Last Updated: 01.02.2024

Hello and Welcome to our Privacy Policy!
This privacy notice aims to give you information on how Samo collects and processes your personal data through your use of our App, including any data you may provide through our App when you set-up a user account.

You need to approve the Samo Terms of Use and Samo Privacy Policy before you can start using the Samo App. If you do not agree to the terms in this Privacy Policy, you should not use any services provided by us. If you want to contact Samo, but on the condition that your information is not used for the purposes explained below, you need to state that in your communication with us.

1. Introduction and Basics

This Privacy Policy includes information on the principles we adhere to and our practices regarding privacy of your personal information that we collect and process. Information that is not considered personal data, falls outside the scope of this Privacy Policy.

We may update this Privacy Policy from time to time, for instance when we start providing new services or when changes in regulations oblige us to provide you with new information. Updates are binding from the update date onwards. Therefore, we recommend you to visit this page regularly and get most up-to-date information on the policy applied to your personal information.

Data Controller for the information you provide to Samo is Samo Culture and Tourism Co., Ltd

As stated in our Terms of Use, Samo we provide is directed at persons older than 18 years. If you are younger, you may use our services only via your parent or legal guardian and under their supervision. If you provide us with any information about children, you guarantee that you have the permission of their parent or legal guardian to do so.

Purpose of this privacy policy is:

To explain, in the most transparent and readable way possible, our ways and purposes of using the data we collect for creating a better mobile app and providing a better experience for you;
To clarify the types of information we collect upon your permission and the purposes and methods for processing of them;
To inform you on the third parties we transfer this information to as well as our purpose and method in doing so;
To let you know your legal rights with respect to your personal data;
To describe the extent of our responsibility for protection of your rights and privacy.

2. General Principles

We will always act in compliance with applicable regulations and respect your personal rights to the greatest extent.

We want you to know that we will always adhere to the following principles as a result of the caution and respect we have for your personal information:

We will act lawfully and fairly and we will be transparent about our processing activities.
We will take necessary steps to ensure that your information is accurate, and when necessary, up to date.
We will process your information for specified, explicit and legitimate purposes and only as long as we need to process them. We will not use your information for any purpose incompatible with those original purposes.
We will only process information that is adequate, relevant and limited with our purposes. Which means we will not request from you any information we do not need and we will dispose of any information that becomes irrelevant.
We will ensure safety of your personal information and take necessary measures to protect it against unlawful access, damage, and destruction.

In the following parts of this Policy, you may find detailed information on how we will apply these principles in practice.

3. What Information We Collect

We collect following information through the Samo App and other ways you share information with us:

Information you give to us by yourself while registering to our Mobile App or while using or contacting Samo, such as your name, birthdate, telephone number and e- mail address, some of which may identify you personally.
Information we generate or obtain during your use of Samo, our website or other services we provide. Examples to this include your IP Address and location, the advertisement ID assigned to your device by our partnered advertisement service providers, audial tours that you purchase and use; information relating to the browser and device you are using, other information necessary to identify your device, account information for the platform you use (e.g. IOS App Store or Google Play Store) to download the App and to purchase the in-app content; technical information of the device you use, your language preferences, information collected from your device’s sensors and receptors such as your momentum, direction etc. and your interactions with our services such as the tours and webpages you have viewed.
We may also match the information gathered from our third-party business partners with your user profile. An example of this is the information transmitted by Facebook to us when you register with Facebook. When you use apps or websites that we have partnerships (direct or indirect) with, information related to your use of such webpages may be transmitted to us.

If you fail to give information to us, or in case you mislead us with the information you give, you may be unable to use our services.

When your information changes, you can update most fields through the settings section of our App.

