Privacy Policy

Contents

1. Introduction
2. What is personal data?
3. Personal data we collect
4. How we collect your personal data
5. Purposes for which we use your personal data and the lawful bases
6. Sharing your personal data
7. International transfers
8. How long we keep your personal data
9. Security of your personal data
10. Your rights
11. How to complain
12. How to contact us

1.       Introduction

Sambro International Limited (“Sambro”, “we, “our”) is committed to protecting the privacy and security of the personal data we collect about end customers and users of our services (“you/your”).

The purpose of this privacy notice is to explain what personal data we collect about you when you visit our website or. When we do this, we are the data controller.

Please read this privacy notice carefully as it provides important information about how we handle your personal information and your rights. If you have any questions about any aspect of this privacy notice you can contact us using the information provided below or by emailing us at marketing@sambro.co.uk.

2.       What is personal data?

‘Personal data’ is any information from which you can be identified, either directly or indirectly. For example, your name or an online identifier.

‘Special category personal data’ is more sensitive personal data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation. 

3.       Personal data we collect

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) and the Data Protection Act 2018. The personal data we collect includes : your name, address, e-mail address and phone number, and the name(s), age(s) and gender(s) of your children. Alongside this, we may collect technical information, this may include your Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform.

4.       How we collect your personal data

We collect most of this personal data directly from you—when you fill in forms or otherwise interact with our Site, www.sambro.com. This includes when you register to use our Site, subscribe to our Unboxer service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, click on a link and report a problem with our Site. We also collect your information when you correspond with us by telephone or email.

When you visit our Site, some information may be stored to enhance your experience and help you navigate the Site. This information will also help us to make our Site more user-friendly and useful. For more details on information collected when you visit our Site, please see our Cookie Policy.

5.       Purposes for which we use your personal data and the lawful basis

When providing services to you, we may use your personal data for the following purposes and on the following lawful bases:

Where personal data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

6.       Sharing your personal data

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.
Selected third parties including:

• our business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and optimisation of our Site. We will disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Sambro International Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation.

7.       International Transfers

When we collect your personal data, it may be processed outside the UK. This is because the organisations we use to provide our services to you are located in other countries.

We have taken appropriate steps to ensure that where personal data is processed outside the UK, it has an essentially equivalent level of protection as it has within the UK. We do this by ensuring that:

• Your personal data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation); or
• We enter into either International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs) (with the UK Addendum) with the receiving organisations and ensure that supplementary measures are also applied, where necessary.

8.       How long we keep your personal data

We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

At the end of the retention period, your personal data will be securely deleted or anonymised.

9.       Security of your personal data

We have implemented appropriate technical and organisational measures to safeguard your personal data and protect it from accidental or unlawful destruction, loss or alteration and from unauthorised disclosure or access.

In addition to the technical and organisational measures we have put in place, there are a number of simple things you can do to in order to further protect your personal information, such as;

1. Never share a One Time Passcode (OTP).
2. Never enter your details after clicking on a link in an email or text message.
3. Always send confidential information by encrypted email where possible this reduces the risk of interception.
4. If you’re logged into any online service do not leave your computer unattended.
5. Close down your internet browser once you’ve logged off.
6. Never download software or let anyone log on to your computer or devices remotely, during or after a cold call.

Secure Online Services

You can easily identify secure websites by looking at the address at the top of your browser which will begin https:// rather than http://.

10.     Your rights

You have certain rights in relation to the processing of your personal data, including to:

• Request access to your personal data (commonly known as a “Subject Access Request”). This enables you to receive a copy of the personal data we hold about you.
• Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground. If you object to us using your personal data for marketing purposes we will stop sending you marketing material.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example, if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party (data portability).
• Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we are permitted by law to do so.

How to exercise your rights

You will not usually need 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. If you wish to exercise your rights, please contact us at marketing@sambro.co.uk.

11.     How to complain

You have the right to lodge a complaint with the supervisory authority, if you believe we are infringing the UK data protection laws or you are concerned about the way in which we are handling your personal data. The supervisory authority in the UK is the Information Commissioner’s Office which can be contacted online at:

• Contact us | ICO
• Or by telephone on 0303 123 1113

12.     How to contact us

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, then please address your correspondence to:

Sambro International Limited, Hardys Gate, Dumers Lane, Bury, Lancashire, BL9 9UE.

13.   Changes to this Policy

This policy was published on 01.09.2023.