the processing of your personal data. Menzies will rely on consent as our lawful basis in limited circumstances, including for processing your personal data for marketing purposes by Menzies or Menzies’ partners, and for our use of nonessential cookies and tracking technologies;
• Contract: Where the processing is necessary for the performance of a contract we have entered into, meaning we need to process personal data in order to comply with the obligations of the contractual arrangement. This also includes data processed during negotiation of a contract;
• Legal Obligation: Where the processing is necessary for us to comply with a legal obligation to which Menzies are subject;
• Legitimate Interests: Where the processing is necessary for the purposes of the legitimate interests pursued by Menzies as a business, except where such interests are overridden by the interests, rights, and freedoms of the data subject (please see below for more  information).

In any event, we will only process your personal information for the purpose(s) for which it was originally collected, and where there is a legitimate basis for doing so.

WE MAY USE YOUR PERSONAL INFORMATION IN THE FOLLOWING WAYS:

• to carry out the logistics and delivery services and comply with our contractual obligations in relation to service provision to you;
• to provide you with information, products and services that you have requested;
• to respond to any request, comment, complaint or query submitted by you;
• to manage our relationship with you, for example, to send you messages about our products or services, such as service updates and to notify you about material changes to our terms and conditions, this privacy notice, our cookie notice and to troubleshoot your account usage and access;
• to create and facilitate your access to and use of Menzies’ online customer portals or zones;
• to carry out customer credit checking, where appropriate;
• to collect payments and issue invoices for services delivered, including charges, deductions and donations to NewstrAid (unless you have opted out of NewstrAid donations);
• to provide you with marketing and promotional material information about Menzies’ goods or services we feel may be of interest to you, where you have consented to this;
• Where you have freely given your consent for such, we will pass your personal data to our trusted third parties and partners so they may serve you with marketing and promotional materials about their products and services.
• to ensure that content from our site is presented in the most effective manner for you and the device you are using;
• to detect and prevent fraud and related activities, and protect our business and legal interests;
• we may record inbound and outbound calls from our Customer Service Centre for training and quality assurance purposes. You will be informed of this at the beginning of the call.
• to administer our site and protect internal operations, including troubleshooting, data analysis, testing, research, system maintenance, quality and security reporting, statistical and survey purposes as further explained below;
• to measure or understand the effectiveness of our communication (both on and offline) and to deliver relevant content to you, where you have agreed to receive it; and
• to collect evidence and supporting documentation for the purposes of defending legal claims and to protect Menzies’ business interests.
• Use of cookies and other tracking technologies on your device which are essential to deliver our Services. We rely on the functionality of these essential cookies to make our website and services function and these cookies cannot be rejected;
• Use of cookies and other tracking technologies that are non-essential for our services and may support our marketing and advertising efforts, where you have consented to this. For example, to serve targeted advertising and content recommendations based on your behaviour on and usage of Menzies’ services, or by determining your approximate location on a city and country level;

COOKIES

Our website may use cookies and other tracking technologies to enhance your experience and enable certain website functionality. To learn about the cookies we use on our sites, please visit our Cookie Notice.

SHARING PERSONAL DATA

We may share your personal information between the Menzies Distribution Companies as necessary to provide our products and services to you.

We may disclose your personal information to third parties in certain circumstances, such as:

• Where we sell or buy any company or business/assets or enter into a joint venture, we may need to disclose your personal information to the prospective seller or buyer of such business or assets or to our business partner in a joint venture business;
• Where we engage data processors or sub-processors, to act on our behalf or assist us in delivering specific services to you. We enter into contractual arrangements with data processor(s) who may process personal data on our behalf, ensuring confidentiality and security obligations in place to protect that data;
• We work with various industry third parties who support us in our business activities or sit within our supply chain. These third parties are only permitted to process shared personal data under our strict instructions and in line with applicable privacy laws. Examples of such parties are analytics and reporting tools, delivery and tracking tools, email providers for outbound emails, publishers and customisation service providers;
• Where 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 contractual rights; or to protect the rights, property, or safety of Menzies Distribution and its subsidiary companies, our customers, or users. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• Sharing information with company insurers and company appointed solicitors as required and necessary to defend legal claims impacting the business;
• Where you are a newstrade retail customer who has kindly chosen to support the NewstrAid charity, Menzies will manage the collection of your weekly donations and/or lottery fees through weekly delivery invoices. Your donations will be passed directly to NewstrAid. No personal details is shared by Menzies to the Charity in order to share donations.

STORAGE OF PERSONAL DATA

In line with the Storage Limitation principle laid down by the UK GDPR, Menzies are committed to retaining personal data for the shortest duration possible to achieve our aims. The retention period for which your data will be retained by Menzies is based on the type and nature of personal data and our purpose for processing it. We will store your personal data for only as long as necessary to fulfil the original purpose for which it was collected. If Menzies are under a legal obligation to retain the data for a longer period, we will do so to comply with our obligations.

Where Menzies is relying on your consent to process your personal data, this data will be retained until such a time you choose to withdraw your consent.