4. Why We Use Your Information

We use the collected information for following purposes, each with some examples in following paragraph, but our use is not limited to those examples and may include similar other uses:

To facilitate your use of our App and listening of the audial tours.
For instance, when you download a tour, we understand which point in the tour’s route you are at and give you the information about that part of the tour, thanks to your location information.
To let you utilize your user account.
We match your purchased tours with your user account so that when you change your device, you can listen to them in your new device by logging in to your account.
To recognize and help you with our customer support.
When you contact us for a problem you are facing in the app, we may use the technical information we have about your device to understand the underlying reason and to find a possible solution.
To provide better services.
By following your interactions with our app, we can keep track of which tours are most used and ensure that the new tours we provide are interesting for all of our users.
To contact you when needed.
When there is an issue related to a payment you make, we may contact you to resolve it. Or when you contact us through different channels, we record those communications so we can look into the issue and respond to you.
Advertisement and Marketing.
Thanks to the information we have, we can create exclusive promotions for you and let you know. Besides we can show you personalized advertisements based on information that we and/or our partnered advertisement service providers have obtained. Additionally, we can offer benefits for recommending us to your friends and then we use the information of you and your friend to validate such benefits.
We do not send marketing material unless we have your prior approval. If you have given approval, we can send you promotional bulletins related to Samo and other services that we think may be of interest to you.
To ensure the safety and security of our services.
We may need to make various controls and examinations on your personal information to prevent unlawful and fraudulent transactions. These procedures may include automatic algorithms as well as human effort under set rules.
Other instances based on your request.
When we allow you to interact with other users or review our tours, we need to use your information to facilitate your interactions and to publish your review
To meet our legal obligations and to resolve disputes.
Some legal regulations bring rules governing our use of your information. Other regulations in various fields such as tax and commerce may also require us to retain information relating to our operations (which may include your information).
Also when there is a legal dispute, we may review the information we hold and serve it to courts and other authorities.

5. Our Legal Basis for Processing Your Information

We may need to process your personal data for performance of the contracts executed between you and us when you start using our App or other services and then when you download audial tours.
We may use your personal data for our legitimate interests unless such use is against your interests in a way overriding our legitimate interest. For instance, we may use the information about your past transactions for giving you the means to review your activity log as well as to make statistical research which help us improve our services.
We may rely on your consent for purposes such as sending you marketing material and obtaining your opinion in voluntary surveys. In those cases, you can always withdraw your consent by sending a notification by e-mail to samoaudioguides@gmail.com. You should include information that enable us to recognize you in that notification. Your notification of withdrawal of your consent will be effective in the future and therefore will not make our prior processing unlawful but it will make us cease to process those information from the receipt of your notification onwards.

6. Cookies and Tracking Mechanisms

When you use our App or website, we or our business partners may place cookies (small text files) to gather information on your use and to utilize the information for providing our functions, managing our infrastructure and marketing. If your wish is not to accept those cookies, you may change the settings of your browser to reflect that. Cookies stored on your local drive are expired after a certain period of time and you can delete them any time through respective settings of your browser. But your refusal of cookies may hinder with your use of our website and other services.

This website uses a web analytics tool named Google Analytics developed by Google Inc. Google Analytics utilizes cookies and other identifiers to help website owners analyze the use of their website by their visitors and for rendering of the services provided by Google. Information related to your use of the website may be transferred to Google’s servers located in various countries and be processed by Google at those locations. Google shall use this information for analyzing your use of web, drafting reports on the use of website for website owners and providing other services related to internet use (e.g. creating user segmentations). Google may transfer this information to third persons upon legal obligations and/ when third persons process this information on behalf of Google. If you do not want your information to be used for Google Analytics, you may use the following link to opt-out: https://tools.google.com/dlpage/gaoptout/

7. Transfer of Information to Third Parties

We make use of third party service providers that help us with providing better services. Our use of those third-party service providers sometimes requires us to share some information with them. But in any case, we will keep being responsible for safety of your personal data and inform you on those transfers, whenever it is feasible to do so. Besides, we will never sell your information to any third party that uses them for purposes incompatible with those we state here.

We utilize some third-party services and software such as Fabric, Mapbox, Google, Amplitude, Branch, Admob, Adjust and Netmera to provide some features (such as maps and advertisements) within our App. We may transmit some information about your registration as well as your device model, software, viewed area, location, user behavior and habits to these providers for them to help with developing and providing our services. We take necessary guarantees from them to protect your information and to use it for specified purposes only. They may transfer your information when they are using another third party service provider (subject to the same guarantees) or in other lawful cases.

You may purchase the digital content within the Samo App via App Store or Google Play Store, depending on the device you are using. In those cases, you give your payment details including credit card and billing information to the respective store and we have no access to those. Yet Samo may transfer to the respective store a limited portion of information such as the name of the content you purchase to facilitate the payments and those platforms may match this information with the user account you use there which enables you to use your content on any device you use with the same store account. Responsibility for the information held by the respective store belongs to you and the operators of those stores only. We recommend you to view their privacy policies for more guidance on these subjects.

