Privacy and Cookie Policy

Background

Samurai Incentives and Promotions Ltd (“Samurai”) understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.samuraiproducts.com (the “Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of the Site. If you do not accept and agree with this Privacy Policy, you must stop using the Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Cookie” means a small text file placed on your computer or device by the Site when you visit certain parts of the Site and/or when you use certain features of the Site.

Details of the Cookies used by the Site are set out in section 13, below;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via the Site This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and “We/Us/Our” means Samurai Incentives and Promotions, a limited company registered in England under company number 05088365, whose registered address is Unit 81, Centaur Court, Claydon Business Park, Gr. Blackenham, Ipswich, IP6.

2. Information About Us

2.1 The Site is owned and operated by Samurai Incentives and Promotions, a limited company registered in England under company number 05088365, whose registered address is Unit 81, Centaur Court, Claydon Business Park, Gr. Blackenham, Ipswich, IP6 0NL.

2.2 Our Data Protection Officer is Anthony Bull, and can be contacted by email at enquiries@samuraiproducts.com.

3. What Does This Policy Cover?
   

This Privacy Policy applies only to your use of the Site. The Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this policy and our use of personal data have been designed to uphold:

4.1.1 The right to be informed about our collection and use of personal data;

4.1.2 The right of access to the personal data we hold about you (see section 12);

4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);

4.1.4 The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Personal Information is data that can be used to identify or contact a single person.  When creating an account, we may collect a variety of information including your name, email address, mailing address, phone number, preferences, date of birth, usernames, and payment information.

We also collect non-personal information, which is data in a form that does not, on its own, allow direct association with any specific individual. Non-personal information may be collected, used, transferred, and disclosed for any purpose.

When using the Site and associated services, we may collect non-personal information such as IP addresses, browser type, operating system, search history, referral source, exit pages, browsing activity, dates and times of visit, other site usage data, geographical location, screen resolution, etc. This data may be compiled and analyzed on both an individual and aggregated basis.

How we use non-personal information:

• We may use non-personal information to better understand customer behavior, provide more useful information to our customers, understand which parts of the Site and associated services are most interesting, and improve our products, services, and advertising.
• We may use non-personal information to send targeted email marketing messages or display targeted advertising.

We may also use non-personal information to diagnose technical issues with our software and server, administer services, gather demographics, and improve the Site and associated services.

Depending upon your use of the Site, some information we may collect includes, but is not limited to, the following (please also see section 13 on our use of cookies and similar technologies):

5.1 Name;

5.2 Business/Company name

5.3 Contact information such as email addresses and telephone numbers;

5.4 Demographic information such as post code, preferences and interests;

5.5 Financial information such as credit / debit card numbers;

5.6 IP address;

5.7 Web browser type and version;

5.8 Operating system;

5.9 A list of URLs starting with a referring site, your activity on the Site, and the site you exit to.

 

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

6.2.1 Providing and managing your access to the Site;

6.2.2 Personalising and tailoring your experience on the Site;

6.2.3 Supplying our services to you (please note that we require your personal data in order to enter into a contract with you);

6.2.4 Personalising and tailoring our services for you;

6.2.5 Replying to emails from you;

6.2.6 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time);

6.2.7 Internal purposes including auditing, data analysis, and research to improve our product offering, service offering, and customer communications;

6.2.8 Analysing your use of the Site and gathering feedback to enable us to continually improve the Site and your user experience;

6.2.9 to provide support and respond to inquiries;

6.2.10 use personal information to keep you posted on Samurai’s latest product announcements, service announcements, promotions, or upcoming events;

6.2.11 to provide you with updates and notices regarding our Privacy Policy;

6.2.12 In any other way we may describe when you provide the information;

6.2.13 To comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and

6.2.14 To fulfil any other purpose for which you provide it or for any other purpose with your consent.

6.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

6.6 When using the Site and associated services, you as the user are responsible for the information that you disclose.  Please exercise discretion and caution when disclosing any information that may help another user locate or identify you.  You understand that by using the Site and associated services, any information that you post or provide is given freely and voluntarily.  Although we have reasonable security measures in place, we cannot and do not assure the confidentiality of any information that you disclose in connection with the Site and associated services.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using the Site and submitting information to us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through the Site.

8. Do We Share Your Data?

8.1 Subject to the provisions of this Privacy Policy, we will not share any of your data with any third parties for any purposes.

8.2 We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

8.3 We may compile statistics about the use of the Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under GDPR.

8.5 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.

9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

10. How Can You Control Your Data?

10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via the Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Your Right to Withhold Information

11.1 You may access certain areas of the Site without providing any data at all. However, to use all features and functions available on the Site you may be required to submit or allow for the collection of certain data.

11.2 You may restrict our use of Cookies.

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable, and we will provide any and all information in response to your request free of charge. Please contact us for more details at marketing@samuraiproducts.com, or using the contact details below in section 14.

