Privacy Policy

Frontier Agriculture Limited and our group ("we", "Frontier", "the Group") are committed to protecting and respecting your privacy. It is important that you understand how we look after your personal information ("personal data") and how we make sure that we meet our legal obligations to you under the UK data protection rules (including associated guidance) (the "Data Protection Laws").

This privacy policy outlines how Frontier will use, store and share your personal data, and supplements any other fair processing or privacy notices provided to you.

Please note any other use of our websites is subject to our terms of use https://www.frontierag.co.uk/terms-and-conditions.

This policy applies to any personal data we collect about you when you:

• use any of our websites set out in section 11 below;
• use any of our apps;
• contact us or when we contact you;
• purchase goods or services from us;
• provide services or goods to us (where, for example, you are a sole trader, partnership or where you are providing services or goods on behalf of your employer/contractor); and/or
• visit our sites.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The details of the applicable data controller depending on which member of the Frontier Group you are dealing with are set out at the end of this policy.

If you have any questions in relation to this policy or generally how your personal data is processed by us please use the "Contact Us" page on our websites, or contact our Data Protection Co-ordinator by post at Frontier Agriculture Limited, Witham St. Hughs, Lincoln LN6 9TN, or by email.

1. PERSONAL DATA WE MAY COLLECT ABOUT YOU

We collect the following types of data:

• Identity data which includes your name and username.
• Contact data which includes your address, email address and telephone number.
• Financial data which includes bank account and payment card details.
• Transaction data which includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical data each time you visit our websites or use our apps. This includes information about your computer and mobile device for system administration including, where available, your IP address, operating system and browser type.
• Profile data which includes your username and password.
• Usage data which includes information about how you interact with and use our website, products and services.

Personal data is also collected in order to help us analyse how users use the websites and apps (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website and app users and to assist us in managing your account and improving your online experience.

Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.

2. HOW THIS INFORMATION IS COLLECTED

We collect some of your information directly from you, through information that you give to us or information that we collect during your visits to our websites or apps or through your communications with us. We also obtain some information from other third parties, including credit reference agencies and Companies House.

Information that you give us

You may share personal data about yourself and your circumstances by:

• filling in forms on our websites or other forms provided to you by us, registering to use our websites and apps, and continuing to use our websites and apps;
• giving us information about yourself in any communications with us either by telephone, e-mail, social media, post or otherwise, either in connection with your customer account or to report a complaint or issue;
• signing in at reception on one of our sites;
• attending one of our events or open days

You are not obliged to provide your personal data to us. However, if you do not provide your personal data to us, we may not be able to provide services to you, respond to your queries or allow you onto our sites.

Information that we collect about you

We collect personal data about you from the following ways:

• information about your calls to us, including a recording of such call and information about your orders for goods or services;
• information about your buying habits and patterns when you purchase goods and services from us;
• when you visit our websites or use our apps (such as MyFarm), including details of your visits including, but not limited to, Internet Protocol (IP) address used to connect your computer to the internet, mobile device IMEI number, mobile phone number, MAC addresses, traffic data, location data, your login information, time-zone setting browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access.

We may also collect information which is stored on your device each time you use one of our apps. For example, we may collect log-in information and geographical location, device type, browser details, operating system, language, time and date, service provider, pages visited, IP address, length of visit and screen resolution, in order to improve our website design and service provided.

For more information please see our cookies policy at: https://myfarm.frontierag.co.uk/dashboard/policies;

• information in connection with services or goods that you provide to us including, for example, in connection with accidents or incidents as part of the service delivery;
• if you visit one of our sites, data including your name, car registration and CCTV images;
• when you call us, including information about complaints and services.

Information that we receive from other sources

We may receive personal data about you from other third parties, including:

• company credit reference agencies, when such checks are required for opening and updating our customer accounts;
• app usage statistics from our software developer and provider of the Greenlight 'My Crop Records'
• third party registers of suppliers where it is a condition of our contract with your employer (for example, to ensure that our supplier has appropriate insurance) when you are involved in the provision of goods or services to us;
• Companies House, postcode checking, VAT checking portals, which is a publicly accessible information source, for data verification checks required to process new customer accounts;
• Red Tractor Assurance and Scottish Quality Crops when we are checking your assurance status;

3. WHY WE NEED YOUR INFORMATION

3.1 The main purpose for which we use your information is to provide you with the information, goods and services that you request from us.

