Terms and Conditions
Privacy Notice
Last Updated :30th April 2024
This Notice explains how, when and why we collect and use your personal data when you interact with CPL Aromas [CPL].
‘Personal data’ is any information or set of information that can identify you as an individual such as your name, address, telephone number, email address as well as any other information about you that CPL may obtain from you directly or indirectly.
We are committed to being transparent in the way we collect and use your personal data and how we protect it. We also recognise your need for reasonable control of your personal data.
This is why this Notice explains to you in detail:
- Who is responsible
- Application of this Notice
- What personal data we collect and how we use it
- How we protect it
- Your rights
- Other important information you need to know
Who is responsible
The Data Controller is the legal entity which is responsible for the personal data collected from you. It determines the means and the purposes of the processing of your personal data; that is, how, when and why it collects and uses your personal data. CPL is a multinational company operating around the globe. The Data Controller for your personal data will depend on who you are:
If you are a visitor of this website the Data Controller is CPL Aromas Limited, Quarry Road, Brixworth Northants NN6 9UB UK.
If you are a customer or a supplier, the Data Controller is the legal entity that manages your business relationship with CPL. This information can be found on the invoice or purchase order you receive or in the agreement you have entered into with CPL.
For any other individuals, with the exception of employees and contractors working on CPL sites, the Data Controller is the legal entity that manages your relationship with CPL. This information can be found in the agreement you have entered into with CPL or can be obtained from your contact person at CPL.
The list of CPL legal entities and their details is available on request in writing from the Chief Financial Officer. For any questions with respect of this Notice, please contact us at CPL Aromas Limited, Quarry Road, Brixworth Northants NN6 9UB marked for the attention of The Chief Financial Officer or email them to data.protection@cplaromas.com
Application of this Notice
This Notice applies to you when you interact with CPL in the course of a prospective or ongoing business relationship, when you visit our websites, when you use the technology we make available to you (e.g. when you visit a CPL site) or when you connect to certain platforms, applications or other solutions under our control or when you join any offline or online events organised by us. This Notice does not apply to CPL employees or other individuals working on CPL sites nor to job applicants who may refer to the privacy notice on CPL job portal and on CPL intranet. For any other individuals, the collection and use of your personal data may be subject to a specific privacy notice.
What information do we collect and what do we do with it?
We collect personal data in two ways:
- Directly from you
- Indirectly, through other sources
Directly from you
We may collect and use personal data that you provide us when you interact with us.
For example, your business contact details, including your full name, contact details, your role within your company and your work experience, the country where you work, the products and services that are of interest to you and your company, your opinion and preferences about a product, your communication preferences, your feedback about our services or our organisation.
We also collect the information that you provide to us when you use the contact forms on our website or when you contact our media relations or on paper forms that we ask you to fill during events such as fairs or other marketing events you participate in.
Indirectly, through other sources
We also collect information about you indirectly, for example when you browse CPL websites, subscribe to our feeds on social media, or otherwise use our network infrastructure and the technology we make available to you. We collect logs about your use of the network, our website (e.g. your view or click on specific content or links or when you click on social media plugins) or the platforms, applications or other solutions we ask you to connect to. We may also collect information such as your IP address, device browser and operating system when you connect to our network infrastructure. We also use cookies to enhance your browsing experience on our websites: please see our Cookie Policy for more information.
We also collect information about you from third parties when we acquire other companies for example or from publicly available sources such as information about you made available on your company’s website, or from public registries such as Commercial Registry if such is required to ensure compliance with applicable laws.
When your company wishes to enter into a business relationship with CPL, we may perform a third party due diligence during which your company may provide us with information about you such as identity verification information, general background information, your business experience and qualifications, your curriculum vitae, financial interests you may have as a director or officer of your company, and any relationship with public officials you may have and such information will be subject to any restrictions under applicable data protection law. We may also collect such information from third parties such as Companies House and third party background check providers.
Where we need to collect personal data by law or under the terms of a contract we have with you or the company you act for and you do not provide that data when requests, we may not be able to perform the contract we have or are trying to enter into (for example, to provide you or your company with products or services). We will notify you if this is the case at the time.
What do we do with it?
