Privacy Policy

www.sosander.com (“our website”) is owned by Sosandar Plc  (collectively referred to as “the Company”we”, “us” or "our” in this privacy notice).

We take user privacy seriously and take reasonable efforts to protect it. We have created this Privacy Policy (hereafter “Policy”) in order to share with you our information collection and use practices. AS MORE CLEARLY DEFINED HEREIN, WE WILL NEVER KNOWINGLY SELL OR ASSIGN YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE AND/OR APPROVAL.

This 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 read this Policy carefully before sharing any personally identifiable information described below.

IMPORTANT INFORMATION AND WHO WE ARE

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. This Policy supplements the other notices and is not intended to override them.

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.

Controller

The data controller is Sosandar Plc (a company registered in England and Wales (company number: 05379931) with its registered address at 40 Water Lane, Wilmslow, Cheshire, England, SK9 5AP), who is responsible for your personal data.

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the data controller by emailing customerservice@sosandar.com

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.

Changes to the Policy and your duty to inform us of changes

This Policy was last updated, and became effective, on 24/05/2018.

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.

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 offences.

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 Abacus.

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.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you (or direct marketing from us if you are not an existing customer) via email or text message. You have the right to withdraw consent to marketing at any time by contacting us by email at customerservice@sosandar.com.

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 customerservice@sosandar.com 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/ ActivityType of dataLawful 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 record and monitor incoming calls

(a)  Identity

(b)  Contact

 

Necessary for our legitimate interests (to maintain customer service standards and to assist staff training)


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 on 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. 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) as we believe it is in your legitimate interests to send these emails to you. Alternatively, 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 either using the My Account section of the website, emailing customerservice@sosandar.com or calling us on 0333 305 2866 or clicking the unsubscribe link in the email.

Marketing by Mail

We would also like to contact you by post to let you know of our new collections and any offers we may be running. This will usually be the form of our latest catalogue. If you're an existing Sosandar customer we will send you our brochure as we believe it is in you legitimate interests to receive these. 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, emailing customerservice@sosandar.com or calling us on 0333 305 2866. When we unsubscribe you, you may still continue to receive mailings for up to 28 days.

Marketing by other companies

We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.


If you have opted in to receive third party mailings, we may share your personal data with carefully selected retail companies and charities who we feel may be of interest to you. If data is shared it is done so on a one time only basis and the company or organisation are not entitled to store your data for further use unless you engage with them. If you wish to check your preferences or opt out of third party mailings, you can do so at any time either using the My Account section of the website, emailing customerservice@sosandar.com or calling us on 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, fulfil and deliver orders, process credit card payments and provide support services on our behalf.

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 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 EEA, we ensure a similar degree of protection is afforded to it (as would be the case in countries within the EEA) by ensuring at least one of the following safeguards is implemented:

Please contact us by email at customerservice@sosandar.com or call us on 0333 305 2866 if you want further information on the specific mechanism used by us when transferring your personal data out of the 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.

The following is a summary of the types of cookies that are being used on our website, along with information on how you can block them.

Most web browsers allow some control of most cookies through the browser settings. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

The Company does not use Cookies to store information such as credit card numbers, telephone numbers, or other information you provide.

This Policy only covers the use of Cookies by Sosandar. It does not cover the use of Cookies by any third parties or advertisers.

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. Each of these websites may have a privacy policy that differs from that of the Company. 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 urge 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. The Company will not release this information to other parties unless you request it.

The Company provides banner and other advertising on its 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:

          1. Request access to your personal data.
          2. Request correction of your personal data.
          3. Request erasure of your personal data.
          4. Object to processing of your personal data.
          5. Request restriction of processing your personal data.
          6. Request transfer of your personal data.
          7. 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 customerservice@sosandar.com..

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 fulfil 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: see Request erasure section below for further information.

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 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.

Where can I access this policy?

This Policy is accessible from the Home Page of the Company web site, under the link “Privacy Policy".

Spy ware

The Company never uses or installs spy ware on user computers, nor do we use spy ware to retrieve information from user computers.

Contact

All comments, queries and requests relating to our use of your information are welcomed and should be addressed to customerservice@sosandar.com.

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 customerservice@sosandar.com

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.

Comply 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 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.