Fresh Group Consulting

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Confidentiality & Professional Ethics Statement

Fresh Group – Food Safety and Quality Consulting (“Fresh Group”, “we”, “our”, or “us”) is committed to protecting the privacy, confidentiality, and security of organizational and personal data. We process organizational and personal data responsibly and in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR), Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), applicable United States privacy laws, including state-level regulations such as the California Consumer Privacy Act (CCPA/CPRA), where applicable. 

Privacy Policy Introduction

Fresh Group – Food Safety and Quality Consulting (“Fresh Group”, “we”, “our”, or “us”) is committed to protecting the privacy, confidentiality, and security of organizational and personal information entrusted to us by our trainees, clients, partners, and website visitors.

As an international consulting firm serving businesses in the food industry, including food manufacturing, catering, food retail, food service, and food supply chains, we recognize the importance of protecting both organizational and personal data and confidential business information.

Fresh Group processes organizational and personal data in accordance with applicable privacy and data protection laws, including:

  • The EU General Data Protection Regulation (GDPR),
  • The Canadian Personal Information Protection and Electronic Documents Act (PIPEDA),
  • Applicable United States privacy laws, including state-level regulations such as the California Consumer Privacy Act (CCPA/CPRA), where applicable.

We are committed to handling organizational and personal information responsibly in accordance with recognized international data protection practices.

Data Controller

The organization responsible for processing personal data described in this policy is:

Fresh Group – Food Safety and Quality Consulting.

Email: raphael.samson@freshgroupglobal.com
Phone: +358 40 664 72 77.

For questions regarding this Privacy Policy or our data protection practices, please contact us using the details above.

Our mission is to provide steadfast support, guidance, and expertise to clients across the Atlantic, ranging from farmers and ingredient suppliers to food processors, manufacturers, packaging producers, retailers, and distributors.

We are committed to ensuring our clients achieve full compliance with food safety regulations, effectively mitigate food safety risks and hazards, and foster a culture of continuous excellence in food safety and quality.

Scope of This Policy

This Privacy Policy applies to company or organizational data, client and prospective client’s data, and personal data collected through:

  • Our website,
  • Consulting engagements,
  • Training and certification programs,
  • Professional communications,
  • Requests for proposals or consulting services,
  • Client relationships and business interactions.

Our services are primarily provided to organizations operating within the food sector, including:

  • Food manufacturers,
  • Food processors,
  • Food distributors and supply chain operators,
  • Food retailers,
  • Catering and food service businesses,
  • Importers and exporters of food products,
  • Food professionals of all levels. 

Organizational and Personal Information We Collect

Fresh Group collects only the organizational and personal information necessary to conduct professional consulting services, business offers and business communications.

Information Provided by Clients or Website Users

This may include:

  • Full name,
  • Business contact information,
  • Company name,
  • Job title or professional role,
  • Email address,
  • Telephone number,
  • Business address,
  • Information submitted through contact forms,
  • Documents or information shared during consulting and project engagements.

Purpose of Processing Company and Personal Data

Fresh Group processes organizational and personal data for legitimate business purposes, including:

  • Responding to inquiries and consultation requests,
  • Providing food safety and quality consulting services,
  • Delivering HACCP, HARPC, and regulatory compliance support,
  • Conducting training, audits, and professional advisory services,
  • Preparing proposals, contracts, and invoices,
  • Managing professional relationships with clients and partners,
  • Maintaining website functionality and security,
  • Complying with legal, regulatory, and contractual obligations.

We do not use organizational and personal data for unrelated purposes without appropriate notice or consent.

Legal Basis for Data Processing

Fresh Group processes organizational and personal data only when there is a lawful basis to do so and when it is necessary for legitimate business activities related to our consulting services.

Depending on the jurisdiction and context, Fresh Group may process organizational and personal data based on one or more of the following legal grounds:

  • Performance of a contract – when processing is necessary to provide consulting, training, auditing, or advisory services requested by a client or prospective client.
  • Legitimate business interests – when processing is reasonably necessary to manage professional relationships, respond to inquiries, provide services, improve our operations, or maintain the security and functionality of our website and communications.
  • Legal or regulatory obligations – when we are required to process or retain certain information to comply with applicable laws, regulatory requirements, or professional obligations.
  • Consent – when individuals voluntarily provide information or explicitly agree to certain forms of data processing, such as submitting information through contact forms or subscribing to communications.