We also use your information:

• to carry out our obligations arising from any contracts entered into between you and us including but not limited to setting up customer credit accounts, your use of our apps and other online services, and in relation to our rights under any such contracts;
• to provide you with information that you request from us or which we feel may interest you. We may, on occasion and, where there is a legal basis for this, send you marketing information by email or post. This can include notifications about the launch of new goods, services, competitions, offers or other relevant news articles that you might find interesting. If you would like to stop receiving such information from us, please click on the "unsubscribe" link in any such emails that we send to you, or use the contact details at the beginning of this policy;
• for research about our customers’ behaviour, and our products and services generally;
• to develop and improve our services;
• to manage the services/goods that you are delivering to Frontier;
• to administer and improve our websites and apps to ensure that content is presented in the most effective manner;
• to allow you to participate in interactive features on our websites, our apps, and in relation to our services, when you choose to do so;
• to administer our websites and our apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to notify you about changes to our goods and services;
• to provide customer support;
• to allow us to open a credit account for you (for example, by running financial and security checks (in particular in relation to trade sanctions)
• to measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties;
• as part of our efforts to keep our sites safe and secure (for example through the use of CCTV on our sites)
• to make suggestions and recommendations to you and other users of our websites and our apps or services about goods or services that may interest you or them; and
• to comply with our legal and regulatory obligations and for the purposes of assisting with the prevention and detection of crime.

3.2 Basis for using your information

Compliance with legal obligations

We may need to process your personal data to comply with our regulatory and statutory obligations, for example to verify your identity, to provide relevant health and safety information for us before we visit customer sites, or where required to assist with the prevention and detection of crime. Failure to provide the requisite personal information when you apply for a customer account with us, provide services to us or use our websites or apps, may mean we cannot provide our goods or services to you or receive services from you, because to allow you to purchase our goods and services or receive services from you may mean we may be in breach of our legal obligations. You will not be able to object to this processing or ask for the deletion of your personal information insofar as it falls under this category

Necessary for the entry into or performance of a contract

When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place an order for goods or services), we will need to collect, process and share your personal information. Failure to provide the requisite personal information when placing your order and financial information on entering into the transaction or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our goods and/or services to you.

Legitimate business interests

We use your personal data as set out in this privacy policy for the legitimate interests of our business to enable us to:

• provide you with goods and services as requested by you;
• to provide you with information about our goods and services where you are a current customer;
• carry out research and analytics to understand our customers and how they use our products and services; and
• develop and improve our goods and services to you and to our other customers.

As indicated below, we may also pass your personal data to members of our Group and other third parties and this is also for our legitimate business interests.

We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.

Legitimate interest

We have a legitimate interest in processing your information as:

• you benefit from the provision of and quality control of our goods and services;
• we have a legitimate interest in recording calls to monitor staff performance, train staff, and improve our processes;
• we will both benefit from the ability to enforce or apply rights under any contract between us;
• we will both benefit from the customer account/any credit account services that we provide;
• we are required to ensure health and safety of our sites and the health and safety of our employees visiting customer sites, and therefore have a legitimate interest in ensuring any processes are effective;
• we have a legitimate interest in ensuring the security of our sites and stored data, and in assisting with the prevention and detection of crime;
• we would be unable to provide our goods and services without processing your information;
• we may both benefit from the provision of information about our goods and services;
• we will both benefit from the use of interactive features on our websites and our apps, from the most effective presentation of information on our websites and apps, and from effective management, updates, improvements, and administration of our websites and app; and
• we have a legitimate interest in processing your information in connection with any mergers, acquisitions or reorganisation of our business, in which case some of your information may be shared with a prospective buyer or otherwise but only so far as is strictly necessary for the purposes of such sale or administration.

Necessity

We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as we process your personal data only so far as is necessary to achieve the purpose outlined in this privacy policy.

Impact of processing

We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data does not unreasonably intrude on your privacy.

Consent

We may, on occasion, send you marketing messages by email and post about us and our events, offers, goods and services, where you have not unsubscribed and where you have purchased similar goods or services from us, or where you have otherwise consented. You may notify us at any time that you no longer wish to receive direct marketing communications from us and where you have provided your consent for such communications you may withdraw this consent at any time.

4. WHO WE SHARE YOUR INFORMATION WITH

4.1. We may share your information with the other members of our Group but only for the purposes specified in this privacy policy. In particular, your information may be shared between the relevant members of our Group for the purpose of sharing credit control details of the relevant Group member's customers to our centralised finance team.

4.2. We may also use a number of carefully selected third parties to supply us with products and services. We will only share your information with these suppliers where it is necessary for them to provide us with the services we need.

4.3. We may disclose a limited amount of your personal information to our parent companies Cargill plc and Associated British Foods for audit purposes.

4.4. We may share your personal information with third parties where they provide us with processing services on our behalf.

