Company Name: The Sand Trading LLC
Company Number: 2273596
Territory: International

The best bits
We only use your data to improve your Sand experience

Keeping it real
We’ll talk to you straight – no stress, no worries

No junk
You choose what and how we speak to you

Super safe
Your data is protected 24/7
Everything we do at Sand is about you! Things change, but it’s nothing to worry about. We take our customers privacy and security very seriously and we are 100% committed to protecting it so you can shop away without a single worry. If you have any questions about how we protect your privacy, just shout us at contact@thesandgroup.ae

HOW WE USE YOUR DATA
We are committed to protecting your privacy. It is important that you understand how we look after your personal data and how we make sure that we meet our legal obligations to you under the data protection rules and regulations in the relevant territory (including associated guidance) (the “Data Protection Laws”). This privacy policy outlines how The Sand Trading LLC will collect, use, store and share your personal data.

If you have any questions in relation to this policy or generally how your personal data is processed by us, please contact our customer care team by letter addressed to: Warehouse 2, Corner of 22/13c Street, Al Quoz Industrial Area 3, PO Box 191314, Dubai, UAE; by email at contact@thesandgroup.ae; or by phone on +971 04 333 5440.

This policy applies to any personal data that we collect about you when you:
*Visit one of our websites;
*Purchase products from us;
*Visit one of our stores;
*Contact us, for example by telephone, email, post or through submitting a form on our websites.

WHO ARE WE?
In this privacy policy, the terms “we”, “our”, and “us” are used to refer to The Sand Trading LLC and it’s subsidiaries and we are the data controller for the personal data you share with us. We will use your personal data fairly, lawfully and in a transparent manner in accordance with the Data Protection laws.

Consent
Sand may send you marketing messages by email, SMS, social media and post; about us and our products; where you have not unsubscribed and where you have purchased similar products and/ or services from Sand, or where you have otherwise signed up, or consented, to receive marketing messaged from Sand.

You have the right to withdraw your consent to processing of this nature at any time by contacting our customer care team using the details at the start of this privacy policy. You can tell us you no longer wish to receive marketing information from us by clicking on the unsubscribe link in any promotional emails.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?
If you have an account with us or make a purchase online with us, or enter a competition or respond to a survey with us, we collect your name and contact details (including your address, telephone number, details about your order, and your billing information (where you are purchasing products).

We also collect details of your interactions with us through our customer contact centres, in store, online or via our apps. For example, when you telephone one of our contact centres, we collect notes of our conversations with you and details of your query and from time to time we may record your calls for training and monitoring purposes. We also collect information about the purchases that you make, your saved items, your payment information, any complaints and comments that you make and your shopping preferences. We also collect CCTV images in all of our stores.

Each time you visit one of our websites, we will also automatically collect information and personal data about your computer for system administration including, where available, your IP address, operating system and browser type. We do this to help us analyse how users use the websites (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account and improving your online experience. We also collect information about your activities on our websites, for example what device you are using and what products you’re looking at.

Please see our Cookie Policy for further information about what information may be automatically collected when you visit our websites.

Please note that, from time to time, we will combine personal data that we receive from other sources with personal data you give to us and personal data we collect about you.

WHERE DO WE GET THIS INFORMATION FROM?
We collect some of your information directly from you, either through information that you give to us or information that we collect during your visits to our websites, stores, or through your communications with us. We may also obtain some information from third parties, including retail analytics companies, consumer insight companies and credit reference agencies and publicly available sources to assist us with understanding customer demographics and shopper behaviours, or where we merge with or otherwise acquire another business.

Information that you give us	You may share personal data about with us by: Filling in forms on our websites, including when you purchase products online, submit queries to us, create an account on one of our websites and/or sign up to receive promotional material and newsletters; Responding to a survey or entering a competition with us; Giving us information about yourself in any communication with us, either by telephone, e-mail, post or otherwise, either in connection with your account, purchases, or to report a complaint or issue. You are not obliged to provide your personal data to us. However, if you do not provide your personal data to us, we may not be able to fulfil your order or provide other services to you or respond to your queries.
Information that we collect about you	We collect personal data about you: *When you visit our websites, including details of your visits to our websites including, but not limited to, Internet Protocol (IP) address used to connect your computer to the internet, MAC addresses, traffic data, location data, your login information, time-zone setting browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access. For more information please see our [link to cookie policy] *When you link your Twitter, Instagram or Facebook accounts with us, to enable you to log onto our websites simply and securely without having to create a new account; *When you visit one of our stores, including CCTV images; *When you contact us in relation to our products, services, a complaint or another query or issue. In particular, calls to our contact centres will be recorded for training and monitoring purposes from time to time.
Information that we receive from other sources	We will receive personal data about you from other third parties, including: *In connection with any mergers or acquisitions where we obtain your information from another company. *When we work with retail analytics companies, consumer insight companies, credit reference agencies and through our use of information from publicly available sources.

