SAMSUNG ESTORE PRIVACY POLICY

GENERAL

Updated: 14 February 2020

SCOPE

Samsung Electronics Nordic AB (Torshamnsgatan 48, PO Box 1235, 164 40 Kista, Sweden, reg. no. 556445-4345, “Samsung”, “we”, “us”, “our”) knows how important privacy is to our customers, and we strive to be clear about how we collect, use, disclose, transfer and store your personal data.

 

This Privacy Policy applies to any estore services provided by Samsung in the Nordics as a data controller. To read more about how Samsung Electronics Co., Ltd. and Samsung Electronics (UK) Limited collect, use, disclose, transfer and store personal data, please visit the Samsung Global Privacy Policy in Swedish here http://www.samsung.com/no/info/privacy/.

 

We inform you in the Samsung eStore flow where we share your personal data with a third party service provider acting as a separate data controller and in those cases please consult the privacy policy of such data controller to learn more about their data privacy practices (on which we have no influence).

PRIVACY POLICY HIGHLIGHTS

Below you will find a summary of the key messages contained in our Privacy Policy. For more detailed information on how we process your information, please click on the headings or continue to read below.

 

           1. How we collect your information

            2. What information we collect and how we use the information (purposes and legal bases)

            3. Sharing your information

            4. How long we keep your data

            5. International transfer of data

            6. Keeping your information secure

            7. Your rights

            8. Contact us

 

Generally, we will collect personal data about you when you buy a product through Samsung eStore. The personal data we collect about you relates to you and your order. We use the least personal data necessary to satisfactorily handle your order and we ensure that all third parties involved in eStore flow are trusted partners. As we are part of a global group of companies sharing global systems and platforms, we need to share personal data with companies related to Samsung Electronics Co., Ltd. by common ownership or control. We do not keep the personal data longer than necessary as described further in this Privacy Policy.

CONTACT US

European Data Protection Officer

Samsung Electronics (UK) Limited

Samsung House, 1000 Hillswood Drive, Chertsey, Surrey KT16 0PS

 

You can also contact us at dataprotection.sena@samsung.com or on our online webpage dedicated to your rights at www.samsung.com/request-desk.

UPDATES

It also is important that you check back often for updates to the Privacy Policy. If we update the Privacy Policy we will let you know in advance about changes we consider to be material by placing a notice or by emailing you, where appropriate. The most current version of the Privacy Policy will always be available here: www.samsung.com/no/estore/privacy-policy. You can check the “effective date” posted at the top to see when the Privacy Policy was last updated.

  • 1. HOW WE COLLECT YOUR INFORMATION

    When purchasing a product via Samsung eStore we will process certain personal data about you, so we can administer your order and successfully deliver the right product to you or the company you represent. We will process personal data that you provide directly to us through the use of Samsung eStore.

  • 2. WHAT INFORMATION WE COLLECT AND HOW WE USE THE INFORMATION (PURPOSES AND LEGAL BASES)

    GENERAL

    We will collect information about you and your order that are necessary to process your order and to conduct your purchase or return satisfactorily, such as your name, contact information, information relating to payment and your order, delivery information (such as name, email address, phone number, home address, purchased product and services, order no., etc.) and technical data (such as IP address and cookies about placed orders etc.).

    We use this information for the following purposes:

    - to enable our payment provider, Klarna (and for businesses, Collector), to arrange for the payment which is necessary to fulfil our contract with you when you purchase or return a product through the eStore. Samsung is the data controller for this processing.

    - if you have chosen to arrange payment for your order via Collector, information about you and your order will also be shared with Collector and used to carry out fraud, money laundering and any other checks and assessment required for compliance with legal and regulatory obligations under the applicable law. Collector Bank AB is the data controller for this processing.

