WARNING: Steenbergs Ltd has become aware that an identity fraudster is falsely using the Steenbergs name and head office address to offer employment and business opportunities to unsuspecting people and businesses. The fraud originates in Nigeria and is in no manner connected to Steenbergs Ltd. There is no Garry Walker or pharmaceuticals or similar business at 6 Hallikeld Close. If you are in the UK, notify Action Fraud at 0300 123 2040.

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Data Protection

Collecting customer details

We accept and understand this is a very tricky area and we try to act responsibly and honestly in everything we do, which includes how we handle customer information provided to Steenbergs during your interactions with us.  We have prepared the following information to give some background as to what we do.  This should be read in conjunction with Steenbergs’ “Privacy Policy” and “User’s Agreement”.  For further information on the use of "cookies" on the Steenbergs websites, please refer to Steenbergs' "Cookie Policy".  If you need further details or have any issues, please call us on 01765 640 088 and we will deal with these quickly and sensitively.

For advice on protecting your privacy when online, please refer to the Information Commisioner’s Office (“ICO”) at www.ico.gov.uk or look at www.ico.gov.uk/upload/documents/library/data_protection/practical_application/protecting_your_personal_information_online.pdf.

Data use within Steenbergs

At Steenbergs, we do collect data relating to our customers during the ordering process.  We do need as much information as possible during the ordering stage, including telephone numbers and emails, because this helps with order queries and delivery, as sometimes the address is incomplete or the delivery business cannot find your address or we need to be able to help you tracking down a parcel that has gone astray.

However, you should, also, be aware that Steenbergs will use this information for direct marketing by electronic mail through our email delivered newsletters.  This enables Steenbergs to provide you with information about new products that we have launched, competitions, offers or recipe ideas as to how to use products that we sell.  We do not send out these email newsletters regularly and you would not receive more than 6 in a year, and usually not more than 4.  This is part of our online marketing that includes trying to build community around the Steenbergs brand via the website, Axel and Sophie Steenberg’s Blog, Facebook and Twitter.  At Steenbergs, we believe that you might be interested in hearing from us.  The control of your personal data provided by you during the account set up phase is controlled by Engage Interactive Limited (“Engage”), which is registered at the ICO under number Z2963649, and Engage operates our newsletter marketing system under this registration.

However, if you do not want to hear from Steenbergs, we are fine with that as well and so we give you several ways to prevent future contacts being made by electronic mail (we do not contact our customers directly by phone, by post or in any other ways save where required to expedite orders during the sales order and delivery phase and to verify customers and so protect Steenbergs from fraudulent activity):

● At the ordering stage, we give you the option to unsubscribe from the future receipt of direct marketing from Steenbergs (see soft opt-in rules below);

● If you receive a newsletter, but do not wish future contacts to be made, you can then either click on the automated unsubscribe button or call us on 01765 640 088 and we will immediately expunge your details from the database held at Engage;

● At any time, you can contact Steenbergs by email to unsubscribe@steenbergs.co.uk or call us on 01765 640 088 and we will immediately expunge your details from the database held at Engage.

We mentioned the soft opt-in rules and felt we should explain these a little further.  Under the soft opt-in rules under Regulation 22 (2) of the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (together the “Acts”), we can contact you if the following criteria are met:

● We have obtained the contact details of the recipient in the course of a sale or negotiations for the sale of a product or service to that recipient;

● The direct marketing material you are sending relates to our similar products and services only;

● The recipient was given a simple means of refusing (free of charge except for the cost of transmission) the use of their contact details for marketing purposes when those details were initially collected and, if they did not refuse the use of those details, at the time of each subsequent communication. 

The wording we currently use at the “New Customer” stage is “Untick this box if you do not want to be added to our newsletter database.”

All the above relates to Steenbergs’ use of personal data collected through the Steenbergs web site for use by Steenbergs.  However, please be aware of the relationship Steenbergs has with its charity partner, which is a trickier area for personal data (see below).  Beyond this specific contractual relationship, Steenbergs does not pass on customer’s personal information to any other body, save where we would be required so to do under law. 

For orders by individuals that are made by telephone, fax, letter or verbally, no personal data is retained beyond that required for financial accounting and order fulfilment purposes, and the data is never used by Steenbergs for marketing purposes, nor is it given, sold or passed on to any other individual or organisation for any purposes whatsoever.

With regards to online payments, these are undertaken through WorldPay, which is an online payments business that is separate from Steenbergs.  More information regarding WorldPay is available at http://www.worldpay.com/about_us/index.php?page=who&c=UK.  The information that you provide to them is required for credit checking purposes and to determine whether purchases are genuine and not fraudulent, as unfortunately fraudulent purchases are attempted and we have been a victim of such.  WorldPay stores and uses that information within their business and it is managed separately from Steenbergs.  You should contact them about how they manage their data if it relates to the WorldPay component of Steenbergs website.