WHY DO WE NEED YOUR INFORMATION?
The main purpose for which we use your information is to provide you with the products that you purchase from us and to send you offers and promotions that you might be interested in.
In particular, we use your information:
*To provide you with the products that you have purchased from us and any receipts of purchase, including to deliver your products, and to send you order status updates;
*To take payments for the products that you have purchased and to give refunds or exchanges;
*To provide customer service and support to you;
*To develop and improve our products and services;
*To develop and improve our websites and set default options for you (such as language and currency) and to ensure that content is presented in the most effective manner;
*To provide you with information that you request from us or which we feel may interest you. We may send you marketing information by email, SMS or post. This can include information about new products and offers that you may find interesting;
*To research our customers’ preferences and trending products;
*To run surveys and competitions;
*To notify you about changes to our products;
*To prevent and detect fraud and crime.

BASIS FOR USING YOUR INFORMATION

Compliance with legal obligations
As a corporate group there are certain laws we need to comply with. In particular, we will need to process your personal information to verify your identity and for fraud and crime prevention purposes. Failure to provide the requisite personal information on sign-up / as you use our websites, may mean we cannot provide our products to you, as to allow you to purchase our products may mean we may be in breach of our legal obligations. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.

Necessary for the entry into or performance of a contract

When you enter into a transaction with us, a contract between yourself and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place an order and receive products from us), we will need to collect and process your personal information. Failure to provide the requisite personal information on sign-up to an account or on placing an order and payment information or objecting to this type of processing / exercising your deletion rights will mean we cannot provide our products to you.

Legitimate business interests
We use your personal data as set out in this privacy policy for the legitimate interests of our business to enable us to:
*Provide you with products as requested by you;
*Carry out research to understand our customers and how they purchase and use our products;
*Develop and improve our products.

As indicated below, we will also pass your personal data to selected third parties and this is also for our legitimate business interests.

We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws and regulations in the relevant territory. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.

We have a legitimate interest in processing your information as:

Legitimate interest	*We both benefit from the effective management of your account(s) (where applicable); *We both benefit from the effective management, operation and administration of our websites; *We both benefit from the provision of products, services and support and from improvements to our services; *We both benefit from updates to our websites; *We will both benefit from the ability to enforce or apply rights under any contract between us; *We are required to ensure the health and safety of our customers and the security of our stored data and have a legitimate interest in ensuring any processes relating to the same are effective and that fraud and other crimes are prevented and detected; *We would be unable to provide our products and services without processing your information; and *We have a legitimate interest in processing your information in connection with any mergers, acquisitions or reorganisation of our business, in which case some of your information may be shared with a prospective buyer or otherwise but only so far as is strictly necessary for the purposes of such sale or administration.
Necessity	We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as we process your personal data only so far as is necessary to achieve the purpose outlined in this privacy policy.
Impact of processing	We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data does not unreasonably intrude on your privacy.

CONSENT
As set out above, we will send you marketing communications where you have not told us that you wish to unsubscribe and where you have purchased similar products and/ or services from us. You will also receive marketing communications from us where you have signed up, or otherwise consented, to receive marketing messages

You have the right to withdraw your consent to processing of this nature at any time by contacting our customer care team using the details at the start of this privacy policy.

WHO DO WE SHARE YOUR INFORMATION WITH?
We do not, and will not, sell any of your information to any third party, including your name, address, email address or credit card information. However, we do share your information with a number of select third parties to enable us to provide our products and services to you, to send marketing information and to improve our business operations as set out below.