    - to arrange the shipping of the purchased products to you to fulfil our contract with you;

    - to manage, handle and administer your order internally to fulfil our contract with you or for compliance with applicable laws on bookkeeping;

    - to ensure that our service providers provide high-quality services to you on our behalf, based on our legitimate interest to ensure high-quality services within Samsung eStore;

    - regarding technical data for cybersecurity purposes, based on our legitimate interest to protect the Samsung eStore from cyberattacks;

    - if you have chosen to participate in campaigns offered by Samsung, to administer, provide and deliver such campaigns;

    - to contact Upgrade+ users in order to inform the users when they are eligible to upgrade their phones;

    - if you have consented to receive marketing information from the Samsung entities mentioned below, we (Samsung Electronics Nordic AB) will also use information about you and your order to improve our online advertising and to personalize our marketing communication with you based on our legitimate interest of sending you marketing communication or showing you online advertising that is relevant for you in relation to the products you own. For more information about how we personalize our marketing communication see our policy here https://www.samsung.com/no/info/privacy/personalized-marketing.

    - to improve your user experience on eStore, based on our legitimate interest to evaluate and further develop the eStore platform. For that purpose, we use the data collected through cookies provided that you gave us your consent to it through the cookie banner;

    - to provide you with support and customer service if you make an inquiry, based on our legitimate interest to help you with your inquiries relating to your order via Samsung eStore; and

    - for internal sales reporting based on our legitimate interest to gain knowledge on how our products are selling and we make personal data aggregated for such purposes.

    Samsung Electronics Co., Ltd. and Samsung Electronics (UK) Limited will use the personal data collected via Samsung eStore for advertising, such as providing customised advertisements, sponsored content and sending you promotional communications with your separate consent if required. For further information please visit the Samsung Global Privacy Policy here http://www.samsung.com/no/info/privacy/.

    OPTIONAL SERVICES

    In addition to the general purposes described above we will process additional information about you if you take advantage of one of the optional services that are facilitated through the eStore. The processing of your personal data for these optional services is based on our legitimate interest to offer you additional services you might be interested in to make our offerings even more attractive. The optional services are:

    Trade-in. If you make use of the trade-in option offered by us through the Samsung eStore, you will effectively sell your trade-in device to our trade-in partner in return of an up-front discount to be used on your purchase of the new Samsung product (subject to applicable conditions). The personal data that we collect within the context of the trade-in option will be processed by us as the data controller for the purpose of providing the trade-in option as part of your purchase of products on the Samsung eStore. The processing of personal data is based on the fulfilment of your contract with us. We will also process the data for compliance with applicable bookkeeping rules and for vendor management purposes for a limited time period.

    We will also share information with our trade-in partner relating to you and your sale of the trade-in device to the trade-in partner, such as your name and type of trade-in device. We will only share such information as necessary for the trade-in partner to fulfill its statutory requirements, such as statutory requirements applicable to trade with used goods. The trade-in partner is the data controller in respect of the personal data that it processes for such purposes and it will process the data pursuant to its own privacy practices (on which we have no influence).

    Note that it is your responsibility to back-up and delete any personal data contained on the device that you send to us or to the trade-in partner.

    Upgrade+ Program. If you choose to enroll in the Upgrade+ Program offered in cooperation with our Upgrade+ Program partners, through the Samsung eStore and other Samsung branded platforms, we will collect the same type of personal data that we collect when you make a purchase from us at the Samsung eStore. The personal data that we collect within the context of the Upgrade+ Program will be processed by us as the data controller for the purpose of providing the Upgrade+ Program services, such as to know when you enrolled in the Upgrade+ Progam, what device you use and when you are eligible for your upgrade. The processing of personal data is based on the fulfilment of your contract with us. We will also process the data for compliance with applicable bookkeeping rules and for vendor management purposes for a limited time period.

    We will share personal data collected within the Upgrade+ Program with Samsung Electronics (UK) Limited since we share the systems and platforms used for providing Samsung eStore. Samsung Electronics (UK) Limited will use your personal data for the purposes described in this Privacy Policy on Samsungs behalf, such as to inform you when you are eligible to upgrade your phone and how you can do it. For further information regarding Samsung’s operating global systems and platforms please visit the Samsung Global Privacy Policy here http://www.samsung.com/no/info/privacy/.

