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SAMPLICO PRIVACY POLICY

Samplico respects your privacy and is committed to protecting your personal data. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities should you need to.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

This policy aims to provide you with information on how we collect and process your personal data through this website, samplico.com, when we interact with you to provide you with our products and services or otherwise throughout the course of our dealings with you.

Who we are

This Website is operated by Denebunu Limited trading as ”Samplico” (referred to as “Samplico”, “we”, “us” or “our” in these privacy policy). Our registered address is 4th Floor Imperial House, 8 Kean Street, London, England, WC2B 4AS and our company number is 13265299. We are the controller responsible for your personal data. Samplico is the company responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below (see ‘How to contact us’ below).

Personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). A data subject is the individual who the personal data relates to.

We may collect and use the following kinds of personal data about you (some of which is subject to you choosing to provide us with it):

  • Identity Data including your first name, last name, marital status, title, date of birth (and age), gender and photo (if you choose to provide this to us).
  • Contact Data including your address, email address and mobile phone number.
  • Transaction Data including details about products and services you have purchased from us.
  • Technical Data including internet protocol (IP) address, your login data, 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.
  • Profile Data including your username and password, purchases or orders made by you, profile city, profile bio, your interests, income level, household details, personal and home care habits, education level, work experience history, career goals, preferences and dislikes, feedback, ratings and reviews and survey responses (where not anonymised by you), data from your social media platforms (such as social networking sites including Facebook).
  • Usage Data including information about how you use our website, products and services, click movements, browsing time and details.
  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We collect and use this personal data to provide products and services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing such products and services to you.

This website is not intended for children and we do not knowingly collect data relating to children

How your personal data is collected

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms, submitting or uploading information to our website, contracting with us to receive sample boxes of products, or by corresponding with us through our website, social media, by phone, email or otherwise. This includes personal data you provide when you:
    • apply for or subscribe to our products or services;
    • create an account on our website to become a member (please be aware that if you choose to create your profile using your social media profiles, we will collect your person data through this third party platform);
    • request marketing to be sent to you;
    • enter a competition, promotion or survey;
    • provide your feedback; or
    • contact us.
  • Automated technologies or interactions. 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 and other similar technologies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
    • as mentioned above, if you choose to create your profile using your social media profiles, we will collect your personal data through this third party platform;
    • sanctions screening providers;
    • credit reference agencies;
    • customer due diligence providers
    • analytics provider, such as Google
    • through automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.

How and why 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 you have given consent;
  • to comply with our legal and regulatory obligations;
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • 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.

The table below explains what we use your personal data for and why.

What we use your personal data for Our reasons
Providing and distributing products and services to you To perform our contract with you or to take steps at your request before entering into a contract
To register you and set you up as a new customer

To perform our contract with you

For our legitimate interest to enable us to better match you with the appropriate sample products that we may be able to offer to send to you

Preventing and detecting fraud against you or us For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us

Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, i.e. to minimise fraud and to prevent consumers registering more than one membership in order to exploit our services.

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
To carry out surveys and/or provide feedback from our members about the products of consumer brands or about members’ haibits as a consumer

To effectively perform our contract with you

For our legitimate interests or those of a third party, i.e. members’ opinons will have a direct impact on consumers to enable them to read about members’ experiences with a products. This will also impact companies and their products, including on how they market, distribute, or advertise products and services to consumers going forwards

For our legitimate business interests to provide our services

To enable us to share product reviews, including with brand partners (unless anonymised) to inform other members and potential customers about the products our members have tried.

Please note your feedback in relation to certain products will be shared on our website and/or transferred as comments to the web pages of brand partners of the relevant products. Where your personal data is included, this will be due to the settings of your membership profile and these settings can be amended at any time.

To effectively perform our contract with you

For our legitimate interests or those of a third party, i.e. to share opinions and feedback of products where our members have chosen to do so

In certain circumstances and for certain types of data, where you have given your consent

In exceptional circumstances where our brand partners would like to include a specific product or service review of a member in their creative or marketing material and do not want to use anonymised data. In such circumstances we facilitate the communications between the member and the brand partner where the member has given their consent for us to do so.

