Data Protection

Data Protection Guideline

SnusArena understands that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data. SnusArena applies the prevailing regulatory framework pertaining to the processing of personal data and continuously strives to provide you with optimal integrity protection. We, in particular, comply with the statutory requirements of the Swiss Federal Law on Data Protection (DSG), the Ordinance to the Federal Law on Data Protection (VDSG), the Telecommunications Law (FMG) as well as the General Data Protection Regulation of the European Union (GDPR) and other applicable provisions of Swiss and European Data Protection Law.

This Data Protection Guideline is intended to help you understand how we collect, process and use your personal data, for example, whenever you create an account or purchase products from the website www.SnusArena.com (“the Website”).

Controller of personal data

SnusArena, SALT LABS Switzerland AG, Grabenstrasse 25, 6340 Baar, ZG, Switzerland, operates the Website. Accordingly, SnusArena is the controller for processing the personal data.

Security

We have implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized SnusArena personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, we cannot guarantee that unauthorized persons will not obtain access to your personal data.

Consent and changes to Data Protection Guideline

By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Data Protection Guideline and elsewhere on the Sites. We reserve the right to make changes to this Data Protection Guideline from time to time. We will alert you to any such changes by updating this Data Protection Guideline. If we make material changes to this Data Protection Guideline that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.

Use of personal data

We mainly use your personal data to fulfill our obligations to you – for example, to create an account and process, save, update and deliver your orders. Your data will also be stored for information and marketing purposes. This means that we may, while respecting our commercial interests, use your personal data to contact you through various information and marketing channels. Below you find information about each category of personal data concerned, and the purpose and legal basis for our processing.

Information submitted by you directly

  •          For customers

If you order a product on the Website, we ask you to provide the following information about yourself:

- First name*
- Last name*
- Street address*
- C/O
- Zip code*
- City*
- Country
- E-mail address*
- Telephone number*
- Payment information*

Fields marked with an * are mandatory fields.

We require this information in order to process (save, update and deliver) your orders and administer potential returns. If you do not provide the above information, we will not be able to process your orders. The legal basis of processing of such data for these purposes is the performance of a contract (order and purchase agreement; see art. 6 para. 1 lit. b GDPR) as well as our legitimate interest in being able to administer possible returns (see art. 6 para. 1 lit. f GDPR).

We further ask you to provide your birth date when first entering the Website. We require this information in order to verify your age. The legal basis of processing of this data is our legal obligation to comply with age limit limitations for the sale of tobacco products.

Furthermore, we process your orders and payment details based on our legal bookkeeping obligations.

Finally, we maintain and process your order history, i.e. information about what items you ordered, such as number of items, date of order and item price. We maintain such data in order to provide you with post-order services, as well as to handle any potential complaints. The legal basis for this processing is our legitimate interest in providing the best service possible, in contributing to the safe use of our goods, and in safeguarding our rights in connection with any potential complaints (see art. 6 para. 1 lit. f GDPR). We further process the above data to comply with our legal obligations relating to product safety requirements, as applicable.

  •          For account holders

When you create an account on the Website, we ask you to provide the following information about yourself:

- First name*
- Last name*
- Telephone number
- E-mail address*
- Password*
- Confirm password*

Fields marked with an * are mandatory fields.

We require this information for the purpose of account creation and administration. The legal basis of processing of such data for this purpose is our legitimate interest in administering your account (art. 6 para. 1 lit. f GDPR). You can reject this data processing at any time. However, we are then not able to further administer your account and will close the account.

  •          For you who contact customer service

When you contact our customer service, we potentially collect the following information:

- First name
- Last name
- E-mail address (if you contact us by email at info@SnusArena.com)
- IP-address (if you use our Live Chat)
- Telephone number and address
- Content of your query

We process this information in order to administer the customer service matter. The legal basis of processing of this data for the above purposes is our legitimate interest in administering the customer service matter and in providing you with good service (see art. 6 para. 1 lit. f GDPR), as well as our potential legal obligations e.g. product safety requirements.

We further process your IP-address when you use the chat function to provide improved service. SnusArena uses SnapEngage Live Chat to provide customer service and live chat functions. SnapEngage Live Chat is provided by SnapEngage, LLC., 1722 14th St., Suite 220, Boulder, CO 80302, USA The data is stored in the EU. SnapEngage uses cookies to ensure that customer service can see how a visitor moves on the site and that customer service can provide support between sessions. For this purpose we rely on our legitimate interest to continually improve our services (see art. 6 para. 1 lit. f GDPR).

