PRIVACY NOTICE

• 1.1 We take your privacy very seriously. Please read this Privacy Notice carefully as it sets out who we are and how and why we collect, store, use and share any personal data we collect from you, or that you provide to us, and how such personal data will be processed by us or by our service providers. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator if you have a complaint.
• 1.2 References to:
  • 1.2.1 our “Services” means the products or the services that we make available to you via the Website, including, without limitation, sending you product samples from brands;
  • 1.2.2 our “Website” means our website available from productsamples.com; and
  • 1.2.3 ”you” or ”your” means the person accessing and using the Website and/or our Services.
• 1.3 In this Privacy Notice where we use the words “personal data” or “personal information” we use these words to describe information that is about you and that identifies you.

• 2.1 com is a division of SoPost Limited.
• 2.2 SoPost Limited is a company registered in England and Wales (company number 08216668) and our registered office is at The Core, Bath Lane, Newcastle upon Tyne, NE4 5TF, United Kingdom. Our U.S. entity is SoPost Inc., and is based at 110 Greene St, Suite 9C, New York, NY 10012 (collectively, “SoPost”, ”we”, ”our”, ”us”).
• 2.3 SoPost Limited is registered with the Information Commissioner’s Office under registration number Z343508X.
• 2.4 As Data Controller, we use and are responsible for certain personal data we collect from you through the Website and when using our Services. When we do so we are subject to the UK General Data Protection Regulation (“UK GDPR”) and any other applicable data protection legislation.

• 3.1 The personal data we collect about you depends on the particular activities carried out through our Website. We may collect, use and process the following information about you (please note, some of this is optional).
• 3.2 Personal information you give us – this is information about you that you give us by filling in forms on our Website or by corresponding with us by phone, email or otherwise. It includes information you provide when you request a sample through our Website.
• 3.3 When signing up to our Services we will ask for your name, date of birth, postal address and email address.
• 3.4 We will ask you to complete your ‘Beauty Profile’ which will involve the collection of:
  • General Profile: information about your household and employment;
  • Skin Profile: your skin type, skin tone and any concerns you may have (special category personal data);
  • Hair Profile: your hair type, hair colour, how it is coloured and any concerns you may have (some of this may be special category personal data);
  • Makeup Profile: the makeup looks you prefer and how often you wear makeup;
  • Fragrance Profile: the type of fragrances you like to wear and how often you wear them.;
  • Food & Drink Profile: your food and drink preference and purchase habits;
  • Health & Fitness Profile: information about your exercise habits and vitamin and supplement consumption (special category personal data);
  • Lifestyle Profile: your hobbies and views on certain product categories;
  • Household Profile: information about products that you use around your home;
  • Family Profile: your family set up and allergy concerns of your children (some of this may be special category personal data);
  • Pets Profile: information about your pets and what products you purchase to care for them;
  • Travel & Holidays Profile: the frequency and type of holidays that you take;
  • Media & Technology Profile: the media platforms which you use; and
  • 18+ Profile: information about your use of alcohol, tobacco and CBD products.
• 3.5 Your Beauty Profile is an essential part of the service that we deliver. We use it to select samples that we think you will like, based on the recommendations made by our brand partners (who never see your Beauty Profile themselves). We use this information to deliver products suitable to the responses that you have provided within your skin tone and other preferences.
• 3.6 Whenever you visit our Website we will automatically collect the following information:
  • Technical Information: including the Internet protocol (IP) address used to connect your computer or other device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Information about your visit: this includes the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), pages you have visited, page response times, download errors, length of visits to certain page and page interaction information (such as scrolling, clicks, and mouse-overs);
  • Information we receive from other sources: this is information we receive about you if you use any of the other websites we operate or the other services we provide. Additionally, if you interact with us via our social media pages, then you may provide us with your personal information. We collect this particular information for the purposes described in this Privacy Notice. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Website. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
• Special Categories of Personal Data
• 3.7 Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. We have referenced which data collected above may fall into this category and such data includes:
  • personal data revealing racial or ethnic origin; and
  • data concerning health and sex life.
• 3.8 Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws whether that is by asking for your specific consent or otherwise.