In order for us to perform our contact with our brand partners

Only where you have given your consent

Management of your account with us To perform our contract with you
Customer service

To effectively perform our contract with you

For our legitimate interests i.e. to make sure we can deliver the best service to you and respond to you when you need us

Management of promotions or competitions that you choose to enter

To perform our contract with you

For our legitimate interests or those of a third party, i.e. to study how customers use our products/services, to develop them and grow our business

Ensuring business policies are adhered to, e.g. policies covering security and internet use For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences For our legitimate interests i.e. to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us

To comply with our legal and regulatory obligations

Updating and enhancing customer records and our service provided to you

To perform our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business and services to existing and former customers

In certain circumstances where you have given your consent

Special Category Personal Data

Special category person data includes personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data (when processed to uniquely identify an individual); and data concerning health, sex life or sexual orientation.

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, for example only where:

  • we have your explicit consent;
  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
  • the processing is necessary to establish, exercise or defend legal claims.

Marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

We may use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us at contact@samplico.com;
  • using the ‘unsubscribe’ link in emails; or
  • updating your marketing preferences on our website at http://www.samplico.com/profile/update/?from_sidebar=1.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and will will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we share your personal data with

We routinely share personal data with:

  • our parent company, Denebunu Limited, with commercial trade number, 13265299, and its office at 4th Floor Imperial House, 8 Kean Street, London, England, WC2B 4AS
  • third parties we use to help deliver our products and services to you, e.g. payment service providers, delivery companies, database/cloud servers;
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
  • third party partners, where approved by you and where you have not chosen to anonymise your data;
  • third party partners, where your data has been anonymised as part of an insight report;
  • credit reference agencies;
  • our insurers and brokers;
  • our bank;

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

  • share personal data with external auditors to ensure compliance with legal and regulatory requirements;
  • disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
  • share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices and those of our parent company, Denebunu Bilgi Teknolojileri Reklam Hizmetleri Pazarlama Sanayi ve Ticaret A.Ş., third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.

How long your personal data will be kept

We will keep your personal data while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal data for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to notify you of any health or safety risk in relation to any of the products that have been delivered to you
  • to show that we treated you fairly;
  • to keep records required by law.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.

Transferring your personal data out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, for example:

  • with our parent company located in Turkey;
  • with your and our service providers located outside the UK;
  • if you are based outside the UK;

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:

  • the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
  • a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

  • all European Union countries and countries of the European Economic Area (‘EEA’);
  • countries that the UK government has made an adequacy decision in favour of, including, Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses, as for transfers to our parent company in Turkey.

To obtain a copy of the standard contractual clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may in exception circumstances transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:

  • you have explicitly consented to the proposed transfer after having been informed of the possible risks;
  • the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
  • the transfer is necessary for a contract in your interests, between us and another person; or
  • the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

If you would like further information about data transferred outside the UK, please us (see ‘How to contact us’ below).

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. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Your rights

You have the following rights, which you can exercise free of charge at any time:

Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten) The right to require us to delete your personal data—in certain situations
Restriction of processing The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object

The right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

  • contact us—see below: ‘How to contact us’;
  • provide enough information to identify yourself; and
  • let us know what right you want to exercise and the information to which your request relates.

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.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have security procedures in place as well as technical and physical restrictions to access to ensure the your personal data is safeguarded at all times.

We have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.

How to make a complaint

Please contact us if you have any query or concern about our use of your information (see below How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), 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 the ICO so please contact us in the first instance.

Changes to this privacy policy

We may change this privacy notice from time to time. Please ensure that you regularly check this privacy policy for any changes that may affect you.

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

How to contact us

You can contact us and our data protection manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details
Address: 4th Floor Imperial House, 8 Kean Street, London, England, WC2B 4AS
Email address: contact@samplico.com