European Economic Area (EEA)

For clients and website users located in the European Economic Area, personal data is processed in accordance with the General Data Protection Regulation (GDPR). Processing is based on lawful grounds defined under Article 6 of the GDPR, including contractual necessity, legitimate interests, legal obligations, or consent where required.

Canada

For clients located in Canada, Fresh Group processes personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). Personal information is collected, used, and disclosed primarily with the knowledge and consent of the individual, except where permitted or required by law.

United States

For clients located in the United States, Fresh Group processes personal information in accordance with applicable federal and state privacy laws. These may include state-level privacy regulations such as the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), where applicable.

Personal information collected from U.S. clients is used only for legitimate business purposes related to providing consulting services, managing professional relationships, responding to inquiries, and complying with legal obligations. Fresh Group does not sell or trade personal information.

Confidentiality of Clients and Prospective Client's Information

Fresh Group operates within industries that require strict protection of proprietary and confidential business information.

During consulting engagements, clients may share sensitive materials such as:

  • Food Safety Plans,
  • HACCP or HARPC systems,
  • Supplier approval programs,
  • Audit reports,
  • Internal operational procedures,
  • Regulatory documentation,
  • Product specifications,
  • Quality management systems,
  • Etcetera. 

Fresh Group treats all client documentation and information as strictly confidential.

We implement professional safeguards to ensure:

  • Restricted access to sensitive information,
  • Secure storage of client documentation,
  • Confidential handling of proprietary materials,
  • Non-disclosure of business-sensitive information without authorization.

Confidential information is only disclosed when required by law or with explicit permission from the client.

Sharing of Personal Information

Fresh Group does not sell, trade, or rent personal information to third parties.

We may share personal information only when necessary, including:

  • With trusted service providers who assist with website hosting or IT services,
  • With legal or financial advisors when required,
  • With regulatory and investigative authorities, only when legally mandatory,
  • When necessary to fulfill contractual obligations.

All third parties receiving personal information are required to maintain appropriate confidentiality and data protection standards.

International Data Transfers

Because Fresh Group serves clients globally, personal data may be transferred between jurisdictions, including the European Union, the United States, and Canada.

When transferring data across borders, we implement safeguards consistent with international privacy laws, including:

  • Standard contractual data protection clauses,
  • Secure data handling practices,
  • Limiting access to authorized personnel.

Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes described in this policy.

Retention periods may depend on:

  • Duration of consulting and project engagements,

  • Legal and regulatory requirements,

  • Financial and accounting obligations,

  • Professional record-keeping requirements.

When organizational or personal data is no longer required, it will be securely deleted or anonymized.

Data Security

Fresh Group implements appropriate technical and organizational safeguards to protect personal information and confidential business documentation.

These measures may include:

  • Secure digital storage systems,
  • Controlled access to sensitive documents,
  • Confidentiality protocols,
  • Secure communication channels,
  • Ongoing review of security practices.

Although we take reasonable steps to protect personal data, no electronic system can guarantee absolute security.

Your Data Privacy Rights

Depending on applicable laws, companies and individuals may have rights regarding their organizational and personal information, including:

  • The right to access personal information,
  • The right to correct inaccurate data,
  • The right to request deletion of personal information,
  • The right to restrict processing,
  • The right to object to certain processing activities,
  • The right to withdraw consent where applicable.

Requests related to personal data may be submitted to:

raphael.samson@freshgroupglobal.com

We will respond in accordance with applicable privacy laws.

Cookies and Website Technologies

Our website may use cookies or similar technologies to enhance user experience and improve website performance.

Cookies may be used for purposes such as:

  • Ensuring website functionality,
  • Understanding website usage patterns,
  • Improving site performance,

Users may manage or disable cookies through their browser settings.

External Website Links

Our website may contain links to external websites operated by third parties.

Fresh Group is not responsible for the privacy practices or content of these external websites. Users are encouraged to review the privacy policies of any external sites they visit.

Updates to This Privacy Policy

Fresh Group may update this Privacy Policy periodically to reflect changes in legal requirements, technology, or business practices.

The most recent version will always be available on our website.

Contact Information

For questions about this Privacy Policy or our data protection practices, please contact:

Fresh Group – Food Safety and Quality Consulting

Website: https://freshgroupglobal.com
Email: raphael.samson@freshgroupglobal.com
Phone: +358 40 664 72 77

Fresh Group is committed to protecting personal information while supporting food businesses worldwide in achieving the highest standards of food safety, regulatory compliance, and operational excellence.

Signed by Raphael Samson for Fresh Group – Food Safety and Quality Consulting.