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PRIVACY POLICY

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Last updated: August 2023

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.

 * IMPORTANT INFORMATION AND WHO WE ARE
   
   Purpose of this Privacy Notice
   
   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.

 * THE DATA WE COLLECT FROM YOU
   
   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.

 * HOW IS YOUR PERSONAL DATA COLLECTED?
   
   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.

 * HOW WE USE YOUR PERSONAL DATA 
   
   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
   
    1. Identity
    2. Contact
    3. Profile
    4. Marketing and Communications
   
    1. 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)
    2. 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)
   
    1. Identity
    2. Contact
    3. Technical
   
    1. 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)
   
    1. 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)
    2. Necessary to comply with a legal obligation
   
   To use analytics data to improve our website and visitor experiences
   
    1. Technical
    2. Usage
   
   Consent
   
   To send you our general and/or investor newsletters  and sales and marketing
   information about our products
   
    1. Identity Data
    2. 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.
   
    1. Technical Data
    2. 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
   
    1. Identity Data
    2. Contact Data
   
   Necessary for our legitimate interests (to prevent fraud)
   
   For legal, [tax,] accounting, reporting, audit purposes 
   
    1. 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. 

 * COOKIES AND SIMILAR TECHNOLOGIES
   
   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.

 * SHARING YOUR PERSONAL DATA
   
   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.
   
    * 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.

 * INTERNATIONAL TRANSFERS
   
   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).
   
   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.

 * DATA SECURITY
   
   We have put in place security measures to seek to prevent your personal data
   from being accidentally lost, used or accessed in an unauthorised way,
   altered or disclosed. In addition, we limit access to your personal data to
   those employees, agents, contractors and other third parties who have a
   business need to know.

 * DATA RETENTION
   
   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.

 * YOUR DATA PROTECTION RIGHTS
   
   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.

 * YOUR LEGAL RIGHTS
   
   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.


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