Privacy

Data Protection Guideline

BuySnus understands that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data. BuySnus 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.BuySnus.ch (“the Website”).

Controller of personal data

BuySnus, MaKe WeBo AB, Box 2180, 531 02 Lidköping, Sweden, operates the Website. Accordingly, BuySnus 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 BuySnus 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. 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. We solely process your telephone number in order to send you text messages with information about the delivery of your purchase orders and other important information in connection with your purchase. The telephone number will not be used for marketing purposes. 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@BuySnus.ch)
- 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. BuySnus 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, BuySnus collects the following information (see also BuySnus’s Information about cookies and other tracking technologies). Note that certain other companies than BuySnus 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 BuySnus’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

BuySnus may share your personal data with other companies within the BuySnus 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.

BuySnus may also share your personal data with other companies who do not process your personal data on behalf of BuySnus, 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.

BuySnus 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 BuySnus 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 BuySnus – 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.

Cookies and other tracking technologies

This Information about Cookies and other Tracking Technologies is for visitors of our www.BuySnus.ch website (“Website”).

It supplements the Data Protection Guideline as displayed above and explains what Cookies are, how we use Cookies, what are your choices regarding Cookies and where you can find further information about Cookies.

By continuing to browse or use our Website, you agree that we can store and access Cookies and Other Tracking Technologies as described in this Information.

Cookies and other Tracking Technologies

A Cookie is a small text file that can be stored on and accessed from your device when you visit our Website, to the extent you agree. The other tracking technologies work similarly to Cookies and place small data files on your devices or monitor your Website activity to enable us to collect information about how you use our Website. This allows our Website to recognize your device from those of other users of the Website. The information provided below about Cookies also applies to these other tracking technologies.

Use of Cookies and other Tracking Technologies

BuySnus uses Cookies and Other Tracking Technologies to identify you and your interests, to remember your preferences, and to track your use of our Website. We also use Cookies and Other Tracking Technologies to control access to certain content on our Website, protect the Website, and to process any requests that you make of us.

To administer our Website and for research purposes, BuySnus also has contracted with third-party service providers to track and analyze statistical usage and volume information from our Site users. These third-party service providers use persistent Cookies to help us to improve the user experience, manage our Website content, and analyze how users navigate and utilize the Website.

Our legal basis for the use of these Cookies is our legitimate interest in connection with the above mentioned purposes (see art. 6 para. 1 lit. f GDPR). You will be informed subsequently on how you can avoid the data processing mentioned above.

Which Cookies are used on this Website?

Our Website uses two types of Cookies: persistent Cookies and session Cookies. Persistent Cookies are stored on your device for a longer period of time after your browser has been closed and are used, for example, to log the choices you made during earlier visits. Session Cookies are stored temporarily in your browser, for example, to remember what language you selected. These are erased automatically after your browser is closed.

There are also third-party Cookies, meaning that the Cookies do not originate from us, but from someone else. Third-party Cookies are often used for web statistics, such as Google Analytics, but also for marketing purposes.

Third Party Cookies

In some cases, BuySnus uses third-party Cookies by trusted third parties. In the following section we will provide you with more detailed information about this kind of Cookies.

Our legal basis for using this kind of Cookies (and the respective services) is our legitimate interest in improving our services and products, Website statistics and in providing the users with personalized information (see art. 6 para. 1 lit. f GDPR). You can oppose to the data processing by Cookies at any time. Please find below information on how to opt-out / deactivate Cookies.

Use of Google Analytics (third-party Cookie)

BuySnus uses Google Analytics, a web analysis service provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (www.google.com). Google (Universal) Analytics uses methods that allow analysis of your use of the Website, such as Cookies. The information generated on your use of the Website is usually transferred to a Google server in the USA and stored there. Due to the activation of IP anonymization on this Website, the IP address will be shortened within Member States of the European Union or in other contracting states acceding to the Agreement on the European Economic Area and in Switzerland before transmission to the USA. Only in exceptional cases is the full IP-address transmitted to a Google server in the USA and shortened there. The anonymized IP address transmitted by your browser in the context of Google Analytics will not be combined with other Google data.

This information is used to evaluate your use of the Website, in order to compile reports on the activities on our Website and to provide other services associated with the use of the Website for the purpose of market research and customizing the Website.This information is also forwarded to third parties where this is required by law or if third parties have been commissioned to process this data. Under the terms of Google Inc., under no circumstances will the IP address be used in connection with other data relating to the user.

Users can prevent Google's collection of the data generated by the cookie that relates to a user's use of the Website (including their IP address) and Google's processing of this data by downloading and installing the browser plug-in available via the following link:

https://tools.google.com/dlpage/gaoptout

Use of Google Tag Manager (third-party Cookie)

BuySnus also uses Google Tag Manager in order to manage Cookies and pixels for tracking tools and other tools. The Tag Manager tool itself is a cookie-free domain and does not collect any personal data. Instead, the tool triggers other tags that may in turn collect data. If you have performed a deactivation at domain or cookie level, this remains in place for all tracking tags implemented using Google Tag Manager. You can prevent the setting of this cookie at any time (see How do I turn off Cookies?).

Use of SnapEngage (third-party Cookie)

BuySnus 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. Snapengage sets Cookies to enable customer service, to see how a user moves on the Website and to provide support between sessions. This means that when a visitor, for example, uses the live chat, SnapEngage can remember this visitor between sessions by storing the personal information the visitor has specified. SnapEngage also sets Cookies to improve their own service.

The following data is collected using this cookie: anonymous data (Browser Information, Cookie Data , Date/Time, Hardware/Software Type, Internet Service Provider, Page Views ) and pseudonymous data (IP Address (EU PII), Clickstream Data).

Use of DoubleClick (third-party Cookie)

This Website uses DoubleClick by Google, a service provided by Google, to provide advertisements that are based on the use of previously visited websites. Google uses a so-called DoubleClick cookie, which enables recognition of your browser when you visit other websites. The information generated by the cookie about visiting these websites (including your IP address) is transmitted to a Google server in the USA and stored there.

Google will use the above-mentioned information to evaluate your use of the Website in order to compile reports on the Website-activities and advertisements for the Website operator and to provide further services relating to use of the Website and the internet. Google may forward such information, where appropriate, to third parties, if required by law or where such third party processes such information on behalf of Google. Google will not associate your IP address with any other data held by Google.

You may reject re-targeting at any time by de-installing the respective Cookies in the menu of your internet browser.

Refuse or withdraw of consent to the use of Cookies

If you do not want Cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject the setting of all or some Cookies and to alert you when a Cookie is placed on your device.

On the following pages you will find explanations of how to configure the processing of Cookies in the most common browsers:

- Microsoft Windows Internet Explorer

- Microsoft Windows Internet Explorer Mobile

- Mozilla Firefox

- Google Chrome for Desktop

- Google Chrome for Mobile

- Apple Safari for Desktop

- Apple Safari for Mobile

If you block or limit Cookies on the Website, it is possible that you will not be able to use all of the services and functions on the Website.

Information about personal data

Read more about how BuySnus collects, uses and processes your personal data in our Data Protection Guideline[A2] .

Changes to this Information about Cookies and other Tracking Technologies

We may change this Information about Cookies and other Tracking Technologies from time to time. Any changes we may make will immediately be posted on this Website. We recommend that you check this page regularly to keep up-to-date.

Contact us

If you have any questions regarding our processing of your personal data, or if you would like to present a request about an excerpt from the registry, data portability, correction or deletion please contact us at

BuySnus – MaKe WeBo AB
Box 2180
SE-531 02 Lidköping
Sweden

info@BuySnus.ch

If you have a complaint regarding BuySnus’s processing of your personal data, you have the right to submit such complaints to the competent data protection authority.

Links to other websites

BuySnus may provide links to third-party websites or information as a service to our users. If you use these links, you will leave the Website. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by BuySnus of the third party, the third- party website, or the information contained therein, and BuySnus shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

Latest update to this Data Protection Guideline: September 20th, 2018 (Version 1.0)


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