Henderson Wholesale Limited

Policy Privacy (including Cookie Policy)



Ref                  : HWL Consumers

Updated          : HWL Marketing - November 2019





At Henderson Wholesale Limited, we understand your concerns about what happens to information which you provide to us and we are dedicated to protecting your privacy.


Henderson Wholesale Limited provides this privacy policy in order to explain how your information is collected and used. The privacy policy also explains the use of certain features on the websites and social media channels.



How do we collect information?


We collect information on you through any of our websites (websites) below:




or any of the social media channels (social media channels) under any of the names of


  • SPAR NI,
  • VIVO NI or



Also through competition paper entry forms, conversations in-store, at events or by telephone, video or image recording by us at various events or in-store or in connection with a contract with you.



What information do we collect from you?


As appropriate for the intended use of the information (described below), we collect certain personal data regarding you including (among other things) your:


  • name address details                     • phone numbers
  • email addresses image\photograph                • online identifiers
  • location data                


and any other information required to perform a contract that you have entered into. We also collect information relating to the options you select on the websites and other websites which are accessible through links from the websites.

How will we use this information?


We will only use your information when the law allows us to. Most commonly, we will use your personal data under the following conditions:


  • to enter you into competitions that we run and administer;
  • where we need to perform the contract we are about to enter into or have entered into with you;
  • 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. Those legitimate interests can include the:
    • running and growing of our business including the use of ancillary services such as IT provision and network security;
    • necessity to keep our records updated;
    • study and development of how our services are used and
    • the informing of our marketing strategy


  • to deliver relevant content of the websites and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  • to use data analytics to improve our websites, products/services, marketing, customer relationships and experiences; and
  • where we need to comply with a legal or regulatory obligation.


Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time, as described below.


We may use your personal data for some or all of the following purposes:


  • dealing with queries/concerns that you have brought to our attention;
  • to enter you into competitions that we run and administer;
  • for administration of a contract with you;
  • to run promotional campaigns;
  • to comply with our legal obligations and responsibilities and establishment and defence of legal claims;
  • to deliver relevant marketing information to you from time to time;
  • to deliver relevant content of the websites and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  • to use data analytics to improve our website, products/services, marketing, customer relationships and experiences; and
  • for good governance, accounting and managing our business operations.



How long do we hold your information for?


Subject to your rights set out in relevant data protection laws and explained in this privacy policy, we will retain your information in accordance with our standard retention policy. Unless that retention policy defines a shorter time, we will keep your information for as long as necessary for the purposes it was collected for, for as long as you (or someone else) would be permitted to take a legal claim against us in a matter which involves your information or as for as long as we are otherwise legally required to retain the information.



Your right to opt out


You may opt out of receiving marketing communications from us. Details of how to unsubscribe from emails will be included with each marketing email we send you.


Alternatively, you can email us at MarketingTeam@henderson-group.com to change your contact preferences. Please be aware that there may be times when it is necessary for us to contact you even if you have opted out of receiving other communications from us, such as for administrative or operational reasons.



To whom will we provide your information?


From time to time we may need to disclose your information to:


  • other companies within our group and their employees;
  • to market research companies to carry out market research about the Henderson Wholesale Limited brands;
  • to professional advisors (including lawyers, bankers, accountants, insurers and insurance brokers);
  • and to third party data processing service providers (such as marketing automation platform and marketing service providers, IT hosting providers, data security providers and FMCG suppliers to Henderson Wholesale Ltd.) who process your information on our behalf in accordance with our instructions to enable us to provide services to you and facilitate the purposes described above.


We will only ever do so as permitted by and in accordance with applicable data protection law.


Some of the recipients of the information may be located outside of the European Union. Whenever we transfer information outside of the European Union, we make sure that similar levels of protection are applied.


Whenever any providers are located in the US, we only transfer information to them if they are part of the “Privacy Shield”, which requires them to provide similar protection (more information is available here: Privacy Shield). In particular, we do business with The Rocket Science Group LLC (trading as MailChimp), who (as at the date shown at the top of this Privacy Policy) are certified under the Privacy Shield (which can be viewed here: MailChimp).


By opting in to receive marketing information via SMS, email or post, you acknowledge and accept that we may need to disclose your information in those limited circumstances and for the purposes described.



What about Cookies and other tracking tools?


As part of our dedication to high standards we use cookies and other tracking tools on the websites. Cookies are small packets of data that your web browser stores on your device when you visit websites, which enable the server to collect information.  Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies. To get the most out of your experience when using the websites / social media channels you will need to use cookies. However, should you want to turn off the cookie function, please see the help section on your web browser.


To read more information on cookies click here: Cookie Policy.

What happens if you follow a link to another website?


If you use other links on the websites that lead to external websites we will no longer have control over the way in which any information is collected from you through those websites. Other websites may handle your information in a different way and should have their own privacy policies.



How can you find out what information we hold about you?


If at any time you wish to know what information we hold about you, please contact HWL Marketing using the details below:


Henderson Wholesale Ltd, PO Box 49, Hightown Ave Newtownabbey BT36 4RT


Telephone: (028) 90343316

email: brandteam@henderson-group.com  


Company No: NI000068



Your other rights over the information


Depending on the information we are using and under certain circumstances, you have rights under data protection laws in relation to some of the information you provide that can identify you (which is known as personal data under data protection laws).


You have the right to:

  • Request access to your personal data;
  • Request correction of your personal data;
  • Request erasure of your personal data;
  • Object to processing of your personal data;
  • Request restriction of processing your personal data;
  • Request transfer of your personal data; and the
  • Right to withdraw consent.


If you want to exercise any of the above rights, please contact us at the address or email address above and let us know.



Your right to lodge a complaint


If you are not happy with how your information has been handled you have the right to lodge a complaint with a supervisory authority. The UK supervisory authority for data protection issues is the Information Commissioner's Office (ICO).  (www.ico.org.uk) We would, however, appreciate the chance to deal with your concerns before you approach the ICO. (for contact details see the previous section How can you find out what information we hold about you?)







What if there are changes to this Privacy Policy?


Occasionally, to better protect you and in accordance with the law, we may need to update our privacy policy. We reserve the right to amend, update or replace this privacy policy at any time and your continued use of our website will constitute your acceptance of any such changes we may make. Any changes we make will be shown here, so please make sure you check this page from time to time.



Cookie Policy


Information about our use of cookies


The websites below use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our websites.



The websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.


A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your computer's hard drive.



Number of Cookies



















After session


Max 10 yrs


Some are permanent


Some are permanent




After session


Max 2 yrs


Some are permanent


Some are permanent


Henderson Group


Max 50 yrs


Max 2 yrs


Some are permanent
















Explanation of Cookies


We use the following cookies:


  • Necessary Cookies:

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.


  • Statistic Cookies:

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.


  • Marketing Cookies:

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.




  • Unclassified Cookies:

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.



Blocking Cookies


You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including necessary cookies), or do not give us consent to use cookies, you may not be able to access all or parts of our site.



More Detail on Cookies


For more comprehensive detail on cookies contact DCO@Henderson-group.com