Privacy Policy

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 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.
• Marketing and Communications Data such as your preferences in receiving communications from us and any correspondence you exchange with us.
• Photos and videos captured at our events you attend or by our CCTV systems in our offices and sites.
• Pseudonymised Data to develop, test, and improve the Ocado Intelligence Automation products and services, and to troubleshoot products and services.

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 personal data so that the Aggregated Data relates to an  individual, we treat the combined data as personal data and use it in accordance with this Privacy Notice.

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 phone, email, or when you register your sales interest at trade shows/ demonstrations or otherwise. This includes personal data you provide when you contact us or subscribe to our communication.
• When you register for our events, we collect information such as name, phone number, and email address. 
• Third parties: We obtain business contact information such as name, email address, job title and company name from third party directories and publicly available sources. 
• Automated technologies: For example, 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 communications). 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

Ocado has set out below a description of how and why we plan to use personal data, as well as on which legal bases we rely on. When we rely on our (or third parties’) legitimate interests, we also explain these interests.

We may process 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.

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.

When you visit our website, we collect some basic information such as your internet service provider's domain name, which pages you accessed on our site and when.

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.

We share personal data with our staff to the extent this is necessary for them to carry out our operations. We also share personal data with the following parties.

• 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.

• 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;

• 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.

Our operations are principally based in the UK and the personal data that we collect from you is mainly processed, stored and used within the UK and in countries of the European Economic Area (EEA). However, in order to offer you the best service we can provide, we also work with service providers from other parts of the world. This means that the data we collect sometimes needs to be transferred, stored and used by companies operating outside the UK and the EEA who work for us or one of our service providers, to countries which may not provide the same level of protection as the UK and the EEA. In these cases, we take steps to ensure one of the following conditions apply:

• 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).

How long will you use my personal data for?

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.