    We will also share such personal data with our Upgrade+ Program partners as required for their provision of services which are included as an integral part of the Upgrade+ Program. The data may for instance be shared with our credit provider partner for the purpose of providing financing under separate credit agreements entered between you and the credit provider as part of the Upgrade+ Program. Our Upgrade+ Program partners will process such data pursuant to their own privacy practices and on their own platforms (on which we have no influence).

    From our Upgrade+ Partners, we will obtain personal data relating to their provision of services to you as required in order for us to provide the Upgrade+ Program to you.

    In addition to the data described above, you may be requested to provide personal data to our Upgrade+ Program partners which they collect directly from you as data controllers for their own purposes. Such data could for instance be information relating to your annual income and occupation and other data which Samsung has no intention to process for our own purposes. To the extent such data is collected on the Samsung eStore, we are processing it on behalf of and according to the instructions from the partners and they will process your personal data based on their own privacy practices (on which we have no influence).

    Note that it is your responsibility to back-up and delete any personal data contained on the device that you send to us or to an Upgrade+ Program partner.

    Samsung Mobile Care is included in the Upgrade+ Program. Therefore, please also see further down regarding processing of personal data relating to Samsung Mobile Care.

    SAS Eurobonus. If you make use of the option to add your purchases made via Samsung eStore to your SAS Eurobonus account and to thereby receive points on your SAS Eurobonus account we will also process your SAS Eurobonus account number. This service will help you accumulate more SAS Eurobonus points when purchasing via Samsung eStore pursuant to the SAS Eurobonus provider’s own privacy practices (on which we have no influence). We will also process the Eurobonus account for compliance with applicable bookkeeping rules and for vendor management purposes for a limited time period.

    Back-in-stock email. If you make use of the option to receive an email when a product you requested on Samsung eStore is back in stock, we will process your email address for this purpose. We rely on our legitimate interest to inform you, upon your subscription, that a product you are interested in to purchase is available again for purchase. The email is only sent once to you and your email is thereafter deleted from the back-in-stock email database.

    Samsung Mobile Care. If you want to conclude a Samsung Mobile Care (“SMC”) insurance policy with the Allianz, we will process personal data requested in the SMC data capture field. We are processing such personal data on behalf of and according to the instructions Allianz and they will process your personal data based on their own privacy practices (on which we have no influence).

    Campaigns and special offers. If you choose to participate in a campaign through the Samsung eStore and that is offered by Samsung, we will collect information about you as described above (your name, email address and phone number), your order (delivery address, IMEI number of your device) and campaign specific information (campaign or redeem code), if any, depending on the terms and conditions applicable to the specific campaign that you participate in. If necessary, we can also use the same type of personal data that we collect when you make a purchase from us at the Samsung eStore and from third parties (such as the retailer where you bought your device) in order to protect Samsung rights in relation to you and to handle potential returns of the products that are subject to the specific campaign according to the terms and conditions applicable to the specific campaign.

    We may collect and use the IMEI number of your device in order to give you access to the campaign. Also, if a campaign code will be processed by Samsung, it will be processed in order to document and match which IMEI number has been used with which campaing code. The processing of the personal data mentioned above is based on our legitimate interest to (i) deliver services, support and assistance in relation to the campaign that you choose to participate in, and (ii) if required, to ensure that the customer’s experience of the campaign is as good as possible and any possible problems are solved, as well as to enforce our rights as described in the terms and conditions applicable to the specific campaign.

    We will also process information about you and your order as described above for purpose of administrating the campaigns you participate in (including possible returns of products), to deliver campaign products and, if necessary, to contact you regarding the specific campaign that you participated in. The processing of such personal data is based on the fulfilment of your contract with us (terms and conditions applicable to the specific campaign).


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    If you do not provide the requested personal data, you will not be able to purchase a product through the eStore or make use of the optional services or receive our marketing information where applicable.

