Privacy Policy
Welcome to the Ocado Group Website Privacy Notice.
The Ocado Group respects your privacy and is committed to protecting your personal data. This Privacy Notice is provided in a layered format so you can read through to the specific areas set out below.
This Privacy Notice aims to give you information on how the Ocado Group collects and processes your personal data through your use of this website, including any data you may provide through this website when you access it or sign up to one of our newsletters. It also explains your data protection rights, including the right to object to certain ways in which we use your personal data.
If you are applying for a position within the Ocado Group, please read our Recruitment Privacy Notice.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice together with any other privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you (for example, our Recruitment Privacy Notice if you are applying for a position within the Ocado Group) so that you are fully aware of how and why we are using your personal data. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.
Data Controller
A “data controller” is the person or legal entity which determines the purposes for which and the manner in which personal data is processed. Ocado Group Plc is the data controller in respect of the personal data collected through this website. Ocado Group Plc (company number 07098618) is a public limited company registered in England, with registered address at Buildings One & Two Trident Place, Mosquito Way, Hatfield, Hertfordshire, United Kingdom, AL10 9UL.
The Ocado Group is made up of different legal entities. When we refer to “Ocado Group”, "we", "us" or "our" in this Privacy Notice, we are referring to Ocado Group Plc.
Different data controllers within the Ocado Group collect and process personal data for different purposes. If an entity other than Ocado Group Plc is the data controller in respect of your personal data, it will provide you with a copy of its privacy notice at the point when it collects your personal data.
The Ocado Group has appointed a data protection officer (DPO). If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us or the DPO using the details set out below.
Contact details for the Data Controller and DPO
Email: privacy@ocado.com
Postal address: Data Protection Officer, Ocado Group, Buildings One and Two, Trident Place, Mosquito Way, Hatfield, Hertfordshire, United Kingdom, AL10 9UL.
You have the right to make a complaint at any time to a supervisory authority. The Information Commissioner's Office (ICO) is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.
Changes to the Privacy Notice and your duty to inform us of changes
We keep our Privacy Notice under regular review and you should check it regularly. If we make any material changes to this Privacy Notice, we will take steps to inform you via appropriate means (e.g. by email). This version was last updated on the date stated at the beginning of this Privacy Notice.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or the data they may collect about you. When you leave our website, we encourage you to read the privacy Notice of every website you visit.
Personal data, or personal information, means any information about an individual who can be identified. It does not include data where the identity has been removed (anonymous data).
We collect, use, store and transfer the following categories of personal data about you :
Identity Data such as first name and last name.
Contact Data such as postal address, email address and telephone number.
Technical Data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Account Data such your username and password.
Usage Data including information about how you use our website.
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from personal data but is not considered personal data as it cannot be attributed to you or other individuals and will not directly or indirectly reveal your identity. For example, we may aggregate Usage Data of our website visitors to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that the Aggregated Data relates to you as an individual, we treat the combined data as personal data and use it in accordance with this Privacy Notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have ordered from us but we will notify you if this is the case at the time.
We collect your personal data as we describe below:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you contact us or subscribe to our newsletter(s).
Automated technologies. As you interact with our website, we will 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. For more information, please refer to our Cookies Notice.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
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 obligation.
Where you have consented to this (for example, when you consent to our use of non-essential cookies or to receiving our newsletters). You have the right to withdraw consent at any time. Please see the “Opting out” section below for more information on how to unsubscribe from marketing.
Purposes for which we will use your personal data
We have set out below a description of how and why we plan to use your personal data, as well as on which legal bases we rely to do so. When we rely on our (or third parties’) legitimate interests, we also explain these interests.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground on which we rely to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which includes notifying you about changes to our terms or Privacy Notice
Identity
Contact
Profile
Marketing and Communications
Necessary to comply with a legal obligation, when we are required by law to provide you with certain information (e.g. about a change in our T&Cs)
Necessary for our legitimate interests (to keep our records updated, correspond with you, handle any queries you may have and send you service messages)
To administer and protect our business and this website (including troubleshooting, data analysis, system maintenance, support, reporting and hosting of data and use of strictly necessary cookies)
Identity
Contact
Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and in the context of a business reorganisation or group restructuring exercise)
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)
Necessary to comply with a legal obligation
To use analytics data to improve our website and visitor experiences
Technical
Usage
Consent
To send you our general and/or investor newsletters and sales and marketing information about our products
Identity Data
Contact Data
Consent (which you are asked to provide when you subscribe or opt in to receive sales and marketing information about our products through our websites)
To display our advertisements to you on other platforms, such as social media platforms . For example, we may provide social media providers such as Facebook and instagram, Twitter, Linkedin etc or Google with hashed identifiers of our users which the provider then matches with those users’ profiles and displays our advertisements to them.
