Sambia Limited Privacy Policy

This privacy policy was last changed 13.06.2018

1. Who We Are
We are Sambia Limited and respect your privacy. This policy describes how we use your personal information.

Sambia Limited, company registered in Gibraltar No 99769, Level 3, Leisure Island Business centre, Ocean Village, Gibraltar (“we”) respect your privacy and values the trust you place in us when you share your personal information with us. This policy sets out how we, as data controller, collect and use your personal information, why we use it, with whom we share it, the rights to which you may be entitled and your choices about our use of your personal information.

This policy covers our use of your personal information arising from use of this website as well as registering / subscribing / buying / using our products and services.

If you have any questions or need any further clarity please get in touch. Contact details are set out below.

2. Your Information
Data collection and usage

We will collect and use your personal information [to allow access to this website, register / subscribe / buy / use our products and services] and purposes set out in more detail in this section.

Your information may be shared with members of our group and some third parties.

Please click here for further details on how we use your information and with whom we may share it.

What we collect and How we use it:

1. information that you give us to make a purchase, whether online or over the phone including:
• your contact details including: your name, address, email address;
• your bank account details;
• the details you provide to make a reservation or booking;
• [the details you provide to open an [online] account with us];
• the product purchased.

We use this information, including to :
• Provide our products and services;
• Manage and administer our services;
• Process your order;
• Take payment from or give you a refund;
• Help us ensure that our customers are genuine and to prevent fraud;
• Provide a reservation or booking service;
• Send personalised offers.
1. Information about the way you use our services including:
• The things that we’ve provided or you’ve purchased;
• When and where you’ve made the purchases;
• What you paid and how;
• Whether you’ve opened electronic communications from us;
• Whether you’ve clicked on links in electronic communications from us.

We use this information, including to:
• Develop new services;
• Improve our services;
• Identify products and marketing that may be of interest to you;
• Personalise our service of things you’re interested in and how you use our services;
• Statistical analysis and research.

iii. Information when you communicate with us whether in person, through our website or via email, over the phone, through social media or via any other medium, including:
• Your contact details (this may include your social media account if that’s the way you communicate with us);
• The details of your communications with us;
• The details you provide to us when you complete a survey;
• The details of our messages to you.

We use this information, including to:
• Answer any issues or concerns;
• Monitor customer communications for quality and training purposes.
• Develop new services;
• Improve our services;
• Personalise our service.
1. Information provided as part of your account including :
• Your username;
• Your password;
• Your account settings;
• Your account preferences;
• Your email address.

We use this information, including to:
• Provide our services;
• Manage and administer our systems;
• Identify how you’d like to use your account.
1. Information that we collect through your use of our website including:
• Device information such as operating system, unique device identifiers, the mobile network system;
• Hardware and browser settings;
• Date and time of requests;
• The requests you make;
• The pages you visit and search engine terms you use;
• IP address.

We use this information, including to:
• Provide our services;
• Develop new services;
• Improve our services;
• Identify issues with the website and user’s experience of it;
• Monitor the way our website is used.
1. Information that we collect from third party partners and corporate customers which could include:
• Payment processing companies;
• Your bank;
• Other entities in our group;
• Other members of a loyalty scheme;
• Administrators of prize draws and competitions.
We use this information, including to:
• Provide our services;
• Manage and administer our systems;
• Take payment from or give you a refund;
• Help us ensure that our customers are genuine and to prevent fraud;
• Personalise our service;
• Statistical analysis and research into our clients;
• Combine this information with other types of information mentioned above.

vii. Information that we collect incidentally from other sources or public sources, including:
• Information available in the media;
• Information presented on our social media timelines;
• Information collected by security systems.

We use this information, including to:
• Maintain market awareness;
• Build and maintain social media branding;
• Provide security to our sites.

viii. Information that we collect from individuals representing organisations, including:
• Contact details of individuals working for organisations;
• Other personal information regarding such individuals.
We use this information, including to:
• Build relationships with other organisations.
Why we collect and how long we keep your information.

We collect and use your information for a variety of reasons. we need some information to enter into and perform our contract – for example your contact and payment details.

Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our customers’ identities.

Some information is processed because you’ve given your consent to that, which can be withdrawn in your account preferences and settings.

