Privacy Notice: Sam’s Export Program
Updated: Dec. 18, 2020
Sam’s Export Program Privacy Notice Summary
The notice below is a supplement to the Sam’s Privacy Notice 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 Notice, this Notice will prevail. Please review the Sam’s Club Privacy Notice 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 Notice 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 Notice 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 |
Customer Care | ||
To register you as a Customer for Sam’s Export |
| Necessary for performance of the contract between you and us |
Deliver orders and provide other services to you |
| Necessary for the performance of the contract between you and us |
Accepting payment for products and services, processing refunds and managing fees and charges |
| Necessary for the performance of the contract between you and us |
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. |
| Necessary for the performance of the contract between you and 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:
| 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:
| 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. |
| 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. |
| 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. |
| 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 |
| Necessary for compliance with our legal obligations to which we are subject and cooperate with regulators and law enforcement bodies. |
