The aim of this privacy policy is to provide you with clear, simple, and comprehensive information about how we handle the personal data you provide or the data we may collect while you browse our website, how it may be shared with third parties, and your rights and options to control your personal information and safeguard your privacy.

One entity processes your personal data on the website www.samuelrosse.com (‘Website’):

• Samuel Rosse (“Samuel Rosse”), a company managed by Luna Doro Ltd a limited liability company with headquarters located at 45 Albemarle Street, 3rd Floor, London, England, W1S 4JL registered in the companies register under no. 15990644, VAT number 04215670375;

Pursuant to Art. 26 of Regulation (EU) 2016/679 (“GDPR”), Samuel Rosse is the data controller for managing product sales on this Website and related activities, such as order processing, payment handling, delivery of products, and after-sales services (returns, refunds, and complaints), as outlined in Article IV below.

For all other purposes outlined in Article IV below, Samuel Rosse is the data controller of personal data collected on the Website in accordance with applicable personal data regulations, particularly GDPR.

Samuel Rosse prioritises the processing, confidentiality, and security of your personal data.

WHAT IS PERSONAL DATA?

Personal data is any information about an identified individual or an individual who can be directly or indirectly identified through an identification number or one or more specific elements, such as their surname, first name, date of birth, customer number, order number, photo, etc.

---

When can we collect your personal data? 

We may collect your personal data when you:

• Create a customer account on this Website;

• Place orders for goods on this Website (including recurring orders);

• Agree to receive marketing communications from us by email, telephone, SMS, or post, based on your preferences;

• Interact with Samuel Rosse via its official social media pages;

• Contact our customer service team;

• Submit information requests to Samuel Rosse;

• Participate in an event we organise;

• Browse the Internet using cookies or click on advertisements for our products;

• Book an appointment online through MyAccount, using the social login plugin if applicable;

• Book an appointment online through Samuel Rosse’s Facebook page.

III. What personal data might we collect? (i) As part of the services we offer, we may need to collect certain data directly from you via electronic forms on this Website for various purposes (see Article IV for a list of processing purposes).

Information we may collect includes:

• Your identity;

• Your gender;

• Your contact details (e.g., email address, phone number, postal address);

• Your personal preferences related to the products we market or this Website (e.g., language);

• Your purchase history;

• Information related to your orders, their tracking, and purchase invoices;

• Browsing data on the Website;

• Information you provide to our customer service;

• Specific information if you report any adverse effects associated with Samuel Rosse products;

• Your payment details if you place an order on this Website.

(ii) We may also collect certain data generated by your purchases of products or services, whether online or in stores, particularly details regarding the type and amount of your purchases.

(iii) Additionally, we may collect information about how you use this Website, such as pages visited or links clicked. Some of this information may be gathered using cookies placed in your browser when you browse the Website. For more information about cookies, please read our cookie policy, available here.

FOR WHAT PURPOSE IS YOUR PERSONAL DATA COLLECTED AND USED?

Samuel Rosse uses your data for purposes defined according to the nature of our interactions with you. Depending on the context, your data may be used for one or more of the following purposes:

a) Allowing you to create a customer account on this Website; b) Managing access to your customer account; c) Recording purchases made on this Website; d) Handling your requests for information or complaints submitted via this Website, customer service, or social media pages (unrelated to after-sales services); e) Tracking and managing alerts you submit as part of our cosmetovigilance obligations; f) Managing the Website; g) Delivering personalised content, communications, and tailored services to enhance your customer experience; h) Improving our products, services, image, and reputation; i) Managing events in which you participate; j) Managing your appointment bookings received through this Website or Samuel Rosse’s Facebook page; k) With your explicit consent (when required), using your personal data to send you tailored communications (newsletters, offers, invitations, and surveys) and analysing your preferences and habits using third-party services to personalise your profile and anticipate your needs. These communications may be sent via email, post, SMS, or phone, based on your indicated preferences and consumer profile.

SAMUEL ROSSE PROCESSED DATA TO:

• Manage the sale of products through the Website (including recurring orders), including:

  • Order processing 

  • Payment for products 

  • Fraud prevention checks 

  • Invoicing of sold products 

  • Delivery of products via designated couriers 

  • After-sales services (returns, refunds, and complaints) related to products 

• Manage customer requests related to the sales contract and after-sales services 

Personal data required by Samuel Rosse to respond to your requests or provide requested services and purchases is marked with an asterisk on all personal data collection forms on this Website. Failure to provide the required data may prevent Samuel Rosse from addressing your request or delivering requested services and purchases. Additional data, such as that related to direct marketing or profiling, is optional and processed by Samuel Rosse only with your explicit consent. Refusal to provide this data may limit our ability to personalise communications and services but does not prevent you from creating and managing a customer account, making purchases, or accessing other services offered by Samuel Rosse.

WHO ARE THE RECIPIENTS OF PERSONAL DATA?

Your personal data is processed by the personnel of Samuel Rosse. We ensure that only authorised personnel have access to your personal data when it is necessary for performing our contractual or legal obligations.

WE MAY ALSO SHARE YOUR DATA WITH:

• Other entities within the Samuel Rosse group, to provide you with tailored services and communications (with your explicit consent when required);

• Third-party service providers acting as processors, under strict obligations to safeguard your data (e.g., IT service providers, payment processors, delivery partners);

• Legal or administrative authorities where required by law or based on legitimate requests;

• Third parties in the event of a merger, acquisition, or transfer of assets involving Samuel Rosse.

HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

Your personal data is retained only for as long as necessary to fulfil the purposes outlined in this privacy policy, subject to applicable legal retention periods. For example:

• Customer account data: Retained as long as your account remains active and for a period of three years after your last interaction with us;

• Purchase data: Retained for the duration required by applicable tax and accounting laws;

• Marketing data: Retained until you withdraw your consent or request deletion, subject to a three-year inactivity period.

Once the retention period expires, your personal data will be securely deleted or anonymised.

WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXCERCISE THEM?

In accordance with GDPR, you have the following rights regarding your personal data:

• Right of access: To obtain confirmation about whether your personal data is being processed and access the data;

• Right to rectification: To request correction of inaccurate or incomplete data;

• Right to erasure: To request deletion of your data, subject to legal or contractual obligations;

• Right to restriction: To limit the processing of your data in specific circumstances;

• Right to data portability: To receive your data in a structured, commonly used format and transfer it to another controller;

• Right to object: To object to the processing of your data for direct marketing purposes or based on legitimate interests;

• Right to withdraw consent: To withdraw your consent at any time where processing is based on consent.

You may exercise your rights by contacting us using the details provided in Article IX. Please include sufficient information to verify your identity and clarify your request.

HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement appropriate technical and organisational measures to ensure the security and confidentiality of your personal data, including:

• Encryption of sensitive data;

• Access controls to limit data access to authorised personnel only;

• Regular security assessments and updates to our IT systems;

• Procedures for managing data breaches and notifying affected individuals and authorities where required.

HOW CAN YOU CONTACT US?

 For any questions or concerns about this privacy policy or the processing of your personal data, please contact us at:

• Luna Doro Ltd: 45 Albemarle Street, 3rd Floor, London, England, W1S 4JL. Email: Customersupport@samuelrosse.com.

We will make every effort to address your concerns and respond to your requests promptly.

This privacy policy may be updated periodically to reflect changes in our practices or legal requirements. We encourage you to review it regularly to stay informed about how we protect your personal data.