Other information we collect because we have legitimate business interests, for example, in:
• Understanding how our customers use our products, services and websites;
• Understanding and responding to customer feedback;
• Researching and analysing the services our customers want;
• Improving our services;
• Receiving information from other entities in our group/[other members of our loyalty scheme] about shared customers;
• Understanding the type of products and services our customers buy and how they use them;
• Personalise our offers so we’re better able to provide offers and ideas that are relevant to you;
• Maintaining a public profile on both traditional and social media;
• Providing security over our business and who we trade with; or
• Developing and maintaining relationships with vendors, partners and other companies and dealing with individuals who work for them [in our sector].
We will keep your information for as long as it is reasonably necessary. It will depend on factors such as whether you have any outstanding purchases or an account with us or have interacted with recent offers. We will also routinely refresh our information to ensure we keep it up-to-date.

Other Uses

Automated Decision Making

We may make automated decisions on certain matters. For example, we may do this to decide whether [we can provide our services to you based on a credit check. this will be informed by credit scoring where we share your information with credit reference agencies, screening on [databases] and confirmation of your information (including by third parties). Depending on the outcome of the credit check, a decision will be reached automatically as to whether we are able to provide products or services to you based on your credit worthiness.

submitting to a credit reference check is necessary for us to offer you a product or service / necessary under applicable law. If this information is not provided we cannot agree to provide a product or service for you.

If you disagree with the decision you are entitled to contest this by contacting us on paul.borge@oceanvillage.gi

Legal Requirements

Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claims. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

Special Information We Collect

Certain types of personal information are more sensitive than others. This “special information” about you includes information about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometrics or religion.

We may collect and receive special information about you. We have identified below the types of special information we may collect or receive, how we will use it and why we will use it.

Information that you give us or that we receive when using our services:
• Specifying certain dietary requirements that imply specific religious beliefs or medical condition.
We use this information to:
• Provide our services.
Why we collect and how long we keep your information

This information may be collected and used when it has been made publicly available.

When you provide us with this information you are consenting that we may collect and use it in the way we’ve set out.

We will keep your information for as long as it is reasonably necessary. it will depend on factors such as whether you’ve any outstanding purchases or an account with us or have interacted with recent offers. we will also routinely refresh our information to ensure we keep it up-to-date

Information we share

There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.
• We may share information about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep your information in accordance with this privacy policy.
• We may also share your information with certain contractors or service providers. they may process your personal data for us, for example, if we use a marketing agency. [other recipients/service providers include advertising agencies, it specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centres.]
Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function.
• We may also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include credit reference agencies, anti-fraud databases, screening agencies and other partners we do business with [such as other loyalty scheme members]. If we are not able to share information with certain third party partners who are also in our loyalty scheme, we will not be able to offer that service].
Your personal information may be transferred to other third party organisations in certain scenarios:
• If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
• If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
• If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the police;
• If we are defending a legal claim your information may be transferred as required in connection with defending such claim.
Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

3 Your Rights

You may have certain rights in relation to your information including a right to access or to correct the information we hold on you.

Other rights may be available in certain circumstances. please click here to see more detail about the rights that may available and how you can get in touch with us.

Data Subject Rights

We’ve listed the rights you have over your information and how you can use them below.

These rights will only apply in certain circumstances. They will generally not be available if there are outstanding contracts between us, if we required by law to keep the information or if the information is relevant to a legal dispute.
• You can remove consent, where you have provided it, at any time.
• You can ask us to confirm if we are processing your information.
• You can ask for access to your information.
• You can ask to correct your information if it’s wrong.
• You can ask us to delete your information.
• You have a right to be forgotten and you can ask that our systems stop using your information.
• You can ask us to restrict how we use your information.
• You can ask us to help you move your information to other companies.
• To help with that, you have a right to ask that we provide your information in an easily readable format to another company.
• You can ask us to stop using your personal information, but only in certain cases.
• You have the right to complain to the relevant supervisory authority.

How to contact us

If you have any questions about this policy please contact our data protection officer: paul.borge@oceanvillage.gi or 00350 200 400 48, or office 3.02, World Trade Center, Bayside Road, Gibraltar, GX11 1AA.

Changes to the Policy

This policy will be changed from time to time.

If you would like to access previous versions of this policy please email the data protection officer on paul.borge@oceanvillage.gi

Other Policies

Cookies

We use cookies that identify your browser or device. they collect and store information when you visit our website [or app] about how you use it.

For more information about cookies, the types of cookies we use and how we use them please see our: cookie policy.

Security

We are committed to keeping your personal information safe. We have physical, technical and administrative measures in place to prevent unauthorised access or use of your information.

Sambia Limited Privacy Policy

This privacy policy was last changed 13.06.2018