Milton's Baking Company Privacy Policy

Updated January 21, 2019

We at Milton's are avid web users like you and hate spam just as much as you do. We are serious about protecting your privacy.

 

Collection of your Personal Information
 

This Privacy Policy applies to the Milton's Website at www.miltonscraftbakers.com and miltonscraftbakers.co.uk (the "Website") and governs data collection and usage. By using this Website or submitting information to us, you consent to the data practices described in this statement.  

 

Types of Data We Collect

 

Milton's collects personally identifiable information, such as your email address, name, address, or telephone number from the Website and in email, text and other electronic messages between you and this Website.   The information that is collected may include information that you provide by filling in forms on this Website, corresponding with Milton's, entering search queries on this Website, or engaging in transactions through this Website.

We may also collect Usage Data, which may include information about your Internet browser, computer hardware and software also is automatically collected by Milton's. This information can include your IP address, device ID, browser type, domain names, access times and dates, number of clicks, pages viewed, one or more cookies (described below) that may uniquely identify your browser, and referring website addresses. This information is used by Milton's for the improvement of our website.  Milton's secures your personal information from unauthorized access, use or disclosure on computer servers in a controlled, secure environment.

 

How we store your personal information. 

 

When you provide us with your name and contact information, they are automatically recorded in a Windows server operating environment via an SQL database using an Always Encrypted Database Engine that is owned and managed by Milton's.  On rare occasion, user contact information may be stored via an offline datastore (i.e., paper) and within a locked facility and only accessible by Milton’s staff. Every 90 calendar days, this offline datastore is evaluated and all records no longer in active use are shredded via an in-house cross-cut DIN Level 3-4 or better shredder.  Technical infrastructure security is managed, updated, and maintained via a third-party IT Support and Cybersecurity NIST compliant firm located in San Diego, CA. 

 

Data Breach Contingency Plan

 

Milton’s is aware that despite best-in-class data security, encryption protocols, restricted usage policies, and on-going employee/staff training the possibility of a data breach may occur, however unlikely.  When and if this occurs and is confirmed, Milton’s maintains a cyber-breach protocol that begins with an always active cyber task force, to the containment of the breach, assessment of the breach severity, and notification of all parties affected with remedial support, if needed.  Additional questions of Milton’s continually updated Data Breach Contingency Plan may be sent to the DPO at:  Vice President of Marketing & Innovation, Milton’s Baking Company, 5875 Avenida Encinas, Carlsbad, CA, 92008 USA, Phone 858-350-9696.

 

How we utilize your personal information. 

 

We use personal data about customers for a wide range of purposes. We use it to respond to your requests; to allow you to post information and other content online; to improve our products and website; to follow up with you after you have communicated with us or submitted information to us; to send promotional communications or offers (unless you have requested that we not send such communications); for marketing, research and legal purposes and other purposes (including, without limitation, call center recordings); to address your interests and concerns; and as otherwise specified in this Privacy Policy and/or at the point of personal data collection. 

We may disclose personal data you provide to consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s).  

 

We do not share personally identifiable information with third parties for any marketing or commercial purposes.  

We may also disclose personal data to third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others') rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations.  We may also disclose personal data to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company.

How we track visitors to the web site. 
An IP address is the unique number that is automatically assigned to your computer when you log onto the Internet.  As you enter Milton's Website, our server records and monitors your IP address and uses it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of our site. The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users.

 

How we use "Cookies." 

 

As you use our website, some information can be “passively” collected using various technologies, such as cookies, web beacons and navigational and location data collection (clickstream, log files, server logs).  Your Internet browser automatically transmits some of this information, such as the URL of the website you just visited and the Internet Protocol (IP) address and browser version currently being used by your computer.  Such technologies help us to keep track of your interactions with our website and provide you with a more customized experience.  Your continued use of the Website indicates your consent to the collection of Usage Data and any other type of automated data processing.  This information applies to the use of cookies by Milton's and does not cover the use of cookies or other tracking technology by any third parties.

 

Accessing, Correcting and Updating Personal Information

You have the right to see information we hold about you, with some exceptions which are described in the privacy laws. If you would like a copy of your personal information, please contact our Data Protection Officer (DPO) at Vice President of Marketing & Innovation, Milton’s Baking Company, 5875 Avenida Encinas, Carlsbad, CA, 92008 USA, Phone 858-350-9696. .  

.You have the right to review and update your personal details. If for any reason you are concerned that the personal information we hold is not correct, please visit our online data access request form at https://miltonscraftbakers/pda-request in order to request access, rectify, delete or object to further processing of collected data.  Only you or, upon your request, our Customer Care team, may access your Personal Data from our online services.  If you prefer, you may contact us by email atPrivacy@miltonsbaking.com

 and we will amend your personal details. 

