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Privacy Policy
This notice applies to all users of www.sosandar.com (“our website”) owned by Sosandar Plc 40 Water Lane, Wilmslow, Cheshire, England, SK9 5AP, (collectively referred to as “the Company” “we”, “us” or "our” in this Privacy Policy)
We are the Data Controller for the personal information you provide during your interactions with us. We take your privacy seriously and ensure your information is processed in accordance with the data protection regulations in the United Kingdom, the Data Protection Act 2018 and UK GDPR (“the regulations”).
This Privacy Policy (hereafter “Policy”) describes how we collect, process and store your personal data.
WE WILL NEVER KNOWINGLY SELL OR SHARE YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE AND/OR APPROVAL.
If you have any questions about this Policy please contact us on [email protected]
Purpose of this Policy
This Policy aims to give you information on how the Company collects and processes your personal data through your use of our website, including any data you may provide through our website when you sign up to our newsletter, purchase a product or take part in a competition.
It is important that you read this Policy together with the Website Terms and Conditions of Use and with any other Policy or fair processing notice 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.
What is the minimum age to use our website?
Our website is not intended for children (under 18 years old) and we do not knowingly collect data relating to children.
If proof comes to the attention of the Company that an individual user is under the age of 18 years, and is accessing our website and/or products without the consent, approval or authorisation of their parents or legal guardian, the Company will immediately terminate such user’s account.
What personally identifiable information does the Company collect and how is it used?
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).
When you visit, register or order products via our website you may be asked to provide certain personal data.
The different kinds of personal data that you may be asked to provide, which we have grouped together, include the following:
- Identity Data includes first name, maiden name, last name, username or similar identifier, password, order number, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Financial Data includes financial and payment data (held in encrypted / tokenised format only as the full data is held by our third-party payment providers).
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
- Profile Data includes your username and password, date of birth, age, location, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 offenses.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 Policy.
If you fail to provide personal data
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, we may not be able to provide the products that you have ordered from us). In this case, we may have to cancel an order for a product that you have made with us (and our standard cancellation terms will apply)but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make an order for products from our website;
- create an account on our website;
- make an enquiry by telephone, email or by completing the “contact us” form on our website;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the section on cookies below
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers such as Google;
- Contact, Financial and Transaction Data from providers of technical, payment, and delivery services such as Elavon Merchant Service, Sagepay, Stripe.
- Identity and Contact Data from data brokers or aggregators such as Experian.
- Identity, Contact, Technical and Profile Data from advertising and marketing companies such as Epsilon International UK Limited (trading as Epsilon Abacus) and Conexance (trading as i-Behaviour).
How 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 we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
- Where you have given your consent to process your personal data for marketing purposes by email, text, or post. You can withdraw your consent at any time
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
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 by email at [email protected] 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 register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process and deliver your order including: (a) To track (and allow you to) track your order; (b) Manage payments, fees and charges (c) Collect and recover money owed to us |
(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 (to recover debts due to us) (c) Necessary for your legitimate interests (to allow you to track your order) |
|
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 |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (d) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw or competition or special offer |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c) Data subject’s consent |
|
To ask you to complete a survey or provide feedback on our products or services |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(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 |
(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 products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (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) |
|
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 |
(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Data subject’s consent (where you are not an existing customer) |
|
To share your personal data with selected third parties, so that they can make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact
|
Necessary for your legitimate interests (to provide you with information about goods / services you may be interested in) |
|
To record and monitor incoming calls |
(a) Identity (b) Contact
|
Necessary for our legitimate interests (to maintain customer service standards and to assist staff training) |
Klarna
If you consent to use Klarna’s payment options, we will pass to Klarna your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.
Klarna will be the Data Controller for the personal information sent for the purpose of using Klarna’s payment options. General information on Klarna can be found here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.
Direct Marketing / Communications preferences
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing). We do this to ensure you always get a great service fully tailored to your preferences, but if you would prefer we do not use these kinds of profiling techniques you can opt out here or by using the unsubscribe option on any of our marketing messages. If you opt out, you may find your communications from us become less relevant to you
Email Marketing
The Company regularly sends out a Newsletter via email (hereinafter "Newsletter") to all existing customers (unless they have ‘opted-out’ of receiving such communications. If you are not an existing customer, you can sign up to receive our Newsletters by opting in at Sosandar.com. In these Newsletters, we may inform you about new features from Sosandar and about the upcoming week’s events or special promotions.
You may choose to unsubscribe from the Newsletter at any time by pressing the unsubscribe link in the footer of our emails.
Marketing by Mail
We also contact you by post to let you know of our new collections and any offers we may be running. This will usually be in the form of our latest brochure. If you're an existing Sosandar customer we will send you our brochure (unless they have ‘opted-out’ of receiving such communications). If you are not an existing customer, you may also sign up to receive a brochure at https://www.sosandar.com/brochure/signup/.
If at any time you wish to no longer receive any mailings from us, you can unsubscribe at any time either using the My Account section of the website, or if you don't have an account with us, you can easily unsubscribe by completing our unsubscribe form. When we unsubscribe you, you may still continue to receive mailings for up to 28 days while we process your request.