We collect and use your personal data to:
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Manage and maintain our business relationship including to create and maintain an account in our systems (such as systems for order and payment management, customer relationship management, sample management or for any other services supporting our business relationship) or to designate you as the contact person for specific business interactions. We may deploy different measures in some countries to be aligned with local regulation. (Please see deviations in the relevant Annexes). |
Legitimate interest (to manage and maintain our business relationship) Necessary for the performance of a contract with you or the company you act for Legal obligation |
The contact person for specific business interactions (e.g. when you are designated as the person responsible for commercial questions, payments) |
We collect your data through various sources, including but not limited to:
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Your identity and business contact details If you are a an individual or sole trader, your financial information |
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Manage your orders: for example to ship and process samples or final products and inform you about the status of your order |
Necessary for the performance of a contract with you or the company you act for |
The contact person for specific business interactions |
The same as in the case of ‘Manage and maintain our business relationship’ |
Your identity and business contact details |
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Deliver with excellence through our customer care, for example to address any queries you may have and record and share internally such queries to better answer them and improve our products and services in the future |
Legitimate interests (to provide excellent customer care) Necessary for the performance of a contract with you for the company you act for |
The contact person for specific business interactions |
The same as in the case of ‘Manage and maintain our business relationship’ |
Your identity and business contact details |
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Analyse your feedback and opinion about our products in order to always improve them or develop new ones |
Legitimate interests (to develop and optimise our products and processes) |
The contact person for specific business interactions |
The same as in the case of ‘Manage and maintain our business relationship’ |
Your identity and business contact details Opinions and feedback which you have provided to us |
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Send you marketing communications and newsletters about our activities and products that may be of interest to you in the course of our business relationship or when you so requested |
Legitimate interests (to develop our products and grow our business) |
The contact person for specific business interactions |
The same as in the case of ‘Manage and maintain our business relationship’ |
Your identity and business contact details Your marketing and communications preferences |
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To promote and grow our business by publishing testimonials you have provided to us |
Legitimate interests (to promote and grow our business) |
The contact person for specific business interactions A visitor to our websites |
The same as in the case of ‘Manage and maintain our business relationship’ |
Your identity Opinions and feedback which you have provided to us |
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
Legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy) |
The contact person for specific business interactions A visitor to our websites |
The same as in the case of ‘Manage and maintain our business relationship’ |
Your identity and business contact details Technical information identifying your device, browser, location, etc. Your usage of our website and products Your marketing and communications preferences |
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To use data analytics to improve our website and your online experience, products, marketing, customer relationships and experiences |
Legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and information our marketing strategy) |
The contact person for specific business interactions A visitor to our websites |
The same as in the case of ‘Manage and maintain our business relationship’ |
Technical information identifying your device, browser, location, etc. Your usage of our website and products |
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To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
Legitimate interests (for running our business, provision of IT administration and services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Legal obligation |
The contact person for specific business interactions A visitor to our websites |
The same as in the case of ‘Manage and maintain our business relationship’ |
Your identity and business contact details Technical information identifying your device, browser, location, etc. |
We may share your personal data to:
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Manage your inquiries when contacting our media or investors relations or when contacting us |
The person who initiates the contact with us |
The contact form on our website or when using one of our channels for raising complaints |
Your business contact details and any other personal data requested through the contact form |
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Send you marketing communications and newsletters about our activities and products that may be of interest to you in the course of our business relationship or when you so requested |
The person who subscribes to our newsletters and other communication channels |
Any CPL form which serves the subscription |
Your business contact details and any other personal data requested through the contact form |
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Enable your participation at any CPL event (both online and offline) |
The person who expresses their intent in any way to participate at CPL event(s) |
Any CPL form which serves the subscription |
Your business contact details and any other personal data requested through the contact form |
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Enable our service providers to provide certain services |
A website visitor or person in a potential or ongoing relationship with CPL |
Our websites or in the course of your enquiry or business relationship with us |
Your identity and business contact details Technical information identifying your device, browser, location, etc. Your usage of our website and products Your marketing and communications preferences |
You are advised to avoid sharing your private email address/phone number/home address with us as we are not capable of recognising the nature of such data.