Legal Basis for Processing Personal Data Under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), Milton's legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.  In addition, we process Personal Data with the principle of data minimization in mind. This means that we limit ourselves to the minimum amount of personal data which is needed to achieve the particular purpose for which we process the Personal Data.  Below are some examples of the purposes for which Personal Data may be processed. 

 

Milton's may process your Personal Data because:

 

·     The processing is necessary to provide the services and features you have requested

·     The processing is necessary to protect the vital interests of our users or of others

·     The processing is necessary to perform a contract with you

·     The processing is necessary for the legitimate interests of our business, such as fraud prevention, information security, or to             comply with the law

·     You have provided consent for us to do so.

Retention of Data 

We will retain your Personal Information only for as long as it is necessary for the purposes set out in this Privacy Policy.  We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website or Service, or we are legally obligated to retain this data for longer time periods. 

Cross Border Data Transfers

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there. Your submission of Personal Information to us indicates your consent to such cross border data transfers. Milton's will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.  

 

We Are Committed to Children's Privacy

We do not knowingly collect or maintain personally identifiable information or non-personally-identifiable information on the Milton's  Website from persons under 13 years of age, and no part of our website is directed to persons under 13.  If you are under 13, please do not use or access the Milton's Website at any time or in any manner. If Milton's learns that personally identifiable information of persons under 13 years of age has been collected on the Milton's Website without verified parental consent, then Milton's will take appropriate steps to delete the information.

 

Security

 

We take appropriate steps to protect personal data from loss, misuse and unauthorized access, disclosure, alteration or destruction, whether in transmission or storage.  Please keep in mind, however, that there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free. Moreover, you are responsible for maintaining the confidentiality of any user name and password you use.

 

Opt-in Emails, Text Messages and Offers.

 

By registering as a user of our Website, you grant us permission to contact you at your e-mail address.  If you are not a registered user of our Website, you may elect to receive information from us about new products and other noteworthy news items, and you may always choose to decline to receive these email messages and text messages at any time.  Please see our opt-out policy described below.  We will never sell, rent, or share your Personally Identifiable Information, including your email or phone number with any third parties for marketing purposes without your express permission. We may share your personal information with our service delivery providers for the purpose of delivering our email and text messages to your or as required by law.

 

Choice/Opt-out.

 

Our users are given the opportunity to opt-out of emails and text messages to which they have previously opted-in. This does not apply to emails that relate to our Website information, Terms of Use, your account, or that are automatically generated by the system (registration confirmation emails).   For example, even if you have unsubscribed from our promotional email messages, we will still send you confirmations when you register for any of our services.  Users who no longer wish to receive our promotional communications, our newsletter or blog may opt-out of receiving these communications by clicking on the Unsubscribe link provided in emails.

The option to cancel mailings and emails. 
Upon registering, you may begin receiving communications from us. If at any time you wish to unsubscribe from our mailings, please just ask by emailing us at
dthomas@miltonsbaking.com.  

 

Your Data Protection Rights Under the GDPR

If you are a resident of the European Economic Area (EEA), you have certain data protection rights.  Milton's has implemented reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data via the online submission form at https://miltonscraftbakers.com/pda-request.  

 

If you wish to be informed of the type of Personal Information we hold about you and/or if you wish to remove such Personal Information from our systems, please contact us at Vice President of Marketing & Innovation, Milton’s Baking Company, 5875 Avenida Encinas, Carlsbad, CA, 92008 USA, Phone 858-350-9696. .  

 

 In certain circumstances, you have the following data protection rights:

 

The right to access, update or delete the information we have on you. In many instances, you can personally access and update your Personal Data by accessing your online account settings.  If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification.You have the right to have your information corrected if that information is inaccurate or incomplete.

The right to object.You have the right to object to our processing of your Personal Information.

The right of restriction.You have the right to request that we restrict the processing of your Personal Information.

The right to data portability.You have the right to be provided with a copy of the information that we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent.You have the right to withdraw your consent at any time where Milton's relied on your consent to process your personal information.

 

Please note that for your safety and security, we may ask you to verify your identity before responding to such requests.

 

Within the EU, all user data privacy protections and concerns may be sent to Milton’s EU/UK GDPR representative: MILTON’S BAKING COMPANY C/O FAIRWAY GB Ltd. 17 The Crescent, Salford M5 4PF UK OR AT PRIVACY@MILTONSBAKING.COM

Service Providers

 

We may employ third-party companies and individuals to facilitate our Website and Services ("Service Providers"), to provide the Website Service on our behalf, to perform Website- and Service-related services or to assist us in analyzing how our Website and Service is used.