  •          Visitors to the Website

When you visit the Website, SnusArena collects the following information (see also SnusArena’s Information about cookies and other tracking technologies). Note that certain other companies than SnusArena also collect your IP address when you visit the Website, in connection with the use of third-party cookies. How this occurs, and how you can go about limiting or turning off cookies in your Web browser, are described in SnusArena’s Information about cookies.

- Device information: your MAC or IP address and settings on the device you use to access our services, the operating system of your computer and the browser used (type, version and language)
- Name of the owner of the IP address range (usually your Internet access provider)
- Date and time of access, name and URL of the data retrieved
- The website from which our domain was accessed (referrer URL)
- The transmission protocol used (e.g. HTTP/1.1)
- Login information: when and how long you use our services, search words you enter when using our services and all information stored in the cookies we install on your device
- Location information: the GPS signal from your device or information concerning nearby Wi-Fi access points and mobile towers that may be sent to us when you use our services.

We use your IP address to direct you to your country´s website, to prevent infringements, incidents and other misuse of our services on the Website, to run statistics on visitors to the Website and to update and improve the Website. It may further be used for identification purposes in criminal proceedings and in the context of civil and criminal proceedings against the concerned individual, as necessary and required.

We further process the above data for the purpose of allowing the use of our Website (establishing a connection), ensuring system security and stability in the long term and allowing our Internet offering to be optimized, as well as for internal statistical purposes

The legal basis for this processing is our legitimate interest in ensuring system security and stability in the long term, preventing misuse and in having a properly functioning Website (see art. 6 para. 1 lit. f GDPR).

Data recipients and data transfers

SnusArena may share your personal data with other companies within the SnusArena Group, as well as with collaborating partners, for example when providing IT and payment services, to the extent required for the use of the Website and contract performance, namely for the processing of your orders, for facilitating the delivery of your orders, for processing your payments, for the provision of our services, and to analyze your user, order, and payment patterns. The use of the disclosed data by third parties is strictly limited to the mentioned purposes. These recipients only process your personal data on our behalf and in accordance with our instructions.

SnusArena may also share your personal data with other companies who do not process your personal data on behalf of SnusArena, but rather under their own control and in their own interest, for example companies providing shipping and payment services. We only share your information with these companies in order to fulfill our commitments towards you. When your personal data is shared with these companies, which are independent controllers, your personal data is processed in accordance with what is outlined in these companies’ data protection guidelines.

SnusArena may also share your personal data with governmental agencies if we are obligated under the law to do so, or on suspicion of criminal activity.

We are entitled to forward your personal data to third-party companies abroad and in particular to other companies in the SnusArena Group, insofar as this is necessary in connection with the purposes described above. These third-party companies are obliged to respect the privacy of users to the same extent as we are.

Data retention

Once you have created an account on the Website, your personal data is stored until your account is deactivated. Otherwise, we store your personal data only as long as is necessary for the purpose for which the data was collected. See more information under each purpose above.

We may also save your personal data for a longer time if it is necessary to fulfill a legal obligation that requires processing in accordance with applicable laws, such as legal retention obligations, or so that we can establish, enforce, or defend legal claims.

Your rights

You have in particular the following rights:

Right to access/extracts from the register. You have the right to know what personal data about you we are processing. Upon request from you, we will provide you with information in writing about our processing of your personal data, free of charge.

Right to data portability. You have the right to request a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format. Provided that it is technologically possible – which is determined by SnusArena – you also have the right to request that we transfer this personal data to another controller. The right to data portability applies to personal data that is processed via automated means, and that is based on the performance of a contract.

Correction of erroneous information. You have the right to request that we correct erroneous or incomplete information about yourself. If you have an account you may also correct certain information by logging in.

Deletion of certain data. You have the right to request that we delete your personal data under certain conditions, for example if your personal data is no longer necessary for the purpose for which we collected the data, if you object to a weighing of legitimate interests we have carried out and support for our legitimate interest is lacking, if your personal data was processed in an unlawful manner or if your personal data has to be deleted in order to fulfill a legal obligation.

In certain cases, we must retain your personal data despite your request, owing to legal requirements such as accounting and tax legislation, or for example if we need to retain certain data in order to establish, enforce or defend a legal claim.

Right to restrict processing of your personal data. You have the right to demand a restriction on our processing of your personal data in certain cases. If, for example, you claim that your personal data is incorrect, you can request a restriction on processing for a period of time that will give us the opportunity to check if your personal data is correct.

Right to object to our processing of personal data. You have the right, under certain conditions, to object to our processing of your personal data.

You have the right to object to processing that is based on the legal grounds of our legitimate interest. However, we may continue processing your data despite your objection to the processing if we have compelling legitimate reasons for the processing that outweigh your privacy interests.

Latest update to this Data Protection Guideline: June 22nd, 2020 (Version 1.0)


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