Privacy Policy

Introduction

Sampl (“we”, “us”, “our”), is committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation (GDPR). Our policy is to be transparent about why and how we process personal data.

This privacy notice applies to personal data provided to us, both by individuals themselves or by others, and it describes why and how we collect and use personal data. It provides information about your data subject rights and what you can do it you have concerns about our processing of your personal data (hereafter called ‘personal information’).

This privacy notice covers personal information that is collected through our website (the “Website”) and all associated sub-domains, by telephone, through LiveChat and through any related social media applications.

Who are we?

We are Sampl Technologies Ltd; a company incorporated in England & Wales with company number 13069140. We are a data controller as defined by legislation, whilst also acting as a Data Processor to enable the fulfilment of sampling campaigns and the capture of marketing permissions and consumer insights for our brand partners. Our registered office is:

20-22 Wenlock Road
London
N1 7GU

Our website: https://www.sampltech.com

We have appointed a Data Protection Officer to oversee our handling of personal information. If you have any questions at all about this privacy notice, the information presented on our Website, or about how we use and process your personal information, please contact our Data Protection Officer by e-mail at: privacy@sampltech.com

What we use your information for

We may use personal data provided to us for the purposes described in this privacy notice or as made clear before collecting your personal data.

In order to provide our services to you, and to promote our business, we need to collect and process certain personal information about you.

We collect personal information from you for one or more of the following purposes:

• To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
• To enable us to process and fulfil your requests for samples, on behalf of our clients (as a data processor)
• To allow us to process your requests to receive marketing information from our clients (as a data processor)
• To collect feedback on behalf of our clients
• To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.
• To fulfil a contract that we have entered into with you or with the entity that you represent. In these circumstances it may be your entity, rather than yourself, that has provided us with your personal data.
• To ensure the security and safe operation of our websites and underlying business infrastructure.
• To manage any communication between you and us.
• To provide data analysis in order to assist us with the pricing of our products and detect market trends.
• To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To improve our website, including as part of our efforts to keep our website safe and secure.
• To allow invoicing and to recover any outstanding payments.
• Where you have given your explicit consent, for marketing purposes.
• For legal, financial reporting and regulatory purposes.

The sections below provide more detail about the personal information we collect for each of these purposes, the lawful basis for doing so, and the retention period applied to each type of data

In addition, to ensure that each visitor to any of our website can use and navigate the site effectively, we collect the following:

• Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
• Your login information, browser type and version, time zone setting, browser plug-in types and versions.
• Operating system and platform.
• Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through, and from our site.

Our Cookies Policy, which can be viewed from the home page of each of our website, describes in detail how we use cookies.

In the “Your Data Protection Rights” section below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights:

• To understand how you use our Website, including clickstream and pages viewed (date and time) and length of visits to certain pages.
• To contact you with information about our services and other related matters, via email or other means.
• To present you with the chance to opt-in for samples or other related offers from our clients.
• To deliver a sample or samples on behalf of our clients to your nominated address.
• To enable you to access, use and view the Sampl platform.
• To collect feedback on behalf of our clients (as a data processor) regarding the sample delivered or other related offers, as well as for the purpose of consumer research.
• Where applicable, to maintain a record of your details, including demographic data and sample requests, for the purpose of further understanding the effectiveness of our campaigns.

What we collect from you

To enable us to provide our services to you, we will collect certain personal information when you create an account or request a sample. This may be provided to us via our Website, by phone, by email or via a third party, such as Facebook.

When using Sampl to request a sample or receive an offer from us, we will require as a minimum, your full name, email address and postal address to deliver our client’s goods to you.

Prospective clients may wish to contact us via our Website. To do so we ask for your company name, your name, a contact email address and telephone number.

Regarding each of your visits to our Website we will automatically collect the following information:

• using our Website as a registered user, we will collect personal information about your sample requests and offers redeemed;
• technical information, including the internet protocol (IP) address used to connect your computer or mobile device to the internet, type of mobile device you use, a unique device identifier, mobile network information, your login information, browser type and version you use, browser plug-in types and versions, operating system and platform;
• information about your visit to our Website, including the full uniform resource locators (URL) clickstream to, through and from our Website (including date and time); pages you viewed or information you searched for; page response times, download errors, length of visits to certain pages; and
• details of your visits to other websites via our Website.

We also work with third parties (including, for example, electronic analytics, business partners, advertising networks, analytics providers, search information providers) and may receive certain information about you from them.

What is our lawful basis for processing your personal information?

Under the GDPR, the lawful bases we rely on for processing your personal information are:

• (a) Your consent. You can withdraw your consent at any time by contacting: privacy@sampltech.com
• (b) We have a contractual obligation.
• (c) We have a legal obligation.
• (d) We have a vital interest.
• (e) We need it to perform a public task.
• (f) We have a legitimate interest.

Who do we share your personal information with?

We may also share your information with selected third parties, in order to offer services to you or to perform any necessary functions on our behalf. Third parties may include:

• Business partners
• Other third parties you have asked us to engage including:
  • Companies you have agreed may receive your personal information to allow you to enter into a contract with them (for example, reward scheme companies)
  • Where you have given your explicit consent, to third parties for marketing purposes

Companies engaged by us to provide contracted services. For example:

• Managed Service Providers
• Software Providers
• Suppliers
• Engineers
• Solicitors
• Debt Collectors
• Survey companies
• Data analytics advisors
• Query search engine operators

Companies engaged by us to manage our communications with you. For example:

• Recording our incoming and outgoing calls
• Online chat provider
• Web hosting
• Email service providers

Your personal information will only be shared with a third party where the third party has agreed to keep your information strictly confidential and to only use your personal information for the specific purpose for which it was provided.

We may also share your personal information with:

• Search engine operators who can assist us in the improvement of our website
• Prospective buyers, in the event that we sell any part of our business or assets
• Regulators and other authorised bodies, whenever we are required to do so by law
• With competent authorities for law enforcement purposes where the sharing is necessary for the prevention or detection of crime, the investigation and prosecution of offenders, or there is an overriding public interest for doing so

Where we keep your personal information and how we keep it safe

We take data protection very seriously and have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way.

In addition, we limit access to your personal information to our clients and other third parties as required in the fulfilment of our services. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

Your data will be stored in our production environment, Amazon Web Services (EU Region), which is contracted by use for the provision of technical services. We remain responsible at all times for the security of your personal information, but if you want to know more about how we interact with Amazon Web Services you can view their privacy notice, amongst their other policies at: https://aws.amazon.com/privacy/

As we use Sendgrid to send emails, we must supply them with your email address, name, and a body for the email. If you want to know more about how we interact with Sendgrid, you can view their Privacy Policies at: https://www.twilio.com/legal/privacy

If you contact us through Live Chat on our website your query will be routed through Intercom, the platform we use to enable this feature. Intercom maintain a copy of all communications undertaken between you and us, you can view Intercom’s privacy policy at: https://www.intercom.com/legal/privacy

Any inbound inquiries (via email or telephone) will be passed through our CRM software, Salesforce, which we use to deal with all consumer or messages – a record will be kept of all inquiries. You can view Salesforce’s privacy policy at: https://www.salesforce.com/uk/company/privacy/

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred via the internet.

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

How long will we hold onto your data for?

We will only retain your personal information for as long as necessary to fulfil the sampling activity we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Once you no longer wish to use our services, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

What marketing activities do we carry out?

You are in control of whether we can use your personal information for marketing. We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving.

When we engage with you, we will ask you (on our website, by email or when we speak to you) whether you want us to contact you with marketing information that we think might interest you and if so, by what method (email, phone, post, SMS). Depending on the options offered and that you select the marketing could be about:

• our products and services,
• products and services for other companies, or
• products or and services from selected third parties.

We may send this information to you directly or via third parties such as search engine operators and marketing companies.

If you wish to unsubscribe from marketing, then you may do so at any time by following the unsubscribe instructions that appear in all marketing communications. Otherwise in respect of marketing from us, you can always contact us using the details set out below to update your contact preferences or details. Although this will stop marketing communications, we will of course continue to send you service related (non-marketing) communications where necessary.

Please note that there is no personal information used in our online ad campaigns so you will need to check your browser or social media settings to avoid seeing these.

“Virtual Try-On” technology

Some Sampl campaigns may incorporate “Virtual Try-On” technology, utilising augmented reality to “try on” makeup or suggest a foundation shade before requesting a sample. This technology is provided by Perfect Corp (https://www.perfectcorp.com/business) and neither Sampl nor Perfect Corp retain any imagery, video, or other biometric information from the process.

How we use “Cookies”

For full details of our use of cookies on our website, please refer to our Cookies Policy.

Your data protection rights

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email: privacy@sampltech.com or use the personal information supplied in the “How to contact us” section below.

To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

• The right to be informed
  As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice and any related communications we may send you.
  
  
• The right of access
  You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
  
  a) The purposes of the processing
  b) The categories of personal data concerned
  c) The recipients to whom the personal data has been disclosed
  d) The retention period or envisioned retention period for that personal data
  e) When personal data has been collected from a third party, the source of the personal data
  
  
• If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
  
  
• The right to rectification
  When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
  
  
• The right to erasure (the ‘right to be forgotten’)
  Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
  
  
• The right to restrict processing
  You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
  
  a) The accuracy of the personal data is contested.
  b) Processing of the personal data is unlawful.
  c) We no longer need the personal data for processing but the personal data is required for part of a legal process.
  d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
  
  
• The right to data portability
  You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
  
  
• The right to object
  You have the right to object to our processing of your data where:
  
  
  • Processing is based on legitimate interest
  • Processing is for the purpose of direct marketing
  • Processing is for the purposes of scientific or historic research
  • Processing involves automated decision-making and profiling

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services and we may need to deactivate your account on our Website.

You can always unsubscribe from our email communications at any time by following the unsubscribe link in our email communications, or by updating your email preferences on your profile on our Website.

How to contact us

If you would like to stop receiving information from us; or your personal preferences change and you do not want us to send you the information requested; or if you have any queries about how we use your personal information; or if you wish to exercise your rights (listed in the Your data protection rights section) then please let us know by contacting us directly:

20-22 Wenlock Road
London
N1 7GU
E-mail: privacy@sampltech.com

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at privacy@sampltech.com.
You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

For more details about your rights under the Act, the rules we have to adhere to in collecting and storing your personal information, and how you can check your data records, please visit https://www.gov.uk/data-protection/the-data-protection-act

Other websites

Our website may contain links to other websites. This privacy notice only applies to our own website so when you link to other websites you should read their own privacy policies.

Changes to this privacy notice

Any changes we may make to our privacy notice in the future will be posted on this page.

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