  • 3. SHARING YOUR INFORMATION

    We will disclose your information as strictly necessary to pursue the described purposes, internally within our business to the relevant teams, such as, without limitation the customer services team, the legal team, the finance team, the technical team and of course the Estore team. We may also disclose your information to the following entities, only to the extent that this will be necessary to assist with conducting the described activities limited to the purposes described in this Privacy Policy:

    Affiliates. Your information may be shared among Samsung affiliates for the purposes described in this Privacy Policy, especially regarding the global systems and platforms used by Samsung eStore and provided by a Samsung affiliate. The term ‘affiliates’ refers to companies related to Samsung Electronics Co., Ltd. by common ownership or control. Our affiliates include companies with the Samsung Electronics name. Affiliates may also include other companies related by common ownership or control. To read more about the privacy practices of Samsung Electronics Co., Ltd. operating global systems and platforms we use. Please visit the Samsung Global Privacy Policy here http://www.samsung.com/no/info/privacy/.

    If you have consented to receive marketing information from any of the Samsung entities mentioned above, we will share information about you and your order made via Samsung eStore with Samsung Electronics (UK) Limited for the purpose of advertising and sending you promotional communications which Samsung Electronics (UK) Limited is the data controller for. Also, as mentioned above, if you are an Upgrade+ Program user, we will share your personal data that we collected within the Upgrade+ Program with Samsung Electronics (UK) Limited for the purpose of sending you a service message when you are eligible to upgrade your phone.

    Service Providers. We will disclose your information to carefully selected companies that provide services for or on behalf of us, such as providers of the eStore platform and connected systems and services, payment providers, logistic service providers, customer service center providers.

    - Your information collected via Samsung eStore is shared with the providers of the eStore platform and connected systems and services.

    - Your information enabling payments to be executed via our payment provider, Klarna Bank AB, will be shared with Klarna and they will also use the information for their own purposes as a separate data controller pursuant to their own privacy practices (on which we have no influence). For more information, please visit Klarna’s website at https://www.klarna.com/se/. If you are a B2B customer, your information will be shared with and used by Collector Bank AB for their own purposes. Collector is a data controller pursuant to their own privacy practices (on which we have no influence). For more information, please visit Collector’s website at https://www.collector.se.

    - For facilitating the shipping of your order, and if you choose to participate in a campaign offered by Samsung, facilitating the shipping of a campaign product as described in the terms and conditions applicable to the specific campaign, your information is disclosed to the relevant logistics partners.

    - For customer service and support matters the information is shared with our call center providers and if needed with other trusted service partners, our payment provider and the provider of our platform for technical returns.

    - If you make use of optional services on Samsung eStore provided by a third party, your relevant data will be shared with the applicable third party as described above pursuant to their own privacy practices (on which we have no influence). For more information, please visit their websites. These entities, where not acting as separate data controllers, are limited by contractual provisions in their ability to use your information for purposes other than providing services for us.

    Partners relating to optional services. We share personal data with our partners within the context of providing the optional services as described in section 2 above in this Privacy Policy.

    Other Parties When Required by Law or as Necessary to Protect Our Services.

    There may be instances when we disclose your information to other parties:
    • to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);
    • to verify or enforce compliance with the policies governing the eStore; and
    • to protect the rights, property, or safety of Samsung, or any of our respective affiliates, business partners, or customers.

    Other Parties in Connection with Corporate Transactions. We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy.

    Other Parties with Your Consent or at Your Direction. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.

  • 4. HOW LONG WE KEEP YOUR DATA

    How long we keep your information depends on what purpose we use it for:

    - Where we process your information in connection with payment or invoicing, we keep such information as long as required by applicable laws.

    - We keep the information used for product shipping and internal order management no longer than may be required or allowed by the applicable laws on statute of limitation, consumer protection or product liability.

    - Information used for ensuring cybersecurity is kept no longer than three months. The information used for providing you with a better user experience on the Samsung eStore is deleted after once the relevant cookies expiry or if you erase them.