• 4.1 We collect and use the above personal data for the purposes described in this section. We will use your personal data to:
  • deliver any products to your nominated address;
  • provide any services requested by you;
  • to recognise you when you return to the Website;
  • to ensure that content from the Website is presented in the most effective manner for you and for your computer, mobile or tablet;
  • to provide you with information, products, services, promotions or advertisements that we feel may interest you, where you have consented to be contacted for such purposes;
  • to allow you to participate in interactive features of the Website and/or the Services, when you choose to do so;
  • to enable retailers and our brand partners to provide you and/or your recipient(s) or friend(s) with products and/or services;
  • to notify you about changes to the Website and/or the Services;
  • collect feedback from you on behalf of SoPost and our brand partners related to a product that we have delivered;
  • audit and monitor usage of the Website;
  • improve the Website and the Services;
  • manage complaints, feedback and respond to questions;
  • comply with any legal or regulatory obligations (including in connection with a court order);
  • verify your compliance with, our Terms of Use and Terms of Service; and
  • for our internal business operations.

• 5.1 under data protection law, we can only use your personal data if we have a proper reason, eg:
• 5.2 where you have given consent;
  • to comply with our legal and regulatory obligations;
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.
• 5.3 A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
• 5.4 The table below explains what we use your personal data for and why.

• 6.1 The information and content held on our Website is deployed geographically to maximise user experience. We will never share your user information with third parties for their promotional purposes without your consent.
• 6.2 We may work with our service providers, suppliers and sub-contractors who help us provide the Website and Services. For example, Google Cloud is our host provider and our production databases are stored in Google Cloud which is contracted by use for the provision of technical services. To know more about how we interact with Google Cloud you can view their privacy notice, amongst their other policies here.
• 6.3 We may share information with our shipping and other distributors and fulfilment service providers.
• 6.4 We use Postmark to send emails from our platform. In order to do this, we have to supply Postmark with your email address and a body for the email. If you want to know more about how we interact with Postmark you can view their privacy notice, amongst other policies here.
• 6.5 If you contact us for customer service then your message will be routed through Zendesk, which we use to help us manage our customer service queries. To do this, Zendesk will retain a copy of all communication between you and us. If you would like to know more about how we interact with Zendesk you can view their privacy policy here.
• 6.6 With your consent during the sign-up process or at other times, we will share your name and contact details with selected advertisers so they can send you newsletters, special offers and other information. You can unsubscribe from those mailings by clicking on the “unsubscribe” link at the bottom of the e-mail correspondence or by contacting the advertiser directly.
• 6.7 We reserve the right to disclose and/or transfer your personal information to external agencies and organisations (including police agencies and the relevant local authority) for the purpose of complying with applicable legal and regulatory obligations.
• 6.8 We may also disclose your information to 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 information in the same way as set out in this Privacy Notice.

• 7.1 The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
• 7.2 It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable laws designed to ensure the privacy of your personal data.
• 7.3 We may transfer your personal data to our service providers with data centres located outside the UK and the EEA. We may also transfer your personal data from the EEA to the UK.
• 7.4 Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
  • in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; or
  • in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR; or
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
  • a specific exception applies under relevant data protection law.
• 7.5 Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available), we will rely on other methods such as legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. If we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
• 7.6 Where we transfer your personal data outside the EEA, we do so on the basis of an adequacy decision or (where this is not available) we will rely on other methods such as legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. If we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
• 7.7 Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this Privacy Notice’ below.
• 7.8 If you would like further information about this section, please contact us (see ‘How to Contact Us’ below).

• 8.1 Our approach to information security is constantly evolving and continually reviewed. We implement a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure and transfer. This includes, by way of example, training and adequate procedures put in place for any staff that handle or have access to your personal information.
• 8.2 We have taken reasonable steps to help protect the personal information we collect. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website and any transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to try to prevent unauthorised access.

• 9.1 You generally have the following rights, which you can usually exercise free of charge:

• 9.1 We may contact you via email with updates about the Services that we offer or any changes that we have made to our Website, subject to your preferences. You can update your preferences and opt in or out at any time by clicking the ‘Unsubscribe’ link in our emails, by replying ‘Stop’ to our text messages or by updating your consent preferences in your account. Your option not to receive promotional and marketing material will not preclude us from corresponding with you, by email or otherwise, regarding your existing or past business relationships with us, and will not preclude us from accessing and viewing your personal information in the course of maintaining and improving our Website and our Services.
• 9.3 You may delete your profile and all personal data from the Website from within your account.
• 9.4 If you would also like to delete or access your personal data from the Website you can do so by visiting the SoPost Privacy portal.

• 14.1 Certain mechanisms may allow you to send web browser signals, known as “Do Not Track” (“DNT”) signals, indicating your choice to disable tracking on the Website. We do respond to certain browser do not track signals at this time. When we detect a DNT signal, we will not include the Google Analytics code and track beyond our own logging as described in the Cookie Policy. We may not be aware of or able to honour and respond to every such mechanism. More information about “Do Not Track” is available at allaboutdnt.orgconcerning such information.
• 14.2 Third parties, other than our service providers (such as our website analytics provider), do not have our permission to track which websites you visited prior to and after visiting the Website. That said, we cannot control third-party tracking and there may be some third-party tracking that occurs without our knowledge or consent.

• 17.1 We use cookies on our Website to allow us to provide a persistent state as you move from a page to another page. It is our commitment to you that no cookies that we set will ever contain any personal data. Cookies aid us in providing you with a secure and safe experience.
• 17.2 We only allow cookies over https and all information inside our cookies is encrypted.

• 19.1 You can choose to refuse or disable cookies that we send to you by configuring your browser to do so. Please consult the documentation for your browser for information on how to do this.
• 19.2 If you’re using our Website and disable some (or maybe all) of the cookies that we require, you may have difficulty using parts of our Website. We may rely on certain cookies to provide a complete user experience.

Google Analytics

• 20.1 We use Google Analytics on our Website to assess the performance and analytics of our content and traffic sources. For instance, where users come from, which pages are most popular, which sites provide most traffic, or how our marketing efforts impact the number of visits we receive.
• 20.2 No personal data is passed to Google Analytics. Instead, meta information (such as the pages you visited, type of device you’re using or which browser you’re using) is used to understand how people are using our Website.
• 20.3 To disable Google Analytics, you can decline the third-party cookie notice on our Website.
• 20.4 We respect “Do Not Track” and we will never use the Facebook Pixel if you have this setting enabled.

Facebook Pixel

• 20.5 We use the Facebook Pixel on our Website to measure the effectiveness of their advertising and to allow them to build audiences based on the actions people take on our Website. For instance, we can stop showing you Facebook adverts to signup to our Website if you’ve already completed the signup process. Or, our Website could show you ads on Facebook that they think will be relevant to you because you’ve got an account on our Website.
• 20.6 The Facebook Pixel also allows Facebook’s ad system to better understand your interests so it can show you ads from advertisers that are relevant and useful. For instance, you may see more ads for beauty products if you have an account on our Website.
• 20.7 Facebook’s ad system prioritises what ad to show you without us or any other advertisers knowing who you are. Facebook doesn’t sell any individual data that could identify you, such as your name.

How do I disable the Facebook Pixel?

• 20.8 To disable the Facebook Pixel, you can decline the third-party cookie notice on our Website.
• 20.9 We respect “Do Not Track” and we will never use the Facebook Pixel if you have this setting enabled.
• 20.10 You can control how Facebook uses data from partners in your.

• 22.1 If you have a question relating to our Privacy Notice or our Cookies Policy, please contact us by post or email.
• 22.2 Our contact details are shown below: