Privacy Policy
Loyalty Card – Terms & Conditions
GENERAL
This Privacy notice
- provides an outline of how The Samir Group (herein after referred to as ‘we’, ‘us’, ‘our’ or ‘the Group’) collects and processes data, whether on individuals (including personal data in respect of individuals who are past, present and prospective clients, intermediaries or other thirds parties with whom the Group interacts and/or any other individual connected/related to those parties) or otherwise.
- informs you about your rights under the local data protection law and the EU General Data Protection Regulation (‘GDPR’),
- applies to all other members of ‘The Samir Group’ along with the following group companies:
– Eumelia Trustees Limited
– ConnectedSky – www.connectedsky.com
– C. Samir & Co. LLC – www.csamir.com
– Desmos Capital Limited – www.desmoscapital.com
– FirstClassProject Limited – www.firstclassproject.com
– CYMEBA – www.cymeba.com - might be subjected to updates and/or alterations for which you will receive a notification.
- any queries or request with regard to this Privacy Notice or (personal) data should be directed to [email protected]
WHAT DATA DO WE HOLD
We process data in the context of providing legal and other services to clients. The categories of data we collect and process, according to the particulars of each case include:
- Contact details (including names, surnames, postal addresses, email addresses, telephone –and fax numbers numbers);
- Information required by The Group to meet legal and regulatory requirements, in particular in respect of anti-money laundering legislation, including but not limited to information on source of funds and source of wealth, Marital status, Tax Residency, Employment information, Identification documentation, Proof of Residence, whether you are part of any criminal proceedings, Whether you have dual nationality, whether you are a Politically Exposed Person, whether you are a US National, whether you hold a US Green card etc.)
- Information provided in the course of the provision of legal, corporate, fiduciary, financial, banking, accounting, payroll, tax, administrative, advisory (non-exhaustive list) (for example, information on professional relationships and background, financial wealth and assets held, transactions entered into, tax status, disputes and court proceedings engaged in);
- Financial information, such as payment related information;
- Meetings attended and visits to our offices;
- Any other information you may provide to The Group for the enablement of services as requested by you.
IMPORTANT NOTICE ON SPECIAL CATEGORY DATA
In certain instances, the personal data that we process may include “Special Category Data” (which includes information on a person’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data processed for the purpose of uniquely identifying a natural person, health data, data on a person’s sex life or sexual orientation or data relating to a person’s criminal record or alleged criminal activity). In such instances, legal bases for processing that data may include explicit consent (where the Special Category Data has been provided to us by the data subject for any of the above-listed purposes) or the processing is being necessary for compliance with a legal obligation or for the purposes of legal proceedings or legal advice.
WHY DO WE NEED THIS DATA?
The Group ensures that the data collected and processed is relevant to one or more processing activities and that we does not collect nor process more or less data than what is reasonably required for achieving the purpose of each processing activity. Furthermore, for each purpose of processing, there is always at least one lawful basis to secure that the rights of individuals are safeguarded by all means. The purposes of processing and the lawful basis of each processing activity are the following:
| Purpose | Lawful basis of Processing |
| 1. To enter into a client-relationship and for the provision of services | Where an individual has been provided with this Privacy Notice and provides personal data thereafter, the processing may be carried out on the basis of consent. Consent may be withdrawn at any given time by writing to [email protected] It is in the legitimate interest of The Group as a provider of legal, corporate, fiduciary, financial, banking, accounting, payroll, tax, administrative, advisory (non-exhaustive list) to collect and process certain personal data in the context of provision of these services The processing of this data is necessary for the aforementioned proceedings or to establish, exercise or defend the rights of the client with relation to these proceedings. |
| 2. For Identity verification, record keeping and maintenance of correspondence details | Processing of such data is necessary for compliance with the legal and regulatory obligations to which we need to abide. |
| 3. To Ensure the security of The Group’s systems, members of staff and premises ( including the use of CCTV equipment in the public areas of the premises) | It is in the legitimate interest of The Group to protect its business environment, members of staff and premises, and to ensure smooth business operations without unauthorized interruption. By entering the The Group Premises both in the Nicosia Headquarters and the Limassol offices, and any other group office and/or representative office worldwide, any individual automatically consents to the use of CCTV monitoring purposes and to abide by the internal health and safety procedures of The Group. |
| 4. To meet all legal, regulatory and ethical obligations applicable to The Group | Processing is necessary for compliance with all legal obligations to which The Group is subject or for the exercise of functions with public authorities both locally and internationally. It is in the legitimate interests of The Group as a provider of services (as mentioned in point 1) to process data to the extent necessary to ensure that it meets all legal, regulatory and ethical obligations applicable to the Company. |
| 5. For the purposes of internal know-how and training | It is in the legitimate interests of The Group as a provider of services (as mentioned in point 1) to process data for internal know how and staff training. |
| 6. To Follow up on comments, enquiries, requests and complaints. | In cases where an individual has been provided with this Privacy Notice and provides personal data thereafter, the processing may be carried out on the basis of consent. Consent may be withdrawn at any time by writing to [email protected] It is in the legitimate interests of The Group as a provider of services (as mentioned in point 1) to collect and process certain personal data to enable it follow up on comments, enquiries, requests and complains in order to enhance client/user experience with the services of The Group. To perform and fulfil the contract with the individual for the provision of services (as mentioned in point 1) |
| 7. To promote, improve and enhance the provision of The Group’s services | In cases where an individual has been provided with this Privacy Notice and provides personal data thereafter, the processing may be carried out on the basis of consent. Consent may be withdrawn at any time by writing to [email protected] It is in the legitimate interests of The Group as a provider of services (as mentioned in point 1) to collect and process certain personal data to enable it to enhance client/user experience with The Group’s services. |
| 8. For Marketing purposes which includes but is not limited to: the sending of updates on important legal, corporate, fiduciary, financial, banking, accounting, payroll, tax, administrative developments; The Group’s company developments and/or events. | In cases where an individual has been provided with this Privacy Notice and provides personal data thereafter, the processing may be carried out on the basis of consent. Consent may be withdrawn at any time by writing to [email protected] or by unsubscribing by following the appropriate procedure which can be found in the relevant marketing material (e.g. by selecting the “unsubscribe” option in the email sent to you) It is in the legitimate interests of The Group as a provider of services (as mentioned in point 1) to process personal data to communicate with persons on topics and events which may be of interest to those individuals |
| For the purpose of provision of IT- related services such as cloud storage, data encryption, Data Leakage Prevention and File- auditing (non-exhaustive list) | It is in the legitimate interests of The Group as a provider of services (as mentioned in point 1) to implement the necessary measures for safeguarding the data as mentioned prior. For enablement of such IT-related safety measures, The Group will provide access to a third party IT Company for provision of such safety measures. |
| 9.Any other purpose(s) which has been agreed or notified to you |
The Group shall not carry out any automated decision-making activities, including profiling, using your personal information.
SOURCES AND RECIPIENTS OF DATA
The sources of data may include clients, intermediaries, other data processors, other data controllers, data subjects directly, third parties connected to the data subject (for example, their employer or another service provider who provides services to the data subject), open-source material, client representatives, Banks , Credit institutions, Administrative Service Providers, Lawyers, Auditors, Accountants, public authorities, any legal entity and/or third party individual who might introduce clients ( Individual and corporate) to us, Companies who Process Payments, The Department of Registrar of Companies and Official Receiver, The Land Register, The Bankruptcy Archive, the press, media, and the Internet.
Reasonable endeavours are made to ensure that data is only accessible by those with a need for access to fulfil the purposes set out above. Requests for access to be restricted in any particular manner should be made to [email protected] and will be considered and, where possible with reference to legal and regulatory obligations, actioned.
The following is a list of potential recipients of data (in each case including respective employees, directors and officers):
- Employees of The Group who received the appropriate training with regard to the GDPR and have signed The Group’s Confidentiality and Non-Disclosure Statement.
- Other service providers ( Legal, Administrative, Governance or otherwise, including any bank or financial institution, audit firm, accountant firm and/or related individuals in relation to the service for which The Group has been engaged) where disclosure to that provider of services is considered necessary to fulfil the purposes set out above;
- Any sub-contractors, Lawyers, third parties, agents or service provides of The Group;
- Courts or Tribunals
- Third parties with whom The Group engages for the hosting of events or other marketing initiatives;
- Law enforcement agencies where considered necessary for The Group to fulfil legal obligations applicable to it;
- Regulators or other governmental or supervisory bodies with a legal right to the material or a legitimate interest in any material;
- Any registrar of a public register where the data is to be included in a public registry.
Unless expressly declared in this Privacy Notice or with the prior consent of the individual, personal data collected from an individual will not be disclosed to any third party other than the above-named parties.
Where The Group is entering into an engagement with a third party pursuant to which data may be processed by that third party, The Group will seek to enter into an agreement with that third party setting out the respective obligations of each party and it will seek to be reasonably satisfied that the third party has measures in place equal to those of The Group to protect data against unauthorised or accidental use, access, disclosure, damage, loss or destruction.
In the event that any such third party is outside of the European Union and where the data being transferred would include personal data which would be protected under applicable Data Protection regulation The Group will ensure that it meets the relevant requirements of that Data Protection regulation prior to carrying out any such transfer. This may include only transferring the data where The Group satisfied that:
- The non-European Union country has Data Protection laws similar to the laws in the European Union;
- The recipient has agreed through contract to protect the information in the same Data Protection standards as the European Union;
- We have obtained consent from relevant data subjects to the transfer;
RIGHTS OF DATA SUBJECTS
Data subjects in the European Union (or any jurisdiction with equivalent legislation to the European Union General Data Protection Regulation) have certain rights in respect of their personal data. Any such data subject wishing to exercise any rights under applicable data protection laws (including the right to withdraw any consent to processing previously given (Any withdrawal of consent shall not affect the lawfulness of processing based on the consent before it was withdrawn or revoked) ; the right of access to data; or to have data corrected, updated, rectified or erased; or for access to data to be restricted or provided to any third party; or to object to any particular processing; or to lodge a complaint with the relevant supervisory authority; or the right to data portability) should send the request in the first instance to [email protected].
In response to such requests, The Group reserves the right to require the individual making the request to provide certain details about himself/herself so that The Group can validate that the individual is indeed the person whom the data refers to. The Group is required to respond to the request of the individual without undue delay and latest within one month of receipt of the request and it will endeavour to do so wherever possible. The Group reserves the right to charge a reasonable fee to cover any expenses that may arise from the request.
In any case in which a data subject chooses not to provide any personal data, or where any of the rights set out above are exercised to limit the processing of personal data, The Group may be unable to provide relevant services, or there may be restrictions on the services which can be provided.
RETENTION OF DATA
The Group retains personal data in accordance with its Data Retention Policy. Any personal data provided to The Group is retained according to such policy, to fulfil the purposes for which the data was collected. Once the business relationship has been terminated, we are obliged under the relevant AML Laws and Regulations to maintain these records consisting of personal data, for a period of minimum 5 years.
Any requests for further information in relation to the continued processing of specific data and requests for destruction of data should be made to [email protected] .
USE OF PERSONAL DATA IN LEGAL PROCEEDINGS
If it becomes necessary that The Group has to take action against you for any reason whatsoever, including but not limited to recovering from you any money you owe to The Group, you expressly agree that the personal data provided by you can be relied upon in identifying and taking legal action against you
CHANGES TO THIS PRIVACY NOTICE
The Group keeps this Privacy Notice under review in order to ensure that it is in line with any changes to the laws relating to privacy and personal data. Any updates will appear on The Group’s website at www.thesamirgroup.com
This Privacy Notice was last updated on 23 May 2018.
COMPLAINTS PROCEDURE
All enquiries in respect of this Privacy Notice or any requests to exercise any of the rights set out above should be directed to the designated email address [email protected] or by post at: Igoumenitsas 12, CONNECTEDSKY HOUSE, 2027, Strovolos, Nicosia, Cyprus.
NOTE:
The General Data Protection Regulation (EU) 2016/679 shall apply from 25 May 2018. Until then the Processing of Personal Data (Protection of Individuals) Laws 2001 until 2012 remain in force.
For any additional information about your rights under the data protection regulation you may visit http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_en/home_en?opendocument
THE SAMIR GROUP LOYALTY CARD – TERMS AND CONDITIONS
Terms & Conditions
1. These present terms and conditions should be read carefully.
2. Definitions:
2.1. Customer: The individual person, either male or female or other who wishes to apply and become the Customer.
2.2. Loyalty Account (hereinafter the ‘Account’): the digital membership account which will be created by following the instructions uploaded from time to time in the Group’s official website.
2.3. Loyalty Card (hereinafter the ‘Card’): The Card issued and provided to the Customer with which the Points will be collected and stored for redemption.
2.4. Loyalty Points (hereinafter the ‘Points’); The Points rewarded to the Customer with each purchase as per the present terms and conditions.
2.5. Loyalty Program (hereinafter the ‘Program’): the reward scheme as this is described in these present terms and conditions.
2.6. Participating Stores: The participating stores shall be Bastet Artisan, Gastroland Project and Bull N’ Gold.
2.7. The Companies: The Companies as those are disclosed in the Group’s official website at www.thesamirgroup.com.
2.8. The Samir Group (hereinafter the ‘Group’): The Group of Companies as this is defined in the Group’s website at: www.thesamirgroup.com.
3. The terms and conditions (including the Privacy Policy which can be accessed at www.thesamirgroup/privacy-policy) govern the Loyalty Card Program, which includes the collection and use of Points and sets out the terms of contract between The Samir Group and the Customer relating to the said Loyalty Program.
4. The Customer may participate in the Loyalty Program by applying for a Loyalty Card in participating stores and he/she will be eligible to receive a Loyalty Card which can be used to earn Points on the same Loyalty Account. The Customer may participate in the Loyalty Program by applying for a Loyalty Card in participating stores and he/she will be eligible to receive a Loyalty Card which can be used to earn Points on the same Loyalty Account.
5. Upon application for registration to the Loyalty Program, the Customer unconditionally accepts these present terms and conditions.
6. The Samir Group may refuse an application of a Customer for participation to the Loyalty Program for any reason and at the Group’s sole discretion including (but not limited to) risk of reputational damage, any reasonable suspicion of previous criminal activity including shoplifting or any previous history of verbal or physical abuse to The Samir Group staff.
7. To register for the Loyalty Program, the Client will complete an application form which will be provided in any Participating Store or register for a Loyalty Account through the Group’s website at www.thesamirgroup.com.
8. A loyalty account will be created in the Customer’s name to record Points to be earned or redeemed by the Customer.
9. The Customer must be at least 16 years of age and resident of Cyprus to be allowed to join the Loyalty Program.
10. The Loyalty Card is issued and provided to the Customer however it remains property of The Samir Group. The Customer is obliged to return the Loyalty Card to the Group on request or destroy it if the Group reasonably requests so.
11. The Customer is, at all times responsible for the security of the Loyalty Card, the security details relating to the Loyalty Account and for the transactions and/or redemption of Points made using the Loyalty Card. The Customer should not share the Loyalty Account username and password with anyone, including The Samir Group staff.
12. If the Loyalty Card is being misplaced or lost or if there is any use from an unauthorized person or such person has become aware of any security codes, passwords, or Loyalty Card numbers the Customer must promptly contact the Group using the following details:
Tel: 70003533Tel: 70003533
Email: [email protected]
Or by visiting any of the Participating Stores.
13. The Loyalty Program is only for individual consumer use only. The Loyalty Card cannot be used for any transaction where the eligible person is a business entity or for any other commercial purposes. The Loyalty Card cannot be used as a credit card or a guarantee card.
14. The collected Points are personally allocated to the Customer and may not be transferred to third person. Loyalty Points may only be redeemed and earned in accordance with these terms.
15. If the Customer materially breaches any of the present terms, and where any such breach can be remedied, if the Client fails to remedy the breach within 30 days of a written notice the Loyalty Card may be terminated and/or cancelled, any Points earned but not redeemed may be cancelled and the Loyalty account will be closed without prior notice. The Samir Group reserves the right to take any action deemed necessary where a Loyalty Cardholder is found to have abused the Loyalty Program.
16. The Samir Group will provide the Customers with information about current promotions, program benefits, rewards and updates using the valid email address and/or mobile number provided in the application form.
17. The Samir Group reserves the right to (i) stop issuing Loyalty Cards at any time if it is decided to terminate the Loyalty Program; (ii) to alter or amend the terms and conditions of operation of the Loyalty Card and/or the Loyalty Program by publishing notices on the website www.thesamirgroup.com; and/or (iii) withdraw or cancel the Loyalty Card and/or the Points (including but not limited to the redemption and issue of such) and/or Loyalty Account on reasonable notice to the Customer by letter, email, sms/text message or publishing such notice on the website at www.thesamirgroup.com.
18. The Samir Group may cease the Loyalty Reward Program at any given time, with or without any prior notice.
19. The Privacy Policy relating to the Loyalty Program (which can be accessed at www.thesamirgroup.com/privacy-policy) sets out the information that will be collected about the Customer, how the information is being used and whom it may be shared with including, but not limited to, details of the promotional information.
20. The Group encourages the Customers to visit the Group’s official website for further information on the collection, processing and safekeeping of the personal data collected at https://thesamirgroup.com/privacy-policy.
21. The Group will retain the Customer’s personal information for as long as the Customer is a member of the Loyalty Programme. The Customer may cancel the membership at any time by contacting the Group at [email protected].
22. The Loyalty Program and these present terms and conditions will be governed by the Laws of the Republic of Cyprus and any disputes may arise between The Samir Group and any Customer shall be brough before the District Courts of the Republic of Cyprus.
23. The Customer may only apply in the Program for him/herself and may only participate in the Program using his own membership card or account. The Customer may not participate in the Program on behalf of other persons.
24. The Customer agrees that any information provided is accurate and true. The Customer agrees to comply with all terms and with the terms of any affiliated and/or related programs, always offers and promotions. The Customer agrees that his/her participation in the Program is entirely at his own risk.
Collection of Points
1. To collect Points for a transaction in a participating store, the Customer should present the Loyalty Card at the till at the time of purchase.
2. The Customer should make purchases of at least €1 in a single transaction for the purchase to qualify for Points. For every €1, the Customer will be awarded with 5 (five) Points.
3. The above reward scheme may be altered at the discretion of The Samir Group at any given time and without any prior notification to the Customer. Relevant announcements will be released in the Group’s website and/or via email and/or via sms/text message or otherwise.
4. The Customer will be entitled to participate in the following reward schemes:
• Within a period of twelve months, for purchases up to €2.499 the reward will be 5%. For example: for a Purchase of €10 the Customer will receive a reward of €0.50.
• Within a period of twelve months, for Purchases between €2.500 to €4.999, the reward will increase to 7.5%. For example: for a Purchase of €10 the Customer will receive a reward of €0.75.
• Within twelve months, for Purchases over €5.000, the reward will increase to 10%. For example: for a Purchase of €10 the Customer will receive a reward of €1.00.
The percentage of the reward will increase automatically once the Customer reaches any of the above purchase tiers.
5. The Points will be rewarded based on purchases or parts of purchases paid without the use of redemption of Points. For example, where a purchase is €25 and the Customer redeems Points equalling to €5, the new rewarding Points will be calculated on the amount payable on the amount of €20 and not the total amount of €25.
6. The Samir Group reserves the right to offer bonus Points on certain products as selected from time to time and in the Group’s sole discretion.
7. Points will be credited to the Loyalty Program instantly, except in the circumstances of system failure when it is expected that Points will be loaded within 48 hours from the time of purchase. In most circumstances any bonus Points earned will be credited to the Loyalty Program 48 hours after the date the goods are purchased. Points cannot be redeemed until added to the Loyalty Account.
8. The Customer may receive Points and make use of the Loyalty Card rewards in all participating stores of the Samir Group.
9. The Group is entitled to cancel Points awarded if the relevant products to which such award relates to are returned and a refund of the purchase price is given.
10. If the relevant products are exchanged for other products, the Points awarded should be adjusted upwards or downwards depending on whether the exchange is for a higher or lower value item.
11. The Group reserves the right to invalidate purchases credited to the Customer’s Loyalty Card if it was proved that that such purchases were improperly credited to the Customer or obtained fraudulently. The Group reserves the right to require proof of qualifying purchases and reserves the right to delay the processing of any reward, without notice in order to assure compliance with these Terms.
Redemption of Points
1. Each collecting period starts once the loyalty card is being activated and should be valid for the next 12 months. Upon expiration of the 12-month period, any Points shall be cancelled, and the available balance will be zero.
2. Points may not be redeemed for cash or other benefits. Customers may not make use of the Points while another offer is running and may not be combined with other, campaigns and promotions.
3. Points may be redeemed in the next purchase of any of the Participating Stores.
Membership Termination of Modification of Loyalty Program
1. The Customer may remove himself from the Program by requesting cancellation of his membership by sending an email at: [email protected].
2. Cancellation may take up to ten (10) business days to finalize. During that period, the Customer may receive promotional emails and may make use of the benefits of the membership like for example to redeem the available Points.
3 The Customer will forfeit his entitlement to any Loyalty Program rewards immediately upon deactivation or termination of his/her membership.The Customer will forfeit his entitlement to any Loyalty Program rewards immediately upon deactivation or termination of his/her membership.
4. If the Client does not make a qualifying purchase during a period greater than twelve (12) months, his membership card and account balance may be reduced to zero.
5. The Samir Group reserves the right to deactivate any Member account that has not earned a qualifying purchase during a period greater than twelve (12) months.
6. The Samir Group reserves the right, at its sole discretion, to (a) suspend, change or terminate the Program, any individual promotion, any benefit, any Customer’s membership in the Program, in whole or in part; (b) modify, limit or suspend the use and/or redemption of any participation credit, such as qualifying purchase credit, in any respect; (c) modify or change redemption procedures, including the amount of participation credit required for particular rewards; (d) modify, limit or suspend the collection of participation credit, including but not limited to imposing time limits and changes in participation credit values.
7. The Customer’s continued participation in the Program after any modification to the Program and/or these Terms will indicate his/her acceptance of any such modification. The Customer expressly agrees to assume responsibility for reviewing the Terms for any updates or modifications. If the Customer does not agree to any changes to the Program or these Terms,
8. He/she must cancel his membership card and/or account (and forfeit any unused participation credits and/or rewards).
Limitation of Liability
1. Neither the participating stores nor The Samir Group, its parents, affiliates, or subsidiaries, affiliates, suppliers, or any of their officers, directors, employees or agents shall have any responsibility or liability for any claim, loss, injury, damage, delay, accident, cost or expense (including, without limitation, attorneys’ fees and costs of suit), nor for any incidental, indirect, special, punitive, exemplary, or consequential damages (collectively, “losses and damages”), directly or indirectly arising out of or related to (i) these terms (ii) the program, or Website (iii) any failure, delay or decision by the Company or Group in administering the program (iv) any unauthorized use of a card or any breach of security beyond our reasonable control (v) any offer, representation, statement or claim about the program; or (vi) the purchase, redemption for or use of any rewards.
2. By participating in the program the Customer hereby agrees: (a) to release The Samir Group and all of its affiliates, subsidiaries, franchisees, program partners, vendors, distributors and independent contractors, and each of their officers, directors, employees and agents from any and all liability, loss or damage incurred with respect to the issuance, receipt, possession, and/or use or misuse of any reward; (b) under no circumstances will the Customer be permitted to obtain rewards for, and he/she hereby waives all rights to claim, punitive, incidental, consequential, special or any other damage or loss, other than for actual out-of-pocket expenses; (c) all causes of action or claims arising out of or connected with the program, or any reward shall be resolved individually, without resort to any form of class action; and (d) any and all claims, judgments, and awards shall be limited to actual out-of-pocket costs incurred, excluding attorneys’ fees and court costs.