Technical Data
Usage Data
Consent, where we obtain this information by using cookies or where otherwise required by law.
Otherwise, we rely on our and third parties’ legitimate interests to carry out marketing activities and inform you of products and services we think you might like.
For fraud detection, monitoring, prevention and investigation
Identity Data
Contact Data
Necessary for our legitimate interests (to prevent fraud)
For legal, [tax,] accounting, reporting, audit purposes
All data
Necessary for our legitimate interests to protect our legal rights, defend our business in the context of disputes, carry out audits and effectively manage our business by keeping appropriate records.
Compliance with legal obligation, to the extent the information is required to meet [tax,] audit and accounting obligations to which Ocado is subject
When we rely on legitimate interests to process personal data, we consider and balance those interests against any potential impact on you (both positive and negative) and your rights and interests. If we consider that our interests are overridden by the impact on you, we will not use your personal data in this way (unless the law gives us another valid ground to do so). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time; you can do this by logging into the website and checking or unchecking relevant boxes to manage your marketing preferences, by following the opt-out links on any marketing message we send you or by contacting us at any time using the contact details set out in this Notice.
Please note that if you decide to opt out from marketing it could take up to 72 hours to process the update through our systems.
Change of purpose
We will only use your personal data for the purposes for which we collected it. If we need to use it for another reason, we will do so, after notifying you, and if that reason is compatible with the original purpose, if we have your consent or we have a legal obligation to use your data in this way.
We also use cookies, which are small text files that are saved to your device when you use our website. We use cookies which are necessary for our website to function, and, when you consent to this, we also use non-essential cookies for purposes such as analytics or advertising. For further information on the cookies used on our website, please refer to our Cookies Notice.
• Internal Third Parties: These include our staff and other companies within the Ocado Group, including:
• Ocado Group companies (in the UK) which provide IT, system administration and business support services;
• Ocado Group companies based in all of the jurisdictions in which we operate, where this is necessary:
• In connection with legal claims, compliance, regulatory and audit functions; or
in connection with the acquisition, merger or sale of a business or assets.
• To support and better understand the users of our website.
• External Third Parties: These include:
• Service providers, to the extent they need to process personal data to provide us with their services. We use providers for the following types of services:
• IT, web and app hosting and management, system administration and business support services;
• Data analytics services to help us understand how our website is used;
• Post or delivery services, printers and mailing houses;
These parties will only process your personal data on our instructions and they are subject to a duty of confidentiality.
• Law enforcement agencies, when this is necessary to comply with the law, to enforce our rights under our terms and conditions or to protect the rights, interests, property or safety of the Ocado Group, our employees or customers, our business partners or others.
• Certain third parties where we have reason to suspect fraud or the commission of any other criminal offence. Such third parties may include business partners, law enforcement bodies, providers of fraud prevention and detection services, and recipients of fraud prevention and detection services.
• Professional advisers including lawyers, bankers, auditors and insurers which provide consultancy, banking, legal, insurance and accounting services.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice and any other privacy Notice has been communicated to you.
• The transfer is to a country which ensures a level of data protection which is equivalent to EEA and/or UK standards.
• The organisation to which we transfer personal data is bound by European Commission-approved standard contractual clauses which offer data protection safeguards, and/ or equivalent standard clauses approved in the UK; or
• A derogation applies in accordance with data protection laws (for example, you have provided your explicit consent, or the transfer of the data is necessary in order for Ocado to exercise or defend a legal claim).
For more information on how we safeguard transfers of your personal information, please contact us at privacy@ocado.com. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention Notice which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) and use anonymous information for research or statistical purposes. Please note this Notice does not apply to anonymous data.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. For further information about these rights, please see the Glossary.
• Request access to your personal data
• Request correction of your personal data, if it is inaccurate or incomplete
• Request erasure of your personal data in certain circumstances
• Object to the processing of your personal data in certain circumstances
• Request restriction of processing your personal data in certain occasions
• Request a copy of certain personal data in a “portable” format (e.g. .csv or pdf file) and request that we transfer this copy to a third party
• Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us using the details set out in this Notice.
Please note these rights may be limited, for example if fulfilling your request would reveal personal data about another person or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of the relevant exemptions upon which we rely when responding to any request you make.
No fee usually required
You will not have to pay a fee to exercise any of the above data protection rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that data protection requests are not submitted by an unauthorised person. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a confirmation of whether we hold your personal data and if so, to also receive a copy of that personal data and certain information about how we use 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. 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 the law. Note, however, that this is not an absolute right and we may not always be required to comply with your request of erasure, for specific legal reasons. If such reasons apply, we will notify you of this at the time of responding to your request.
Object to the processing of your personal data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request that we provide certain of your personal data in a “portable” format (e.g. in a .csv or pdf file) and that we also transfer this 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.