Privacy Notice: Sam’s Export Program

and last updated on December 18, 2020 11:00 AM

Updated: Dec. 18, 2020
By

Sam’s Export Program Privacy Notice Summary

The notice below is a supplement to the Sam’s Privacy Policy and applies only to members located in the European Economic Area (EEA) who are participating in the Sam’s Export Program. As part of the program we collect information about your company, including personal information about your company contact information through forms available on the Sam’s Export website, including but not limited to: the Export Member Agreement Form, Export Price Request Form, and the Export Member Profile Form. Sam’s Club is the controller of personal information collected on these forms. In the event of a conflict between this Notice and the Sam’s Privacy Policy, this Notice will prevail. Please review the Sam’s Club Privacy Policy for further details on how Sam’s Club uses member data.

Why are we allowed to collect and use your information?

Sam’s Club collects your information and processes it in order to provide services to your company as a Sam’s Club member and manage Sam’s Club’s business operations. Please refer to the Sam’s Club Privacy Policy for details. If you are located within the EEA, Sam’s Club must have a legal basis for processing your information. The legal bases for processing personal information may include:

a. We need to use your Information to meet our contractual obligations to you, such as fulfilling your company’s orders.

c. We need to use your Information to enable us to run our Sam’s Export Program business successfully.

d. We need to use your information to comply with applicable law. Where the law tells us that we need to use certain information, then we are allowed to do so, as long as we only use it for that purpose.

A more detailed description of the information we collect, and the purposes of such collection, is provided at the end of this Notice.

Where is your Information kept, processed or accessed from?

Your Information will be processed outside of the EEA. and will be hosted on systems located in the U.S. or other countries that may not have the same data protection laws as a country in the EEA. We have implemented appropriate safeguards (such as contractual arrangements) in accordance with legal requirements to ensure that your personal information is adequately protected, wherever it is processed. We protect your personal information by using reasonable security measures, including physical, administrative, and technical safeguards.

Your rights

You have a right to request access to, and correction or deletion of the personal information that we hold about individuals that represent your company. You may also request that we cease processing of your personal information where you believe such processing is causing you harm.

Data Subject Requests, complaints, and questions about this notice can be directed to Sam’s Club Privacy Office. Please include the label “GDPR Request” in the subject line of your email communication. You can also contact us the Privacy Office via the address below:

Mail:
Sam’s Club Corporate
Privacy Office, MS #0160
702 SW 8th Street
Bentonville, AR 72716-0160

Individuals located in the EEA have the right to report concerns directly to the Data Protection Authority for their country of residence.

How long do we keep your information?

We are required to maintain copy of the member agreement executed for each program shipment indefinitely. Unless otherwise stated in the Privacy Policy or other written notice we provide to you, or if we are required for legal reasons, we will keep any other Personal Information collected from for 5 years and then we will securely delete it.

We do need to keep some anonymous information for longer than this, such as customers’ shopping habits and buying patterns, to support the effective operations of Sam’s Club. We remove all names, contact details and any other information that could identify individual customers from this anonymous data.

PURPOSES FOR PROCESSING AND CATEGORIES OF INFORMATION

Processing Purpose

Categories of Personal Information

Legal Basis for Processing
For further explanation on how we rely on each legal basis please see "Why are we allowed to collect and use your Personal Information?" above.

Customer Care

   

To register you as a Customer for Sam’s Export

  • Company
  • Name
  • Email address
  • Telephone number
  • EIN

Necessary for performance of the contract between you and us
Necessary for compliance with our legal obligations

Deliver orders and provide other services to you

  • Company
  • Name
  • Address
  • Email address
  • Telephone number
  • Member ID

Necessary for the performance of the contract between you and us
Necessary for compliance with our legal obligations

Accepting payment for products and services, processing refunds and managing fees and charges

  • Company
  • Name
  • Email address
  • Encrypted payment card information

Necessary for the performance of the contract between you and us
Necessary for compliance with our legal obligations

Managing our customer service relationship with you. For example, when you communicate with Customer Services in-store, Customer Contact Centre or through online feedback forms.

  • Company
  • Name
  • Email address
  • Feedback or experiences you have provided us

Necessary for the performance of the contract between you and us
To meet our legitimate interests to run our business effectively by understanding how you are using our services and how to better apply the feedback provided to us

Online identifiers, Cookies and Analytics

   

Collecting online identifiers for analytics purposes, to help us understand our customers better, to find out more about the kind of things they like or are not so keen on and help the improvement of products, services, websites and communications.

Online identifiers such as:

  • IP address
  • device ID
  • session ID
  • cookie information
  • purchase history

To meet our legitimate interests to run our business effectively by understanding how you are using our products and services and interacting with our communications and how to improve this offering

Collection of online identifiers such as your interaction history and website feedback to maintain, develop and test our computer systems

Online identifiers such as:

  • Interaction history
  • Website feedback

To meet our legitimate interests to run our business effectively by ensuring our customers get the best experience and are able to shop online securely

Collection of information from cookies to serve relevant content and advertisements to you on our Grocery Home Shopping and George.com websites and mobile apps. This information helps us understand the effectiveness of the advertising you see during your online experience.

Online identifiers such as cookies

To meet our legitimate interests to run our business effectively by understanding how you interact with our advertising content on various websites and mobile applications

To improve our websites, products, services, communications, customer relationships and experiences we may collect anonymous demographic information from you.

  • City
  • Postcode
  • Nearest store
  • Shopping feedback
  • Average spend
  • Purchase history and cookie information

To meet our legitimate interests to run our business effectively by improving our products and services and understanding how our customers interact with our customer services providers and communications

Marketing and Competitions 

   

We will collect contact details about you to send you offers, suggestions, recipes and news about products and services we think you'll love via email, SMS or push notifications.

  • Company Name
  • Email address
  • Telephone number

In some cases, we are required to get 'opt-in' consent from you, e.g. you tick a box to say you want to receive direct marketing. In others, where we are marketing our products and services to existing customers, we can get permission by offering an 'opt-out' e.g. you tick a box to say that you don't want to receive direct marketing.

We will collect contact details about you to allow you to enter into a prize draw, competition, or complete a survey about your experiences shopping with us.

  • Name
  • Email address
  • Telephone number
  • Mailing address

In some cases, we are required to get 'opt-in' consent from you, e.g. you tick a box to say you want to receive direct marketing. In others, where we are marketing our products and services to existing customers, we can get permission by offering an 'opt-out' e.g. you tick a box to say that you don't want to receive direct marketing.

Security and defense of legal claims

   

To defend, manage or process legal claims and comply with legal obligations

  • Age details
  • Valid forms of identification such as passport/Driver's license)

Necessary for compliance with our legal obligations to which we are subject and cooperate with regulators and law enforcement bodies.