Privacy Policy

PRIVACY POLICY

This privacy policy sets out the privacy practices for gemsatwork ltd, a company incorporated in England & Wales with company number 09786861 and having its registered office at 8-9 Ship Street, Brighton, United Kingdom, BN1 1AD (“we”, “us”, “our”). Our websites are https://www.gems-sampling.com/ (the “Website”) and all associated sub-domains.

In order to provide our services to you and to promote our business, we will need to collect and process certain personal information about you.

We are committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation, together the “Data Protection Laws”. This privacy policy describes how we collect and use personal information about you during and after our relationship with you and your employer or our partners (as defined in paragraph 1 below), as appropriate.

If you have any questions at all about this policy or the Website, or about how we use and process your personal information, please do not hesitate to contact us by e-mail at privacy@gemsatwork.com or, alternatively, in writing to: gemsatwork (or gems sampling), 8-9 Ship Street, Brighton, United Kingdom, BN1 1AD, United Kingdom.

If we change our privacy policy, we will post the changes on this page and may place notices on other pages of the Website so that you may be aware of the information we collect and how we use it at all times. Continued use of the Website will constitute your agreement to any such changes.

1. Our role In order to enable us to set up your account on our Website and provide our services to you via our Website, we have been provided with your business email address by your company Ambassador, including your name & email address.

We also collect certain other personal information about you, as described further in this privacy policy.

The information your Ambassador gives to us allows us to send service-related messages to you regarding our product sampling services. This may include but is not limited to: voting emails to receive a product, offers to opt-in to receive a product, confirmation emails, and feedback surveys.

As part of our service, we have partnered with big-name brands to offer you exclusive discounts and offers. You will need to opt-in to receive these emails and can opt out of receiving these at any stage, as described further in this policy.

We also collect data through our survey platform, which is hosted and stores all data securely.

As part of our commitment to delivering high-quality insights, we collect survey data from our Ambassadors, as well as their colleagues, clients, and customers. This data helps us enhance our services, refine our sampling strategies, and provide valuable feedback to our partners.

All survey data is collected, processed, and stored in accordance with the highest security and compliance standards, including the General Data Protection Regulation (GDPR) and ISO/IEC 27001, the internationally recognised standard for information security management via our sister company https://www.sampltech.com. This platform is accessed via QR codes on posters/leaflets or through a link shared with colleagues, clients, and members. To provide additional context to feedback providers, we create branded landing pages that include product details, purchase locations, and feedback submission options.

Additionally, we collect data on our sampling sites, including company-wide information (e.g., average age, education level) and more granular details using a wishlist that allows individuals within companies to share personal preferences on key topics (e.g., sensitive skin, children in school). This helps us tailor sampling campaigns effectively.

For the purposes of the applicable Data Protection Laws, gemsatwork ltd is the data controller of your personal data collected in connection with your use of our Website.

2. What information we collect In addition to your business email address provided to us by your employer, we will collect certain personal information about you when you activate your account or complete information (such as your preferences) on our Website.

We may also collect information from you based on your interactions with the Website, such as attitude or behavioural information collected when you redeem a benefit, enter a campaign, competition, or survey, and/or when you report a problem with our Website.

With regard to each of your visits to our Website, we will automatically collect the following information:

1. Using our Website as a registered user, we will collect information about your points, rewards, and the benefits redeemed by you;

2. Technical information, including the internet protocol (IP) address used to connect your computer or mobile device to the internet, type of mobile device you use, a unique device identifier, mobile network information, your login information, browser type and version you use, browser plug-in types and versions, operating system, and platform;

3. Information about your visit to our Website, including the full uniform resource locators (URL) clickstream to, through, and from our Website (including date and time); pages you viewed or information you searched for; page response times, download errors, length of visits to certain pages; and

4. Details of your visits to other websites via our Website.

We also work with third parties (including, for example, electronic analytics, business partners, advertising networks, analytics providers, and search information providers) and may receive certain information about you from them.

We use cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you use the Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy.

3. Lawful basis and purposes of processing of your personal information We collect information about you so that we can:

• Identify you and manage your account on our Website;

• Process your voucher transactions;

• Liaise with your Ambassadors and our partnered affiliated companies, our suppliers, and group companies;

• Improve our services;

• Promote our business and market our services;

• Manage our business, including for accounting and auditing purposes;

• Conduct our regular group reporting activities on the performance of our company, in the context of a business reorganization or group restructure;

• Maintain our IT systems and manage hosting of our data;

• Deal with legal disputes involving you, your employer, or our suppliers;

• Prevent fraud; and

• Comply with our regulatory obligations.

We will only use your personal information when the law allows us to, i.e., when it is necessary to:

• Perform our obligations towards you and/or your employer or the Ambassador;

• Comply with our legal and regulatory obligations;

• Pursue our legitimate interests (e.g., conducting our business efficiently and profitably and promoting our business), where your interests and fundamental rights do not override these interests. It may also become necessary to process your personal data for a legitimate interest of a third party, such as through feedback during product sampling. We will also rely on our legitimate interests for the proper administration of our Website and to manage our operations (e.g., maintaining appropriate records and databases).

We will only use your information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.