 

These third parties will only gain limited access to your Personal Data from us to perform these specific tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

Analytics

 

We may use third-party Service Providers to monitor and analyze the use of our Website and Service.  

 

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website and Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Website or service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing  

 

Milton's uses remarketing services to advertise on third-party websites to you after you visit our Website and Service. We, and our third-party vendors, may use cookies to inform, optimize and serve ads based on your use of our Website and Service. 

 

If you are a resident of the European Economic Area (EEA), you have the right to opt-out of decisions based solely on automatic decision-making, such as certain types of behavioral remarketing.  Below are ways in which you can opt-out of each remarketing service:

 

Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout- for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

 

Bing Ads Remarketing

Bing Ads remarketing service is provided by Microsoft Inc.

You can opt-out of Bing Ads remarketing by visiting: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

 

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

 

Pintrest

Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data

You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy

AdRoll

AdRoll remarketing service is provided by Semantic Sugar, Inc. You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1nt=1nw=falseFor more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

 

Instagram

Instagram is a product of Facebook Inc. For more information on the privacy practices of Instagram, please visit Instagram’s Data Policy: https://help.instagram.com/519522125107875/?helpref=hc_fnav&bc[0]=Instagram%20Help&bc[1]=Privacy%20and%20Safety%20Center

 

Mailchimp

For more information on the privacy practices of Mailchimp, please visit:​ https://us18.admin.mailchimp.com/?_ga=2.15697334.1026117654.1550592720-648905735.1529604434

Subprocessors

 

Under GDPR guidelines, a subprocessor is any business, contractor, or organization that may have access to or processes user data on behalf of Milton’s.  Milton’s requires its subprocessors to satisfy equivalent obligations as those required of Milton’s under applicable data protection laws and regulations, including but not limited to the following requirements:

  • Process personal data in accordance with data controller’s documented instructions

  • Implement and maintain appropriate technical and organizational measures and to protect against unauthorized access and anticipated threats or hazards to personal data.

  • Promptly notify Milton’s about any actual or potential security breach affecting personal data processed on behalf of Milton’s

  • Cooperate with Milton’s in responding to requests from data controllers, data subjects or data protection authorities, as applicable

 

The following is a list of the name(s), location(s), and activities of the service-specific subprocessors:

 

Narrative Northwest

A digital marketing and social media consulting provider located in the United States. User Data deletion is set to 90-day manual review, confirmation, and removal if applicable.  See below Subprocessor Auto and Manual Deletion guidelines.

 

Orca Consulting

A venue management firm located in the United States.  User Data deletion is set to 90-day manual review, confirmation, and removal if applicable.  See below Subprocessor Auto and Manual Deletion guidelines.

 

Destini

A product location service located in the United States.  User Data deletion is set to 90-day manual review, confirmation, and removal if applicable.  See below Subprocessor Auto and Manual Deletion guidelines.

 

Wix

A content management platform service located in the United States.  User Data deletion is set to 90-day manual review, confirmation, and removal if applicable.  See below Subprocessor Auto and Manual Deletion guidelines.

 

123 Form

An online web/data collection service located in the United States.  User Data deletion is set to 90-day manual review, confirmation, and removal if applicable.  See below Subprocessor Auto and Manual Deletion guidelines.

 

ATS OnDemand

A career/job management service for employment within Milton’s located within the Unites States.   User Data deletion is set to 90-day manual review, confirmation, and removal if applicable.  See below Subprocessor Auto and Manual Deletion guidelines.

 

Subprocessor Auto and Manual Deletion

 

All subprocessors are required to auto-delete or manually review and then delete all user data considered no longer in use or deemed relevant based on pending services, promotions, or other digital marketing efforts every 90-days.  The DPO is required to receive quarterly compliance confirmation from all subprocessors.  

 

 

Arbitration; Claims Must be Brought on an Individual Basis 

 

By using the Website, you agree that any dispute in any manner arising out of or relating in any way to this Privacy Policy, its enforcement or interpretation, or because of an alleged breach, default, or misrepresentation in connection with any of its provisions, shall be submitted to binding arbitration with Judicial Arbitration and Mediation Services, Inc. ("JAMS") in the San Diego, California area. ARBITRATION MEANS THAT YOU WILL NOT HAVE AND YOU WAIVE THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS. Rights to the prehearing exchange of information and other discovery, as well as appeal rights, are more limited than were you to sue in court. 