13. Our Use of Cookies and Other Technologies

13.1 The Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of the Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.2 All Cookies used by and on the Site are used in accordance with current Cookie Law.

13.3 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Site may not function fully or as intended.

13.4 Certain features of the Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that the Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

13.5 The Site uses analytics services. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how the Site is used. This, in turn, enables us to improve the Site and the services offered through it. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of the Site, it does enable us to continually improve the Site, making it a better and more useful experience for you.

13.6 The analytics service(s) used by the Site use(s) Cookies to gather the required information.

13.7 In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

13.8 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access the Site more quickly and efficiently including, but not limited to, login and personalisation settings.

13.9 The use of Cookies by our partners, affiliates, or other service providers is not covered by our privacy policy but rather by their own privacy policy. We do not have access or control over these Cookies.

13.10 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

13.11 We may also use pixel tags, web beacons, clear gif technology, action tags or other similar tracking technology. These features allow us to monitor the use of the Site and associated services. Examples of information that may be collected include the IP address of the computer that downloaded the page, the browser type, information regarding any Cookies previously placed on the computer by that server. In addition, we may collect and aggregate the time spent on the  Site, viewer actions such as scrolling or clicking, and user action on the Site including page views. We may also use variants of this technology provided by a third party to collect information about your visit in conjunction with our Cookies to provide offers and information that may be of interest to you.

14. Social Media Features and Widgets

The Site may include social media features, widgets or integrations such as Facebook, Twitter, LinkedIn, Yahoo, Microsoft, Google, or other relevant social media platforms. These features and widgets will be clearly marked with relevant logo or phrasing (for example, the Facebook button or Facebook like button). If you choose to click one of these features or widgets, your browser may connect directly to their server to display the content. These features may collect your IP address, which page you are visiting, and may use cookies to enable features to work properly. These features and widgets may either be hosted on our servers or third-party servers. Your interactions with any third-party features or widgets are governed by the respective privacy policy of the company providing it.

15. Control of Personal Information

14.1 Registered users of the Site can modify or delete the personal information that they provided upon registration including their contact preferences. We may, from time to time, send you promotional emails regarding our product and service offerings that may be of interest to you. You may opt out from receiving promotional emails by clicking the “Unsubscribe” button at the bottom of any promotional email received.  Please note, that even if you opt out of promotional emails you may still receive messages pertaining to services offered including, but not limited to, communications related to fulfilling a transaction, service announcements, notices regarding Samurai’s Terms of Use, Privacy Policy, or administrative messages.

14.2 You may delete your account at any time through the Site. Please note that even after removing information from your profile or deleting your account, copies of the deleted information may remain viewable elsewhere to the extent that it has been shared with others or it was otherwise distributed pursuant to these terms. We will retain your personal information for as long as your account is active or as needed to provide you with requested services. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

16. California Privacy Rights

If you are a California resident, you have the right to request information regarding the manner in which we share certain categories of your personal information with third parties, for the third parties’ direct marketing purposes. You have the right to submit a request to us at the designated address and receive the following information:

• The categories of information we disclosed to third parties for the third parties direct marketing purposes during the preceding calendar year.
• The names and addresses of third parties that received such information, and if the nature of a third party’s business cannot be reasonably determined from the third party’s name, examples of the products or services marketed.

To request a copy of this information in a standardized format (note – the information will not be individually tailored to you), please send your request to us at enquiries@samuraiproducts.com.

17. Children’s Privacy

Samurai does not knowingly collect, use, or disclose personal information from children under the age of 13, except as permitted by the Children’s Online Privacy Protection Act (“COPPA”) any other relevant laws.  We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without verifiable parental permission. If we are made aware that we have collected personal information from a child under 13 years old in a manner that is inconsistent with COPPA, we will delete this information as soon as possible.

18. Confidentiality and Security of Personal Information

Samurai is committed to protecting your privacy and we treat your privacy very seriously. We limit access to personal information about our customers to our employees and agents on a need-to-know basis. Personal information is only provided to personnel who need to know the information to provide services requested. We follow generally accepted standards and best practices to protect the security of personal information submitted to us from unauthorized access including encryption, secure passwords, physical security, etc. These protections, however, are not a replacement for the security measures in your control. No method of electronic data transmission or electronic data storage is one hundred percent secure and we cannot guarantee the absolute security of your information. It is important that you protect against unauthorized access to your password and to your computer or mobile device.

19. Third Parties

This Privacy Policy solely governs the use and disclosure of information that Samurai collects from you and does not apply to the practices of any third party. Please be aware that when you click through to a third-party website or application or use a third-party feature or widget that our Privacy Policy no longer applies and any information you provide to them is subject to their privacy policy.

20. Contacting Us

If you have any questions about the Site or this Privacy Policy, please contact us by email at enquiries@samuraiproducts.com. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).

21. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on the Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of the Site following the alterations. We recommend that you check this page regularly to keep up-to-date.