We will also use a number of carefully selected third parties to help us to provide you with products, services and to market to you. In particular, we disclose your information to:
*Companies that do things to get your purchases to you, such as payment service providers, warehouses, order packers and delivery companies;
*Our trusted service providers, such as marketing agencies, advertising partners, website hosts and other third parties who provide services to help us to tailor our marketing to you;
*Credit reference agencies, law enforcement and fraud prevention agencies;
*Companies approved by you, such as social media sites, including companies such as Facebook and Google; and
*We will provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.

We will only share your information with third party suppliers where it is necessary for them to provide us with the services we need.

We may disclose your information to other companies in connection with any merger, acquisition, insolvency situation or otherwise, in which case we will only disclose your information so far as is necessary.

We may also need to disclose personal data to third parties to comply with a legal or regulatory obligation, or if necessary for legal proceedings.

WHAT AUTOMATED DECISIONS DO WE MAKE ABOUT YOU?
We carry out some profiling of you for the purposes of improving and developing our products and services and to help us to tailor our marketing to you.
The impact of any automated decision is to ensure you experience the best service possible.
We use information that we learn about you such as your gender, preferences, hobbies, interests and purchase history to make sure the marketing you receive from us and the way our websites are displayed to you are appropriate and tailored to you.

WHERE IS YOUR INFORMATION STORED AND HOW LONG DO WE KEEP IT FOR?

Transfers outside of the European Economic Area
The information which we collect about you may be transferred outside the European Economic Area. In the event of such transfer, we will ensure the adequate standard of security is in place for example by incorporating the European Commission approved clauses into our agreements with such third parties to ensure the security of your personal data.

Retention of your personal data
We will only keep your information for as long as is necessary to carry out the purposes we collected it for, as set out in this privacy policy (unless a longer retention period is required by the applicable law). We typically keep your personal data for 6 years from the purchase in order to enable us to deal with any issues or concerns you may have about the products or services you have received, and to allow us to bring or defend legal proceedings. In some circumstances, some of your data will be deleted in much shorter timescales, for example:

*Cookies are deleted in accordance with our Cookies Policy
*CCTV images are kept for 60 days;
*Marketing consents will be refreshed/deleted after 4 years, however, our aim is only to market to you for as long as we believe you want to continue hearing from us based on how you interact with us.

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we will also keep hold of some of your information, even if it is no longer needed to provide our services to you.

Security of your personal data
Transmission of information via the internet is not and cannot be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

WHAT NON-PERSONAL IDENTIFIABLE INFORMATION DO WE COLLECT?
We may also collect non-personally identifiable information (that is, information that does not specifically identify you), for the purposes of aggregates and statistics.

WHAT RIGHTS DO YOU HAVE?
You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. You may contact us using the details at the beginning of this privacy policy to exercise any of these rights.
In some instances, we may be unable to carry out your request, in which case we will contact you to explain why.

1. You have the right to request access to your personal data	You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.
2. You have the right to ask us to rectify your personal data	You have the right to request that we rectify your personal data if it is not accurate or not complete.
3. You have the right to ask us to erase your personal data	You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply if we no longer need to use your personal data to provide products to you, where you withdraw your consent for us to send you marketing information, or where you object to the way we process your personal data (see right 6 below).
4. You have the right to ask us to restrict or block the processing of your personal data	You have the right to ask us to restrict or to block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don’t need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims.
5. You have the right to port your personal data	You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you.
6. You have the right to object to our processing of your personal data	You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.
7. You have the right not to be subject to automated decisions	You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.
8. You have the right to withdraw your consent	You have the right to withdraw your consent where we are relying on it to use your personal data, for example where we are relying on your consent to send you marketing information.

Marketing
We always give you the choice of whether or not you wish to receive marketing communications from us.

By contacting us at contact@thesandgroup.ae you can tell us that you do not wish to receive marketing communications from us and we will update your records. You can also click on the unsubscribe link in any promotional emails.

WHAT IF YOU HAVE A COMPLAINT?
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request made by you, or would otherwise like to make a complaint, please contact our customer contact centre in the first instance using the details at the start of this privacy policy, so that they can do their very best to sort out the problem.

OTHER WEBSITES
Our websites may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites.

CHANGES TO THIS PRIVACY POLICY
We will take all measures necessary to communicate any changes to this privacy policy to you, and will post any updated privacy policies on this page.

This policy was last reviewed and updated in May 2024