Steenbergs believes that it is exempt from registration with the ICO as it is not the data controller in relation to customer data provided.  Should you wish to check or alter your personal information held by Engage, you can contact us and we will pass on your request or you can contact them directly at 01423 876 354 or visit their website www.engageinteractive.co.uk.  Steenbergs has, also, registered with the ICO under number Z3175919.

Data use with charity partner

Via Engage Interactive (ICO registered number Z2963649), Steenbergs does pass on information collected in its sales processes to a charity, but beyond that we do not provide any information to any other organisations.  We try and explain our reasoning for this charity partnership below.

Because we believe in the power of development to reduce multidimensional poverty around the world, Steenbergs likes the idea of promoting development work by charities.  As part of this, in 2011, we started what might become a series of ongoing relationships with charities.  We would look to determine the relevant charity through discussions with our customers on a regular basis, as well as consideration on whether there continues to be merit in such a relationship.

Steenbergs currently has a relationship with WaterAid, whereby we donate 20p from each sale through steenbergs.co.uk to WaterAid and, critically for data use, we explain, and customers need to be aware, that WaterAid may contact customers unless they chose not to be contacted at the checkout stage.  Prior to 24 May 2012, this was through an opt-out process and, following legal advice, the wording used was as follows:

● “Steenbergs has donated 20p from this sale to the international charity, WaterAid, on your behalf and they would like to tell you a bit more about their work. If you don’t want your details passed to WaterAid or WaterAid Trading Ltd just tick this box.”

Since 24 May 2012, we switched to a positive opt-in to contacts by WaterAid, feeling that this was more closely aligned to Steenbergs' ethical ideals.  The new wording for the positive opt-in is now as follows:

● "Steenbergs has donated 20p from this sale to the international charity, WaterAid, on your behalf and WaterAid would love to keep you informed about their work and how your support is changing lives. To do so they’ll use the details you’ve provided but promise to never share them with any other organisation for their marketing purposes. To hear more from WaterAid and WaterAid Trading, just tick the box."

Before we entered into the contractual relationship with WaterAid, we explained to customers and those on our newsletter, Facebook and Twitter accounts that we wished to donate some of our sales income to a charity.  At that time, no issues were raised against this and the only comments we received were all positive that Steenbergs, as an ethical business, wanted to use some of its sales to support ethical charities.  Simultaneously, we consulted via the same base of customers as to whether we should support Practical Action or WaterAid for the first period and overwhelmingly our stakeholders wanted WaterAid to be supported. 

By law, it is not possible simply to say we will provide some of our income to WaterAid as the The Charity Commission believe that this means that charities are not being given the benefit of their value to a business like ours and any spin-off from linking with a charity could be used by the wrong type of businesses.  Therefore, the link has to be formalised and consideration needs to flow from the company to the charity over and above any donation given, so WaterAid advised that we needed to enter into a contractual agreement and to provide legally obtained customer information as consideration for the linkage with WaterAid.  The approach that is, therefore, taken by WaterAid and other charities is for an opt-out as detailed above which has been approved as meeting the regulatory requirements and we introduced this opt-out box from the start of the relationship in September 2011.  As noted earlier, customers’ personal data is controlled by Engage and it provides any relevant data to WaterAid.

The downside for customers and Steenbergs is that (a) customer data was provided to WaterAid via the opt-out system initially, and (b) WaterAid will contact customers, however on balance we believe that this relationship is beneficial to all our stakeholders.  We realise that some of our customers have not been happy with the contacts made, therefore, we will continue to review the situation, including asking our customers about the experience at the end of this particular contract and whether our stakeholders continue to see merit in any such charitable relationship.  In particular, Steenbergs has listened to its customers and moved from an opt-out to a positive opt-in for direct marketing contacts by WaterAid with Steenbergs' customers.

Steenbergs believes that it is exempt from registration with the ICO as it is not the data controller in relation to customer data provided.  Should you wish to check or alter your personal information held by Engage, you can contact us and we will pass on your request or you can contact them directly at 01423 876 354 or visit their website www.engageinteractive.co.uk.  

Final word

Over and above this, if you want alternatives to following the soft opt-in route, while on Steenbergs’ web site, you could provide a dummy telephone number, such as “000”, and/or use an email address that you only use for online purchases and so has been depersonalised (notwithstanding the fact that if you had declined future contacts, neither Steenbergs nor our charity partner would or could contact you).  However, if you do not give us all relevant information, we might not be able to expedite delivery if there are order or address queries.  Finally, telephone or other offline orders are, also, made by a number of customers as an alternative way of placing orders, however this might not give you the same data protections that might be available under the Acts were you to make the order online via the website.

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