LEGITIMATE INTERESTS

We may commonly rely on legitimate interests as a lawful basis to process your personal information, provided that your interests do not override our own. This also includes where we are pursuing the legitimate interests of a third party. Legitimate Interests is only one lawful basis available under data protection laws. We will only rely on consent for direct marketing. Otherwise, we may process your data because we have a legal obligation to do so, or where we have a contract with you.

Examples of processing conducted in pursuit of our legitimate interests (or the interests of a third party) include:

• to understand how our website and other services are used;
• to administer and protect our business and web presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting);
• to manage our relationship with you, including sending you service messages, notifications of material changes to terms and notices, to reset your account password, to respond to any comment or query submitted by you;
• To issue customer surveys and gather responses;
• To improve and develop our service user experience;
• Engage with customers and contacts on social media; and
• To collect and share charity donations and lottery ticket entries where you are a supporter of the NewstrAid Benevolent Charity unless you have chosen to opt-out of donation and fee deductions.
• To deliver and circulate promotional materials on behalf of NewstrAid to promote the charity’s activities unless you have opted out of receiving this postal marketing.

NEWSTRAID BENEVOLENT FUND

Menzies is a proud supporter of NewstrAid Benevolent Fund, a charity registered and operating in the United Kingdom (charity number 1116824, Scottish charity number SC038775). NewstrAid provides a wide range of support services to people who work or have worked in the sale and distribution of newspapers and magazines. As a newstrade wholesaler, Menzies supports NewstrAid in a few different ways:

• Distribution of promotional material on behalf of NewstrAid;
• Collection of weekly Retail Charitable donations on behalf of NewstrAid;
• Collection of small society lottery (“200 club”) weekly entry fees on behalf of NewstrAid;
• Administration of lottery prizes to winning retailer customer;
• Sharing donations collected on the Charity’s behalf with the Charity.

Retailer customers are automatically opted-in to contribute charitable donations and small society lottery fees to the charity through their newstrade account with Menzies. You can opt-out of making either or both contributions at any time. Menzies’ retailer customers can opt-out by emailing enquiries@menziesdistribution.com. Alternatively, you can email NewstrAid directly at mail@newstraid.org.uk or use one of their various other contact methods here.

Menzies may process your personal data when collecting donations or lottery fees, such as your customer account number, store name and address, and donation and marketing preferences. The applicable lawful basis for processing personal data for the purposes of collecting donations and/or lottery fees on behalf of NewstrAid and sharing promotional material on behalf of the charity is legitimate interests (including those pursued by a third party, in this case, the NewstrAid Benevolent Fund).

As a retailer customer, if you would like to opt-out of receiving promotional material about the Charity, please contact us at enquiries@menziesdistribution.com.

For more information on retailer donations, please visit NewstrAid’s website here. For NewstrAid’s privacy policy, see here.

TRANSFERS OUTSIDE OF THE UK

The personal data that we hold about you may be processed in or transferred to a destination outside the UK in limited circumstances. For example, your data may also be processed by our trusted suppliers acting as data processors where they operate outside of the UK. Whenever we transfer your personal data out of the UK, adequate protections are afforded to it by ensuring that at least one of these appropriate safeguards are in place:

• Where the destination country has been granted an adequacy decision from the UK Government, or the destination country offers adequate or exceeding levels of protection for Personal Data as the UK, such as EU member states or members of the European Economic Area.
• Where Menzies relies on service providers operating outside of the UK or EEA, we will adopt an appropriate transfer mechanism approved by the UK Government and European Commission, such as Standard Contractual Clauses with the UK’s International Data Transfer Addendum (IDTA), which protects the personal data transferred internationally to the same degree offered by the UK.

For further information regarding the transfers of your personal information outside of the UK and EEA, please contact us at privacy@menziesdistribution.com.

SECURITY OF YOUR DATA

The security of your personal data is of vital importance to Menzies. We have embedded technical and organisational security measures into our business practices and infrastructure to protect the personal data we process. Our controls are in place to protect your personal data from unauthorised access or disclosure, improper use, alteration, unlawful or accidental destruction or loss and theft.

The Menzies Distribution Companies comply with the requirements as laid down by data protection law to ensure that your personal information is transmitted securely using the latest secure server technology, protecting your personal and transactional information to the highest standards. Menzies stores Personal Data in UK based, secure on-premises data centres.

Where we have given you (or where you have chosen) a password which enables you to  access certain parts of our site, you are responsible for keeping this password confidential.We ask you not to share a password with anyone and inform us if you believe your password is or could be compromised.

Any party, including Menzies employees and contractors or third-party suppliers in their capacity as data processors, are subject to confidentiality provisions in contractual agreements, as well as various company policies, procedures, and controls, and will only process personal data under Menzies’ strict instruction. Access to personal data stored on Menzies systems is strictly limited to individuals (employees, contractors, suppliers) who undoubtedly require access to perform their duties in delivering the services.

However, despite maintaining security measures to protect data, please be aware that the transmission of information via the internet can never be completely secure. Menzies will do our utmost to protect your personal information however we cannot guarantee that it will be secure whilst in transit to and from our services over the internet. By engaging with us you acknowledge the inherent risk of using the internet.