    - We store the information used for providing support and customer service in accordance with our Customer Service privacy policy, which you can find on Samsung’s support website.

    - If you want to read about the retention practices of Samsung Electronics Co., Ltd.and Samsung Electronics (UK) Limited maintaining global Samsung systems and platforms and where applicable providing marketing communications (including communication to Upgrade+ Program users), please visit the Samsung Global Privacy Policy here http://www.samsung.com/no/info/privacy/.

    For the optional services we keep your information for the following time periods:

    - Trade-in: Your information is kept for a limited time period necessary for vendor management purposes.

    - Upgrade+ Program: Your information is kept for as long as you are enrolled on the Upgrade+ Program and as long as required by applicable laws, such as bookkeeping rules.

    - SAS Eurobonus: Your information is kept for a limited time period necessary for vendor management.

    - Back-in-stock email: Your email address is kept until the requested product is back in stock and you have been sent one email reminder. Thereafter you email address is deleted.

    - Samsung Mobile Care: We only keep personal data for the time period as instructed by Allianz.

    - Campaigns: We store your personal data processed in order to deliver the specific campaigns for maximum of two (2) years after the specific campaign has ended. Your personal data related to the specific campaign will be destroyed or deleted from our systems when no longer needed. Please note that this does not include personal data that can be retained for the purposes defined below.

    We take appropriate measures to ensure that we process and keep personal data about you based on the following logic:

    a) At least during the time period in which the information is used to fulfill our obligations to you in the specific campaign;
    b) As required by law, contract or as a result of a statutory obligations;
    c) Only as long as required for the purpose for which the personal data was collected and needs to be processed or longer if required by a contractual obligation, applicable law, statistical purposes or for appropriate security measures; or
    d) As long as required for us to exercise our rights as described in the terms and conditions applicable to the specific campaign.

  • 5. INTERNATIONAL TRANSFER OF DATA

    Certain operations, such as, managing orders in and maintaining the Samsung eStore systems and, if applicable, providing you with marketing communications (including communication to Upgrade+ Program users) will involve the transfer of your personal data to Samsung Electronics Co., Ltd. (Korea) and Samsung Electronics (UK) Limited (located in United Kingdom). We take appropriate measures, in compliance with applicable law, to ensure that your personal data remains protected. Such measures include the use of Standard Contractual Clauses to safeguard the transfer of data outside of the EU/EEA.

    For more information, or to obtain a copy of the contractual agreements in place, please contact us at dataprotection.sena@samsung.com.

  • 6. KEEPING YOUR INFORMATION SECURE

    We take protection of your data seriously, and have put in place appropriate technical and organisational measures to safeguard the information we collect in connection with the eStore services. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure.

  • 7. YOUR RIGHTS

    You have the right (i) to request details about the information we collect about you and to request us to correct inaccuracies in that information, (ii) to object to the processing based on legitimate interests or for direct marketing purposes, or request the restriction of the processing, (iii) to request access to, the erasure or portability of your information. Also, you have the right (iv) to withdraw your consent in the situations when you have given it. Under the laws of some jurisdictions, we may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. If you would like to make a request to access your information or exercise any other applicable rights, contact us on our dedicated GDPR online portal at http://www.samsung.com/request-desk or at dataprotection.sena@samsung.com.

  • 8. CONTACT US

    If you have any specific questions, please contact us at:

    European Data Protection Officer
    Samsung Electronics (UK) Limited
    Samsung House, 1000 Hillswood Drive, Chertsey, Surrey KT16 0PS

    You can contact us at dataprotection.sena@samsung.com or on our online webpage dedicated to your rights at www.samsung.com/request-desk. If you would like to exercise your right to access, rectification, deletion/erasure, object, restrict processing or portability, please contact us on our dedicated online portal at www.samsung.com/request-desk or using the email above.

    You may lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal data infringes applicable law. Contact details for all EU Supervisory Authorities can be found here.