We may share your personal data with:
CPL affiliates in order to deliver you better services. As a global company, our employees in various sites may need access to your personal data in order to deliver you better services through streamlined processes.
Third party service providers that provide solutions and services for our organisation to help us deliver our services with excellence. For example, these services providers may help us to (i) deliver emails or other communications, (ii) develop and host some of our solutions (iii) provide customer services or payment services or (iv) assist us in background checks, fraud prevention and risk assessment, (v) enable your subscription to our newsletter, face-to-face or online events or other marketing channels, (vi) provide CRM solutions to facilitate contact and to support you in your choice of our products and services (delivering product samples)
We may also share your personal data:
in connection or in the course of a merger or a sale or acquisition of a business
when we are legally required to do so by a competent authority.
We do not sell your personal data to third parties.
How is it protected – Security of your personal data
We consider your personal data as confidential information. We deploy technical and organisational measures to secure your personal data and ensure that it is protected from unlawful access, alteration and loss. Organisational measures mean for example that we ensure that only the persons who need to do so for business purposes, have access to your personal data. Technical measures mean that we perform regular checks on our infrastructures but also on our service providers to ensure that they comply with CPL security policies.
Your rights
You are in control of your personal data.
Right to access and to correct. You have the right to request a copy of the personal data we hold about you by contacting us. We make regular checks to ensure we keep your personal data up-to-date. However, we need your help in doing this, so please contact us if you want to correct personal data that you have provided us with.
Right to object and to restrict. You have the right at any time to object to the processing of your personal data (e.g. when you do not wish to receive direct marketing communications or newsletters from us). Under certain circumstances, you also have the right to obtain the restriction of the processing of your personal data (e.g. until an inaccuracy in your personal data is corrected by us following your request).
Right to erasure. If you no longer wish us to process your personal data, you may contact us. We may however retain certain of your personal data for compliance with applicable laws and regulations and in accordance with our data retention rules.
Right to lodge a complaint. We make our best to be transparent, protect your personal data and offer you as much control as we can. If however you deem that we did not do it in compliance with applicable privacy and data protection laws, you can get in touch with us. You also have the right to lodge a complaint with the data protection supervisory authority in your country or in the country where your Data Controller is located.
Right to control Cookies and other technologies on our websites. When you first visit our websites, you are asked to consent to the use of cookies and other technologies. You can manage your choice at any time.
Other important information
Data retention
We retain your personal data for as long as it is necessary for each of the purposes outlined above. We may however retain certain of your personal data for compliance with applicable laws and regulations (e.g. for tax and audit purposes) and in accordance with our data retention rules. Where it is no longer required to retain data that can still identify you, we will either erase, anonymise or aggregate it so that you may no longer be identifiable as a single individual.
International data transfers
We operate globally as a group and rely on service providers to support our global solutions. Therefore, we may transfer your personal data outside of the UK or the European Economic Area (“EEA”) (depending upon where we collect your personal data) if that is appropriate to achieve any of the purposes set out in the overview above “What do we do with it?”.
The European Commission has issued an adequacy decision for the UK, meaning that the UK's data protection laws and measures are considered to offer an appropriate level of protection to the personal data of individuals in the (EEA). The UK government has also issued its own adequacy decision for the EEA. This means that it is considered safe for personal data to be transferred between the UK and the EEA and vice versa.
If we transfer your personal data to a country other than the UK or an EEA member state, we will make sure that your personal data is protected by the following safeguards:
the laws of the country to which your information is transferred ensure an adequate level of data protection; or
the transfer is subject to specific contractual safeguards approved for use in the UK or EEA (depending upon where we collect your personal data) which give personal data the same protection that it has where it was provided to us.
Changes to this Notice
The most recent version of this Notice is on this page. We may modify this Notice at any time without notice, except if such modifications contain substantial changes that may affect individuals’ rights under applicable privacy and data protection laws, in which case you will be notified of such changes at the beginning of this page.
Contact
In case you have further questions about this Notice, please get in touch with us at: data.protection@cplaromas.com or by post by writing to us at
CPL AROMAS LIMITED
Attn: Chief Financial Officer
Quarry Road,
Brixworth,
Northants
NN6 9UB
UK