MARKETING

Where you agree, we would like to keep you up to date with information about our business and services, including offers, promotions and business-to-business marketing material, via email, post and telephone. We will only process your personal data for marketing where you have freely given your consent, such as ticking an empty tick-box mechanism on one of our websites. You can change your mind at any time. If you have previously agreed to receive marketing correspondence from Menzies Distribution Companies, you can unsubscribe (opt-out) at any time by updating your account preferences in iMenzies or by using the ‘unsubscribe’ links at the bottom of the promotional emails we send you. Otherwise, you can email or call us using the details on our Contact page.

Menzies collects consent for direct marketing on behalf of our trusted third-party partners. This is known as third party consent, meaning your consent is provided to Menzies to provide marketing and promotional material on our partner’s behalf. You will be informed of who our third-party partners are at the point of consent. Consent for third party marketing can be withdrawn at any time by updating your account preferences, unsubscribing using a link at the bottom of a marketing email or by contacting us.

We may also distribute promotional material on behalf of NewstrAid Benevolent Charity to retailer customers, in addition to collecting and managing donations and lottery costs (unless opted-out of such). These will be distributed as part of your regular service deliveries, including via post, in tote boxes. This is to provide you with information about the Charity’s activities and updates as they are likely to be of benefit to persons within the newstrade industry.

We may perform live marketing calls for marketing purposes, which you can refuse at any time. Before we call you, we will check in advance that you have not registered with the Corporate Telephone Preference Service (CTPS) and the Telephone Preference Service (TPS) and that you have not previously informed us that you object to live marketing calls.

LINKS TO OTHER SITES

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. Please be aware that the Menzies Distribution Companies have no control over third party websites, which will have their own privacy notices, and that we do not accept any responsibility or liability for these notices. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and please check these policies before you submit any personal data to the websites in question.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

Whenever you are asked to fill in a form on the website, leave the opt-in tickbox clear to indicate that you do not want to receive marketing material from Menzies; and

If you have previously agreed to us using your data for marketing purposes, you may change your mind at any time by unsubscribing using the link provided at the footer of any promotional material shared. Alternatively, you can email us at privacy@menziesdistribution.com.

We will not sell, share or lease your personal information to third parties unless we have your permission or are required by law to do so.

YOUR RIGHTS

Under UK Data Protection Laws, you have the following rights over the way Menzies uses your information:

• Right to object: you have the right to object to your data being processed in certain circumstances, for example, for direct marketing or profiling.
• Right to erasure: also known as the right to be forgotten, enables you to request deletion or removal of your personal data where there is no necessary reason for us to continue to process it. However, this is not an absolute right, and we may not be able to comply with your request for legal reasons, which will be explained to you at the time of your request where applicable.
• Right to restrict processing: the right to restrict how your personal information is used or request suppression of your data in certain circumstances;
• Right to data portability: allows individuals to obtain and reuse their personal data for their own purposes across different services.
• Rights related to automated individual decision-making and profiling: automated individual decisionmaking is making a decision solely by automated means without any human involvement and automated processing of personal data is used to evaluate certain things about an individual.
• Withdraw consent: At any point we are relying on your consent to process your personal data (such as for marketing purposes), you have the right to withdraw that consent at any time. This does not apply to processing activities that do not require consent, nor does it impact the lawfulness of processing carried out before you withdraw consent.
• Right of access (Subject Access Request): the right to confirmation as to whether or not we are processing your personal data and, if we do, to obtain a copy of it (subject to exemptions).
• Right to rectification: the right to have inaccurate data rectified or completed if incomplete.

You may exercise your rights at any time. To do so, please contact us by email at privacy@menziesdistribution.com or write to our Data Protection Officer at Menzies Distribution Ltd, 2 Redheughs Rigg, South Gyle, Edinburgh EH12 9DQ.

Please note that before we can begin to fulfil a data subject rights request, we may need to request certain information from you to help us verify your identity or the authority of any third party acting on your behalf. This is a protective measure to ensure that your personal data is not disclosed to any unauthorised third party or that your data is not amended without your knowledge or approval. We may ask you to provide other details to assist us in handling your request, such as clarification on what you are looking for.

If you believe that our processing of your personal information is contrary to data protection law, please contact us using the details below in the first instance. You are also entitled to lodge a complaint with the Information Commissioner’s Office, the UK supervisory authority for data protection issues. Details of how to do this may be found at www.ico.org.uk.

CHANGES TO THIS PRIVACY POLICY

We may update this policy from time-to-time to ensure that it accurately reflects our data processing activities or changes to data protection laws and regulation. Any new version of this Privacy Notice will be considered to be valid at the time of posting on our website. Please check this page regularly for any updates or changes.

CONTACTS

If you have any questions about our privacy policy or how we use your personal information or to exercise any of your privacy rights under UK GDPR, please contact us privacy@menziesdistribution.com or alternatively send a signed letter addressed to:

Data Protection Officer, Menzies Distribution Ltd, 2 Redheughs Rigg, South Gyle, Edinburgh EH12 9DQ

This policy was last updated in May 2024.