 

This arbitration provision is equally binding on claims brought by us as on claims brought by you or others. Arbitrations will be conducted under the applicable JAMS rules. The parties to arbitration will have all the same claims, legal rights, and remedies in arbitration that would be available in court. A single neutral arbitrator shall be selected in accordance with the JAMS Streamlined Arbitration Rules, which shall provide you a reasonable opportunity to participate in the arbitrator selection. It is further agreed that any disputes as to whether the scope of this arbitration provision covers the claim will be submitted to the arbitrator, and not a court, for decision. The parties to arbitration will have full right to use legal counsel at their own expense. All costs of arbitration (including arbitrator fees) shall be paid by us, except if you bring the arbitration, you may be charged an initial filing fee that shall not exceed the filing fees that you would incur for bringing an action in court. You will not be required to pay fees and costs incurred by the opposing parties if you do not prevail in arbitration. In arbitration, the parties may conduct reasonable discovery and shall reasonably exchange non-privileged information relevant to the dispute. The arbitrator's award shall be in writing and provide a written statement of the essential findings and conclusions. The arbitrator will not have the power to commit any error of law or legal reasoning, and the award may be vacated or corrected on appeal to a court of competent jurisdiction for any such error. As an exception to this arbitration provision, no one subject to the provision will be precluded from seeking remedies for disputes or claims less than $10,000 in the aggregate that can be brought in a court of competent jurisdiction.

 

ANY ARBITRATION SHALL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY. It is expressly understood and agreed that neither you nor we are entitled to arbitrate or bring any dispute covered by this arbitration provision as a class, consolidated, representative, collective, or private attorney general action, and the arbitrator(s) will have no authority to proceed on a class, consolidated, representative, collective, or private attorney general action basis.  This means:

·    You cannot bring a claim as a plaintiff or class member in a class action, consolidated action or representative action.

·    The arbitrator cannot combine more than one person’s claim into a single case, and cannot preside over any consolidated, class        or representative arbitration proceeding (unless we both agree to change this).

·    The arbitrator's decision or award in one person’s case can only impact the person who brought the claim, not other ngrok              customers, and cannot be used to decide other disputes with other customers.

 

If any part of the agreement to arbitrate in this section is found unenforceable, the unenforceable term will be severed and the remaining arbitration terms will be enforced (but in no case will there be a class, representative or private attorney general arbitration). In the event that any of the class action restrictions are ever deemed illegal or unenforceable, the illegally deemed or unenforceable restriction(s) shall be severed from this arbitration provision, and any class action shall be exempted from this arbitration provision and brought in court. This arbitration provision is subject to the Federal Arbitration Act, and may be enforced in any court of competent jurisdiction.

 

California Privacy Requirements and Rights 

 

California Do Not Track Notice:

Because there are not yet common, industry-accepted "do not track" standards and systems, the Site does not currently respond to Do Not Track signals.

 

California Disclosure Information:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes, and (2) the names and addresses of all such third parties.  To request the above information, please e-mail us at: dthomas@miltonsbaking.com or write to us at: 5875 Avenida Encinas, Carlsbad, CA 92008 USA with a reference to California Disclosure Information.

 

We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received.  Please note that we are required to respond to each customer only once per calendar year.

 

Data Protection Officer Responsibilities and Questions

Vice President of Marketing & Innovation, Milton’s Baking Company, 5875 Avenida Encinas, Carlsbad, CA, 92008 USA, Phone 858-350-9696.Our Data Protection Officer (DPO) adheres to a quarterly review of this User Data Privacy Policy and publishes updated compliance and regulation updates prompting for re-acceptance among all users upon their next online access. The DPO also provides updates to Milton’s key decision makers regarding data protection legislation as new information is published accordingly.  Bi-annually, all Milton’s employees/staff partake in cybersecurity, user data protection, and acceptable use IT training with a final assessment/test requiring an 80% or greater final score less remedial training is required for all scores 79% or lower.  

 

For information and questions about the use of your personal information or this Privacy Policy, you may contact our Data Protection Officer at Vice President of Marketing & Innovation, Milton’s Baking Company, 5875 Avenida Encinas, Carlsbad, CA, 92008 USA, Phone 858-350-9696.

Changes to this Statement 
Milton's  may occasionally update this Privacy Policy to reflect feedback from users like you and to reflect changes in our policies. We encourage you periodically to review this Privacy Policy to be informed of how Milton's is protecting your information.  In general, we only use your personal information in the manner described in the Privacy Policy in effect when we receive the personal information you provided. Your continued use of the Milton's Website after any such updates constitutes your agreement to this Privacy Policy and any future revisions.

 

Last Modified: January 21, 2019