4.5. We will not share your personal information unnecessarily.

4.6. We may also disclose your personal information:

(i) to business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, for example where we use a third party to provide services to enable us to deliver goods and/or services to you, and in particular for credit reference checks and for development and support of our online services and apps;

(ii) to members of our Group and third party suppliers and service providers for the purposes listed in section 3.1 above, for example where we use a third party to provide services to enable us to deliver goods and/or services to you or where we share IT platforms or processes with our Group;

(iii) to Google Analytics, search engine providers and other selected third parties that assist us in the improvement and optimisation of our websites and our apps;

(iv) to our regulators, law enforcement or fraud prevention agencies, as well as our advisors (including legal advisors and auditors), courts, any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.;

(v) in the event of a merger, acquisition or other similar event, to a prospective buyer or otherwise of our business or assets, in which case we will disclose your personal data to such prospective buyer or otherwise of such business or assets;

(vi) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Frontier, our customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and

(vii) to legal advisors and otherwise in connection with legal proceedings in order to enforce or apply our rights under any contract.

5. AUTOMATED DECISIONS ABOUT YOU

5.1. We may carry out some profiling of you for the purposes of improving and developing our products and services and to help us to tailor our marketing to you. The impact of any automated decision is to ensure you experience the best service possible.

6. WHERE WE STORE YOUR INFORMATION AND HOW LONG IT IS RETAINED

6.1. The information we collect about you may be transferred outside the European Economic Area for the purposes listed in section 4 above, and we will only do so as permitted under Data Protection Laws.

6.2. Retention of your personal data

We will typically keep your personal data for 6 years from the closure of your account with us in order to enable us to deal with any issues or concerns you may have about how we handled your account, and also to allow us to bring or defend legal proceedings. Some information, for example information relating to health and safety, may be kept for up to 80 years. In some circumstances, some of your data will be deleted in much shorter timescales, for example:

• data from our online accounts or apps are kept for a maximum of 3 years from the date of the last online activity;
• marketing emails and other communications where possible will typically be deleted after 3 years, unless we are required for legal and regulatory purposes to retain such communications for a longer period;
• cookies are refreshed in accordance with our cookies policy https://myfarm.frontierag.co.uk/dashboard/cookies
• CCTV data will typically be deleted after 30 days;
• Any other information will typically be deleted after 6 years from the date of our last positive interaction with you or sooner wherever possible.

6.3. Security of your personal data

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data whilst in transmission to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data. We also make sure that any third parties that we deal with keep all personal data they process on our behalf secure.

If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.

7. YOUR RIGHTS

You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. You may contact us using the details at the beginning of this privacy policy to exercise any of these rights.

In some instances, we may be unable to carry out your request, in which case we will write to you to explain why.

(i) You have the right to request access to your personal data

You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.

(ii) You have the right to ask us to rectify your personal data

You have the right to request that we rectify your personal data if it is not accurate or not complete.

(iii) You have the right to ask us to erase your personal data

You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply if we no longer need to use your personal data to provide the debt management services to you, where you withdraw your consent for us to process special categories of your personal data, or where you object to the way we process your personal data (see right 6 below).

(iv) You have the right to ask us to restrict or block the processing of your personal data

You have the right to ask us to restrict or block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we do not need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims.

(v) You have the right to port your personal data

You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you.

(vi) You have the right to object to our processing of your personal data

You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.

(vii) You have the right not to be subject to automated decisions

You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.

(viii) You have the right to withdraw your consent

You have the right to withdraw your consent where we are relying on it to use your personal data

8. IF YOU HAVE A COMPLAINT

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request made by you, or would otherwise like to make a complaint, please contact the Data Co-ordinator in the first instance using the details at the start of this privacy policy, so that they can do their very best to sort out the problem.

You can also contact the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or at www.ico.org.uk.

9. DETAILS OF THE DATA CONTROLLER

For the purpose of applicable data protection legislation the data controller is Frontier Agriculture Limited (registered no. 05288567), with its postal address at Witham St Hughs Lincoln, LN6 9TN.

10. SOLE TRADERS, PARTNERSHIPS AND BUSINESSES

Where we provide products and/or services for a sole trader, partnership or business that you represent or are employed / contracted by and this involves the collection and use of your personal data by us, this will be done in accordance with the relevant parts of this privacy policy.

11. OUR WEBSITES

11.1 This policy applies to the following websites:

12. OTHER WEBSITES

Our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites

13. CHANGES TO OUR PRIVACY POLICY

We will take reasonable measures necessary to communicate any changes to this privacy policy to you. In any event, all updated privacy policies will be posted on this page.

This policy was last reviewed and updated in March 2025.