Postal marketing by other companies
We may share your personal data with carefully selected retail companies and charities who we feel may be of interest to you so that they can send you a copy of their brochure or other marketing by post. If you wish to opt out of third-party mailings, you can do so at any time either using the My Account section of the website, emailing [email protected], or calling us at 0333 305 2866.
Opting-out
If you unsubscribe or opt out of communications from us, we are not responsible for removing personal data from the lists of any third-party partner or advertiser who has previously been provided your information in accordance with this Policy and with your consent.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product/service experience, or other transactions.
Disclosure of your personal data
The personal data you provide to us may be accessed by or given to third parties who act for us for the purposes set out in this Policy or for other purposes approved by you. Those parties process information, fulfill and deliver orders, process credit card payments, and provide support services on our behalf.
In order to identify new customers for our business, we are a member of a number of co-operatives of retail brands in the UK. For this purpose, we work with Epsilon International UK Ltd (trading as Epsilon Abacus) and Conexance (trading as i-Behaviour), both of which are companies that allow retailers and charities who are members of the cooperative to pool and share certain information relating to their customers. The member retailers are active in the clothing, collectibles, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors and travel categories.
We share certain information with Abacus / i-Behavior relating to what our customers buy (including Identity, Contact, and Transactional Data). Epsilon Abacus / i-Behaviour use this information in order to build a profile of our customers and combines this with the information that they have received from other member retailers in order to identify suitable prospects to receive an introduction from us via the post. Abacus / i-Behavior may share some personal data belonging to our customers (limited to name and postal address) with other retailers who are members of the cooperative, where they have identified that the relevant customer may be interested in receiving an introduction to the other member retailers by post.
If you would rather your information was not included in this processing you can opt-out at any time using My Account section of the website, emailing [email protected], or calling us at 0333 305 2866.
In addition to the above, we may also share your personal data with the following third parties in the following circumstances:
- with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
- to enforce or apply our terms and conditions or to investigate potential breaches; and/or
- to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent or as otherwise set out in this Policy.
International Transfers
Many of our external third parties are based outside the UK or European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it (as would be the case in countries within the UK or EEA) by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or Information Commissioner in the UK. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en;
- where we use certain service providers, we may use specific contracts approved by the European Commission or Information Commissioner in the UK which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; or
- where we use providers based in the US, we may transfer data to them In these circumstances, we have appropriate contractual and technical safeguards in place to ensure your information is protected in accordance with the data protection regulations.
Please contact us by email at [email protected] or call us at 0333 305 2866 if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
Does the Company use cookies?
Cookies are small text files that a website can write to your computer. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use cookies to identify you and allow you to log in once to our website and search or post without having to log in again and again. Cookies are also used by our affiliates or links to identify you as a user of our website.
For information on which cookies we use on our website please see our Cookie Policy.
Is my information protected on third-party websites?
Our website may contain links to various third-party websites, plug-ins, and applications, and the external websites of our advertisers and/or third-party partners. This Policy does not cover the privacy policies of other websites nor do we control these third-party websites and are not responsible for their privacy policies. We recommend you to check the privacy policies of each website that you may visit or interact with.
The only personal data that may be shared between Sosandar and one of our partner websites is that which pertains to information used in the furtherance of tracking an order and providing you with correct information regarding same.
Order information, including order numbers and amounts, may be available to Sosandar, affiliate merchants, and third-party affiliate program management companies, for accurate tracking purposes. We will not release this information to other parties unless you request it.
We display banners and other advertising on our website, from Google and other third parties, that may place and read cookies on your browser, or use web beacons to collect information in the course of advertisements being served. If you are concerned about your privacy regarding these advertisements, please refer to Google’s (or other third party) privacy policies.
What about data security?
We employ security measures to protect, so far as reasonably possible, your personal data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or as long as the law requires or permits.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.
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.
Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request the erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
May I see the information the Company collects about me?
You are entitled to see the personal information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us at [email protected].
You will not have to pay a fee to access your personal data (or to exercise any of the other rights set out above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
We will try to respond to all legitimate requests within one month. Occasionally it may 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.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for 6 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data, please contact us at [email protected] if you would like your data deleted.
In some circumstances, we may anonymise your personal data (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.
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 update this Privacy Policy accordingly.
Please note that we may process your personal data without your knowledge or consent in rare circumstances and only where this is required or permitted by law.
Where can I access this policy?
This Policy is accessible from the Home Page of the Company website, under the link “Privacy Policy".
Spyware
The Company never uses or installs spyware on user computers, nor do we use spyware to retrieve information from user computers.
How to complain
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 deal with your concerns before you approach the ICO so please contact us in the first instance on [email protected].
Changes to the Policy and your duty to inform us of changes
This Policy was last updated, and became effective, on 14/03/2023.
We may make changes to this Policy from time to time to time. We will post a copy of the updated Policy on our website prior to any change becoming effective and we urge you to check this Policy frequently in order to determine whether any changes have been made. If we make any material changes we will also notify you of such change by email in advance. Your continued use of our website, including your registering or placing an order on our website, following any changes to the Policy (which will be notified to you as described above) signifies your acceptance of those changes.
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
Glossary
LAWFUL BASIS
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 by email at [email protected]
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.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
