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SAMOS E-COMMERCE LTD. respects your privacy and is committed to protecting your personal data. This privacy and cookie policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy and cookie policy.
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website (https://samos-e.com/), including any data you may provide through this website when you access our site, create a user account or use our service.
It is important that you read this privacy and cookie policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy and cookie policy supplements other notices and privacy policies and is not intended to override them.
SAMOS E-COMMERCE LTD. ("We"). We are a private limited company registered in England and Wales under company number 11290535 and have our registered office at Suite 3, Independent House Independent Business Park, Imberhorne Lane, East Grinstead, West Sussex, England, RH19 1TU. We are the controller and responsible for your personal data (the "Company", "we", "us" or "our" in this privacy and cookie policy).
If you have any questions about this privacy and cookie policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy and cookie policy or our privacy practices, please contact us
You 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 resolve your concerns before you approach the ICO, so please contact us in the first instance.
We keep our privacy policy under regular review.
This version of the privacy and cookie policy was last updated on Wednesday, 10 October 2018.
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.
The website may include links to the websites belonging to third parties. We are not responsible for any content published by any such third parties, nor are we responsible for any malware contained on any such websites. Before filling in your personal details, please ensure that you are doing so on our website to avoid unauthorised use of your personal data by any third party.
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 site, we encourage you to read the privacy policy of every website you visit.
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).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data 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 it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy and cookie policy.
We do not collect any "Special Categories of Personal Data" about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you provide to us personal information belonging to someone else
If you provide personal information about other people, then you must:
When providing information about other people, ensure that you have all relevant permissions and authority to make all necessary disclosures.
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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
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:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that 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 we are relying on 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 inform you of marketplace developments and activity and of changes to our products and services. | (a) Identity (b) Contact | Necessary for our legitimate interests |
to process and deliver our services; to carry out mandatory or other regulatory checks; and for the prevention and detection of fraud or other illegal or criminal activity. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (c) Necessary to comply with our legal and regulatory obligations |
to manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy (b) asking you to leave a review or take a survey to carry out statistical analysis and market research and testing. | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) |
to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); and to update the records we hold about you from time to time. | (a) Identity (b) Contact (c) Technical | (a) 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) (b) Necessary to comply with a legal obligation |
to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you; to develop and improve our services, products and business, including analysing and improving our credit risk models, data collected and our customer service offering; and to provide and administer the marketplace and our related services. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our services, to develop those services, to grow our business and to inform our marketing strategy) |
to use data analytics to improve our site, services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
to make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our services and grow our business) |
Who we disclose your personal information to as part of our services
We may disclose your personal data:
Any such third parties who process your personal data on our behalf are only permitted to process your personal data in accordance with our instructions and we take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable data protection laws.
Marketing
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted-out of receiving marketing communication.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
We may disclose your personal information to third parties:
We have put in place appropriate security measures 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
How long will you use my personal data for?
We will not keep your personal information for longer than is necessary, for the purposes for which it was collected and is processed and for the purposes of satisfying our legal, accounting or regulatory reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data by contacting us
In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
A cookie is a small file that asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Overall, cookies help us provide you with a better site, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can set your browser to refuse all or some browser cookies, or to alert you when sites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
All Cookies used by and on the website are used in accordance with the Data Protection Legislation. We may use some or all of the following types of cookie:
A cookie falls into this category if it is essential to the operation of the site, supporting functions such as logging in, your shopping basket, and payment transactions.
It is important for us to understand how you use the site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping us to improve the website and your experience of it.
Functionality Cookies enable us to provide additional functions to you on the website such as personalisation and remembering your saved preferences. Some Functionality Cookies may also be Strictly Necessary Cookies, but not all necessarily fall into that category.
It is important for us to know when and how often you visit the site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with Analytics Cookies, this information helps us to better understand you and, in turn, to make the website and advertising more relevant to your interests.
Third-Party Cookies are not placed by us; instead, they are placed by Third-Parties that provide services to us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on the site, or by third parties providing analytics services to us (these Cookies will work in the same way as Analytics Cookies described above).
Any of the above types of cookie may be a Persistent Cookie. Persistent Cookies are those that remain on your computer or device for a predetermined period and are activated each time you visit the site.
Any of the above types of cookie may be a Session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit the website until you close your browser. Session Cookies are deleted when you close your browser.
We may use the following Cookies:
Cookie | Name | Purpose | More information |
XSRF-TOKEN | Cross site Request Forgery token | This is used to protect users from malicious requests made from their browser | https://en.wikipedia.org/wiki/Cross-site_request_forgery#Cookie-to-header_token |
__cfduid | Cloudflare user identifier | used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. | https://support.cloudflare.com/hc/en-us/articles/200170156-What-does-the-Cloudflare-cfduid-cookie-do- |
__zlcmid | Chat User Id | Used for live chat functionality | |
__zlcprivacy | Privacy decision | Used to track the privacy choice to delete the above cookie | |
_ga | Google Analytics | Used by Google Analytics to distinguish users. | https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage |
_gid | Google Analytics | Used by Google Analytics to distinguish users. | https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage |
samos_session | Session Cookie | Used to track the current session |
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such staff may be engaged in, among other things, the delivery of your order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy and cookie policy.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access and will ensure that any third party receiving your personal data adopts such appropriate measures necessary to safeguard your personal data.
Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Under certain circumstances, you have rights under the relevant data protection laws in relation to your personal information.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other 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 personal data is not disclosed to any person who has no right to receive it. 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.
"Comply with a legal obligation" means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
"Legitimate interest" means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 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.
"Performance of Contract" means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
“External third parties” means: