This policy comes in to force on 13th December 2020
We are committed to protecting and respecting your privacy.
Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
For the purpose of UK data protection laws, the data controller is Samba Tech Limited of 182a High Street, Beckenham, Kent, BR3 1EW. United Kingdom.
Data Protection Principles
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:
- processed lawfully, fairly and in a transparent manner,
- processed for specified, explicit and legitimate purposes,
- adequate, relevant and limited to what is necessary,
- accurate and kept up-to-date,
- kept for no longer than is necessary, and
- processed in a manner that ensures appropriate security.
What information do we collect?
We may collect, use, store and transfer different kinds of personal information about you, including:
- Identity Data, such as your name, title and date of birth,
- Account Identity Data, such as your email address and your password,
- Contact Data, such as your billing address, delivery address, email address and telephone numbers,
- Financial Data, such as bank account and payment card details,
- Transaction Data, including details about payments to and from you, and other details of products you purchase from us,
- Technical Data, including IP addresses, your log-in 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 our website,
- Profile Data, including purchases or orders made by you, feedback and survey responses,
- Usage Data, including information about how you use our website, products and services, and
- Marketing Data, such as your preferences in receiving marketing from us and our third parties, and your communication preferences.
'Special Category' Data
Information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sex life or sexual orientation, or certain types of genetic or biometric data is known as 'special category' data.
During the course of dealing with you, we do not expect to collect any 'special category' data about you.
How We Collect Your Personal Information
We may obtain personal information by directly interacting with you, such as:
- placing orders for products via our website,
- creating an account on our website,
- participating in discussion boards or other social media functions on our website,
- browsing our website while logged into your www.dvdbinders.co.uk My Account,
- entering a competition, promotion or survey organised by us, or otherwise providing us with feedback,
- subscribing to our publications, or otherwise requesting marketing material to be sent to you, or
- corresponding with us by phone, email, letters or otherwise.
We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies.
We may also collect personal information about you from third parties or publicly-available sources, such as:
- analytics providers (such as Google),
- credit reference and fraud prevention agencies,
- providers of technical, payment and delivery services,
How do we use your information?
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- you have given us consent,
- we need to perform a contract we are about to enter into, or have entered into, with you,
- where it is necessary for our or a third party's legitimate interests, and your interests and rights do not override those interests, or
- where we need to comply with a legal or regulatory obligation.
We do not use 'special category' information.
Purposes for which we will use your Personal Information
We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the 'legal basis' that allows us to use your information, as follows:
Purposes for which we will use the information you give to us
To register you as a new customer
It will be necessary for the performance of the contract between you and us
To process your order and, if accepted, to deliver the products to you (including managing payments, fees and charges)
It will be necessary for the performance of the contract between you and us
To manage your queries or complaints
It will be necessary for the performance of the contract between you and us
To collect and recover money owed to us
It will be necessary for our legitimate business interests, namely to ensure we receive payment for products and services that you have ordered from us
It will be necessary for our legitimate business interests, namely to ensure you are aware of our current terms and conditions
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them
To enable you to participate in a prize draw, competition or complete a survey
It will be necessary for our legitimate business interests, namely to study how customers use our products, to develop them and help grow our business
To create customer profile types that are used to help identify new customers from other sources. These profiles DO NOT contain personal data.
This will be done after you give your consent for us to do.
Your consent can be withdrawn by changing your preferences using the My Account functionality on our website.
To provide you with information about special offers and other products we sell that are similar to those that you have already received from us (which may include some 'profiling' to ensure you only receive information that we believe is relevant to you)
Where you have previously received marketing communications from us, then it will be necessary for our legitimate business interests, namely to ensure you continue to receive communications that you have previously agreed to receive.
In all other cases, we will only do this if you give us your consent
To prevent customers from trading with Samba Tech Limited who have been abusive or who have abused or misused the products and/or services that we supply.
It will be necessary for our legitimate business interests, namely to prevent the misuse of our products or services
To prevent customers from trading with Samba Tech Limited who have been fraudulent and to pass their details on the relevant legal/regulatory organisation.
It will be necessary in the public interest to help prevent fraudulent or dishonest behaviour.
To notify you when you have products in your basket that have not been through the ordering process
It will be necessary for our legitimate business interests, namely to ensure we provide the quality of service you expect from us
(Where goods and/or services are being provided to Samba Tech Limited).
To have a contractual relation with you to supply goods and/or service.
It will be necessary for our legitimate business interests, in order to fulfil our contractual obligations.
To contact you to undertake customer satisfaction surveys, invite you to provide product reviews or for market research.
It will be necessary for our legitimate business interests, namely to develop products, services, applications and designs that attract and retain customers, improving customer interaction with our sites.
We will only use your personal information for the purpose(s) 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
What if you cannot or will not provide Us with your Personal Information?
It is a contractual requirement for you to provide us with certain information, namely your name, delivery address, phone number and email address. During the ordering process you will be required to provide payment information to our chosen payment service provider. We do not hold any of your bank or credit/payment card details. If you do not provide us or payment service provider with that information, we may be unable to accept and process your order and deliver the products to you, and/or we may have to cancel your order. You may also be liable to pay additional costs, as explained in paragraph 8.18 of our terms of sale.
How do we protect visitor information?
We implement a variety of security measures to maintain the safety of your personal information. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. When you place orders or access your personal information, we offer the use of a secure server. All sensitive/credit information you supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases to be only accessed as stated above.
Do we use "cookies"?
Our website uses encrypted cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
Strictly necessary cookies.
These are cookies that are required for the operation of our website. These include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of billing services.
Analytical / performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to identify issues with our site and improve the way our website works.
These are used to recognise you when you return to our website. This enables us to personalise our content to you, greet you by name and remember your preferences (for example, your choice of language or region).
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Disclosure of your Information
We may share your personal data with trusted third parties. For example, to delivery your orders, to handle complaints, for fraud management, to help us personalise our offers to you and so on.
This is the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- We require all third parties to respect the security of your personal information and to treat it in accordance with the law.
- We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Third parties we work with are:
Delivery of your orders, including proof of delivery and tracking information. Depending on the service chosen this will be one of Hermes, DPD, Royal Mail, Parcel Force or through a parcel delivery broker such as Parcel Monkey or Parcels2Go.
Behavioural analysis that allows us to personalise your experience and the information we provide to you. We use Google Analytics.
How we manage our electronic communication with you. This is done through either 123-reg and Bluepark.
Fraud Services and
We may use a combination of Experian, DWP, Citizens Advice Bureau and the Police when fulfilling our 'public interest' and legal responsibilities to prevent fraud and dishonest behaviour. We may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We primarily use Bluepark to host and support our website and other business systems
When necessary we will enlist solicitors for resolution of legal matters.
Addressing of printed material will be delivered by either My Hermes or the Royal Mail.
During the payment process you will be directed to options to complete your payment through Sage Pay or PayPal depending on your preference.
Market Research Services
Should you wish to comment on our products or service you will be able to do so via our in-built product review functionality.
So we can show you products that might interest you while you are browsing the internet, we use the services of Google, Facebook, and Twitter.
We may be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
When appropriate your personal information may be shared with HM Revenue & Customs, the UK Information Commissioner's Office, regulators and other authorities who require reporting of processing activities in certain circumstances.
We do not have any affiliate partners.
Where we store your Personal Information?
Our store is hosted on Bluepark Solutions Ltd (www.bluepark.co.uk). They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Bluepark's data storage, databases and the general Bluepark application. They store your data on a secure server behind a firewall in the United Kingdom.
If you choose a credit card payment, we use Sage Pay (www.sagepay.com) as our direct payment gateway to complete your purchase. Sage Pay is an e-commerce service provider that authorizes and facilitates the secure transfer of payment information between the merchant's site and the acquiring bank. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. In addition, we also provide the option to complete your payment through PayPal (www.paypal.com).
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
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 we will store your Personal Information?
The length of time that we will store your data will depend on the 'legal basis' for why we are using that data, as follows:
Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us
We will use/store your data for as long as it is necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject
We will use/store your data for as long as it is necessary for us to comply with our legal obligations
Where we use/store your data because it is in the public interest
We will use/store your data for as long as it remains a matter of public interest for us to do so. The law sets out what matters are considered to be in the public interest, and we will use/store your data in accordance with those requirements
Where we use/store your data because it is necessary for our legitimate business interests
We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data)
Where we use/store your data because you have given us your specific, informed and unambiguous consent
We will use/store your data until you ask us to stop
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive 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 requirements.
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
- You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
- You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
- You have the right to ask us to erase the information we hold about you (the 'right to be forgotten'). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
- You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
- You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
- Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
- Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
- You have the right to object to us using/storing your information for direct marketing purposes.
If you wish to exercise any of your legal rights, please contact our customer services team by writing to the address at the top of this policy, or by emailing us at firstname.lastname@example.org.
You also have the right, at any time, to lodge a complaint with the UK Information Commissioner's Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.
Opting out of Marketing communications, removing or modify information you have provided to us
To modify your e-mail subscriptions, please let us know by modifying your preferences in the "My Account" section. Please note that due to email production schedules you may receive any emails already in production.
To delete all of your online account information from our database, sign into the "My Account" section of our site and remove your shipping addresses, billing addresses & payment information. Please note that we may maintain information about an individual sales transaction in order to service that transaction and for record keeping.
We may undertake 'profiling' to ensure you only receive information that we believe is relevant to you (for example, where we had a special offer that was relevant only to young adults under the age of 25, we would profile those of our customers to whom we can legitimately send marketing emails to ensure that the marketing email is sent only to appropriate recipients).
Otherwise, we do not make any decisions that produce legal effects concerning you, or which would otherwise significantly affect you, by means of an automated decision-making process.
Third party links
Our 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 notice of every website you visit.
Changes to our policy
This policy was last modified on Dec 13, 2020.
Questions and feedback
Questions, comments and requests regarding this policy are welcomed and should be addressed to our customer services team by writing to the address at the top of this policy, or by emailing us at email@example.com
Terms and Conditions
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website.