We can charge you through your mobile carrier for the digital content within our app if you use the carrier(s) we are associated with. In those cases, we may transfer your phone number, name and surname as well as other information related to your account and purchase to the respective carrier for facilitation of the payments to our associated mobile carrier.

When we accept credit card payments or other methods that may be of use to you, we transfer your payment information as well as some account information to our payment service providers for realizing the payments and prevention of fraudulent transactions.

We often collaborate with third-party business partners to provide discounts and free content to you. In those cases we may transfer the information that you need to provide in order to utilize the promotion as well as some of your account information to those third parties for enabling you to benefit from the promotion and to prevent fraudulent participations and misuse.

Law enforcement agents and other authorities may request information from us. We will share your information only when there is a legal obligation to do so; or when it is necessary to prevent and/or prosecute a crime and all those transfers will be lawful at all times.

8. Transfers to Third Countries

By approving this Privacy Policy, you agree to international transfer of your personal data. Our Information Technology infrastructure and servers are located within China. You should know that these countries where we transfer your personal data may include those not designated as providing adequate legal safeguards for protection of personal data by China. Also, some of the third parties stipulated above may be located in various countries. We guarantee that your personal data is only transferred to countries regarded to be providing adequate safeguards or to parties that guarantee to ensure the safety of your personal information.

In case you do not approve those international transfers, you should stop using our App as well as other services we provide and you should request erasure of your information by sending an e-mail to samoaudioguides@gmail.com.

9. Data Retention

We keep your personal data only for a reasonable amount of time that allows us to provide our services and meet legal requirements. Some information including your e-mail address, name and purchase history are retained for the time period your user account remains active. After your account has been deactivated, we keep retaining the information to meet legal requirements and to keep statistics which help us improve our services. The period we keep the information such as usage statistics and interactions with the App may be shorter. These periods always overlap with the amount of time that the information remains relevant and reasonably up-to-date and may vary from one category of information to another. After those retention periods, we delete or anonymize your personal information so that they can no longer be associated with you. To request erasure of your information before the retention periods end and to request more information about this issue, you may always contact us on samoaudioguides@gmail.com.

10. Information Security

In line with the personal data protection rules of China, we take reasonable measures to prevent unauthorized access to and unlawful use of personal data. We give priority to privacy and protection of personal data from the beginning until the end of our business processes and we provide you privacy-enhancing options as default.

The measures we take for protecting the personal information you give us includes both technical and physical restrictions. Only authorized and duly trained personnel can access your personal information and even their access is limited to the extent that they need it to do their job.

In case a data breach occurs despite all our efforts to prevent it, we will fulfil our obligation to inform you and relevant supervisory authorities about any breached information.

11.Your Rights

We want you to know that in line with regulations governing personal data you have following rights :

(a) To learn: if we process your personal data, the types of data we process, sources we get your personal data from, third parties we transfer your personal data to within the country or internationally, the period for which we keep the personal data or how we determine that period;

(b) To access your personal data and to request the data provided by you to be given to you or another data controller in a structured, commonly used and machine readable format,

(c) To learn the purposes for which your personal data is processed and to query if they are used in a compatible manner with those purposes,

(d) To object to and request restriction of processing of your personal data,

(e) To request rectification of inaccurate and incomplete personal data about you,

(f) To request erasure of your personal data when there is no legal basis for further processing,

(g) To request notification of procedures such as erasure and rectification to other third parties to whom your personal data has been transferred,

(h) To object to any negative consequences arising from automatic analysis of your personal data,

(i) To request indemnification for any damages arising from unlawful processing of your personal data.

You can these rights by sending an e-mail to samoaudioguides@gmail.com. Your application should include the information you have given to us while registering or making use of our services.

12. Your Right to Complain - Applicable Law and Competent Courts

You can e-mail us at samoaudioguides@gmail.com for issues related to this Privacy Policy. We will notify you of the result of your request within a reasonable period and at the latest within 30 days. Unless your request has been caused by our unlawful act and when it creates an extra burden for us, we may ask for a reasonable fee to be paid for completion of your request.